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HomeMy WebLinkAbout09-4230MICHAEL L. BANGS, ESQUIRE I.D. #41263 429 SOUTH 18TH STREET CAMP HILL, PA 17011 (717) 730-7310 HEMPT BROS., INC., Plaintiff VS. JEFFREY A. EASON Defendant ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - qd30 0iVit-T&M CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims 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 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 MICHAEL L. BANGS, ESQUIRE I.D. #41263 429 SOUTH 18TH STREET CAMP HILL, PA 17011 (717) 730-7310 HEMPT BROS., INC., Plaintiff vs. JEFFREY A. EASON Defendant ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 -- y 3,? c N. 7 frti CIVIL ACTION - LAW COMPLAINT AND NOW comes the Plaintiff, Hempt Bros., Inc., by and through its attorney, Michael L. Bangs, Esquire, and files the following Complaint: 1. Plaintiff, HEMPT BROS., INC., is a Pennsylvania corporation with its principal place of business at 205 Creek Road, Camp Hill, Cumberland County, Pennsylvania ("Hempt"). Hempt owns approximately 11,000 acres in Cooke Township, Cumberland County, the acreage surrounding the Toland quarry ("Toland Property"). 2. Defendant, JEFFREY A. EASON, is an adult individual who resides at 1829 Lindsey Lane, Dauphin, Dauphin County, Pennsylvania, and trades or operates or does business as Woods & Wildlife Forestry ("Eason"). 3. Eason entered into an oral agreement with Hempt whereby Eason agreed to act as a broker for Hempt to solicit bids for the harvesting of certain marked trees owned by Hempt at the Toland Property. 1 4. In accordance with that oral agreement, Eason would advertise for bids by reputable foresters; negotiate an agreement with the foresters; and oversee the removal of the specific trees to be harvested under the agreement. 5. In accordance with the terms of the agreement, Eason would collect the amounts due and owing Hempt under the terms of the agreement and remit to Hempt those funds in accordance with the terms and conditions of a Timber Sales Agreement between Hempt and the chosen forester. 6. In accordance with the terms of the oral agreement, Eason would be paid a percentage commission for completion of its work as a broker. 7. Eason, pursuant to the oral agreement, received bids for the harvesting of the trees at Toland Property which subsequently resulted in a Timber Sales Agreement being entered into between Hempt and the chosen forester, Big Valley Hardwoods. Attached hereto and marked as Exhibit A is a true and correct copy of the Timber Sales Agreement. 8. Big Valley Hardwoods has paid Eason all the amounts due and. owing under the Timber Sales Agreement and has harvested all of the trees subject to the agreement. 9. Eason retained the initial $4,217.28 commission due him under the Timber Sales Agreement and subsequently remitted to Hempt the initial $10,000.00 paid to Eason by Big Valley Hardwoods. 10. Eason has received the remaining funds from Big Valley Hardwoods in the amount of $20,926.72 but has failed to remit those funds to Hempt. 11. Hempt has made repeated demands to Eason to remit those funds to Hempt under the terms of the oral agreement and in accordance with the Timber Sales Agreement between Hempt 2 and Big Valley Hardwoods. Despite repeated requests, Eason has failed or refused to remit those funds to Hempt. COUNTI BREACH OF CONTRACT 12. Paragraphs 1 through 11 are incorporated herein by reference:. 13. Hempt and Eason had in the past a course of dealing whereby Eason would provide brokerage services to Hempt on an oral contract basis. 14. The oral agreement that Hempt and Eason entered into regarding the Toland Property was similar to those prior agreements. 15. Eason, on a number of occasions, told Hempt that the remaining funds due and owing in accordance with their oral agreement, which was paid to Eason by Big Valley Hardwoods, would be paid. 16. Eason had a duty to Hempt to remit that payment to Hempt immediately upon being paid by Big Valley Hardwoods and prior to Big Valley Hardwoods removing any trees from Hempt's property. 17. Eason breached the agreement and his duties to Hempt when he failed to remit the final payment made by Big Valley Hardwoods to Hempt immediately upon receipt of those funds. 18. As a result of Eason's breach of the agreement, Hempt has been damaged in the amount of $20,926.72, that being the last payment due Hempt by Eason for the trees removed from the Toland Property by Big Valley Hardwoods. 3 WHEREFORE, Hempt demands judgment against Eason in the amount of $20,926.72, plus interest, plus costs of suit. COUNT II UNJUST ENRICHMENT 19. Paragraphs 1 through 18 are incorporated herein by reference. 20. Eason has retained funds that belong to Hempt for trees removed from Hempt's property. 21. Eason has been unjustly enriched at the expense of Hempt by Eason's failure to pay the last installment due Hempt from Big Valley Hardwoods in the amount of $20,926.72 which is the last payment paid to Eason for Hempt's lumber removed by Big Valley Hardwoods. 22. Eason had a duty to remit those funds to Hempt since Eason (lid not own the lumber removed from the Toland Property nor have a right to retain those funds. WHEREFORE, Hempt demands judgment against Eason in the amount of $20,926.72, plus interest, plus costs of suit. COUNT III CONVERSION 23. Paragraphs 1 through 22 are incorporated herein by reference. 24. The payments collected by Eason from Big Valley Hardwoods were the property of Hempt and not of Eason. 25. Eason had the responsibility and duty to turn those funds over to Hempt upon being paid by Big Valley Hardwoods. 4 26. Eason had no right to retain those funds since it had already been paid a commission for the work performed in setting up the contract between Big Valley Hardwoods and Hempt. 27. Eason does not have the consent of Hempt to retain those funds nor does Eason have any lawful justification for retaining those funds. 28. Eason has converted those funds to his own use by his failure; to remit those remaining funds in the amount of $20,926.72 to Hempt. 29. Eason's conversion of those funds is unlawful and without legal justification and Hempt is due damages in the amount of the converted funds of $20,926.72. WHEREFORE, Hempt demands judgment against Eason in the amount of $20,926.72, plus interest, plus costs of suit. Respectfully submitted, MICHAEL L. L GS Attorney for Plaintiff 429 South 18th Street Camp Hill, PA 17011 (717) 730-7310 Supreme Court ID #41263 Received: Jun 22 2009 10:20am JUN-22-2009 09:54A FROM:MICHAEL BANGS, ESQ. (717)730-7310 TO:7610635 P.2 VERIFICATION MAX J. HEMPT, being duly sworn according to law, deposes and says that he is the President of Hempt Bros., Inc., a Pennsylvania corporation, and that as such officer, he is authorized to make this Verification on its behalf and that the facts set forth in the foregoing document are true and correct to the best of his knowledge, information and belief, and further understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. HEMPT BROS., INC. BY. MAX J. HEMPT President 6 EXHIBIT A a . i. Woods & Wildlife Forestry Timber Sales Agreement This Agreement entered this 3 day of No by and between '-?? I Hereinafter called the "Seller", and With the principal place of business at_ P14 / 700 Z Hereinafter called the "Buyer". 1. Description of Sale Area: The woodland is l Pennsylvania, located _f s II. Trees Designated for cutdn All trees marked with an paint spot about 4 ri feet above the ground, and is also marked with a stump spot at a point below stump height. III. Conditions of Sale: A. The buyer Agrees to: t. To pay the seller the sum of $ 3 .oodollars for the above mentioned trees on approximately LO acres. Payment to be made as follows: A. dollars Iz1o W;? 5 c..i? Ic?1 B:_ ? ?? ?? O c7 dOllarS ?:o s ? , n C: 6.7?- dollars a s *All checks should be made payable to Woods do Wildiife Forestry D: An escrow account shall be retained in the amount of Z , aU And made payable to: W0 W and shall be submitted before any harvesting begins. 2. The contract expires on c7 " A. The expiration date on the contract may be extended at the discretion of the seller. fn the event that an extension is granted, the buyer will be assessed additional consideration of 5300.00 for each month or part thereof an extension is granted. ct, Y "r" tss c n S. Compliance with the provisions of the contract by subcontractors will be the responsibility of the buyer. 3. To do all in his power to prevent and suppress forest fires on or threatening the sales area. 4. To be responsible for securing and paying for any type of right- of-way license, permits, or other approvals necessary for timber removal, and compliance with all applicable statutes, regulations and ordinances. 5. To assume all responsibility for the determination and location of the property lines. 6. To be responsible for all damage done by their employees or agents to roads, bridges, pipelines, telegraph, telephone, or power lines crossing the designated cutting area or damages to fields or any other improvements or structures thereon. 7. In the event those trees that are not marked for harvest are felled, the buyer agrees to pay the seller triple the marked value. 8. The buyer shall do everything, which is practical in the opinion of Woods & Wildlife, to prevent damage to residual trees not marked or designated for felling. The buyer shall pay the seller as designated in paragraph III-A-7 for each tree damaged by the buyer neglect or careless operation. Damaged trees shall remain on the property unless the seller or Woods & Wildlife grants permission for removal. 9. To maintain tops of harvested trees no higher than five feet above the ground. All tops shall be pulled back from the fields, roads, streams, trails, and property lines. 10. To carry insurance to protect himself and the seller from all liability for damage to the property, or injury or death to persons, such coverage shall be no less than the following limits: Commercial Gonad Uability General Aggregate $1,000,000.00 (Not including products) $1,000,x.00 Product Aggregate Limit Each Occurrence Limit $1,000,000-00 Business Auto Per Account $500,000.00 (includes bodily injury and property damage) Commercial Blanket Excess Liability Products Aggregate $2,000,000-00 $2,000,000.00 General Aggregate Each occurrence $2,000,000.00 11. To conduct and maintain haul roads at his expense, and any or all other temporary haul roads, will be the responsibility of the buyer, and must be approved by the seller. 12. To pay and hold the seller harmless from all debts or sues or, demands or claims against the buyer or against any of the buyers employees, subcontractors, and suppliers, for services or labor performed; or materials furnished in said work, and all debts, demands or claims growing out of the removal of said timber. 13. To pay and hold the seller harmless from all claims for damage, claims done by the buyer, his subcontractors or his employees, to persons or property during the progress of work; and. to hold the seller harmless from all liens, attachments, suits, causes or action, costs, expenses, and attorney's fees arising from and (or in any connection with any or all the debts, dues, claims, demands, or damaged property) caused or incurred in any manner in the removal of said timber. 14. Conditions of Escrow: All funds will be returned upon satisfaction f the above conditions in this contract. S. The seller Agrees: 1. To guarantee the purchaser and assignees title to the forest products covered by this contract, and to defend it against all claims. 2. To grant freedom of the entry and right-of-way to the buyer, his employees, contractors, and assignees on and across the areas to be covered by this contract; and also privileges usually extended to buyers or stumpage which are not spedfically covered providing they do not conflict with specific provisions of this contract. Signed this day of /j, ?" V, ? g?t? 200 8. Seller v Buyer L5 i /:- i / t:, 1_ L C ?- I ??{? t--"C4-?T Q F i r 'Y OF TH 2L03 J' `? 2 3 F `? ?':? $18.50 po ATN RTC aa?o?? Sheriffs Office of Cumberland County Sheriff Kline iojr ci t'wrW6 ? '140 ff Edward L Schorpp Solicitor Ronny R Anderson Jody S Smith Chief Deputy OF FICE OF 7hE SrERIFF Civil Process Sergeant Hempt Bros., Inc. vs. I Case Number Jeffrey A. Eason 2009-4230 SHERIFF'S RETURN OF SERVICE 06/24/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Jeffrey A. Eason, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 07/01/2009 07:12 AM - Dauphin County Return: And now July 1, 2009 at 0712 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint, upon the within named defendant, to wit: Jeffrey A. Eason by making known unto himself personally, defendant at 1829 Lindsey Lane Dauphin, PA 17018 its contents and at the same time handing to him personally the said true and correct copy of t SHERIFF COST: $37.44 July 02, 2009 N .a 71 _ >i Cn 7 ?- C - 7LLI - W ?_ C 1? f r, of Mary Jane Snyder Real Estate Depu y , William T. Tully • Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff HEMPT BROS., INC. JEFFREY A EASON Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy VS Sheriff s Return No. 2009-T-1809 OTHER COUNTY NO. 20094230 And now: JULY 1, 2009 at 7:12:00 AM served the within COMPLAINT upon JEFFREY A EASON by personally handing to JEFFREY A EASON 1 true attested copy of the original COMPLAINT and making known to him/her the contents thereof at 1829 LINDSEY LANE DAUPHIN PA 17018 Sworn and subscribed to before me this 1 ST day of July, 2009 lli? NOTARIAL SEAL FmConunission JANE SNYDER, Notary Publi ighspire, Dauphin County Expires Set 1 2010 So Answers, Sheriff of D in By Deputy Sheriff Deputy: G MILLER Sheriffs Costs: $49.25 6/26/2009 MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF T.D. NO. 41263 429 SOUTH 18TH STREET CAMP HILL, PA 17011 (717) 730-7310 HEMPT BROS., INC., ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) NO. 2009-04230 CIVIL TERM JEFFREY A. EASON, ) Defendant ) CIVIL ACTION TO: JEFFREY A. EASON 1829 Lindsey Lane Dauphin, PA 17018 DATE OF NOTICE: July 28, 2009 IMPORTANT NOTICE Required by Rule 237.1(a)(2) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 CHAEL L. BANGS Attorney for Plaintiff FILED O-' RC E OF TIF 2009 J011_ 30 Fill 2= 5 2 ?i° 1j s Y ti MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF I.D. No. 41263 429 South 18th Street Camp Hill, PA 17011 (717) 730-7310 HEMPT BROS., INC. ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) NO. 2009-04230 CIVIL JEFFREY A. EASON, ) Defendant ) CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff and against Defendant in the amount of $20,926.72, plus interest, plus costs of suit, for his failure to file a responsive pleading in the above-referenced matter. I hereby certify that the attached Notice in accordance with Rule 237.1(a)(2) was mailed by regular mail on or about July 28, 2009 to Defendant at 1829 Lindsey Lane, Dauphin, Pennsylvania, 17018. Respectfully submitted, D V v - `? MICHAEL L. BANGS Attorney for Plaintiff Date: I MICHAEL L. BANGS, ESQUIRE I.D. NO. 41263 429 SOUTH 18TH STREET CAMP HILL, PA 17011 (717) 730-7310 -7 ATTOI FOR PLAINTIFF HEMPT BROS., INC., ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) NO. 2009-04230 CIVIL TERM JEFFREY A. EASON, ) Defendant ) CIVIL ACTION TO: JEFFREY A. EASON 1829 Lindsey Lane Dauphin, PA 17018 DATE OF NOTICE: July 28, 2009 IMPORTANT NOTICE Required by Rule 237.1(a)(2) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU., UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 ? A i I d _ C EL L. BANGS Attorney for Plaintiff MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF I.D. No. 41263 429 South 18th Street Camp Hill, PA 17011 (717) 730-7310 HEMPT BROS., INC. ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) NO. 2009-04230 CIVIL JEFFREY A. EASON, ) Defendant ) CIVIL ACTION - LAW ADDRESS CERTIFICATION I hereby certify that the addresses of the Plaintiff and Defendants are as follows: Plaintiff: Hempt Bros., Inc. 205 Creek Road Camp Hill, PA 17011 Defendant: Jeffrey A. Eason 1829 Lindsey Lane Dauphin, PA 17018 MIC ABANGS 1 Attorney for Plaintiff FlLED-Or? OF THE PRO*d4 OTAW 1909 AUG 17 PM 2: 17 PENNSYNNNI A *.14.Oo P o ATTy ?,?` 8848 ? aaq a? y K)04&, lvAo ? MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF I.D. No. 41263 429 South 18"' Street Camp Hill, PA 17011 (717) 730-7310 HEMPT BROS., INC. ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ) NO. 2009-04230 CIVIL JEFFREY A. EASON, ) Defendant ) CIVIL ACTION - LAW NOTICE PURSUANT TO RULE 236 TO: JEFFREY A. EASON, Defendant(s) You are hereby notified that on Ig , 20D9 , the following (Judgment) (Order) (Decree) has been entered aga st you in the above-captioned case: $20,926.72, plus interest, plus costs of suit. DATE: I - &__ -4 4 N - roth0n0tary I hereby certify that the name and address of the proper person(s) to receive this notice is: Jeffrey A. Eason 1829 Lindsey Lane Dauphin, PA 17018 A: JEFFREY A. EASON, Defendido/a o Defendidos/as Por este medio se le esta notificando que el de del 20__, el/la siguiente (Orden) (Decreto) (Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe: $20,926.72, plus interest, plus costs of suit. FECHA: Protonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: Jeffrey A. Eason 1829 Lindsey Lane Dauphin, PA 17018 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: V? ? Confessed Judgment ? Other File No. 2o09-423o Amount Due * ZL- 9'Z0• rl2 : Interest Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of ?? QCT ( N County, for debt, interest and costs, upon the following described property of the defendant (s) CEVy U ()r'; A" j- ALL ?e ?SOOAL P oi= CC4=' i+f( IU i AK) i w c,?UPA i"VWA1QA. 0619. 6Sc y C-r` tIv , PRU aN IV" PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ? (Indicate) Index this writ against the garnishee (s) as a ; defendant(s) described in the attached exhibit. Date Signature: Print Name: Address: Attorney for: Telephone: is pe d?enn?s against real estateAf the I?t 0 AEA- L.. r&4k 42q S'. li rtt ST CAM P t l t._1... , 74 f o l 'AA l iL'n ri- (IM -73t - _73iC Supreme Court ID No: `t Qc3 RUED-OFFICE OF TK FR67MARYr 2009 AUG 17 Fm Z' 17 Cl1P, sl- -; '?ti ?;;OUN Y . PENNSYLVANIA 4a4.00 P 0 ATT`I 3q. 4q CBF 79.50 ', 1yoo " 6L .50 151a - q4 - Po AT7--/ 4a.00 Oue,00 • 50 L.L Cry 8948 P-rIA Gaga-? ?P WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-4230 Civil CIVIL ACTION - LAW TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due HEMPT BROS., INC., Plaintiff (s) From JEFFREY A. EASON,1829 Lindsey Lane, Dauphin, PA 17018 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all personal property. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(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 $20,926.72 Interest Atty's Comm % Atty Paid $156.44 Plaintiff Paid Date: 8/17/09 L.L. $.50 Due Prothy $2.00 Other Costs 0k4T-'?iU4 C R. Long, of n tart' (Seal) By: Deputy REQUESTING PARTY: Name MICHAEL L. BANGS, ESQUIRE Address: BANGS LAW OFFICE 429S.18 TH STREET CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-730-7310 Supreme Court ID No. 41263