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HomeMy WebLinkAbout10-3888r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,. PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff VS. DONNA SHAPER Defendant ~ ..... ~ - `~ Er` _... ~ r-~ . ~ [_. CIVIL ACTION ~'-' -n 'z - -" v ' "` : ,- ~- ~ w - •~ ~ ~ • - PRAECIPE FOR TRANSFER OF JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment in favor of Plaintiff and against the above-named defendantlsl, pursuant to Pa.R.C.P.D.J. No.4021D), for failure of defendant(s) to appeal, within 30 days, a judgement entered April 13, 2010 against the above-named defendant(s) before District Justice Richard S. Dougherty, as set forth in the transcript of judgment, which is attached hereto. Assess damages as follows: Judgment Amount 4,337.70 Payments Total $4,337.70 Dated: June 8, 2010 AMATO D ASSOCIATES, P.C. By: ~ - - Ronald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM 1090862 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CII~$r:r•Axn Mag. Dist. No.: 09-1-03 MDJ Name: Hon. RICHARD S. DOIIGHERTY Address: 98 S ENOLA DR STE 1 ENOLA, PA Telephone: (717 ~ 7x8-a8o5 17oa5 ATTORNEY FOR PLAINTIFF AMATO AND ASSOCIATES, P.C. 107 N COMMBRC$ NAY BETHLEHEM, PA 18017 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAIILT JQDQ~NT PLTF NOTICE OF JUDGMENT/TRANSCRIPT clvl~ casE PLAINTIFF: NAME and ADDRESS rBLIIESTONS INVESTMENTS INC. ~ 107 N. COi~RCE NAY C/O AMATO 6c ASSOCIATES LBETHLEHEM, PA 18017 J V.S. DEFENDANT: .NAME and ADDRESS rSHAFER, DONNA ~ a3a s. ENOLA DRIVE ENOLA, PA 17oa5 L_ J Docket No.: CV- OOOOOa5-10 _ Date Filed: .1/x6/10 - (Date of Judgment) 4/13/10 ® Judgment was entered for: (Name) BLIIESTONE INVESTMENTS INC . ® Judgment was entered against: (Name S~P'~• ~~ in the amount of $ 4, 337. Defendants are jointly and severally liable. .Damages will be assessed on Date & Time 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 $ Amount of Judgment $ 4,159.70 Judgment Costs $~~a Lnterest on Judgment $ - Attorney Fees Total $ 4, 337.70 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ 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 JUDGMENT/TRANSCRIPT 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. APR' l _ 3 2010 Date I certify that this is a true MAY ~ 4 2010 Date My commission expires first Magisterial District Judge nirig the judgment:. Magisterial District Judge_ 01~ SEAL AOPC 315-07 DATE_PRINTED: 5/x4/10 2:46:00 PM FlLED--irr=~u~ Zoio .-u~ ~ ~ P~ ~: ~ 9 PEPS; vS'yLVtiNl~ ~a~.,~g ~a7. ~s /~ ,~`$ X53 y ~ 2~t 5Cv ~ N~~ M~:r~ r , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff vs. DONNA SHAPER ~> No. CIVIL ACTION 0 Defendant CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: C/o Ronald Amato, Esquire 107 North Commerce Way Bethlehem PA 18017 I do certify that the precise last known address of the within named defendant is: 232 S Enola Dr ENOLA PA 17025-2812 AMATO ASSOCIATES, P.C. By: onald 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 BLUESTONE INVESTMENTS, INC. Plaintiff No. vs. DONNA SHAFER 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 Defendants) 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 Donna Shafer is over 18 years of age, resides at 232 S Enola Dr, ENOLA PA 17025-2812 and is employed; Sworn to and subscribed before me this v\ day of^~,y-~ 2010 A. 2~ NOTAR PUBLIC NOTARIAL SEAL piOFMl1I d ~CIIOENECK Pubtb YANOVER TOMINMl~ NW17fIAMPTON' C'. i 1 My ~ Yr~oh 29, 201.^. . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW BLUESTONE INVESTMENTS, INC. Plaintiff No. vs. DONNA SHAPER CIVIL ACTION Defendant 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 $ ON 2010. ( - A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY -CUMBERLAND COUNTY Per: If you have any questions concerning the above, please contact the undersigned. AMATO~D 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 (6101 866-0400 A DEBT COLLECTION LAW FIRM f i~t»1.7~Ui i It,~ Of' T~« ~~~T~'O~~1lT~,~Y 2~1~ OAT ?2 Fr 2~ ~2 Bluestone Investments, Inc. ~;;~ ~~ ~; = p C ~, ~ p C C1 L~ y' THE COURT OF COMMON PLEAS Plaintiff (Respondent) ~` ~ ~ ~ ~ `~' ~i~'~, ~ 3 t,~~umberland COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Donna Shafer, : NO. 10-3888 Civil Defendant (Petitioner) AND NOW COMES the Defendant, Donna Shafer, through her attorney, William L. Adler, and respectfully represents the following: 1. This petition is filed pursuant to PA RCP 206.1. 2. Bluestone Investments, Inc. filed a civil complaint with the district justice Richard Dougherty, magisterial District number 09-1-03 in Cumberland County Pennsylvania to number CV-25-10 on 3anuary 26, 2010. 3. The plaintiff, Bluestone Investments, Inc., allegedly acquired legal title to a credit card account of defendant that she held through Chase Bank USA, NA. 4. This complaint from the office of the district justice was improperly served on the defendant in that on March 19, 2010 the Constable delivered the complaint to the defendant's boyfriend, Shawn Vest, and not to the defendant. (Copy attached as Exhibit "A") 5. Mr. Vest never gave the complaint to the defendant. 6. Mr. Vest moved out of the defendant's residence in June of 2010 when the defendant found that he had fathered a child by another woman. 7. The defendant believes and therefore avers that if the notice of the district justice judgment was sent to the defendant, that Mr. Vest intercepted this notice and disposed of it in furtherance of his attempt to cover-up the failure to deliver the complaint to the defendant. 8. Having never received notification of the complaint or the entry of judgment, defendant did not appeal the judgment. 9. This judgment in the amount of $4337.70 was transferred to the office of the Prothonotary in Cumberland County, Pennsylvania. 10. Normal procedure would have included the mailing of a notice of judgment to the defendant. 11. A copy of a notice of judgment that was a part of the file of the prothonotary in this matter has no pertinent information completed. A copy of this notice is attached hereto as Exhibit "B." 12. Defendant never received this notice. 13. Service of the complaint was improper due to that fact that it was not served on the defendant. 14. Defendant's due process rights have been violated due to improper service of the complaint. COUNT I -PETITION TO OPEN/STRIKE JUDGMENT 15. Petitioners hereby incorporate by reference the allegations set forth in paragraphs one through fourteen. 16. The judgment must be stricken or opened. A Petition to Strike/Open Judgment must be granted if the Petition: (a) is timely filed; (b) alleges a meritorious defense; and (c) presents sufficient evidence to require submission of the case to a jury. 17. This case is timely filed because defendant first discovered the entry of the judgment when the writ of execution was delivered to her. 18. After the writ was delivered to her, she contacted plaintiff to get copies of statements from what was originally a Washington Mutual account. 19. Plaintiff informed defendant that these would be sent, but they were not. 20. Defendant contacted an attorney when she received the notice of sheriff sale of her personal property. 21. Although defendant did originally have a balance on a Washington Mutual credit card, her card was lost/stolen, and charges were made on her card which were not hers. 22. Washington Mutual/Chase failed to acknowledge this or do anything about it. 23. Defendant disputes most of the charges alleged in the complaint. 24. Defendant's meritorious defense is that she does not owe the balance alleged in the complaint because around $2,500.00 in charges were not hers. 25. Proceedings should be stayed in this case because: (a) the instant Petition to StrikelOpen states prima facie grounds for relief; (b) the harm to Defendants from denying a stay would be severe and irreparable; and (c) the only "harm" to Bluestone Investments, Inc. from granting a stay would be a short delay in enforcement pending a proper judicial determination of whether such enforcement is justified. WHEREFORE, Defendants respectfully request that the judgment entered in the above-captioned matter be stricken or, in the alternative, opened, and that all proceedings in this matter stayed. Attorney for Defendants 4949 Devonshire Rd. Harrisburg, PA 17109 717-652-8989 Supreme Court ID Number 39844 BAL@Bi11Ad1erLaw.com October 20, 2010 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW BLUI;STONE INVESTMENTS. 1NC. ; Plaintiff No. vs. DONNA SHAPER : CIVIL ACTION Defendant . NOTICE 4F JWDGIVIENT IKX) NOTICE IS HEREBY GIVEN THAT A .JUDGMENT IN THE ABOVI? CAPTIONED MAT`T'ER HAS BEEN ENTf~FiED AGAINST THE ABOVE-NAMED DEFENDANT(s} IN THE AMOUNT OF 5 ON , 2010. ( ) A COPY OF ALL DOCUMENTS FILED WITH 7HE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF TH£ WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY -CUMBERLAND COUNTY Per: If you have any questions concerning the above, please contact the undersigned. AMATO D ASSOCIATES, P.G. 13y: onald Arnato, Esq., Atty ID #32323 Michael R. Lease, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #$4464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, Pq 18017 (6101 866-0400 A DEBT COLLECTION LAW FIRM ~~~ ~ VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING PLEADING ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S.A. Section 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: D © l0 CERTIFICATE OF SERVICE I, William L. Adler, Esquire, Attorney for Defendants, hereby certify on the ~~ day of ll ~/~a ~~~~ , 2010, I served a copy of the within Petition upon the following person by first class mail, postage prepaid, addressed as follows: Plaintiff Amato and Associates, PC 107 N. Commerce Way n Bethlehem, PA 18017 / William L. Adler, Esquire William L. Adler, Esquire 4949 Devonshire Rd. Hamsburg, PA 17109 Phone: 717-652-8989 Fax: 717-307-3343 Email: BAL@BillAdlerLaw.com Supreme Court ID: 39844 Bluestone Investments, Inc., Plaintiff (Respondent) v. Donna Shafer, Defendant (Petitioner) ~F THE~'P~~ ~F~ONOTARY U~ ~~~r~LA~~~ CQUF1 i Y P~t~}~5YL4';~~dIA OV i _., 2010 IN THE COURT OF COMMON PLEAS Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 10-3888 Civil ORDER AND NOW, THIS ~ day of ~%~~~- , 2010, upon consideration of the Petition to Strike Off and/or Open Judgment and For a Stay of Proceedings, it is hereby ORDERED that: (1) a rule is issued upon the respondent to show cause why the petitioner is not entitled to the relief requested; (2) the respondent shall file an answer to the petition within ~ ~ days of this date; (3) the petition shall be decided under Pa.R.C.P. No. 206.7; (4) depositions shall be completed within ~~D days of this date; (5) argument shall be held on __ ~I~uGG'~t.jiYiC o7~ , 2010, in Courtroom at /I:DO a.M, ;and (6) notice of the entry of this order shall be provided to all parties by the petitioner. IT IS FURTHER ORDERED that, except as otherwise stated, all other proceedings herein, including execution, are STAYED until further Order of this Court. BY THE COURT: ~~ ~ 'stribution: Ronald Amato, Amato and Associates, PC, 107 N. Commerce Way, Bethlehem, PA 18017, William L Adler, , 4949 Devonshire Rd., Harrisburg, PA 17109, BAL@Bi11Ad1erLaw.com ~o~~$~iv ~~ BLUESTONE INVESTMENTS, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DONNA SHAPER, DEFENDANT 10-3888 CIVIL TERM ORDER OF COURT AND NOW, this ~ day of November, 2010, a hearing on the within claim for exemption shall commence at 11:30 a.m., Friday, November 5, 2010, in Courtroom Number 5, Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, Ronald Amato, Esquire 107 North Commerce Way Bethlehem, PA 18017 ~liam L. Adler, Esquire 4949 Devenshire Road Harrisburg, PA 17109 ~nna Shafer 232 S. Enola Drive Enola, PA 17025-2812 :saa -~F.s m~ ~ L~cl. „~~.1,~ Albert H. Mas and, J. a ~'p ~ ~ _,.. ~ _; :.~ rri c~ r-- r-n ~ ~ ~, ~:~, - a~. ~~ ~ ~ =~~ ~ ~ o~ ~_ ~~ ~ ~~ ~~ ~ ~ ~ tr f ...... ...... FILED-OFFICE OF THE PROTHONOTARY 2010NOV 24 pN 2.-40 OH PENNSYLVAN A A William L. Adler, Esquire 4949 Devonshire Rd. Harrisburg, PA 17109 Phone: 717-652-8989 Fax: 717-307-3343 Email: BALQBillAdler-Law.com Supreme Court ID: 39844 Bluestone Investments, Inc , : IN THE COURT OF COMMON PLEAS Plaintiff' (Respondent) : Cumberland COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW Donna Shafer, :NO. 10-3888 Civil Defendant (Petitioner) STIPULATION 1.. A,judgment in the amount of'$4,337.70 was entered against the defendant in the office ofthe prothonotary of Cumberland County, Pennsylvania. 2. A wt it of'execution was issued against the defendant to collect on the above judgment. 3.On Otober 22, 2010 the defendant filed a petition to strike or open the judgment 4.. The parties have agreed to a settlement of this matter as follows: a, Defendant shall pay plaintiff' $100.00 per month commencing November 12, 2010 with payments to be made on or before the 12' of the month until the defendant has paid a total of $1,500 00 to the plaintiff's. 5.. In the event defendant fails to pay the $100.00 by the 12' of the month, defendant shall have a one week grace period within which to pay the $100.00 monthly installment . 6 In the event defendant fails to pay the $100.00 monthly installment by the 19`' of each month, the plaintiff can recommence execution proceedings on the original judgment amount.. 7. Upon payment of the $1,500..00 in accordance with the terms of this agreement, the plaintiff' shall mark the judgment satisfied in full.. 8. Defendant waives any fuithet objection to the sufficiency of judgment or the amount of the Judgment. William L. Adler, Esquire Attorney for Defendant Bluestone Investments, Inc.. By r November 4, 2010`^ ?? w cS?crM. t Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F1LED-O FILE 7 THE PPOTHOPkC fA V ZQ?B DEC 20 PH 4: 7 014BERLAND CO UN T .I, u_PENNSYLVANIA Bluestone Investments, Inc. vs. Donna J. Shafer Case Number 2010-3888 SHERIFF'S RETURN OF SERVICE 08/25/2010 08:20 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on August 25, 2010 at 1958 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Donna J. Shafer, by making known unto Donna J. Shafer, at 232 S Enola Drive, Enola, Cumberland County, Pennsylvania 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 08-26-10. 10/13/2010 Sheriffs sale scheduled for Monday, November 1, 2010 at 1500 hours. 10/14/2010 05:35 PM -Sale bill posted on October 14, 2010 at 1735 hours by Deputy Cobaugh. Sale date set for Monday, November 1, 2010 at 1500 hours. Copy of sale bill mailed to Attorney Amato. 10/27/2010 Claim for exemption filed this date. Taken to Court Administration to schedule a hearing. Property sale postponed for November 1, 2010 at 3:00 p.m. 11/02/2010 ORDER OF COURT - And now, this 27th day of October, 2010, upon consideration of the Petition to Strike Off and/or Open Judgment and For a Stay of Proceedings, it is hereby ordered that: (1) a rule is issued upon the respondent to show cause why the petitioner is not entitled to the relief requested; (2) the respondent shall file an answer to the petition within 21 days of this date; (3) the petition shall be decided under Pa. R.C.P. No. 206.7; (4) depositions shall be completed within 60 days of this date; (5) argument shall be held on December 20, 2010, in Courtroom 5 at 11:00 A.M.; and (6) notice of the entry of this order shall be provided to all parties by the petitioner. It is further ordered that, except as otherwise stated, all other proceedings herein, including execution, are STAYED unfil further Order of this Court. By the court: Albert Masland, Judge 11/02/2010 ORDER OF COURT -And now, this 2nd day of November, 2010, a hearing on the within claim for exemption shall commence at 11:30 a.m., Friday, November 5, 2010, in Courtroom Number 5, Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, Albert H. Masland, Judge 11/05/2010 Claim for exemption hearing cancelled this date. 1212012010 STIPULATION 1. A judgment in the amount of $4,337.70 was entered against the defendant in the office of the prothonotary of Cumberland County, Pennsylvania. 2. A writ of execution was issued against the defendant to collect on the above judgement. 3. On October 22, 2010 the defendant filed a petition to strike or open the judgment. 4. The parties have agreed to a settlement of this matter as follows: a. Defendant shall pay plaintiff $100.00 per month commencing on November 12, 2010 with payments to be made on or before the 12th of the month until the defendant has paid a total of $1,500.00 to the plaintiffs. 5. In the event defendant fails to pay the $100.00 by the 12th of the month, defendant shall have a one week grace period within which to pay the $100.00 monthly installment. 6. In the event defendant fails to pay the $100.00 monthly installment by the 19th of each month, the plaintiff can recommence execution proceedings on the original judgment amount. 7. Upon payment of the $1,500.00 in accordance with the terms of this agreement, the plaintiff shall mark the judgment satisfied in full. 8. Defendant waives any further objection to the sufficiency of judgment or the amount of the judgment. Filed in the office of the Prothonotary November 24, 2010 at 2:40 p.m. 12/20/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per Court Order dated October 27, 2010. SHERIFF COST: $131.40 December 20, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF By Sharon R. Lantz sz so ?rcc 7% 7Y J 53 zn U , int Sre ift i ,sett' Ir; WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-3888 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BLUESTONE INVESTMENTS, INC, Plaintiff (s) From DONNA SHAFER, 232 S. Enola Drive, Enola, PA 17025-2812 (1) You are directed to levy upon the property of the defendant (s)and to sell all cash on hand or in the possession of the defendants, accounts receivables, furniture, furnishings, equipment, inventory, tools, vehicles, electronic equipment, any and all other personal property belonging to defendant. . (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 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 $4,337.70 L.L. $.50 Interest from 6/14/10 -- $32.86 Atty's Comm % Due Prothy $2.00 Atty Paid $53.75 Other Costs Plaintiff Paid Date: 8/3/10 l Da . Bu 1, Proth notary (Seal) By: Deputy REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND ASSOCIATES, PC 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA a CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. : Plaintiff No. 10-3888 Civil vs. n a "? .? DONNA SHAFER : c m CIVIL ACTIONr o a -- -Or n ? Defendant(s) D < r-0 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please satisfy the judgment entered in the above-captioned case. AMATO AND LESSA, P.C. By: ? Daniel A. Wechsler, Esq., Atty ID #203922 Justin N. Davis, Esq., Atty ID #84464 David A. Lovejoy, Esq., Atty ID #19829 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400