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HomeMy WebLinkAbout09-8773TWA SAN ARBITRATION CASE. WAR K 40TREMM JAMES W. ADELMAN, ESQUIRE Mail@morrisadelman.com «IDENTIFICATION #02604 MORRIS & ADELMAN, P.C. PO BOX 30477 `Philadelphia PA 19103--8477 215/568-5621 ATTORNEY FOR PLAINTIFF Four Colour Imports Ltd Four Colour Imports Ltd COURT OF COMMON PLEAS 2410 Frankford Avenue CUMBERLAND COUNTY Louisville KY 40206 CIVIL DIVISION vs. The Nippert Company (A PA Corp) 728 Creek Road . Carlisle PA 17013 NO. 09 - 8773 CiviI -- rk COMPLAINT-CIVIL ACTION NOTICE TO DEFEND 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 afte 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 fur,=her 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. LAWYER REFERENCE SERVICE Cumberland County Bar Association 2 Liberty Av Carlisle PA 17013 717/249-3166 JWA1214.2 1. Plaintiff is Four Colour Imports Ltd. Defendant(s) is The Nippert Company (P. PA Corp). COUNT I 2. At the oral request of Defendant(s), Plaintiff sold and delivered to Defendant(s) goods and merchandise, at the times, of the % kinds, in the quantities, and for the prices set forth in Plaintiff's books of original entry, a true and correct copy of which is attached hereto, made part hereof, and marked Exhibit "A". 3. Defendant(s) received and accepted the goods described in Exhibit "A". 4. The prices, including service and/or other charges, if any, which are set forth in Exhibit "A", are the fair, reasonable and `market prices and the prices which Defendant(s) agreed to pay. 5. All credits, if any, to which Defendant(s) is entitled are set forth in Exhibit "A". 6. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff claims there is now justly due and owing by Defendant(s) the sum of $5,196.69 with interest at 18% from May 30, 2009 and costs on Count I. JWA1214.2 COUNT II 7. Paragraphs 1 through 6 are incorporated by reference. 8. On or before May 30, 2009, Plaintiff delivered goods to Defendant at the times, of the kinds, in the quantities, and for the prices set forth in Plaintiff's books of original entry, true and correct copies of which are shown as Exhibit "A". 9. Defendant received and accepted the goods shown on Exhibit "A", and benefitted thereby. 10. Defendant received the benefit of the goods from Plaintiff and it is unconscionable for Defendant to receive those benefits without making restitution to Plaintiff. 11. It can be inferred from the acts in the light of the surrounding circumstances that Defendant implied that it would pay Plaintiff for the goods. 12. Under the circumstances of the case, the ordinary course of dealing and the common understanding of man, there is shown a mutual intention by Plaintiff to sell and Defendant to pay for the goods. JWA1214.2 13. Under the circumstances, the goods were delivered to Defendant under an implied promise to pay. 14. All conditions precedent to the present action have occurred or been performed. Y 15. Defendant is liable to the Plaintiff in the sum of $5,196.69 under the theory of quantum valebant, quantum meruit, quasi contract, implied contract, goods had and received, and/or unjust enrichment. WHEREFORE, Plaintiff claims there is now justly due and owing by Defendant(s) the sum of $5,196.69 with interest at 18% from May 30, 2009 and costs on Count II. JAMES W. ADELMAN, ESQUIRE A orneys For Plaintiff Post Office Box 30477 Philadelphia PA 19103-8477 215/568-5621 JWA1214.2 I , t VERIFICATION Co ?- f'Q C I hereby states that he/she is the of Plaintiff in this action, and verifies that the statements made in the attached Complaint 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. §4904relating to unsworn falsification to authorities. l Phone: (502) 896-9644 Four Colour Imports, Ltd 2410 Frankfort Avenue Louisville KY 40206 Fax: (502) 896-9594 Statement Joseph's Heartprint George Nippert 728 Creek Road Carlisle PA 17015 Closing Date 06/26/09 Page Number I Invoice # Date Type Disc Date Due Date Reference Amount Days 0000009524 12/31/08 I 12/31/08 0-1/30/09 01/31/09 F 01/31/09 01/31/09 02/28/09 F 02/28/09 02/28/09 03/31/09 : -F 03/31/09 03/31/09 04/30/09 F 04/30/09 04/30/09 05/30/09 F 05/30/09 05/30/0; Bal. Due 12 4896.20 2.45 71.03 74.55 75.66 76.80 5196.69 0000009524 Total Balance 5196.69 Past Due Past Due Past Due Current 1-30 Days 30-60 Days > 60 Days 0.00 0.00 0.00 5196.69 r t i INVOICE Date: 12/31/08 Due Date: 01/30/09 Inv. No.: 9524 Page No.: 1 ?pr FOUR COLOUR IMPORTS, LTD. rY Four 2410 FRANKFORT AVE. LOUISVILLE, KY 40206 CdOW PHONE: (502) 896-9644 knPortt, Ltd. Overdue invoices automatically receive a finance charge of 1.5% per month. Please pay by due date to avoid extra expense. • PRODUCT INVOICE (7102) DACEASY To Ready Cad DWEery Charts yid Foam 7-BW1222.0505 4896.20 ° = 00 0 _ .- ..,. . 4896.20 :TOTAL..- ;- i 4 S - ;,,.. ?aY, ,. Y_ ?•,::.. ,.::,. ;.:, NET TO..PAY 4896.20 D00226 (8!07)(4815338) 553720 0 r O 4qa. m Po Ar-y Co 1o4N5I51o4ol e 02W 3aa SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor OF THE D 1010 JAN -5 'PH 2, 28 Olm??i?Y m Four Colour Imports, Ltd. vs. The Nippert Company Case Number 2009-8773 SHERIFF'S RETURN OF SERVICE 12/28/2009 10:35 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on December 28, 2009 at 1035 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: The Nippert Company, by making known unto Brenda Nippert, Owner at 728 Creek Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 December 29, 2009 SO ANSWERS, -000, 1 R THOMAS KLINE, SHERIFF By - DepuFherif f Cour-ySIAC Shen't Te'eso't. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FOUR COLOUR IMPORTS LTD N0.2009-08773 2410 Frankford Avenue Louisville, KY 40206 : vs. THE NIPPERT COMPANY 728 Creek Road Carlisle, PA 17013 and F & M TRUST, Garnishee PRAECIPE TO AMEND WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter. (1) directed to the Sheriff of Cumberland County .~., ;~ .,f. -',~: N -~ ~~ 'p (2) against THE NIPPERT COMPANY 728 Creek Road, Carlisle~PA 17013, defendant; and (3) against F & M TRUST 14 N. Hanover Street, Carlisle, PA 1.7013, garnishee; (4) and index this writ (A) against defendant and (B) against , as garnishee, as a lis pendens against real property of the defendant in name of garnishee as follows: All accounts, funds, deposits, debts, or other items of personal property standing in the name of the defendant. (5) Amount Due: Attorney's Commission Interest from $ 2.506.34 for Plaintiff c..-4 ._~ c _,-, `_T _, , , -; =z~ :..~ Al~lu ply WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-8773 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FOUR COLOUR IMPORTS LTD., Plaintiff (s) From THE NIPPERT COMPANY, 728 Creek Road, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all 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: F&M TRUST, 14 N. Hanover Street, Carlisle, PA 17013 All accounts, funds, deposits, debts or other items of personal property standing in the name of the defendant 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 ~d,SOCo.3~f Interest from 2/4/10 L.L. $.50 Atty's Comm Atty Paid $166.40 Plaintiff Paid Date: 4/5/10 (Seal) Due Prothy $2.00 Other Costs id D. Buell, Pr thonotary By: Deputy REQUESTING PARTY: Name JAMES W. ADELMAN, ESQUIRE Address: MORRIS &ADELMAN, PC 1920 CHESTNUT ST, SUITE 300 PO BOX 30477 PHILADELPHIA, PA 19103-8477 Attorney for: PLAINTIFF Telephone: 215-568-5621 Supreme Court ID No. 02604 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r T~~F1lED-t~!'r Sh2rlff ~~~ utr of ~anit~erJa ~~f.~ t-"tG a ~ ~"~~.+}~~.~rVl- Jody S Smith Chief Deputy ZQ ~ ~ ~~~ ~ 3 ~~ ~ : { ~? Edward L Schorpp Solicitor ~ - ~R«~ CLM~~:~~--h tJ c~;~,1N1Y PE~V~#SYI.V~~ ~~: Four Colour Imports, Ltd. vs. Case Number The Nippert Company 2009-8773 SHERIFF'S RETURN OF SERVICE 05/11/2010 10:31 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 11, 2010 at 1031 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: The Nippers Company, in the hands, possession, or control of the within named garnishee, F & M Trust, 14 N Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Donna K. McNaughton, Certified Teller, 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. SO ANSWERS, ~-~.. May 12, 2010 RON R ANDERSON, SHERIFF i liam line, Deputy .~i CountySuit~ Shen;f. Telc;cseft, li,::. .: OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: RAINBOW HOPKINS FARMERS & MERCHANTS TRUST CO. 150 Lincoln Way East Chambersburg, PA 17201 FOUR COLOUR IMPORTS LTD. COURT OF COMMON PLEAS 2410 Frankford Avenue CUMBERLAND COUNTY Louisville, KY 40206 CIVIL DIVISION vs. : THE NIPPERT COMPANY 728 Creek Road Carlisle, PA 17013 and FARMERS & MERCHANTS TRUST CO. NO. 2009-08773 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary (X) Judgment Against Garnishee ~s~ ( ) Complaint (Confession of Judgment) ( ) Judgment transferred from another jurisdiction ( ) Judgment by Default ( ) Money Judgment ( ) Judgment in Replevin ( ) Judgment for Possession ( ) Judgment on Award of Arbitrators ( ) Judgment on Verdict ( ) Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: JAMES W. ADELMAN, ESQUIRE At this telephone number: 215-568-5621 MORRIS & ADELMAN, P.C. BY: JAMES W. ADELMAN, ESQUIRE IDENTIFICATION #02604 ATTORNEY FOR PLAINTIFF POB 30477 Four Colour Imports Ltd Philadelphia PA 19103-8477 215/568-5621 Four Colour Imports Ltd 2410 Frankford Avenue Louisville KY 40206 VS. The Nippert Company (A PA Corp) 728 Creek Road Carlisle PA 17013 and Farmers & Merchants Trust Company Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION C N ~ ~`'r <- ° ~ N _~L-i f . _ .."'7 i ~._ - -~ , . ~:• -~ c~> ::e ~> -< N0. 2009-08773 ORDER FOR JUDGMENT AGAINST GARNISHEE AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Please enter judgment in favor of Plaintiff and against Farmers & Merchants Trust Company, Garnishee, in the amount of $410.99 pursuant to the attached Answers to Interrogatories filed by the Garnishee. Judgment Entered As Above: P othonotary-. torneys For Plaintiff s~y,avPd ~/y ~ ~9~d6~ /~~r~e'"4!/r"i JWA0524.4 05/24/2010 12:01 FA.g 717 261 3646 F lu M ~~ r --r v - v v: ~a amp f r r ~~9 Vv77 rbDi l2tUp'1' . O~ a~ 0 ~~ [1002 ~Q,~O'O7/009 You are hereby notiFied to plead to the ex~c.~osed Interrogatories w~.thin twenty (20) ays from service hereon or a efaul udgment may be ante ed ag in t yoga - P-C- MORRIS & ADEI~MAN, P.C. $Y. JAMES W. ApELMAN, ESQUIRE IDENTIE'ICATION # 02604 1920 Chestnut Street, S/~00 P_O_ Sox 30477 ' Philadelphia, PA 19103-$477 (215) 568-562. At r ays fox Plaintiff. FOUR CO~,OC~R IMPORTS LTD. 2 410 L'ran kf o rd Avenue Louisville, KY X10206 vs. THE NIPPERT COMPANY 72B Creek Road Carlisle, pA 17013 and F & M TRUST, Garnishee . COURT OF COMMON PLEAS CUMSERI,.AND COUNTY . CIvXL DIVZSTON NO. 7_009-08773 TNTFRROGAT08IES TO GARNISHEE TO: F & M TRIIST I4 N_ Hanover Street Carlisle, PA 17013 Garnishee You are required to file answers to the following Ini:errogatoxies within ~:wenty,(20) days after service upon you_ Failure to do so may result in judgment against you_ 1. At the time you were served ox at any subsequent time, did yQU owe the Defendant any money or were you liable to [him] the defEndan on any negotiable or othez wriL'ten instrument, or d~.d [he] the de endant claim that you owed [him] the def ndant any money ox were liable to [ham] the defendazat for any reasons? State the amount ~S- ~,(z~nd~ IJ-PpG{~-~" YY1d1lY1~'o11V1S ~l~ yes ~ , specifically. h t l~ b ~t n ' ~ ~ 0 ~~ i s ~, g ~ f~~ s~ .~ h 2 b~ l~ n c ~ O ul Y1~" W i-Hrl ~~ M OlC Th ~ d e~-P.n ~ ~ n-t-r W a S ~ l I n v~l ~ dl ->t-h ~~ ~~ 20 ~ D . ~ ~ - _- ~.~oo.o~ ex~mP~o~ p~~ ~_._ ~{~~- d - - 05/24/2010 12:01 FAX 717 261 3646 _ F & M i ~v'.r. ~.. .. ~u -tea. ~~c ~7 rran !1 lcrYVV7.7 srp Cl !.'KUbl i @10 0 IQ~v08/009 2. At the time you were served or at any subsequent time, was there in your possession, custody or control, or in the joint possession, custody or control of yourself and others, any property o.f any nature owned svl.ely or in pars: by the Defendant? Zf your answer is In the afiixmative, describe the nature and value of said property. N~- 3, At the tune you were served or at any subsequent time, did you hold legal. title to any property of any nature owned solely or in part by the Defendant? Xf your answer is,1 in the affa.rmat~.ve, describe the nature and value of said pzoperty_ `~'~~ 4. At the time you were served or at any subsequent time, did you hold as .fiduciary any property in which the Defendant had are interest? If your answer is i.n the affirrnati.ve, describe the nature and value of said pzoperty. ~ ~~ 5_ At any t3.me before or after you were served, did the Defendant~tr_ansfer o r deliver any property to you or to any person or place pursuant to your direction or consent; and what was the y ~S, ~e d e~ da h~' hA S Irri Q1.c( ~ consideration there for? ~d se ~ deposits s~nc~ . - v ~~M rt~~s+ was 6. At any time after you were served, did you pay, transfer oz deliver any money or pxopezty to the Defendant or to any person or place pursuant to [his] the de endant's direction or otherwise discharge any claim of the Defendant against you? 1{ $~ ~''1~ d ~ f~enda n-t~ v~! a S 9 ~ ~~.+~ ~ e X30 o urt d ~ -tom ~ eXem~lioN . 05/24/2010 12:01 FAX 717 261 3646 F & M ~. -: ------ - - -- . ~ ~ 005 ^. __~ _„ ..~ ... _.. --~.. .~ ~ ..~~v» oan inuP1 Ip,JVV'J/VV9 7. If you are a bank or other financial i,nstittlt7.on, at the time you were served or at any Subsequent time did the defendant have funds on. deposit in an account in which funds are deposited e~,ecl.ronica7.7_y on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, zevy or attachment under Pennsylvania or federal law? If so, identify eackl account and state the reason for the exemption, the amount being withheld under each exemption and the entity electx'onica2ly depositing those funds on a recurring basis. N0, ~41Na15 Ark SOt'Yt~~"IY11lS `~YGr11s~~Y~tl,~ ~.~M ~ ~a y Pa I ace o ~- -~. 8. Zf you are a bank or other financial institution; at Lhe time you were sertred or a.t any subsequent 't~.me did the defendant ha'crG funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did,not Exceed the amount of the general monetazy exemption under 42 Pa.C.S_ ~B1232 rf so, i.dentiiy each aGCOUnt. 1~ib• (a) Identify aJ.7, dacuments that were given to the Bank or signed for the Bank establish.~n the account. SUNG Si~N~I-t~ulrG, t~IYal Sion{off ~y ~ ~~~endal Nipp~~~' as `~.~~ (b) State the Sank s understanding of the legal ~ompositi.on P~~~ of its customer and identify all documents the Bank has 1 that showed that legal composition_ (c) State all addresses given for the Bank's customer and a11. addresses to which the account statements were to be sent. ~Z.~ G~ee~- ~Oolo~ Gulp-I~s 1 ~, PA ~~013 e~~,n~l ~ ~- N - Pe~c~-t- db~ N i ~~ t'~-t ~t not ~ o • ~'R--h+v c ~-~.s ~rtiDliN9 in ~~~3ot~. 05/24/2010 12:01 FAX 717 261 3646 F & M - - - ~ 003 .•~5t11/2010 14;22 2155634627 MQRRIS PAGE f,1/e1 LAW OFFICB6 ~OR~tTS ~ ~~~.~, P. C. .>v~Mes w, AoE~nnnn 1920 CHESTNUT STREET ~ SUiTE 300 KFSlNBTH F. CAROBUS PHILADELPNiR, PA 18103-4620 RpEEfit M, MOARIs couNeriro nle Fran ~ 215-568-582'1 FPOEFIT M_ REt83i~IN 8a4^'74b-8a6$ FAX: 215-588-9253 g08F_g7 I_ MOgRl6 1e2~ - 2001 May IZ, 203.0 Ms. Rainbow HQpk3n.s F&M Trust 15o Lincoln Highway Eaat Chambersbvrg, P.A 17201 VXA FAX ONLY: 7I7-26~.-3646 RE: Four Color imports, Ltd. vs: The Nippert Company Our file no. 92267 Cumberland County CCP Docket No. 2009-06773 Dear Ms. Hopkins: sErm ALA us. Ma~~ ro: MORfi1S S ADELMAN. p_C. F~,o. BOX 3~r pFnvwR~PHIA. Pa ~maa.Eea~~ E-meu: maummorrteadalman_corn This firm z~epresents the judgment creditor in connection with the above - re f erenc-ed bank at t achmez~t . Zt is vur ux~deratal3diz~g that the account you atCached is standing in the name of Brenda Nippert trading as The Na.ppert Company, and there is roughly $se3 in it. $300 of that is exempt. If Mr_ yr Mrs. Nippert come into their local, branch ~,nd ask for the 5300, please giv® them cash in that amount. .Also, please restrict the remaining 583.00 until my business paxtner, Jam Adelman, comes back from his vacation next week. He will pall you and let you know whether he thinks iir is worthwhile to proceed w:~th the attachment fox the -remaining funds , Mr. Nippert is under extreme stress. H~.s wife and Qne of his six ch~.l.dren are x.11. Flease mak easy as easy as pessib7.e for ham to effect the wit awal. y yours, M. MORRIS MORRIS & ADELMAN P.C. BY: JAMES W. ADELMAN, ESQUIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION #02604 POB 30477 Four Colour Imports Ltd Philadelphia PA 19103-8477 215/568-5621 Four Colour Imports Ltd 2410 Frankford Avenue Louisville KY 40206 vs. The Nippert Company (A PA Corp) 728 Creek Road Carlisle PA 17013 and Farmers & Merchants Trust Company 150 Lincoln Highway Chambersburg PA 17201 Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION • c ~ `~ . ~_' ~ ~- ~-~ ~ ,_; • .. ~. f 1'f ~~`' ~: ~ ~ • y- NO. 2009-08773 ~ ~ - ORDER TO SATISFY JUDGMENT AGAINST GARNISHEE BANK TO THE PROTHONOTARY: Please mark the judgment in the above-entitled case against garnishee, Farmers & Merchants Trust Company, satisfied upon payment of your costs only. I S & ~.H'~LMAN„ P . C . So -Qz cle~eci~ as .~abc~ve ~_ .. Proms ra?'p.~" J .- ES W. ADELMAN, ES"QUIRE At orneys For Plaintiff ~~ 9 ~a~~ /~~.~ a ~~3 F~~ JWA0609.2 ~,. . MORRIS & ADELMAN, P.C. BY: JAMES W. ADELMAN, ESQUIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION #02604 Four Colour Imports Ltd POB 30477 Philadelphia PA 19103-8477 215/568-5621 Four Colour Imports Ltd 2410 Frankford Avenue Louisville KY 40206 vs. The Nippert Company (A PA Corp) 728 Creek Road Carlisle PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION N0. 2009-08773 ORDER TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment in the above-entitled case satisfied upon payment of your costs only. So Ordered As A ve: .~ Prothonotary MO IS & ELMAN, .C. Y: J ES W ADELMAN ESQU JWA0619.2 . IRE torneys For Plaintiff ^~ r- ~ ~ ~ -~•~ ~~~ g ~y ~~ t._~ -; v, ~.J . I ~=- e~ ~ ~~~ .1~~ a .., ~ ~ `, '~'~ ~., SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~ ,. Sheriff ~~~ ai ~umb~r~ ~,- ~ ~ - ~ ~ ~° ~ ~ - ~ . r °~1~ Jody S Smith ~~ 6°' ChiefDeputY ~ ~~'S~ ~~ Zu~~ ~,j'~ --~~ l`Y: i u 1' Richard W Stewart ~~ ~'~ '~VG" y p/1~! I : S~ SOlICItOt fCE ~?F "H@S~ERlPF ~~~i''J!:.' ~ ~ ._ . ''~~~')~ ~, ~ ~ . Four Colour Imports, Ltd. Case Number vs. The Nippert Company 2009-8773 SHERIFF'S RETURN OF SERVICE 05/11/2010 10:31 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 11, 2010 at 1031 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: The Nippert Company, in the hands, possession, or control of the within named garnishee, F & M Trust, 14 N Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Donna K. McNaughton, Certified Teller, 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. 06/07/2010 11:15 AM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2010 at 1100 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: The Nippert Company, by making known unto George Nippert, business owner and adult in charge, at 728 Creek Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handinc to him 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 06-OS-10. 08!04/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiff's attorney. SHERIFF COST: $171.95 August 04, 2010 SO ANSWERS, RON R ANDERSON, SHE FF B aron R. Lantz ~'~. s'o ltd... eK~ 7~Y4~ ~ayL2~ (c) CountySuite Sheriff, Teleosoff, Inc.