HomeMy WebLinkAbout09-5570i ?
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
Judicial District, County Of CUMBERLAND
NOTICE OF APPEAL
FROM
MAGISTERIAL DISTRICT JUDGE JUDGMENT
COMMON PLEAS No. QQ_ 5570 0 t?il Trr?l
NOTICE OF APPEAL Piled eha/o9
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District
Judge on the date and in the case referenced below.
NAME OF APPELLANT I MAG. DIST. NO. I NAME OF MDJ
ADDRESS OF APPELLANT CITY STATE
C/O AMATO & ASSOCIATES PC 107 N. COMMERCE WAY BETHLEHEM
DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant)
7/13/09 YELLOW BOOK SALES & IBUTION CO V. GARY MORTON
DOCKET No. SIGNATURE OF APPELLANT O ORNEY OR AGE
CV-260-09
ZIP CODE
AND A B A BIZ NESS, INC.
This block will be signed ONLY when this notation is required under Pa. If appellent was Claimant (see Pa. R.C.P.D. J. No. 1001(6) in action
R.C.RD. J. No. 1008B.
This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED
operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty
(20) days after filing the NOTICE of APPEAL.
Signature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
This section of form to be used ONLY when appellant was DEFENDANT (see Pa, R.C.P.D.J. No. 1001(7) in action before Magisterial District
Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or attorney or agent
RULE: To
appellee(s)
Name of appellee(s)
OWNER
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date , 20
Signature of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-05 COURT FILE TO BE FILED WITH PROTHONOTARY
"EALI
Ft ED e !"
;l= T}(F f ,e,;R
21,09:tU?G i Fr'""`?
es
A:I': hereby sever or affirm that 1 served
a copy of the Notice of Appeal, Common Pleas No. ..,upon the Magisterial DiF'
,late ofservice) ?, ? by personal service by (certified) upon the qr
iI by error :iemut El by ?C.. s ,
senders receipt attached i . , ?.
"!-TICRIBED BEFORE ME
t t i i ,... ._..._.? -,20
......:.....,,....
My C:n,
AOPC 312A-05
20
"esipnated --l-,
r
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLJL11D
Mag. Dist. No.:
09-1-01
MDJ Name: Hon.
CHARLES A. CLEMENT, JR
Address: 400 BRIDGE ST
OLDS TONNE COMMONS -SUITE 3
NEW CUMBERLAND, PA
Telephone: (717 ) 774-5989 17070
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF:
NAME and ADDRESS
FiELLOW BOOK SALES & DISTRIBUTION Cd
107 N COMMERCE WAY
C/O AMATO & ASSOC
LBETHLEHEM, PA 18017 J
VS
DEFENDANT: .
NAME and ADDRESS
r&ARY MORTON/GL MORTON/ABA BIZ NES07
116 4TH STREET
NEW CUMBERLAND, PA 17070
YELLOW BOOK SALES & DISTRIBUTION CO L J
107 N COMMERCE WAY Docket No.: CV-0000260-09
C/O AMATO a ASSOC Date Filed: 5/29/09
BETHLEHEM, PA 18017
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR DEFENDANT (Date of Judgment) 7/13/09
® Judgment was entered for:
(Name) GARY MORTON/GL MORTON/ABA BIZ NESS
119 Judgment was entered against: (Name) YELLOW BOOK SALES & DISTRIBUTI
in the amount of $ • 0
F] Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
F1 This case dismissed without prejudice.
Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127
Portion of Judgment for physical damages arising out of
residential lease Q
Date
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
J U L 13 2009 Date
I certify that this is a true and correct copy of the record of the
My commission expires first Monday of January, 2014
AOPC 315-07
Amount of Judgment $ .00
Judgment Costs $ .00
Interest on Judgment $
Attorney Fees $
Total $ .00
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
_ , Magisterial District Judge
containing the judgment.
Magisterial District Judge
SEAL
DATE PRINTED: 7/15/09 11:31:00 AM
All,
WOW
Aw,
-------------
4 /'q
COMMONWEALTH OF PENf? OYLYA
COURT OF COMMON PLEAS' NOTICE OF APPEAL
Judicial District, County Of CiMERLANN FROM
MAGISTERIAL DISTRICT JUDGE JUDGMENT
COMMON PLEAS No. OQ, 670 Ct yi I &I
NOTICE OF APPEAL F11ed 811010?
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District
Judge on the date and in the case referenced below.
OF APPELLANT
MAG. DIST. NO. I NAME OF MDJ
OF APPELLANT CITY STATE ZIP CODE
0 MATO & ASSOCIATES
OF JUDGMENT IN THE (
DOCKET No.
CV-260-09
A B A BI I NESS, INC.
This block will be signed ONLY when this notation is required under Pa. If appellant was GIalmant (see ra. rr.c.ru. j. rvo. luul(o) In acton
R.C.P.D. J. No. 10088.
This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED
operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty
(20) days after filing the NOTICE of APPEAL.
Signature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.D.J. No. 1001(7) in action before Magisterial District
Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or attorney or agent
rr
RULE: To appellee(s)
Name of appellee(s)
OWNER
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date , 20
Signature of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT)TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
(Defendant)
AOPC 3125 COURT FILE
7165 9704 3350 0003 1312
Postage $
Certified Fee
Return Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
Total Postage & Fees
?g61e
o°' off S
< A
7 d
vj?b?l HE)
Sent To
sneer, apt. N Gary Morton a/k/a G. Lloyd Morton
or PO Box No. .
City, stare, rp+4 116 4th Street _ __--
7165 9704 3350 0003 1329
Postage $
$nAA
Certified Fee 86100 Postmil
Return Receipt Fee
(Endorsement Required) J S2 30
Restricted Delivery Fee
(Endorsement Required) en nn d
Total Postage & Fees
Sent To
street, APt-No.; ABA Biz Ness, Inc.
or PO Box No.
city, stare, L'p+4 116 4th Street -
7165 9704 3350 0003 1343
Postage $
Certified Fee
Return Reoelpt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
Total Postage & Fees
O Heil
6.
Sent To
Honorable Charles A. Clement, Jr.
street, apt. No.; District Court 09-1-01
or PO Box No. S d3
City, state, Zip+4 400 Bridge t, - ---- -,,,,?
1 [
OF THE PPOTHONOTAR'
2009 AUG 17 PM 2: 19
c &E'.iiL;5c?0 COUNTY
PENPdS"1'L.VANIIA
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff
No. 09-5570
VS.
GARY MORTON a/k/a G. LLOYD MORTON
and A B A BIZ NESS INC.
CIVIL ACTION
Defendants
ENTRY OF APPEARANCE
Kindly enter my appearance on behalf of Plaintiff, Yellow Book Sales and Distribution
Company, Inc., in the above-captioned matter.
AMATO AND ASSOCIATES, P.C.
By: ,
Ronald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
F1LEL
0:: Tfjr-
2009 AUG G0 AM f 1: 20'
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff : No. 09-5570
VS.
GARY MORTON a/k/a G. LLOYD MORTON
and A B A BIZ NESS INC.
CIVIL ACTION
Defendant
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, 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
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or
(800) 990-9108
AMATO ND ASSOCIATES, P.C.
By:
Ronald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #1203922
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff
No. 09-5570
vs.
GARY MORTON a/k/a G. LLOYD MORTON
and A B A BIZ NESS INC.
CIVIL ACTION
Defendants :
COMPLAINT
The above Plaintiff brings this action against the above Defendants to recover the sum of
$6,402.37, with interest thereon as hereinafter stated, upon the following cause of action:
1. Plaintiff, YELLOW BOOK SALES AND DISTRIBUTION COMPANY, INC.,
is a Delaware corporation registered to do business in Pennsylvania with an address at 2560
Renaissance Blvd., King of Prussia, PA 19406.
2. Defendant, GARY MORTON a/k/a G. LLOYD MORTON, is located at 116 4th
Street, New Cumberland, PA 17070.
3. Defendant, A B A BIZ NESS INC., is located at 116 4th Street, New Cumberland,
PA 17070.
COUNTI
Breach of Contract
4. Plaintiff is engaged in the publishing business and publishes a telephone directory
known as the Yellow Book.
5. Defendants entered into a written contract with Plaintiff pursuant to which Plaintiff
agreed to publish certain advertising in the 2007-08 Harrisburg-Hershey-Carlisle edition of Plaintiff s
phone directory in exchange for Defendants' promise to pay the prices set forth in said contract, a
true and correct copy of which is attached hereto, made a part hereof and marked Exhibit "A."
6. Defendants' offer to advertise was accepted by Plaintiff in King of Prussia,
Montgomery County, PA.
7. Plaintiffperformed and complied with the contract and advertised in accordance with
Defendants' direction, consent and approval, all to Defendants' benefit.
8. There was no error or omission in any of the subject advertising.
9. Under the terms and conditions of said contract, Defendants agreed to pay Plaintiff
the total amounts for the periods listed in regular monthly installments, as set forth at length in said
contract.
10. Defendants agreed to remit all payments to Plaintiff at Plaintiffs place of business
in King of Prussia, Montgomery County, PA.
11. However, Defendants failed to make regular monthly payments to Plaintiff pursuant
to the contract.
12. Defendants' failure to make regular monthly payments to Plaintiff constitutes a breach
of the contract.
13. Pursuant to the terms and conditions of the contract, Plaintiff accelerated all
remaining payments due under the contracts when Defendants failed to make regular monthly
payments.
14. The prices charged for the aforesaid advertising is just and reasonable and are those
which Defendants promised, in writing, to pay Plaintiff.
15. A total principal amount which became due as a result thereof, after allowance for
all proper credits for payments and/or adjustments, if any, was $3,970.00, as set forth in the
statement of Defendants' account taken from Plaintiff s records, a true and correct copy of which is
attached hereto, made part hereof and marked Exhibit "B."
16. As set forth in the contract, Defendants agreed to pay Plaintiff interest on the above
amount, determined by applying the agreed interest rate of 18.00% per annum on the total
accelerated balance of $3,970.00, which currently totals $1,122.27.
17. Plaintiff is entitled to have the agreed interest continue to accrue through the date of
judgment in this matter.
18. Under the contract, Defendants further agreed to pay Plaintiff s reasonable attorneys'
fees incurred in the collection of any balance due Plaintiff, which currently totals $1,310.10.
19. Based upon the above, Defendants owe Plaintiff a total of $6,402.37.
20. Plaintiff has made demand against Defendants for the aforesaid amount, but
Defendants have failed or refused to pay the same or any part thereof.
WHEREFORE, Plaintiff demandsjudgment against Defendants for $6,402.37, together with
the continually accruing interest charge at the agreed rate of 18.00% per annum, costs of suit and all
other relief to which Plaintiff may be entitled.
COUNT II
Alternative to Count I - Unjust Enrichment
21. Plaintiff incorporates the allegations of every paragraph ofthis Complaint enumerated
above as if said paragraphs were fully set forth here at length.
22. At Defendants' request, Plaintiff conferred a benefit upon Defendants by providing
the phone directory advertising services described in the exhibits attached hereto.
23. Defendants received and accepted the benefit of said services provided by Plaintiff.
24. At all times material hereto, Defendants were aware that Plaintiff was providing the
aforesaid services to Defendants and that Plaintiff expected to be paid for such.
25. At all times material hereto, Defendants, with the aforesaid knowledge, permitted
Plaintiff to provide said services and to incur damages.
26. At all times material hereto, Defendants were unjustly enriched by retaining the
benefit of receiving said services without paying Plaintiff fair and reasonable compensation.
27. Allowing Defendants to retain the benefit of said services without paying fair
compensation would be unjust.
28. By reason of the aforesaid unjust enrichment of Defendants at Plaintiff s expense, an
implied contract exists between Plaintiff and Defendants and Defendants are obligated to pay
Plaintiff the quantum meruit value of the services described in the exhibits attached hereto in the
amount of $3,970.00.
WHEREFORE, Plaintiff demands judgment against Defendants for $3,970.00 together with
the continually accruing interest charge at the statutory rate of 6.00% per annum, costs of suit and
all other relief to which Plaintiff may be entitled.
AMATO AND ASSOCIATES, P.C.
By:
Ronald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
VERIFICATION
hereby states that he/she is the ' A'Owa/? 6dc
Plamtiff'in this action, and verifies that the statements made in the
of YIaw lC S21 dad
attached document are true and correct to the best of his/her knowledge, information and belief. The
undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A.
§ 4904 relating to unsworn falsification to authorities.
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yellowbook
2201 Renaissance Blvd., 4th FL
King of Prussia, Pa 19406-2673
Tel: 800.242.5774
Fax: (610) 731.2789
STATEMENT OF ACCOUNT
DATE: April 29, 2009
CUSTOMER'S NAME & ACCOUNT #: A B A Biz Ness Inc
MA 291256
ORDER ADVANCE MONTHLY # OF NET
TOTAL PAYMENT BILL DATE DIRECTORY AMOUNT MONTHS BILLING
$ 4,728.00 $ 788.00 08/07-05/08 Harrisburg-Hershey- $ 394.00 10 $ 3,940.00
Carlise 07/08
PAYMENTS RECEIVED:
None
"BILLING FEES** $ 30.00
TOTAL BILLED $ 3,970.00
TOTAL PAYMENTS $ -
TOTAL DUE $ 3,970.00
EXHIBIT
'!7 rt=via 2 it 4', 1 i G J
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff
Vs.
No. 09-5570
GARY MORTON a/k/a G. LLOYD MORTON
and A B A BIZ NESS INC.
CIVIL ACTION
Defendant(s)
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of Plaintiff's Complaint was
served via first class mail, postage prepaid on August 21, 2009:
Gary Morton
G. Lloyd Morton
116 4th Street
New Cumberland PA 17070
A B A Biz Ness Inc.
1164 th Street
New Cumberland PA 17070
AMATO AND ASSOCIATES, P.C.
By. \
Ronald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
FILE
OF THE F H'ONO TARP
1f
2009 AUG 28 Pl 2: 45
CUM;-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff No. 09-5570
VS.
GARY MORTON a/k/a G. LLOYD MORTON
and A B A BIZ NESS INC.
: CIVIL ACTION
Defendant
PRAECIPE FOR JUDGMENT
TO THE PROTHONOTARY, CUMBERLAND COUNTY:
Kindly enter judgment by default for want of an answer in favor of Plaintiff and against
the above-named defendant(s) only and assess damages as follows:
Debt $6,402.37
Interest (from August 10, 2009 to October 20, 2009
at 18% per annum) 192.08
Payments
Total
$6,594.45
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED
AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM
CERTAIN FROM THE COMPLAINT.
Pursuant to RCP 237. 1, 1 certify that a copy of the annexed written notice(s) of intention to
file this praecipe was mailed or delivered to all parties against whom judgment is to be
entered and to their attorney of record, if any, after the default occurred, and at least ten
days prior to the date of filing of this praecipe. Please note that said notice was mailed to all
parties on October 8, 2009.
Dated: October 20, 2009
AMATO AND ASSOCIATES, P.C.
By:
,orra"'LotrAmato, Esq., Atty ID #32323
ichael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
2083856
• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff No. 09-5570
VS.
GARY MORTON a/k/a G. LLOYD MORTON
and A B A BIZ NESS INC.
CIVIL ACTION
Defendant
CERTIFICATION OF ADDRESSES
I do certify that the precise last known address of the within named plaintiff is:
2004 Renaissance Blvd
KING OF PRSA,PA 19406
I do certify that the precise last known address of the within named defendant is:
PO Box 62400
Harrisburg PA 17106
AMATO A SSOCIATES, P.C.
By:
d Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK SALES AND :
DISTRIBUTION COMPANY, INC.
Plaintiff
No. 09-5570
vs.
GARY MORTON a/k/a G. LLOYD MORTON
and A B A BIZ NESS INC.
CIVIL ACTION
Defendant(s)
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF NORTHAMPTON
The undersigned, being duly sworn, according to law, deposes and says that he is
unable to determine whether or not the above Defendant(s) is/are not in the Military or
Naval Service of the United States or its Allies, or otherwise within the provisions of The
Servicemembers Civil Relief Act;
That Gary Morton is over 18 years of age, resides at PO Box 62400, Harrisburg PA
17106 and is employed;
Sworn to and subscribed
before me this`d` day
of 2009 A.D.
NOTAR PUB
0WFFRE1r 90N0Wd=
NANMR TG',.. CN H P, NORT11AWn*N CWY
My COmr,-:;.c:::-1 [xplrM UWA 3% 2012
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff : No. 09-5570
VS.
GARY MORTON a/k/a G. LLOYD MORTON
and A B A BIZ NESS INC.
Defendant(s)
TO: Gary Morton a/k/a G. Lloyd Morton
PO Box 62400
Harrisburg PA 17106
Date of Notice: October 8, 2009
IMPORTANT NOTICE
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 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
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or
(800) 990-9108
AMATO AND ASSOCIATES, P.C.
By: 1 I XD
Ronald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
Attorney File# 2083856
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff : No. 09-5570
VS.
GARY MORTON a/k/a G. LLOYD MORTON
and A B A BIZ NESS INC.
Defendant(s)
TO: A B A Biz Ness, Inc.
PO Box 62400
Harrisburg PA 17106
Date of Notice: October 8, 2009
IMPORTANT NOTICE
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 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
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or
(800) 990-9108
AMATO AND ASSOCIATES, P.C.
By:
Ronald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
Attorney File# 2083856
FLED--OrrKI
OF THE OWPONO7AAY
2009OCT 26 Pty 2: 26
1J?J41 Y 4 1
PENNSYLUWIA
? oo QQ
c* a(,g6t6
04 ,5i (0
Nut?c?u, 4?'W'`4d
• • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
'YELLOW BOOK SALES AND
w DISTRIBUTION COMPANY, INC.
Plaintiff
VS.
GARY MORTON a/k/a G. LLOYD MORTON
and A B A BIZ NESS INC.
Defendant
No. 09-5570
CIVIL ACTION
NOTICE OF JUDGMENT
(XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED
MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s)
IN THE AMOUNT OF $6,594.45 ON 00f 9J4 , 2009.
( ) A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF
CUMBERLAND COUNTY IN SUPPORT OF THE WIT IN
JUDGMENT IS/ARE ENCLOSED. L_zV
PRO ONOTA ERLAND COUNTY
If you have any questions concerning the above, please contact the undersigned.
AMATO AND ASSOCIATES, P.C.
By: ( 1
Ron A Amato, Esq., Atty ID #32323
chael R. Lessa, Esq., Atty ID #88617
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM