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09-3098
ROBERT D. KODAK, ESQUIRE KODAK & IMBLUM, P.C. 407 N FRONT STREET, PO BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7159 Attorney for Plaintiff MINNETONKA MOCCASIN CO., INC. IN THE COURT OF COMMON PLEAS OF Plaintiff Cumberland COUNTY, PENNSYLVANIA v NO. O4- 3CA S L%tV i I. ex-IK FITCH'S TRADING POST, INC. and DELORES FITCH BASEHORE, CIVIL ACTION - LAW personal guarantor Defendant(s) NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 717-249-3166 MINNETONKA MOCCASIN CO., INC. IN THE COURT OF COMMON PLEAS OF Plaintiff Cumberland COUNTY, PENNSYLVANIA v NO. FITCH'S TRADING POST, INC. and DELORES FITCH BASEHORE, CIVIL ACTION - LAW personal guarantor Defendant(s) COMPLAINT The Plaintiff, MINNETONKA MOCCASIN CO., INC., by its attorneys, KODAK & IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of FOUR THOUSAND THREE HUNDRED ELEVEN DOLLARS AND EIGHTY-NINE CENTS ($4,311.89), along with interest thereon at the rate of 1'h% per month from November 30, 2008, upon a cause of action of which the following is a statement: 1. The Plaintiff, MINNETONKA MOCCASIN CO., INC., is a corporation organized and existing under the laws of the State of Minnesota, having its principal office and place of business at 1113 E. Hennepin Avenue, Minneapolis, MN. 2. The Defendant, FITCH'S TRADING POST, INC., is a corporation having its principal office and place of business at 900 Market Street #214, Lemoyne, Cumberland County, Pennsylvania 17043. F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\MINNETONKA 35464.wpd 2 3. The Defendant, DELORES FITCH BASEHORE, personal guarantor for Fitch's Trading Post, Inc., is an adult individual with an address of 900 Market Street #214, Lemoyne, Cumberland County, Pennsylvania 17043. 4. Defendant, Fitch's Trading Post, Inc., is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, as more fully set forth on the Pennsylvania Department of State Corporation Bureau print out attached hereto, marked Exhibit "A" and made a part hereof. 5. On or about November 8, 2006, Defendants submitted a Credit Application and Personal Guaranty to Plaintiff, which credit was granted to Defendant, a true and correct copy of which is attached hereto, marked Exhibit "B" and made a part hereof. 6. On the dates, in the amounts, and for the prices set forth in a true and correct copy of the Plaintiffs Statement of Account hereto attached, marked Exhibit "C" and made a part hereof, Plaintiff, at the special instance request of the Defendants, sold and delivered goods, wares and merchandise of the kind and description set forth on said Exhibit to the total amount of Five Thousand Seven Hundred Eighteen Dollars and Twenty-Four Cents ($5,718.24). 7. The prices charged for said goods, wares and merchandise were just and F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\MINNETONKA 35464.wpd 3 reasonable, were the legal and market prices therefor and were the prices which the Defendant promised and agreed to pay to Plaintiff. 8. Defendant became entitled to certain credits against the charges aforementioned, as more particularly shown on Exhibit "C" , to the total amount of Two Thousand Five Hundred Dollars ($2,500.00). 9. The principal balance due and owing by Defendants to Plaintiff is the sum of Three Thousand Two Hundred Eighteen Dollars and Twenty-Four Cents ($3,218.24), as appears by Plaintiff's Affidavit of Claim hereto attached, marked as Exhibit "D" and made a part hereof. 10. Due to the default of Defendant, and pursuant to the terms and conditions of the Credit Application and Personal Guaranty executed by Defendants hereto attached as Exhibit "B", attorney's fees in the total amount of One Thousand Ninety-Three Dollars and Sixty-Five Cents ($1,093.65) have been added to said account. 11. Plaintiffs Invoices are not attached to this pleading due to the voluminous nature of same and have previously been provided to Defendants. 12. Plaintiff frequently demanded payment from Defendants of said amount due and owing as aforesaid, but Defendants refused and neglected and still refuse and F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\MINNETONKA 35464.wpd 4 neglect to pay said amount or any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of FOUR THOUSAND THREE HUNDRED ELEVEN DOLLARS AND EIGHTY-NINE CENTS ($4,311.89), together with interest as set forth herein. Respectfully submitted, KODAK & IMBLUMLP: Robert D. Kodak, Esquire 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7159 Attorney for Plaintiff F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\MINNETONKA 35464.wpd Business Entity Page 1 of 2 Corporations Online Services I Corporations I Forms I Contact Corporations I Business Services Search By Business Name By Business Entity ID Verify Verify Certification Online Orders Register for Online Orders Order Good Standing Order Certified Documents Order Business List My Images Search for Images Business Entity Filing Date: 5/11/2009 History (Select the link above to view the Business Entity's Filing History) Business Name History Name Name Type FITCH'S TRADING POST, INC. Current Name Business Corporation - Domestic - Information Entity Number: 618776 Status: Active Entity Creation Date: Registered Office Address Mailing Address: 7/31/1975 230 NORTH THIRD STREET HARRISBURG PA 17101-0 No Address Officers Name: RICHARD L BASEHORE Title: President Address: 2011 MARKET ST CAMP HILL PA 17011-21 Name: DELORES F BASEHORE Title: Secretary Address: 2011 MARKET ST CAMP HILL PA 17011-21 Name: RICHARD L BASEHORE Title: Treasurer Address: 2011 MARKET ST CAMP HILL PA 17011-21 Name: DELORES F BASEHORE Title: Vice President Address: 2011 MARKET ST CAMP HILL PA 17011-21 https://www.corporations. state.pa.us/corp/sosk 5/11/2009 l? "L/ uu/ GUUD 1-i: LJ /11 rdnaddl rl IL;HS PAGE 01 3 -7;L PIX.ARP.'rYPF. ()R PRINT CI,F:ARLY STORE NAME CORPNAME S'..4r? C? STOREADDRESS -57r CTTY/STATE2IP - lv 710 /-r// G L 4c . BILLING ADDRESS_ Sr}?-1 G CrrY/STATE/ZIP / -7o l / PHONE: STORE (/// --7)7-3 o- 7 Po o H0ME/OFFICE C7/ -7) S 70-- :2-?j3 FAX I/'7/_ 7 '7 -3 0 - 41 33 / E-MAIL .. "' PRODUCT SOLD, . c,, . ,vQ i,*W YR BUSINESS STARTED PURCHASED NEW SOLE OWNER l,-PARTNERSHIP CORP STATE TAX OWNERS NAME 1Q1 c-* A644-" 4, ,? S C,4? 2E SOCIAL SECURITY # w see j PARTNER NAME SOCIAL SECURITY #- ?- T& ?I CORP OFFICERS ************LJST 3 TRADE REFERENCES*******6**A* FEDERAL ID # NAME STREET CITY/STATE i?5'TiG?1J /.O/V,O v 216=5' c 7J '4e-du GC r, -,I- G /v/A7 HANK /wit/ ? .?/d?/?i?7.?'?t??7 S'T. /-? - /? CITY/STATE e/ff /`Tic.G7, . PHONE (&'2 - z z (o / BANK ACCOUNT # 0 2 7 3P" CONTACT NAME/'?G ?) 7d, 5a o S ? G '7 ?'? ?- TERMS: NET 30 DAYS- PAST DUE ACCOUNTS ARE CHARGED 1.5% INTEREST OR THE MAXIMUM ALLOWED BY LAW PER MONTH ON THE OUTSTANDING BALANCE. SHOULD IT BE NECESSARY TOREFER THE ACCOUNT TO A LICENSED COLLECTION AGENCY OR ATTORNEY FOR LEGAL ACTION. ALL SUBSEQUENT CHARGES AND LEGAL FEES SHAW, BE PAID BY THE APPLICANT. SIGNATURE OF APPLICANT OR APPLICANTS' REPRESENTATIVE ACKNOWLEDGES RECEIPT AND TOTAL LIABILI'T'Y FOR PAYMENTOF ALL MERCHANDISE ORDERED. APPLICANT HEREBY AUTHORIZES AND GRANTS MINNET MOCCASIN TEE RIGHT TO INVESTIGATE CREDIT REFERENCES AND BANKING INFORMATION. _ / ? SIGNATURE DATE--- !/?? P o IN ADDITION, I/WE, HEREBY. PHRSONALLYGIVE THIS CONTINUING GUARANTEE TOMINNETONKA MOCCASIN, THAT I/WE WILL COMPLY WITH THE TERMS AND CONDITIONS STATED ABOVE. SIGNATURE 4a4 DATE _ ?/ u P:6 (- PHONE o OI zl o Ln G. ? n M co O m N O Ti O d c r E 4) m 3 >Z O U lQ C d m d H R d FL z H O o U ? z Ln H Ln W z O W N 4 z Ln o O x 4 Z z z °a z f Ol H Y'1 r7 10 ?. ? a N N (`7 rr1. _ !? C? W Q? l0 N N N r-1 H m m: ' m m Ln Ln. m Ln. m m ? ri m Ln N cn Qi N r-I O r r - Z l 'i N r-i -I H r 1 O O O O O O . Q) O O O O O O O U O O O O O O O = 0 0 0 0 0 0 0 O O O O o O O rn ?r m m m m m m m Qy n O m 0 0 0 0 0 0 C r, w N O. O r-1 m ri ?n r- m m 1o r- Ln r- H O. O O O O O . O [[. m O V v Ln u U U U U. U U a Ln H H w w w w w w w H H H H H ? r-7 a ? ? ?] , ' W m. m m m m m m m m m m m 0 0 0 O O O O O O O O O LO m m O H c-1 ,-I O O O O 0. N O. N r7 rl O cn r'7 m m m rn m m Lit M m q r` m m O O O O O O O O O O O O .-I ° C m Z M c V z t ? U 0 0 CD o E W ___11111 ?s Q a, 'r O N rn 0 , m "D c? O H ,?, cn IO CO 10 H 7t -?4' N C) co a 3 O1 m m;; fu M rn ;;?F m "D F co - - a r k?O H L- 00 0 H M O1 m m C CO dr (YI N O O M d+ d+ ? dr LCi lO L M M ii Ln Ln Lh Ln M LC) Ln Ln a M .. r4 C . CO Zy Hr_ ' 1V1^ , O vS : r 0) H (n ( I'D v dr Vr N N M en m 4 r :?4 co a) l0 N N N H rH co co ? 41 r ? Ol r) Ln L11 M ln Ln Ln H H O O - - - l 0 r m m m --i m co fn co In N M ,' U E E I p v-4 Z: H a sn a < `"' W z E ? ?.. o ca E+ ? w o ?? c ? ? C Ln W C7 W r ? U] R a ? z Pi v c ? H a , - to I?rrr H W a L N{ r U U H C, o to rs N U •dr O H + Ei It p H O W Pro 01 a U E,,, M c 1 W Ur m Ca CC) O co ao 00 co 00 co 00 co (M"' 00 co Is Ln O Co O Ln CD O CD H CD r-i O I CD o O o CD O CD O CD O Uri N O N c•'1 M O M M M M M M C: Ln lO Ln ln r m M d+ r co o) (D m C Nr4 0 0 0 0 0 0 0 0 0 0 O H ? o U x x } 00 00 CO CO OO OO OD CO CO CO OO m OD ? U U 0 CD 0 CD CD CD 0 CD 0 CD 0 CD p M WZ{'ii Q Ln Cjl ln O H -1 H T{ O H rI O _ xHcn N O N M CD M CD rI M M M M ro Ur34 O C dr Ln d? ?M L? r-1 M (Y) %D r co rn ' ' U o - O o o o o O O O O O O O ° x?lz co T cn Lr)?N z H 0 H 0 N 0 H 0 H 0 H 0 H 0 LL co Lr) cpM 111 " O O 0 O 0 O 0 O 0 Q 0 0 0 -o : W r z j? 0 T' T ? ?? - Z 0 0 0 0 0 0 0 0 0 c M °D Ur • ? M © M M - =&& W m M d+ o r O1 O 00 0 O CO 0 O co 0 o 00 0 O co CD O co 0 O co 0 o z " 0 Pa Or T. ?? CO m - 42 r lp to L? N Ln O L? O 1 H 0 M 0 M 0 IO 0 r 0 m 0 m C m 0 W P OD HUU H H Q cp O X Q 00 CD . Ln U' U U U U U D U (D 2 W co ?C 0 ? Ln H H H t+ f3+ f? w G CI f? - p U Pq arE?, 0 CC CC _ X C/^, H H H H H Hl ?4 r-a ?-l a. r-l Hl m Ur?H ^ 1 U W H C" ? O. K fl0 Affidavit of Plaintiff's Claim STATE OF ?4 i nee s e t a } } COUNTYOF Hennepin } ss. FEDERAL TAX ID# 41-0647360 Before me, the undersigned Notary Public, in and for the County aforesaid, personally appeared Jerry F u h r raP i c t P r who being by and me first duly sworn according to law, deposes and says that he is Credit M = r of Minnetonka Moccasin 1. A corporation organized and doing business under the laws of the State of M i n n P G o t a 2. A partnership composed of 3. A sole trader doing business as the Plaintiff in this cause, and as such he is authorized to make this affidavit, that he is familiar with the books and business of said Plaintiff, that the account against: F i t ch s Trading Post 900 Market St #214 Lemoyne, PA 17043 the Defendant herein, which is hereto attached and make a part hereof, is a correct copy of the books of original entry and is just and true within the personal knowledge of this affiant, that the items thereon stated and composing the said account were sold and delivered to Defendant at the special instance and request of said Defendant, that the charges made therefor are fair and reasonable and as per contract, that full credit has been duly given for all payments, deductions and lawful set-offs to which the Defendant is entitled. There now remains due and owing from Defendant to Plaintiff the sum of Three thousand two hundred eighteen 24 /P0&rs ($ 3218.24 ) together with interest thereon from the 23 day of Apr i 1 , 2009 : 04t ? NT Sworn to and subscr' ed before me, a Notary Public in and for the State and County aforesaid, this the day of , 206 . In Witness Whereof, I have hereunto set my hand and affixed my official seal. Impress/ MARY L WALKER (NOTARY PUBLIC - MINNESOTA a My Commission Expires Jan. 31, 2010 My commission expires: , N TARP PUBLIC ]P-- VERIFICATION I, ROBERT D. KODAK, state that I am not a party to the action but that, at the request of the Plaintiff, MINNETONKA MOCCASINCO., INC., and based upon knowledge, information, records and documents supplied to me by the Plaintiff, the averments set forth in Plaintiffs Complaint are true. A Verification executed by the Plaintiff will be supplied as soon as it becomes available. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Robert D. Kodak, Esquire Dated: May 11. 2009 O ;n?')TA(Y ?QQ9 P i' 1 S PH 12: 1 *qs .5© ou Q Sheriffs Office of Cumberland County R Thomas Kline 8,?v of 4?uln6rrft Edward L Schorpp Sheriff Solicitor t` • ?r Ronny R Anderson Jody S Smith Chief Deputy or ,:E = S-ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/30/2009 12:30 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 30, 2009 at 1230 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Delores Fitch Basehore, by making known unto herself personally, defendant at 900 Market Street #214 Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. 05/30/2009 12:30 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 30, 2009 at 1230 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Fitch's Trading Post, Inc., by making known unto Delores Basehore, adult in charge at 900 Market Street #214 Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $58.84 June 01, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF "Deputy Sheriff 2009-3098 Minnetonka Moccasin Co. V Delores Fitch Basehore SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~-, C' f'~ rr Sheri R Anderson ~f' -.- c_._ ~r ~ JOdy S Smlth ~~{, l.' ~f 4rr,gt,~rf~tir0 ~^.) `~ ~7 c~ ; ~.:_, Chief Deputy _ - , ,; ~- a Edward L Schorpp _.,. Solicitor ~ ~ ~ ,~ -..~ ~~rr .- -~ ;:s .. -T,~ ._ c~~ 'n ~~ .~ Minnetonka Moccasin Co., Inc. vs. Case Number Delores Fitch Basehore 2009-3098 SHERIFF'S RETURN OF SERVICE 01/26/2010 04:24 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January 26, 2010 at 1620 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Fitch's Trading Post, Inc and Delores Fitch Basehore, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Nob oulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Sheri Guttshall, ssista t anch Manager, personally three copies of interrogatories together with three true and at~~d c pie of the writ of execution and made the contents there of known to her. January 27, 2010 SO ANSWERS, RONNY R ANDERSON, SHERIFF %cl ~ bun•, S.iR~ Sheriff, ie{e:;=oft. 1n:. MINNETONKA MOCCASIN CO. INC. Plaintiff v FITCH'S TRADING POST, INC and DELORES FITCH BASEHORE, PERSONAL GUARANTOR, Defendant(s) TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-3098 CIVIL ACTION -LAW PRAECIPE ~ N O ~ G ~ -~, r : r : :.~" ~ rr'1 ao ~~ ,. ~;- A, ~:-: ~ cn ~n Jrn .~ .;.~ •- w -< Please Satisfy Judgment and Discontinue Case. TO: Cumberland County Prothonotary Dated: March 17, 2010 ~_~. . Robert D. Kodak, Esquire Attorney for Plaintiff Attorney I.D. No. 18041 i t SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ~~tiw„ts~ a i~uridcr~~~'0 Chief Deputy ~,.->~`~ '} ~ ~ ~'t;t ~~~tti Edward L Schorpp " Solicitor c~~,~~ of fhs ~„r~,~F Minnetonka Moccasin Co., Inc. vs. Case Number Delores Fitch Basehore (et al.) 2009-3098 SHERIFF'S RETURN OF SERVICE 01/26/2010 04:24 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January 26, 2010 at 1620 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Fitch's Trading Post, Inc and Delores Fitch Basehore, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Sheri Guttshall, Assistant Branch Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. 01/28/2010 01:30 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on January 28, 2010 at 1330 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Delores Fitch Basehore, by making known unto Delores Basehore, at 900 Market Street, Ste # 214, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on February 1, 2010. 01/28/2010 01:30 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on January 28, 2010 at 1330 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Fitch's Trading Post, Inc., by making known unto Delores Basehore, Owner and Adult in Charge, at 900 Market Street, Ste # 214, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on February 1, 2010. 03/04/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this ~,vrit is returned SATISFIED. SHERIFF COST: $219.68 (PAID) - SO ANSWERS, ~~ March 04, 2010 RON R ANDERSON, SHERIFF By 8 ~ :z ~ S Z fi4yr ~!~~ Sharon R . Lant z IW.t V( iLtr' ,~h. ~4,~'t'_~~'JWI r~ ',~ Jl~t1 ~t~~.f_ 0~1c~3~ ~ ~ ~ ~d b , ~~ (c) CouniySui~e Sheriff. Telecsoft. In:. ~ ~~ ~ryG -~ ~ ~~5 ~~3 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-3098 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MINNETONKA MOCCASIN CO, INC, Plaintiff (s) From FITCH'S TRADING POST, INC and DELORES FITCH BASEHORE, Personal Guarantor, 900 Market Street #214 Lemoyne, PA 17043 (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property, including but not limited to furniture, jewelry, electronics, supplies, etc. . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PNC BANK, 105 Noble Blvd, Carlisle, PA 17013 All accounts under defendants names -Acct #XXXXX2738 XXXXXX7743, Social Sec XXX-XX-9658 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3,908.05 Interest from 1/21/10 @ $0.64 per diem -- $26.88 Atty's Comm 5 %- $195.40 L.L. $.50 Due Prothy $2.00 Atty Paid $178.34 Plaintiff Paid Date: l /22/10 (Seal) Other Costs J_ David D. Buell, Prothonotary By: Deputy REQUESTING; PARTY: Name ROBERT D. KODAK, ESQUIRE Address: KODAK & IMBLUM, PC PO BOX 11848 HARRISBURG, PA 17108-1848 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 .~ ~ ~~ • DISTRIBUTION PLAINTIFF Minnetonka Moccasin Co, Inc. WRIT NO. 2009-3098 Minnetonka Moccasin Co, Inc. -vs- Fitch's Trading Post, Inc and Delores Fitch Basehore. Real Debt $ 3,908.05 Interest 37.12 Attorney's Comm. 195.40 Writ Costs, Atty 178.34 Writ Costs, Pltff. Miscellaneous Attorneys Fees $ 4,318.91 Sheriff s Costs: Docketing $ 18.00 Poundage 78.16 Law Library .50 Prothonotary 2.00 Service 20.70 Postage 1.32 Advertising Postpone Sale Bad Check Charge Surcharge 50.00 Garnishee 9.00 Levy 40.00 TOTAL $ 219.68 lietenaant raid to 5hentf~ $ 4,538.59 Advance Costs 250.00 Total Collected $ 4,788.59 DISIBUTION Pd. To Pltff. $ 4,318.91 Refund of Adv. Costs 250.00 Sheriff's Costs 219.68 So Answers: Ronny R. Anderson Sheriff B