HomeMy WebLinkAbout12-5673
• ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
. YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff No. ~aZ 3(07,3 ~
vs.
c-~ ~.,~r
ROBERT MONAHAN a/Wa ~ ~ r~
ROBERT MONAEiAN JR. and ~
KEYSTONE SIG1'd SYSTEMS, INC. ~ r ~ ~
d/b/a CENTRAL SIGN SYSTEMS v' c.,, c~
CIVIL ACTION .r-c~ -s,
~ ~ ~ irk
Defendants ~ ~X~ _
c~;~
~,.e
PRAECIPE FOR TRANSFER OF JUDGMENT ~ ~ ~
TO THE PROTHONOTARY, CUMBERLAND COUNTY:
Kindly enter judgment in favor of Plaintiff and against the above-named defendants,
pursuant to Pa.R.CP.D.J. No.402(D), for failure of defendants to appeal, within 30 days, a
judgment entered March 29, 2011 against the above-named defendants before HONORABLE
WILLIAM I. MARUSZCZAK, as set forth in the transcript of judgment, which is attached
hereto. Assess damages as follows: /
Judgment Amount 6,316.26
Post Judgment Interest
(from 03/29/2011 to 08/23/2012
at 6.00% per annum) 379.68
Payments 4,210.86
Total $2,485.08
Dated: August 23, 2012
AMATO A LESSA, P.C.
By:
ald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
David A. Lovejoy, Esq., Atty ID #19829
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Paul F. Troisi, Esq., Atty ID #309511 .~3f.a.5 Ply A'rTN
Attorneys for Plaintiff d~ 3~J 7 ~8
107 North Commerce Way 2~0?~~(~
Bethlehem, PA 18017
(610) 866-0400 ~p~2
A DEBT COLLECTION LAW FIRM
2101531
AFFIDAVIT OF NO APPEAL September 11, 2012
YELLOW BOOK SALES AND District Justice
DISTRIBUTION COMPANY, INC. Docket Number:
vs. CV-174-11
ROBERT MONAHAN a/k/a ROBERT
MONAHAN JR. and
KEYSTONE SIGN SYSTEMS, INC. d/b/a
CENTRAL SIGN SYSTEMS
As of September 1 1, 2012, a District Justice appeal has not been filed in the Court of Common
Pleas of Montgomery County in the above captioned matter.
AMATO A LESSA, P.C.
By:
R ald Amato, Esq., Atty ID #32323
ichael R. Lessa, Esq., Atty ID #88617
David A. Lovejoy, Esq., Atty ID #19829
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Paul F. Troisi, Esq., Atty ID #30951 1
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
1610) 866-0400
A DEBT COLLECTION LAW FIRM
COMMONWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENT/TRA41J5~CR~t
. ~~~OUNTY OF: >~ONTt30~Y CIVIL CASE Cil,,~~-
• Mag. Dist. No.: f LAINTIFF: NAME and ADDRES5~
38-1-09 YELLOW BOOR SALES & DIET CO. INC. ~
• MOJ Name: Hon. 107 N C~RCE WAY
WILLIAM I. ~lARIISZCZAR C/O A1~AT0 & LSSSA, PC
Adtlress: 485 S HSL~DBRSON ROAD LBETHLSF~I, PA 18017 J
RING OF P~~tIISSIA, PA VS.
DEFENDANT: NaME ara aooaess
Telephone: (610 > 265-3950 19406 ROBERT MONAHAN A/R/A, ET AL. ~
127 s 29TS sTRSST
HARRISBURG, PA 17103
YELLOW BOOR S S ~ DIST CO. INC. L J
107 N COM~RC WAY Docket No.: CV - 0000174 -11
C/O AllfATO ~ L SSA, PC Date Filed: 2/23/11
HSTffi~EHEM, PA 18017
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF {Date of Judgment} 3/29/11
Judgment was emtered for: (Name) YELLOW BOOR SALES ~ DIST CO. I
® Judgment was emtered against: (Name) CENTRAL SIGN SYSTffiYIS
in the amount of $ 6, 316.2
Amount of Judgment $ 6,153.01
Defendants are jpintly and severally liable. Judgment Costs $
Damages will be'assessed on Date & Time Interest on Judgment
Attorney Fees $T~0
This case dismissed without prejudice. Total $ 6, 316.26
Amount of Judgement Subject to AitachmenU42 Pa.C.S. § Si27 post Judgment Credits $
$ Post Judgment Costs $
Portion of Judgm nt for physical damages arising out of wT
residential lease ~ Certified Judgment Total $
ANY PARTY HAS THE RIG(~H~~T TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT 8Y FILING A NOTICE
OF APPEAL WITH THE PR07~WONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OFIItFIIS NOTICE OF JUDGMENTIrRANSCRIP7 FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE Ii1ROVIDED iN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JU ES, IF THE
JUDGMENT HOLDER ELE TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER P OCESS MUST
COME FROM THE COURT OEI COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MACi13TE~lAL DISTRICT JUDGE .
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGiMENT 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 JUQGMENT.
Date ,Magisterial District Judge
ify t t this is a trtJe/a erect copy of the a rd of the edings containing the judgment.
Date ~i I~ , Ma isterial District Jud e
9 9
My commission expires first Monday of January, 2016 SEAL
AOPC 315-07
DA'~E PRINTED: 3/30/11 3:02:00 PM
_
i ~ COMMONWEALTF~~-l~~-PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT
_ p• COUNTY OF: MONR'GOMERY CIVIL CASE
Mag. Disl. No.• ~ PLAINTIFF: NAME and ADDRESS
38 -1- 09 ~YEI.IAW BOOR SALES & DIET CO . INC . ,
MDJ Name: Hon. lO7 N COMf!I~RCE WAY
~ WILLIAM I. IwTARIISZCZAIC C/O AMATO ~ LSSSA, PC
rwd`ess: 4 8 5 S HEi~DERSON ROAD LBETHI,8HEINI, PA 18 017 J
RING OF ~RIISSIA, PA VS.
DEFENDANT: NaMe aid noDRess
Te~evnone: (610) 26~i - 3950 19406 rROBERT MONAHAN A/R/A, BT AL. ~
127 S 29TH STREET
HARRISBIIRG, PA 17103
YELIAW BOOR S7~LES 6i DIST CO. INC . L_ J
107 N COMMSRC~ WAY Docket No.: CV- 0000174 -11
C/O AMATO ~ L~4SSA, PC Date Filed: 2/23/11
BBTiEII,BAffiYI, PA 18017
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF (Date of Judgment) 3/2'9/11
® Judgment was entered for: (Name) ~LLOPI BOOR SALES & DIST CO. I
® Judgment was entered against: (Name ROBERT 1~NAHAN A/R/A
in the amount of'$ 6, 316.
Amount of Judgment $ 6,153.0
Defendants are faintly and severally liable. Judgment Costs $
Damages wiN be assessed on Date & Time Interest on Judgment $-tea
Attorney Fees $D'D
This case dismissed without prejudice. Total $ 6 316.26
Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Post Judgment Credits $
$ Post Judgment Costs $
Portion of Judgm nt for physical damages arising out of
residential lease ~ Certified Judgment Total $
ANY PARTY HAS THE RI IHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PRO HONOTARYlCLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY O i'~HIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE ~iOYIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JU ES, IF THE
JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER P ESS MUST
COME FROM THE COURT OI: COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAG~TE L DISTRICT JUDGE .
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JU MENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WrrH THE JUDGMENT.
Date ,Magisterial District Judge
c ify th t this is a trlu~e an rest copy of the r c d of the ings containing the judgment.
~ Date ~ ,Magisterial District Judge
My commission expires first Monday of January, x016 SEAL
AOPC 315-07
DATE PRINTED: 3/30/11 3:00:00 PM ,
, COMMONWEALTH"C~~j~PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT
_ ~ at;OUNTY OF: NON~'C~oKSRY CIVIL CASE
' Mag. Dill. No.' ~ PLAINTIFF: NAME and ADDRESS
• 38 - 09 ~713LLON BOOR SALES ~ DIST CO. INC . ~
MDJ Name: Hon. 1O7 N COIrII~IiBRCS NAY
WILLI~IYi L. MARIISZCZAR C/O AMATO ~ LESSA, PC
Address: 485 S $RSON ROAD LBETHLEHElS, PA 18017 J
RING OF P~iIISSIA, PA VS.
DEFENDANT: NgME and ADDRESS
Ta~ephone: (610) 265-3950 19406 rROBERT MONABAN A/R/A, BT AL. ~
127 S 29TS STRSST
HARRISBIIRG, PA 17103
YSLL~O~T BOOR SA~.ES ~ DIST CO. INC. L J
107 N COI~RCE~ NAY Docket No.: CV- 0000174 -11
C/O A1iiAT0 ~ LE~SA, PC Date Filed: 2/23/11
BETBLE>E~I, PA '18017 .
THIS iS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF (Da#e of Judgment) 3/29/11
® Judgment was entered for: (Name) YSLLON HOOK SALES ~ DIST CO. I ~
® Judgment was entered against: (Name) ROBS'RT I~NAHAN JR. AND
in the amount of $ 6, 316.2 j
Amount of Judgment $ 6,153.01
? Defendants are jointly and severally liable. Judgment Costs $
Damages will be assessed on Date & Time Interest on Judgment
? Attorney Fees $~0
? This case dismissed without prejudice. Total $ 6, 316.26
Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Post Judgment Credits $
$ Post Judgment Costs $
? Portion of Judgment for physical damages arising out of
residential lease Certified Judgment Total $
ANY PARTY HAS THE RIG~#T TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY fILING A NOTICE
OF APPEAL WITH THE PR01fHONOTARY/CLERK OFTHE COURT OF COMMON PLEAS, CfVIL DIVISION. YOU
MUST INCLUDE A COPY OF 1it3 NOTICE OF JUDGMENTlrRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE ~I~OVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDG S, IF THE
JUOGNIENT HOLDER ELECT 70 ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PR~DCESS MUST
COME FROM THE COURT Otx COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAti1STERMAL DISTRICT JUDGE . ,
UNLESS THE JUDGMENT ~ ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JU MENT 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.
i
~ ~ Date ,Magisterial District Judge
i ify ; at this is a truls correct copy o e r of the o e ' gs containing the judgment.
Date ,Magisterial District Judge
My commission expires first Monday of January, x016 SEAL
AOPC 315-07 !
DA~$ PRINTED: 3/30/11 3:00:00 Plri
1. i ~ '
• COMMONWEALTH ~ PENNSYLVANIA NOTICE OF JUDGMENT/TRAt~SfC~i1~T
. *COUN3Y OF: ~N~'~Y CIVIL CASE ; ; -r
• Mag. Dist. No.: ~ PLAINTIFF: NAME and ADDRESS ~
' 3 8 - fir- 0 9 rYgLLOW HOOK SALES ~ DI ST CO . ~ INC . ~
MDJ Name: Hon. 107 N CO~RC13 WAY
WILLIAli 1. I~ARIISZCZAR C/O AIItATO ~ LSSSA, PC
Add`°~: 485 S H>~JffitSON ROAD LBETHLSI~M, PA 18017 J
RING OF RIRIISSIA, PA VS.
DEFENDANT: NAMe and ADDaess
Telephone: (610) 265 - 3950 19406 ~ROB$RT MONAIiAN A/R/A, 8T AL. ~
127 S x9TR STRSI3T
EARRISHDRG, PA 17103
Y$LLOW BOOR S ~ DIST CO. INC. L_ J
107 N CO~RC 'WAY Docket No.: CV-0000174-11
C/O A1(ATO ~ L ~$SA, PC Date Filed: 2/x3/11
HSTI, FA ' 18 017
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF (Date of Judgment) 3/x9/11
® Judgment was entered for: (Name) YSLI,OW BOOR SALES & DIET CO. 1"
® Judgment was entered against: (Name) RgYSTONB SIGN 3YSTffi44, INC . D/B/A
in the amount of'$ 6, 316.2
Amount of Judgment $ 6,153.01
Defendants are jointly and severally liable. Judgment Costs
Damages will be assessed on Date & Time Interest on Judgment
Attorney Fees $--IID
This case dismissed without prejudice. Total $ 6, 316.26
Amount of Judgrlhent Subject to Attachment/42 Pa.C.S. § 8127 Post Judgment Credits $
$ Post Judgment Costs $
Portion of Judgm nt for physical damages arising out of
residential lease ~ Certified Judgment Total $ r
ANY PARTY HAS THE RI ~fT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PRO HONOTARY/CLERK OP THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF'rHIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE pOVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGMENT HOLDER ELEC >5 TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PI#OCESS MUST
COME FROM THE COURT O~ COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED 8Y THE MAGISTEI~iAL DISTRICT JUDGE .
UNLESS THE JUDGMENT'iS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUO~iMl:NT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTbR PAYS IN FULL,
SETTLES, OA OTHERWISE COMPLIES WITH THE JUDGMENT.
Date ' ,Magisterial District Judge
I rtify at this is a true and rrect copy of the r d of the edings containing the judgment.
S ~ Date ,Magisterial District Judge
My commission expires first Monday of January, x016 SEAL !
AOPC 315-07 i
DA~1'E PRINTED: 3/30/11 3:01:00 PM ~
-
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff No.
vs.
ROBERT MON~~IAN a/k/a
ROBERT MON ~3AN JR. and
KEYSTONE SIG~1 SYSTEMS, INC. :
d/b/a CENTRAL SIGN SYSTEMS :
CIVIL ACTION
Defendants
AFFIDAVIT OF NON-MII,ITARY SERVICE
COMMONWEALTI}i OF PENNSYLVANIA
COUNTY OF NOR1r'EIAMPTON
The undersigned, being duly sworn, according to law, deposes and says that he is wnable to
determine whether ol~ not the above Defendants 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 ROBERIT MONAHAN a/k/a ROBERT MONAHAN JR. is over 18 years of age, resides at
5215 Simpson Ferry Road, Mechanicsburg PA 17050-3500.
Sworn to andl subscribed
before me thi,~'~'tlay
of ~ 2012 A.D.
NOTARY P
COMMONWEALTH OF NSYLVANIA
Notarl~l Se+~L'
Mkhelk C. B~ht, Publk
Cny or eethlmt~em, County
My Cann9sMon 62015
MEMBER, PENNSYEVANiA ON N01'ARIFS
' ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
- - CIVIL ACTION -LAW
' YELLOW BOOK SALES AND :
DISTRIBUTION COMPANY, INC.
Plaintiff No.
vs.
ROBERT MONAFIAN a/k/a
ROBERT MONA~F,IAN JR. and
KEYSTONE SIGIINT SYSTEMS, INC. .
d/b/a CENTRAL ~IIGN SYSTEMS
CIVIL ACTION
Defendants
NOTICE OF JUDGMENT
(XX) NOTICE I5 HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED
MATTER I~IAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANTS
IN THE AMOUNT OF $.i'1~'s;'~~ON ~ / 3 , 2012.
A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF
CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN
JUDGMENT IS/ARE ENCLOSED.
PROTHONOT Y -CUMBERLAND COUN Y
Per:
If you have any questions concerning the above, please contact the undersigned.
AMATO AND LESSA, P.C.
By:
onald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #8861'7
David A. Lovejoy, Esq., Atty ID #1989
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Paul F. Troisi, Esq., Atty ID #309511
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
`INt THE COURT OF COMMON PLEAS OF CUMBERLAND CC NITV, PENI?SYL\k[-'NIrf_ CIVIL ACT ION - LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff
vs.
ROBERT MONAHAN a/k/a ROBERT
MONAHAN JR. and KEYSTONE SIGN
SYSTEMS, INC. d/b/a CENTRAL
SIGN SYSTEMS
Defendant(s)
Cusquehanna Bank
Garnishee
No. 12-5673 Civil Term
?-y
n `
rT1
cr•
CIVIL ACTION
C-) -?
.:
C-- r
INTERROGATORIES TO GARNISHEE
To: Susquehanna Bank, Garnishee
1 196 Walnut Bottom Road, Carlisle, PA 17015
You are required to submit answers to the following interrogatories within twenty (20) clays
after service upon you. Failure to do so may result in a judgment being entered against you:
1 . At the time you were served or at any subsequent time did you owe the
defendant any money or were you liable to the defendant on any negotiable or other written
instrument, or did the defendant claim that you owed the defendant any money or were liable
to the defendant for any reason?
See answer on attachment.
2. At the time you were served cr at any subsequent time was there in your
possession, custody or control or in the joint possession, custody or control of yourself and
one or more other persons any property of any nature owned solely or in part by the
defendant?
No.
3. At the time 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 or in which defendant
held or claimed any interest?
NO.
4. At the time you were served or at any subsequent time did you hold as
fiduciary any property in which the defendant had an interest?
NIX
5. At any time before or after you were served did the defendant transfer or
deliver any property to you or to any person or place pursuant to your direction or consent
and if so what was the consideration therefor? See answer on attachment.
r' S. A-L any time after you were served did you pay, transfer or deliver any money
Or property to the defienclant or any person oi' place pursuant -io the defendants direcilon Cr
otherwise discharge any claim of the defendant against you?
See answer on attachment.
7. If you are a bank or other financial institution, 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 electronically on a recurring basis and which are identified as being funds that
upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal
law? If so, identify each account and state the reason for the exemption, the amount being
withheld under each exemption and the entity electronically depositing those funds on a
recurring basis.
No.
8. If you are a bank or other financial institution, at the time you were served or
at any subsequent time did the defendant have 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 monetary exemption under 42 Pa.C.S.A. § 8123? If so, identify each account.
No.
9. At any time before or after you were served, did the defendant, either solely
or in part, have any account (savings, checking, certificate of deposit, money market,
deposits or any other debt and/or property) with your office?
No.
10. If your answer to interrogatory #9 is in the affirmative, state: NIA
A) the account number of each account;
B) the amount of money in each account.
AMATO AND LESSA, P.C.
By: 1
Ronald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
David A. Lovejoy, Esq., Atty ID #19829
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Paul F. Troisi, Esq., Atty ID #309511
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
Attorney File#: 2101531
Attachment to Answers to Interrogatories
RE: Yellow Book Sales and Distribution Company, Inc. vs. Robert Monahan a/k/a
Robert Monahan Jr. and Keystone Sign Systems, Inc. d/b/a Central Sign Systems
Docket #: 12-5673
#1 Answer:
No for Defendant, Robert Monahan a/k/a Robert Monahan, Jr.
Yes, Defendant, Keystone Sign System, Inc. DBA Central Sign Systems, has three
checking account numbers XXXXXX7690, XXXXXXX7872 and XXXXXX6261 held
in the name Keystone Sign Systems, Inc. with a combined available balance of
$10,760.71.
#5 Answer:
Prior to service, Defendant, Keystone Sign System, Inc., received loans from the bank.
The loans are secured by liens against a Telex TL389 Crane, two (2) 2005 Super Duty
F250's and a 2003 Ford Bucket Truck F450, as well as all inventory, chattel paper,
accounts, equipment, fixtures, furniture, vehicles and general intangibles.
#6 Answer:
Garnishee has allowed access to funds in excess of the judgment amount.
VERIFICATION
I, Catherine M. Bush, verify that the facts set forth in these Garnishee's Answers to
Interrogatories are true and correct to the best of my knowledge, information, and belief. This
statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. §
4904) related to unworn falsification to authorities.
Dated: October 15, 2012
Catherine M. Bush,
Assistant Secretary and
Legal Counsel
Susquehanna Bank
26 North Cedar Street
Lititz, Pa 17543
(717) 625-6273
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAIN
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff
vs.
ROBERT MONAHAN a/k/a
ROBERT MONAHAN JR. and KEYSTONE
SIGN SYSTEMS, INC. d/b/a
CENTRAL SIGN SYSTEMS
Defendant
Susquehanna Bank
Garnishee
PRAECIPE FOR JUDGMENT AGAINST GARNISHEE
TO THE PROTHONOTARY, CUMBERLAND COUNTY:
Kindly enter judgment in favor of the Plaintiff and against the above-named Garnishee, in the
amount of $2,746.00, admitted in the answer to interrogatories to be in the garnishee's possession,
together with statutory interest and costs. The amount of the judgment of the Plaintiff against the
Defendant is $2,485.08.
Dated: October 19. 2012
AMATO AND LESSA, P.C.
By: ,
Wald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
David A. Lovejoy, Esq., Atty ID #19829
.Justin N. Davis, Esq., Atty ID #84464
///c"~l~r~ Daniel A. Wechsler, Esq., Atty ID #203922
~~o'!^ I (,,~,~~ Paul F. Troisi, Esq., Atty ID #30951 1
F~ W~ cam- Attorneys for Plaintiff
J~sk-- ~e~~.f~ Uri 0~~~`n} 107 North Commerce Way
L.~ Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
,~~ ~~~ , so~ a
a
~~~~.~ 32~ s l y
~~a$asaa-\
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff No. 1 <?-5673 Civil Term
vs.
ROBERT MONAHAN a/k/a
ROBERT MONAHAN JR. and
KEYSTONE SIGN SYSTEMS, INC.
d/b/a CENTRAL SIGN SYSTEMS
Defendant
Susquehanna Bank
Garnishee
CIVIL ACTION
CERTIFICATION OF ADDRESSES
I do certify that the precise last known address of the within named plaintiff is:
2001 Renaissance Blvd
KING OF PRSA,PA 19406
I do certify that the precise last known address of the within named defendant is:
5215 Simpson Ferry Road
Mechanicsburg PA 17050-3500
I do certify that the precise last known address of the within named garnishee is:
1 1 96 Walnut E3ottom Road
Carlisle, PA 17015
AMATO A LESSA, P.C.
By: ~..
~onald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
David A. Lovejoy, Esq., Atty ID #19829
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
F'aul F. Troisi, Esq., Atty ID #30951 1
Attorneys for Plaintiff
107 North Commercf: Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff
No. 12-5673 Civil Term
vs.
ROBERT- MONAHAN aik/a
ROBERT MONAHAN JR. and KEYSTONE
SIGN SYSTEMS, INC. d/b/a
CENTRAL SIGN SYSTEMS
Defendant
Susquehanna Bank
Garnishee
CIVIL ACTION
NOTICE OF JUDGMENT AGAINST GARNISHEE
(XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE
CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE
NAMED GARNISHEE IN THE AMOUNT OF 52,746.00
ON aC~ - 31 201 2.
A COPY OF ALL DOCUMENTS 1=ICED WITH THE PROTHONOTARY
IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED.
"~ ~. 4
PROTHONOTARY - CUMBERLS~ND:OOUNTY
'r /
E ~~
Per: r ~ " ____
If you have ar~y questions concerning the above, please contact
±he undersigned.
AMATO D LESSA, P.C
E3y : _ ~'_
`~ Ronald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
David A. Lovejoy, Esq., Atty ID #19829
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Paul F. Troisi, Esq., Atty ID #30951 1
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRNI
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
/R Anderson
;>f
vdy S Smith
Chief Deputy
Richard W Stewart
Solicitor
~ ~~ ~
. yr
~ i _'~'~ y}^~
art rF . , -~.= ..~,~~rF
~f- SHE ~ o~Ha~a~A~ ~,,
CUME3E~LAM~ COUNTY
PENWSY~yq~lA
Yellow Book Sales and Distribution Company, Inc. Case Number
vs.
Robert Monahan (et al.) 2012-5673
SHERIFF'S RETURN OF SERVICE
10/09/2012 10:44 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October
9, 2012 at 1044 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendants, to wit: Robert Monahan A/K/A Robert Monahan Jr., and
Keystone Sign Systems, Inc. D/B/A Central Sign Systems, in the hands, possession, or control of the
within named garnishee, Susquehanna Bank, 1196 Walnut Bottom Road, Carlisle, Cumberland County,
Pennsylvania, by handing to Tami L. McKee, Financial Service Representative, 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.
10/19/2012 Writ put on "hold" at request of plaintiffs attorney.
11/09/2012 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. Defendant paid $ 2,746.00 directly to plaintiffs
attorney.
SHERIFF COST: $156.80 SO ANSWERS,
November 09, 2012 RON R ANDERSON, SHERIFF
a. as P~ -C'o
~~~~o3y
(cl CcuntvSuite SI^eriff, Teleosoft, Inc.
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
YELLOW BOOK SALES AND
DISTRIBUTION COMPANY, INC.
Plaintiff
vs.
ROBERT MONAHAN a/k/a ROBERT
MONAHAN JR. and KEYSTONE SIGN
SYSTEMS, INC. d/b/a CENTRAL SIGN
SYSTEMS
Defendant(s)
No. 12-5673 Civil Term
• ~..~ ~,
v
„~
~~ ,
'~ ~ ~~~°:
y; ~ ~
.'"' "n .3
:
; .,N 11; ..
..
.
~
cr,,
CIVIL ACTION ~" ~"~ ~' ' `
~:.
~
''
~ ~ , .
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:
onald Amato, Esq., Atty ID #32323
Michael R. Lessa, Esq., Atty ID #88617
David A. Lovejoy, Esq., Atty ID #19$29
Justin N. Davis, Esq., Atty ID #84464
Daniel A. Wechsler, Esq., Atty ID #203922
Paul F. Troisi, Esq., Atty ID #30951 1
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
vs.
No. 12-5673 Civil Term
ROBERT MONAHAN a/k/a ROBERT
MONAHAN JR. and KEYSTONE SIGN
SYSTEMS, INC. d/b/a CENTRAL SIGN
SYSTEMS
Defendant(s)
Susquehanna Bank
Garnishee
CIVIL ACTION
PRAECIPE TO SATISFY AGAINST GARNISHEE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please satisfy the judgment entered against Susquehanna Bank, Garnishee, ONLY in the
above-captioned matter.
AMATO AND LESSA, P.C.
By:
Ron~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
r.~-.~ 3a~~~
~~-ag 3 ~ ~