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HomeMy WebLinkAbout12-6679IN THE COURT OF COMMON PLEAS OF ~ C a 4 ~ `- , CUMBERLAND COUNTY, PENNSYLVANIA a~~.Y t, ';tit~i'~~ ~ f'~ ~ • ` CERTIFIED COPY OF LIEN - ~- DOCKET # a~~ ~ ~ U ° 1 ~ DATE ENTERED ~'~~~~'~~ ~ L~~~ D~EPAROTMENT OF LOABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND TO THE PROTHONOTARY OF SAID COURT: Pursuant to Section 1605 of the Pennsylvania Workers' Compensation Law, 77 P.S. § 2705 this is a Certified Proof of Payment for the balance of payments made by the Fund on behalf of the uninsured employer to be entered of record by you and indexed as judgments are indexed. BUREAU OF WORKERS' COMPENSATION NUMBER: 3673471 UNINSURED EMPLOYER GUARANTY CLAIM NUMBER: UEG1-9291, UEG1-9292 ACCOUNT NUMBER: None vs. ON THE RUN MART, INC. 101 NORTH WALNUT STREET MECHANICSBURG, PA 17055 DATE DISBURSEMENTS AMT PAID CREDIT BALANCE DUE Legal $-0- -0- $-0- Fees Indemnity $767.72 -0- $767.72 Pa ments Medical $3,941.92 -0- $3,941.92 Pa ments Litigation $1,561.79 -0- $1,561.79 Ex enses ACS $3,693.10 -0- $3,693.10 Adjusting Costs TOTAL: $9,964.53 FILING FEE(S): $21,50 ADDITIONAL _~_ COSTS: SATISFACTION $9,986.03 AMOUNT: The undersigned, Director, Bureau of Workers' Compensation, Department of Labor & Industry, certifies that the above balance is due and payable by the above named defendant under the provisions of the Pennsylvania Workers' Compensation Law. Pursuant to section 1605 of said law, 77 P.S. § 2705, the above balance is a judgment and stahrtory lien upon the franchises and property, both real and personal, including after acquired property, of the above named defendant and attach thereto from the date of entry this Certified Copy of Lien. 7 ep en J. it ov d irector, a of Workers' Compensation /a"Zy^/ Date c ~~ 4~0« ~~ ~~~SC~ a ~ d Y °' ~ .ti U o a~ ~ ~ ~ ~ v. ~' 'r' . ~ ~ '~ a ~ ;, C7 a~.~ ~ ~w~ -d o o ~ ~' ~ ~;C v >, O ~ Q ~ .b °~' cba °' ~ '~ ~ c~i O ~ ~ W ca a~ > .~ ~ ,~ ~ ~ ~ o ,~ -o ~ ~ o ~~ '~ ~ • ~ .C . a i o ~ `~ c3~ ~~b v ~ ~~ ~ «s ~,^o U ~ N ~ a> l~ ~n ° ~ O ~ 'b ~ ~ 3 ~ ° ~ ,~ x a i a i •~ ~ 'C ~ ~ ~ ~ ~z~ W a~ a ~ o ~ o ~ .C 'b U ~, '~ 'C ~ ~ 3 U ~ ~ a~i ae ~ y '~ O ~ ~ v O ' ° ~ .~ .~ ~ .~ ~ c ~ ~ ~ d ~ •~ p ' ~ ~ a ~ b o ~ w ~ ~ ~ ~ . ~ °' ~ ~ U , c~ CC x .c ~ Ly ,~ ~+ Q ~ ~ V7 '~ y C~ ~ ~ ro ~ " c .?, ~ ~ v ~, o '~ ~ a on ~ 5 .r °' ~ ~, .a °~' ~ o ~ ~a~ • ~ o y.. ~ 4. ~ ,~ .~' O o ~ O O v y 0 a~ i p Y Q i. N^ -d ~ y F y U 'D CL p ° ~ ~ O '~ 3 ~ Q p c~ ~-+ ~ cC ~ •o c , ~ 3 ca •° °' `~ o • ~ ° Y ~ ~ ~ Q .ti a i b c ~ c .~ ~b ~ C ~ ~ ~ W ~ O aU ~ V o E -"~ ~ d Q ~ ¢ za o > ~ >~~ Q a d ~ ~ ~ ~~ v z ~ Z Oa ~ w~~ off ~ Hw~~ 1 0 o° Q dz~ ~¢ ~ °~ ~~ ~ ~ ~~~ ww F z w av~ o~ ~"~ ~U o A Q A ~ w~ U ~~d ~~a a~ ~3~ U ~Fz oz°O~ o~ z 0 H xd w ~' AW ~a W U ~~ 0;~~3 o O '~ ~3 Az ~d w~ U ~ a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson E!LEO-OFF'IC Sheriff OF THE PROTHONOTAR"i" �Q�;�tr Qt�aa��rr��iry Jody S Smith Chief Deputy 20 13 MAR 20 AM 9: 44 a� Richard W Stewart CUMBERLAND COUNTY Solicitor OFF46OFTi G PENNSYLVANIA Commonwealth of PA, Dept of Labor and Industry, Uninsured Employers Case Number vs. On the Run Mart Inc 2012-6679 SHERIFF'S RETURN OF SERVICE 03/14/2013 01:02 PM-Stephen Bender, Deputy Sheriff,who being duly sworn according to law, states that on March 14, 2013 at 1300 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant,to wit: On The Run Mart, Inc., in the hands, possession, or control of the within named garnishee, Citizens Bank, 665 North East Street, Carlisle, Cumberland County, Pennsylvania, by handing to Tabitha Zarichansky, 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. The writ of execution and notice to defendant was mailed on March 15, 2013 to On The Run Mart, Inc. at 101 N Walnut Street, Mechanicsburg, PA 17055. STEPHEN BENDER, DEPUTY SO ANSWERS, March 15, 2013 RON R ANDERSON, SHERIFF t;�l^cu;;ty5uiie�heri8,7eieosc*; ,_,,. Mar. 14. 2013 2:54PM No. $470 P. 8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Commonwealth of Pennsylvania Department of Labor&Industry, Uninsured Employers Guaranty Fund, CIVIL ACTION-LAW Plaintiff ; No. 12-6679 c - ��- VS. rnm 3ft X­n On the Run Mart, Inc. z ro c 01 Nodh'Walnut Street r- --io Mechanicsburg,PA 17055, )-7 cz . . o rCrI Defendant L And ~ Citizens Hank 4301 Carlisle Pike Camp Hill,PA, 17011, Garnishee 1 1t.ret5 'P� —INICREQgAIMS IN&T HMENT To CIMENS BANK(Garnishee): You are required to file verified answers to the above interrogatories within twenty(20)days after service upon you. Failure to do so may resin In judgment against you. I. At the time you were served or at any subsequent time did you owe the defendants) any money or were you liable to it on any negotiable or other written Instrument, or did it claim that you owed It any money or were liable to It for any reason? No Mar. 14. 2013 2:54PM Na. 8470 P. 9 2. At the time you were served or any subsequent time was there In your possession custody or control or in the Joint possession, custody or oor*ol of yourself and one or more other persons any property of any nature owned solely or in part by the delbrWant(s)? 3. If the Answer to question number two(2)above was"Yes", please state the nature of the pwropeety owned by defendent(s), If the nature of the property is money or other flnanc l assets, Identify a)the amount, b)the We of account(e)In which the money or flruvwlai asset is held;and 3)the account number(s). 4. At the time you were served or at any subsequent time did you hold legal title to ar y property of any nature owned solely or in party by the defendant(s)or In which the defendant held or claimed any interest? 1-10 S. At the time you were served or at any subsequent time did you hold as fiduclary any property in which the defendants) had an interest? 8. At any Urns before or after you were served did the defendants)trarWeer 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 therefore? Mar. 14. 2013 2:54PM No. 8414 P. 10 7. At any time aft you were served did you pay, transfer, or dearer any money or property to the defendant(s) or to any person or place pursuant to his or her direction or otherwise discharge any claim of the defendants) against you? Nb 8. If you are a bank or other financial Institution, at the time you were seared or at any subsequent time did the defendernt(s)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 dal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity ele,atronically depositing those funds on a recurring basis. N c7 9. If you are a bank or other financial institutes, at the time you were served or at any subsequent tine, did the delandant(s) have funds on deposit In an ac ownt 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. § 81237 If so, identify each account. 14. If you have answered "Yes"to any of the Interrogatories numbered 1 through 7 above, state the amount of money or clam, or other iiebillity which you hereby admit to be owed to, owned by, or claimed by the defendants)and describe the nature of such claim or Ilabglty and such other property as you have hereby admitted to be to your possession. NIL Ma r, 14. 2013 2:54PM No. 8470 P. 11 VERIFICATION I _ l tft UWYMA AJ► being sect to the penalties of 18 Pa.C.S.A. §4W4, relating to unswom falsirmllon to authorities, state that the attached answers and/or documents are submitted in response to the foregoing Interrogstortes In Attachment, and that to the best of my knowledge, Information and belief they are true and complete. Date: � g� �� By. CITIZENS SAW ??An(A 0i,, L/ Citizens Bank of Pennsylvania 525 William Penn Place PW2140 cor��to�,wMIw.vuva Pittsburgh,PA 15219-1721 Nancy J.Lay,Notmy Pubhc A#49*vy County my C mmjsvq ' SepL 22 2016 Respectfully submitted, MEMBER,PEMNSYIV"_ 1TON OR MOTARMS Date: �,. ---- Erich M, Diehl (Attorney I.D. 040388) Assistant Counsel Bureau of Workers' Compensation Legal Division—Room 327 1171 South Cameron Street Harrisburg, PA 17104 (717) 783-4467 9th JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND, Docket No. 12-6679 Plaintiff -v rnmw w �r- Vs. CD ., ON THE RUN MART, INC. a o � � w A PLAINTIFF'S MOTION FOR TO COMPEL ANSWERS TO INTERROGATORIES IN AID OF EXECUTION AND NOW, comes the Plaintiff, the Commonwealth of Pennsylvania, Department of Labor and Industry, Uninsured Employers Guaranty Fund, which submits the following Motion for to Compel Answers to Interrogatories in Aid of Execution and alleges the following: 1. Plaintiff is the Commonwealth of Pennsylvania, Department of Labor and Industry, Uninsured Employers Guaranty Fund, an agency of the Commonwealth of Pennsylvania with offices located at 1171 South Cameron Street, Harrisburg, Pennsylvania, 17104. . 2. Defendant is On the Run Mart, Inc., whose last known address is 101 North Waltnut Street, Mechanicsburg, PA 17055. 3. This Motion is made pursuant to Pennsylvania Rules of Civil Procedure 3118(a)(6). 4. On or about October 31, 2012, Plaintiff filed a lien in the Court of Common Pleas of Cumberland County against On The Run Mart, Inc. with a satisfaction amount of $9,986.03. That lien was docketed to 12-6679. A copy of that lien is attached hereto and marked as Exhibit "A". O 5. The $9,986.03 satisfaction amount of the lien filed against On The Run Mart, Inc. represents amounts paid by Plaintiff on behalf of Defendant, an uninsured employer, following a Decision and Order circulated by Workers' Compensation Judge James Deeley on August 12, 2011, in the matter of Saundra Hood v. Sun Up & Uninsured Employers Guaranty Fund, Bureau Claim No. 3673471, plus a $21.50 lien filing fee. 6. On November 2, 2012, Plaintiff mailed a Notice to Employer of Entry of Lien pursuant to Section 1605 of the Pennsylvania Workers' Compensation Act, 77 P.S. 2705, which notified Defendant that Plaintiff filed the lien against it in the Court of Common Pleas of Cumberland County, Pennsylvania, reflecting an amount due of $9,986.03. A copy of the Notice to Employer of Entry of Lien is attached hereto and marked as Exhibit "B". 7. The Notice to Employer of Entry of Lien was mailed to Defendant by Certified United States Mail, Return Receipt Requested, Postage Prepaid, Parcel No. 7012 0470 0000 3782 0274. 8. On May 2, 2013, Plaintiff mailed Written Interrogatories Pursuant to Rule 3117 of the Pennsylvania Rules of Civil Procedure (Discovery In Aid of Execution) to Defendant by regular first class United States Mail, postage prepaid. A copy of those written interrogatories is attached hereto and marked as Exhibit "C". 9. More than thirty (30) days has passed since Defendant was served with the written interrogatories, and no answers have been made. 10. More than thirty (30) days has passed since Defendant was served with the written interrogatories, and no objection to them has been lodged. 11. More than thirty (30) days has passed since Defendant was served with the written interrogatories, and no protective order has been requested. 12. Plaintiff requests that this Honorable Court issue an order directing Defendant to provide answers to the written interrogatories within thirty (30) days. WHEREFORE, Plaintiff requests that this Honorable Court issue an Order directing Defendant to provide answers to the written interrogatories within thirty (30) days. 4 4 Date: .1,A7 AO By: OZ Erich M. Diehl, Esq. Assistant Counsel Bureau of Workers' Compensation Legal Division — Room 327 1171 South Cameron Street Harrisburg, PA 17104 (717) 783-4467 Supreme Court I.D. #40388 r i EXHIBIT A ti a COMMONWEALTH OF PENNSYLVANIA GOVERNOR'S OFFICE OF GENERAL COUNSEL November 2, 2012 VIA CERTIFIED AND REGULAR, FIRST-CLASS MAIL On The Run Mart, Inc. 101 North Walnut Street Mechanicsburg, PA 17055 NOTICE TO EMPLOYER OF ENTRY OF LIEN Pursuant to Section 1605 of the Workers' Compensation Act ("Act"), 77 P.S. §2705, the Department of Labor and Industry has filed the following lien against you in the Court of Common Pleas of Cumberland County, Pennsylvania. Docket No. Amount* Date Filed 12-6679 $9,986.03 10/31/2012 *This amount does not include costs of collection to date. A date stamped copy of the lien is enclosed for your review.'.This lien is for the balance of payments made by the Fund on your behalf due and payable under the Law. It is a lien on your franchises and property, both real and personal, including after-acquired property. The lien attached to your property on the date it was entered of record by the Prothonotary of the Court. Section 1605 provides that upon expiration of ten (10) days from the date of this Notice a writ of execution may be issued on this lien. If a writ of execution is issued, so much of your property as is necessary to satisfy the lien, including legal costs, will be taken. rich M. Diehl Assistant Counsel Office of Chief Counsel Workers' Compensation Division 1171 South Cameron Street Harrisburg, PA 17104 OFFICE OF CHIEF COUNSEL I DEPARTMENT OF LABOR&INDUSTRY WORKERS'COMPENSATION DIVISION 1171 SOUTH CAMERON STREETI HARRISBURG, PA 17104 ' pennsylvania Ph: 717-783-4467 1 Fx: 717-783-4469 1 www.dli.state.pa.us DEPARTMENT OF LABOR&INDUSTRY EXHIBIT B IN THE COURT OF COMMON PLEAS OF rj F, ;^ DOCKET# f CUMBERLAND COUNTY,PENNSYLVANIA DATE ENTERED t�lli; � � l tj'� #355 ` L a" VIPARTM ONWE ALTH OF PENNSYLVANIA CERTIFIED COPY OF LIEN ; t_1 S Y L`d t�, ENT OF LABOR&INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND TO THE PROTHONOTARY OF SAID COURT: vs. Pursuant to Section 1605 of the Pennsylvania Workers' Compensation Law,77 P.S. §2705 this is a Certified Proof of Payment for the balance of payments made by the Fund on ON THE RUN MART,INC. behalf of the uninsured employer to be entered of record by 101 NORTH WALNUT STREET you and indexed as judgments are indexed. MECHANICSBURG,PA 17055 BUREAU OF WORKERS' COMPENSATION NUMBER 3673471 UNINSURED EMPLOYER GUARANTY CLAIM NUMBER UEG1-9291,UEG1-9292 ACCOUNT NUMBER None DATE DISBURSEMENTS BALANCE DUE AMT PAID CREDIT Legal $-0- -0- $-0- Fees Indemnity $767.72 -0- $767.72 Payments Medical $3,941.92 -0- $3,941.92 Payments Litigation $1,561.79 -0- $1,561.79 Expenses ACS $3,693.10 -0- $3,693.10 Adjusting Costs TOTAL: $9,964.53 FILING FEE(S): $21.50 ADDITIONAL -0- COSTS: SATISFACTION $9,986.03 AMOUNT: The undersigned,Director,Bureau of Workers'Compensation,Department of Labor&Industry,certifies that the above balance is due and payable by the above named defendant under the provisions of the Pennsylvania Workers'Compensation Law. Pursuant to section 1605 of said law,77 P.S.§2705,the above balance is a judgment and statutory lien upon the franchises and property,both real and personal,including after acquired property,of the above named defendant and attach thereto from the date of entry this Certified Copy of Lien- Step en J. ir�ov d Date Director, e of Workers'Compensation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA DOCKET# DATE ENTERED COMMONWEALTH OF PENNSYLVANIA Procnonotatp DEPARTMENT OF LABOR&INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND v. ON THE RUN MART INC. 101 NORTH WALNUT STREET MECHANICSBURG,PA 17055 NOTICE TO DEFENDANT OF ENTRY OF LIEN This is a copy of the Certified Copy of Lien which has been filed with the Prothonotary of the Court designated on the reverse side of this notice. The Department of Labor&Industry of the Commonwealth of Pennsylvania, at the expiration of ten CERTIFIED COPY OF LIEN UNDER (10)days after the receipt of this notice, is authorized by law to execute upon this lien. This means PENNSYLVANIA WORKERS' COMPENSATION that your property may be levied upon, attached and sold to the extent necessary to satisfy this lien. LAW Execution will not occur if this lien is satisfied. Payment should be made by a Cashers Check, Certified Check or Money Order made payable to the Commonwealth of Pennsylvania. The Account Number shown on the reverse side of this document should be affixed to the lower left corner of the remittance and mailed to the address below: Pennsylvania Uninsured Employers Guaranty Fund Post Office Box 1774 Harrisburg,PA 17105-1774 Any questions concerning this Lien should be addressed to the Uninsured Employers Guaranty Fund office at the address or telephone number shown on the enclosure. a EXHIBIT C s i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND, Civil Action - Law Plaintiff Docket#: 12-6679 vs. ON THE RUN MART, INC. Lien Defendant Plaintiffs Interrogatories Directed to Defendants) Pursuant to Rule 3117 of the Pennsylvania Rules of Civil Procedure Discovery In Aid of Execution Plaintiff,hereby makes demand that the Defendant(s) answer the following Interrogatories pursuant to the Pennsylvania Rules of Civil Procedure 3117 and 4001 of seq. These Interrogatories must be answered as provided in Pa. R.C.P. 4006 and the Answers must be served on all other parties within thirty (30) days after the Interrogatories are deemed served.. These Interrogatories are deemed to be continuing as to require the filing of Supplemental Answers promptly in the event Defendant or their representatives (including counsel) learn additional facts not set forth in its original Answers or discover that information provided in the Answers is erroneous. Such supplemental Answers may be filed from time to time, but not later than 30 days after such further information is received, pursuant to Pa.R.C.P. 4007.4. These Interrogatories are addressed to you as a party to this action; your answers shall be based upon information known to you or in the possession, custody or control of you, your attorney or other representative acting on your behalf whether in preparation for litigation or otherwise. These Interrogatories must be answered completely and specifically by you in writing and must be verified. The fact that investigation is continuing or that discovery is not complete 1 shall not be used as an excuse for failure to answer each interrogatory as completely as possible. The omission of any name, fact, or other item of information from the Answers shall be deemed a representation that such name, fact, or other item was not known to Defendant, their counsel, or other representatives at the time of service of the Answers. 1. State: (a) All of the names under which you, Sultan Bhatti, currently conduct, or have previously conducted, business, or those businesses in which you hold, or previously held, and ownership interest, including, but not limited to, On the Run Mart, Inc., and any predecessors, successors, assigns or affiliated entities of said businesses. Include any alternate spellings of the business names. (b) For each entity identified in Question 1(a), identify the: (1) official business name; (2) business structure (i.e. sole proprietorship, corporation, limited liability company, etc.), (3) type of business; (4) principal place of business; (5) registered address for service of process; (6) business telephone number(s); (7) dates the business was in operation; (8) FEIN number; (9) the name and address of any individual(s)/business(es) that have, and/or have ever had, an ownership interest in the business. (c) For each business identified in Question 1(a) identify whether business is currently conducted under that name, and if not identify year in which business was last conducted under that name. (d) For each business identified in Question 1(a) provide copies of all relevant documents executed to form and commence operation of said business. This includes, but is not limited to, fictitious or associated name registrations, partnership agreements, articles of incorporation, certificates of organization, and/or any documents filed with the Pennsylvania Department of State. (e) For each business identified in Question 1(a) identify how much capital was allocated to start the business and identify whether that capital was in a separate business account or held in an individual's account. In each case provide the name of the financial institution, account number, name on the account, and name of all individuals, or entities, who had access to said account. I (f) For each business identified in Question 1(a) provide the most recent takfilings for the last five years that entity was in operation. For any entity in operation less than five years provide the tax filings for each year the entity was in operation. This request is deemed to include all applicable tax filings for the specific business including, but not limited to, both Federal and State tax returns, and the applicable corporate, partnership, or individual tax returns filed by the entity or its agents or principals. (g) State whether each business identified in Question 1(a) has ever changed, or currently plans on changing,.,its name and/or entity structure? If yes, list all business names, entity structures, date of the change or proposed change, and all owners of, or individuals with an interest,in, the resulting business entity. (h) For each business identified in Question 1(a) identify whether that business has filed for bankruptcy protection or intends to file for bankruptcy protection in the future? If so, state the court in which the bankruptcy petition was filed, the docket number, and the current status of the bankruptcy action. (i) State whether you, Sultan Bhatti, are currently employed? If Yes, state: (1) The name and address of your employer; (2) Your salary or wages; (3) How you are paid, i.e. cash, check, direct deposit, etc; (4) Where your pay is deposited or cashed, including the institution's name and address as well as the account number; (5) How long you have been working for this employer; and (6) Your job title and duties. (j) List all sources of income, including, but not limited to, self- employment, government benefits, retirement benefits, structured or lump sum settlements, etc., for Sultan Bhatti for the past five years. For each source of income, state: (1) From whom, or what, income is received; (2) The amount of income received; (3) Why income was received from each source; (4) How the income was received, i.e. cash, check, direct deposit, etc.; (5) When income was last received from each source. (k) Does Sultan Bhatti receive any form of public assistance? If so, identify: (1) The type of assistance received; (2) The amount of assistance received; (3) When assistance was first received; and (4) When assistance was last received. (1) Provide Sultan Bhatti's most recent tax filings for the last five years. If you have not filed taxes for the last five years, provide the fillings for each year you did file taxes. This request is deemed to include all tax filings for Sultan Bhatti, including, but not limited to, Federal, State, and Local tax returns, filed individually or jointly with another. 2. Business Assets: (a) For each business identified in Question 1(a) that is no longer in operation state the following: (1) The name of the business; (2) The date upon which the business ceased to operate; (3) The manner in which the business ended operations (i.e. asset sale, stock transfer, etc.) and provide any documentation evidencing the same; (4) The name and address of the successor(s) to the business; (5) The name and address of all individuals having an ownership interest in the successor(s). (b) To the extent that any business identified in Question 1(a) was sold or transferred, provide the name and address of the person(s), or entity(ies), to whom it was sold or transferred and attach a copy of the agreement(s) evidencing that transfer. (c) To the extent that any business identified in Question 1(a) has sold or transferred assets to another entity(ies) or successor(s), identify the assets transferred, value of those assets, the consideration received, who received the consideration, and a copy of the agreements evidencing those transactions. (d) Does any business identified in Question 1(a) have any account or investment in any type of financial institution, individually or with another or in the name of another, including checking accounts, savings accounts, certificates of deposit and money market accounts? If so, with regard to each such account or investment, state the following: (1) The type of account or investment; (2) The name and address of the financial institution; (3) The name and address of each person in whose name the account is held or has been held; and (4) The account number. (e) Does any business identified in Question 1(a) own any interest in real estate? If so, with regard to each such interest state the following: (1) The size and description of the parcel of real estate, including improvements thereon; (2) The name, address and interest of each person who has or claims to have an ownership interest in the parcel of real estate; (3) The date the entity acquired its interest in the parcel of real estate; (4) The consideration transferred or paid for the interest in the parcel of real estate: (5) An estimate of the current fair market value of the parcel of real estate; (6) The amount of any indebtedness owed on the parcel of real estate and to whom that indebtedness is owed; and (7) The name of the insurance company, and policy number, for each insurance policy covering the parcel of real estate or any improvements thereon. (f) Does any business identified in Question 1(a) hold a mortgage on or other security interest in any real estate? If so, as to each such mortgage or other security interest state: (1) The description of the real estate; (2) The date when the mortgage or other security interest was acquired; (3) The identity of the assignor of the mortgage or other security interest, if any; (4) The outstanding balance due on the note or obligation which the mortgage or other security interest secures; (5) The identities of the mortgagor(s), or party(ies) granting the security interest, and the real owner(s); (6) The identity of any documents which relate to the mortgage or other security interest; and (7) The priority of the mortgage or other security interest. M (g) State the year, make, and model of each motor or motorized vehicle in which any business identified in Question 1(a) has an ownership interest or claim of interest, whether individually or with another, and with regard to each item state the following: (1) The date the vehicle was acquired; (2) The license plate number of the vehicle; (3) The consideration paid for the vehicle; (4) The name and address of each other person or entity who has a right, title, claim, or interest in or to the vehicle; (5) The approximate fair market value of the vehicle; (6) The amount of any indebtedness on the vehicle and the name and address of the creditor; (7) The registration information for each vehicle, including the VIN number; and (8) The name of the insurance company and the policy number for all insurance policies covering each vehicle. (h) Does any business identified in Question 1(a) have any safe deposit box or other similar storage facility in its name (either individually or jointly with another individual or entity), in the name of any entity in which it has any ownership or other involvement (either alone or jointly with another entity or individual) or in which it has contained personal property with a value in excess of$100? If so, as to each such box or facility state: (1) The identity of the institution in which the safe deposit box or facility is rented or maintained; (2) The number under which such safe deposit box or facility is rented; (3) The name under which such safe deposit box or facility is rented; and (4) The contents of such safe deposit box or facility. (i) Is any business identified in Question 1(a) the beneficiary under an insurance policy on the life of any person? If so, identify the policy, including policy number, the issuer, the insured, the amount of the policy, the current value of the policy, and any other beneficiaries. r VN A Q) For every business identified in Question 1(a) identify all insurance policies, including workers' compensation, general liability and health that the business currently maintains or has ever maintained. For each policy, include: (1) The name of the insurer; (2) The policy number(s); (3) The type of insurance. 1 3. Personal Assets: (a) List all other aliases of Sultan Bhatti. (b) Provide Sultan Bhatti's social security number, alien registration number and/or tax identification number. (c) Identify any other social security numbers, alien registration numbers, and/or tax identification numbers used, or previously used by Sultan Bhatti and identify the years in which these numbers were used, why they were used, and why they are no longer used. (d) Identify your home address and telephone number(s), including direct line and any mobile or cellular number(s). (e) Do you hold, or have you ever held, an ownership interest in any business identified in Question 1(a)? If yes, identify that ownership interest and describe the amount of and value of that ownership interest. (f) Does any other individual hold an ownership interest in any business identified in Question 1(a)? If yes, identify that individual, provide their home address, and identify their ownership interest and describe the amount of and value of that ownership interest. (g) Do you have any account or investment in any type of financial institution, individually or with another or in the name of another, including checking accounts, savings accounts, certificates of deposit and money market accounts? If so, with regard to each such account or investment, state the following: (1) The type of account or investment; (2) The name and address of the financial institution; (3) The name and address of each person in whose name the account is held; and (4) The account number. (h) Do you own any stocks, bonds, securities, or other investments, including savings bonds? If so, with regard to each such stock, bond, security or investment state: (1) A description of the stock, bond, security or investment; (2) The name and address of the entity issuing the stock, bond, security or investment; (3) The date of acquisition of the stock, bond, security or investment; (4) The name and address of any other owner or owners in such stock, bond security, or investment. (i) Do you own any interest in real estate? If so, with regard to each such interest state the following: (1) The size and description of the parcel of real estate, including improvements thereon; (2) The name, address and interest of each person who has or claims to have an ownership interest in the parcel of real estate; (3) The date the interest in the parcel of real estate was acquired; I (4) The consideration transferred or paid for the interest in the parcel of real estate: (5) An estimate of the current fair market value of the parcel of real estate; (6) The amount of any indebtedness owed on the parcel of real estate and to whom that indebtedness is owed; and (7) The name of the insurance company, and policy number, for each insurance policy covering the parcel of real estate or any improvements thereon. Q) Do you hold a mortgage on or other security interest in any real estate? If so, as to each such mortgage or other security interest state: (1) The description of the real estate; (2) The date when the mortgage or other security interest was acquired; (3) The identity of the assignor of the mortgage or other security interest, if any; (4) The outstanding balance due on the note or obligation which the mortgage or other security interest secures; (5) The identities of the mortgagor(s), or party(ies) granting the security interest, and the real owner(s); (6) The identity of any documents which relate to the mortgage or other security interest; and (7) The priority of the mortgage or other security interest. (k) State the year, make, and model of each motor or motorized vehicle in which you, Sultan Bhatti, have an ownership interest or claim of interest, whether individually or with another, and with regard to each item state the following: (1) The date the vehicle was acquired; (2) The license plate number of the vehicle; (3) The consideration paid for the vehicle; (4) The name and address of each other person who has a right, title, claim, or interest in or to the vehicle; ti (5) The approximate fair market value of the vehicle; (6) The amount of any indebtedness on the vehicle and the name and address of the creditor; (7) The registration information for each vehicle, including the VIN number; and (8) The name of the insurance company and the policy number for all insurance policies covering each vehicle. (1) Have you, Sultan Bhatti, filed for bankruptcy protection, or intend to file for bankruptcy protection in the future? If so, state the court in which the bankruptcy petition was filed, the docket number, and the current status of the bankruptcy action. (m) Are you the beneficiary of any trust? If so, identify the name, address and telephone number of the trustee, the duration of the trust and his interest therein, the amount of income he receives from the trust annually, the amount of principal to which he is entitled upon distribution, the date of distribution, and the identity of all documents relating to the creation of the trust. 0 a. (n) Do you have any safe deposit box or other similar storage facility in your name (either individually or jointly with another individual or entity), in the name of any entity in which you have any ownership or other involvement (either alone or jointly with another entity or individual) or in which you have personal property with a value in excess of$100? If so, as to each such box or facility state: (1) The identity of the institution in which such safe deposit box or facility is rented or maintained; (2) The number under which such safe deposit box or facility is rented; (3) The name under which such safe deposit box or facility is rented; and (4) The contents of such safe deposit box or facility. (o) Are you the beneficiary under an insurance policy on the life of any other person? If so, identify the policy, the issuer, the insured, the amount of the policy, the current value of the policy, and any other beneficiaries. (p) Identify all insurance policies you currently hold, including workers' compensation, general liability, health, homeowner's and automobile. For each policy, include: (1) The name and address of the insurer; (2) The policy number; (3) The type of insurance. 4. State the name and address of the person answering these Interrogatories and their relationship with the Defendant(s). Date: May 2, 2013 By: sepfi J. S rt , ss' tant nsel Supreme Court 0923 Attorney for Plaintiff Bureau of Workers' Compensation Legal Division — Room 327 1171 South Cameron Street Harrisburg, PA 17104 (717) 783-4467 (Phone) (717) 783-4469 (Fax) a' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND, Civil Action - Law Plaintiff Docket#: 12-6679 vs. ON THE RUN MART, INC. Lien Defendant VERIFICATION I being subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities, state that the attached answers and/or documents are submitted in response to the foregoing Interrogatories and that to the best of my knowledge, information and belief they , are true and complete. Date: By: w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND, Civil Action - Law Plaintiff Docket#: 12-6679 vs. ON THE RUN MART, INC. Lien Defendant CERTIFICATE OF SERVICE I, Joseph J. Swartz, Esquire, do hereby certify that on this date I served an original and two copies of the foregoing Interrogatories on the following individuals by mailing it to them by United States First Class Mail and by Certified Mail, United States Postal Service, Parcel Number 7012 3050 0002 3948 4282 and 7012 3050 0002 3948 4299, postage prepaid, addressed as follows: On the Run Mart, Inc. 101 North Walnut Street Mechanicsburg, PA 17055 On the Run Mart, Inc. c/o Sultan 13hatti, A-1 United Auto Services 1330 North 3rd Street Harrisburg, PA 17102 r ssep J. wa q istant Co se Bureau of Workers Compensation Legal Division — Room 327 1171 South Cameron Street Harrisburg, PA 17104 Date: May 2, 2013 (717) 783-4467 y 9th JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND, Docket No. 12-6679 Plaintiff Vs. ON THE RUN MART, INC. CERTIFICATE OF SERVICE I, ERICH M. DIEHL, Esquire, do hereby certify that on this date I served a copy of the foregoing Motion to Compel Answers to Interrogatories in Aid of Execution the following individual by mailing it to them by regular first class United States Postal Service Mail, addressed as follows: ON THE RUN MART, INC. 101 North Waltnut Street Mechanicsburg, PA 17055 Erich"IT Diehl, Esq. Assistant Counsel Bureau of Workers' Compensation Legal Division - Room 327 1171 South Cameron Street Harrisburg, PA 17104 Date: Z7 -2� 3 (717) 783-4467 91" JUDICAL DISTRICT OF PENNSYLVIANA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION—LAW DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND Docket No. 12-6679 Plaintiff Vs. ON THE RUN MART, INC. Defendant ORDER AND NOW, this day of , �.Y/f rYl� 2013, upon consideration of the Plaintiff's Motion to Compel Answers to Interrogatories in Aid of Execution, a Rule is hereby issued on Defendant to show cause why the Motion should not be granted. Rule is returnable thirty (30) days from this date. BY TH URT, Date: J t �,�O13 7. cy Copi*es ,�y�`` CAP l n�.- . _ t Cn 9th JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA : CIVIL ACTION - LAW DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND, : Docket No. 12-6679 Plaintiff • • Vs. -6; • 7� ON THE RUN MART, INC. • CD y(-) MOTION TO MAKE RULE ABSOLUTE 5'' 0 ' 1. Plaintiff is the Commonwealth of Pennsylvania, Department of Labor and Industry, Uninsured Employers Guaranty Fund, an agency of the Commonwealth of Pennsylvania with offices located at 1171 South Cameron Street, Harrisburg, Pennsylvania, 17104. 2. Defendant is On the Run Mart, Inc., a Pennsylvania corporation whose last known address is 101 North Walnut Street, Mechanicsburg, PA 17055. 3. Defendant's Vice President is Sultan Bhatti, whose last known address is 4270 Williamsburg Drive, Apartment A, Harrisburg, Pennsylvania, 17109. A copy of a Commonwealth of Pennsylvania, Department of State Business Entity Filing History is attached hereto and marked as Exhibit A, as proof that Sultan Bhatti is Defendant's Vice President. 4. On August 28, 2013, Plaintiff filed a Motion to Compel Answers to Interrogatories in Aid of Execution requesting that this Honorable Court issue an Order directing Defendant to provide Plaintiff with written answers to interrogatories within thirty (30) days. 5. On September 9, 2013, this Honorable Court issued an Order and a Rule on Defendant to show cause why Plaintiffs Motion to Compel should not be granted. The Rule was returnable thirty (30) days from September 9, 2013. A copy of the Court Order is attached hereto and marked as Exhibit B. WHEREFORE, Plaintiff respectfully requests that this Honorable Court schedule a hearing for the purpose of allowing Defendant the opportunity to explain why it should not be held in civil contempt of court for failure to respond to the Court's September 9, 2013 Order. In the alternative, Plaintiff respectfully requests that this Honorable Court hold Defendant in contempt for failure to respond to its September 9, 2013 Order, and issue a bench warrant for the arrest of Sultan Bhatti, so that he is available to appear before this Court and explain why Defendant has not responded to the Court's September 9, 2013 Order and why Defendant has not provided Plaintiff with Answers to Interrogatories. Respectfully submitted, Date: /0/Z&//20/ By: 4 Eric M. Diehl, Esq. Assistant Counsel Attorney for Plaintiff Bureau of Workers' Compensation Legal Division — Room 327 1171 South Cameron Street Harrisburg, PA 17104 (Attorney I.D. #40388) (717) 783-4467 (Phone) (717) 783-4469 (Fax) EXHIBIT "B" 9th JUDICAL DISTRICT OF PENNSYLVIANA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA : CIVIL ACTION—LAW DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND : : Docket No. 12-6679 Plaintiff • • Vs. • ON THE RUN MART, INC. • r-m'= tea; • .,. rr, Defendant : = ORDER LAJ °L7 AND NOW, this 9 ��, day of f ", fit 2013, upon consideration of the Plaintiff's Motion to Compel Answers to Interrogatories in Aid of Execution, a Rule is hereby issued on Defendant to show cause why the Motion should not be granted. - Rule is returnable thirty (30) days from this date. BY TH i URT, Dater - t,� A0.�.3 J. • ( r 35 -+n T r? r -- '� .fw"'Q z EXHIBIT "C" COURT ORDER RETURN OF SERVICE I, JOHN FORNEY, of ACS Claim Service Inc, certify that I personally delivered the enclosed COURT Order to Mrs. Bhatti, at her home, 4270 Williamsburg Drive, Apartment A, in Harrisburg, PA, on September 17, 2013. Mrs. Bhatti accepted served on behalf of her husband who was unavailable. She confirmed that Mr. Sultan Bhatti also resided at this address and she agreed to deliver it to him. JOHN S FORNEY t.a ACS CLAIM SERVICE, INC. P.O. BOX 257 MECHANICSBURG, PA 17055 9th JUDICAL DISTRICT OF PENNSYLVIANA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA • CIVIL ACTION—LAW DEPARTMENT OF LABOR& INDUSTRY • UNINSURED EMPLOYERS GUARANTY FUND • • Docket No. 12-6679 Plaintiff • Vs. • • ON THE RUN MART, INC. _� r c- C. Defendant • 3 D ORDER _;`" AND NOW, this 9tA, day of ...6,,,49/5 r�?.L)E 2013, upon consideration of the Plaintiff's Motion to Compel Answers to Interrogatories in Aid of Execution, a Rule is hereby issued on Defendant to show cause why the Motion should not be granted. Rule is returnable thirty (30) days from this date. BY T 1 •URT, Date.S.a/` F,v ll< Ad3 J. pi Fri c-) C � _ r— _ r.._ •-■� , --.{C.: C: "r". " 9th JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA : CIVIL ACTION - LAW DEPARTMENT OF LABOR & INDUSTRY : UNINSURED EMPLOYERS GUARANTY FUND, : Docket No. 12-6679 Plaintiff • • Vs. • • ON THE RUN MART, INC. CERTIFICATE OF SERVICE I, ERICH M. DIEHL, ESQ., do hereby certify that on this date I served the Defendant, On the Run Mart, Inc., with a copy of the foregoing Motion to Make Rule Absolute, by mailing same to the following individuals by regular United States Mail, First Class, postage prepaid, at the following addresses: On the Run Mart, Inc. 101 North Walnut Street Mechanicsburg, PA 17055 Sultan Bhatti Vice President On the Run Mart, Inc. 4270 Williamsburg Drive Apartment A Harrisburg, Pennsylvania, 17109 Date: AP/ / Erich M. Diehl, Esq. Assistant Counsel Attorney for Plaintiff Bureau of Workers' Compensation Legal Division — Room 327 1171 South Cameron Street Harrisburg, PA 17104 (Attorney I.D. #40388) (717) 783-4467 (Phone) (717) 783-4469 (Fax) 3 9th JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA : CIVIL ACTION - LAW DEPARTMENT OF LABOR & INDUSTRY : UNINSURED EMPLOYERS GUARANTY FUND, : Docket No. 12-6679 Plaintiff • Vs. • ON THE RUN MART, INC. • ORDER OF COURT AND NOW, this tet4 day of No vi/4E!'C 2013, upon consideration of Plaintiffs Motion toMak eRul G bsi te, a hearing is hereby scheduled for ) at /..00 a,41./p.m. in Courtroom No. 3 in the Cumberland County Courthouse. All parties are directed to appear in person. BYT '- 0 Date: //• fi "/.3 J. • -v 3 : zr+i== C-Ap Ces SILL-441/43 /i/ia/ia r 9th JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND, Docket No. 12-6679 Plaintiff Vs. ON THE RUN MART, INC. 101 NORTH WALNUT STREET MECHANICSBURG, PA 17055, Defendant ' 5F G:. c` ENTRY OF APPEARANCE < Nj TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Plaintiff in the above captioned matter and mail copies of all future correspondence and court documents to my direct attention. Respectfully submitted, Date: /2/o2flJq By Erich M. Diehl, Esq. Assistant Counsel Bureau of Workers' Compensation Legal Division — Room 327 1171 South Cameron Street Harrisburg, PA 17104 (717) 783-4467 (Phone) (717) 783-4469 (Fax) Attorney I.D. #40388 9th JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND, Docket No. 12-6679 Plaintiff Vs. ON THE RUN MART, INC. CERTIFICATE OF SERVICE I, ERICH M. DIEHL, ESQ., do hereby certify that on this date I served the Defendant, On the Run Mart, Inc., with a copy of the foregoing Entry of Appearance, by mailing same to the following individuals by regular United States Mail, First Class, postage prepaid, at the following addresses: On the Run Mart, Inc. 101 North Walnut Street Mechanicsburg, PA 17055 Sultan Bhatti Vice President On the Run Mart, Inc. 4270 Williamsburg Drive Apartment A Harrisburg, Pennsylvania, 17109 Date: zv/,�te By: Erich M. Diehl, Esq. Assistant Counsel Attorney for Plaintiff Bureau of Workers' Compensation Legal Division — Room 327 1171 South Cameron Street Harrisburg, PA 17104 (Attorney I.D. #40388) (717) 783-4467 (Phone) (717) 783-4469 (Fax) COMMONWEALTH OF PENNSYLVANIA IN THE COURT OF COMMON DEPARTMENT OF LABOR & INDUSTRY PLEAS OF CUMBERLAND UNINSURED EMPLOYERS GUARANTY FUND, COUNTY, PENNSYLVANIA Plaintiff V. ON THE RUN MART, INC. CIVIL ACTION - LAW Defendant NO. 12-6679 CIVIL TERM IN RE: PLAINTIFF' S MOTION TO MAKE RULE ABSOLUTE ORDER OF COURT AND NOW, this 16th day of December, 2013, by agreement of the parties, the Defendant is given until December 31, 2013, to file full and complete answers to interrogatories . A further hearing in this matter is scheduled for Friday, January 10, 2014, at 1 : 30 p.m. The Defendant ' s president, Afzal Mahmood, and its vice-president, Sultan Bhatti, are directed to appear along with counsel for Plaintiff. Failure of the Defendant ' s representatives to appear shall result in the issuance of a bench warrant for their arrest . By the Court, cl C _U X w -- MW = 7:­ C5 m Edward E. Guido, J. C =r �-y.",� o c� rich M. Diehl, Esquire -+ '' For the Plaintiff -c ./Sultan Bhatti 4270 Williamsburg Drive, Apartment A Harrisburg, PA 17109 J eo : lfh q. fr r 9th JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA : CIVIL ACTION - LAW DEPARTMENT OF LABOR & INDUSTRY : UNINSURED EMPLOYERS GUARANTY FUND, : Docket No. 12-6679 Plaintiff Vs. ON THE RUN MART, INC. ORDER OF COURT AND NOW, this 9th day of JANUARY, 2014, upon the request of the Plaintiff, the hearing in the above captioned matter, scheduled for January 10, 2014 at 1:30 p.m. is hereby postponed sixty (60) days pending the submission of Answers to Discovery Interrogatories by Defendant to Plaintiff. Lit ,A7a111.4,..ee Cu, Meh'iof"•') are"14,04°"'R"-' BY THE • rT, J. EDWARD GUIDO, JUDGE ERICH MARK DIEHL, ESQUIRE fir-- ^ /SULTAN BHATTI --o_ 4270 WILLIAMSBURG DRIVE,APT.A � HARRISBURG, PA 17109 -` -` i'es 1 l a /Y 0) COMMONWEALTH OF PENNSYLVANIA IN THE COURT OF COMMON DEPARTMENT OF LABOR & INDUSTRY PLEAS OF CUMBERLAND UNINSURED EMPLOYERS GUARANTY FUND, : COUNTY, PENNSYLVANIA Plaintiff . V. ON THE RUN MART, INC. CIVIL ACTION - LAW Defendant NO. 12-6679 CIVIL TERM IN RE: PLAINTIFF' S MOTION TO MAKE RULE ABSOLUTE ORDER OF COURT AND NOW, this 16th day of December, 2013, by agreement of the parties, the Defendant is given until December 31, 2013, to file full and complete answers to interrogatories . A further hearing in this matter is scheduled for Friday, January 10, 2014, at 1 : 30 p.m. The Defendant ' s president, Afzal Mahmood, and its vice-president, Sultan Bhatti, are directed to appear along with counsel for Plaintiff. Failure of the Defendant ' s representatives to appear shall result in the issuance of a bench warrant for their arrest . By the Court, Edward E. Guido, J. Erich M. Diehl, Esquire For the Plaintiff Sultan Bhatti VIHVK1, SNN3d 4270 WilliamsbiA DP1 e,8 ir'tment A Harrisburg, P739 61 33Q ER : lfh IONOH1O id 'NI SI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Commonwealth of Pennsylvania Department of Labor & Industry, Uninsured Employers Guaranty Fund, : CIVIL ACTION - LAW Plaintiff Vs. : No. 12-6679 On the Run Mart, Inc. 101 North Walnut Street Mechanicsburg, PA 17055, Defendant And Wells Fargo Bank 604 East High Street Carlisle, PA 17013-2608 Integrity Bank 3345 Market Street Camp Hill, PA 17011 Garnishees PREACIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY OF SAID COURT: Issue a writ of execution in the above captioned matter: 1. directed to the Sheriff of Cumberland County, Pennsylvania 2. against ON THE RUN MART, INC. Defendant 3. against WELLS FARGO BANK Garnishee ry 4. against INTEGRITY BANK Garnishee 5. Balance of payments made by the Uninsured Employers Guarantee Fund of behalf of the uninsured employer Lien Filing Fee Less Payments Total Amount Due: Date: S/9//9 4.29.0c too/ e1FP ,217.00 d ' 4 79.. -JP el 01/636.6 P#--- 3057/3 \ilio4 oP /Sse) e o/ By /f $9,964.53 $ $29.00 -0- $ 9,993.53 Erich M. Diehl Supreme Court I.D. #40388 Assistant Counsel Commonwealth of Pennsylvania Department of Labor & Industry Bureau of Workers' Compensation Legal Division — Room 327 1171 S. Cameron Street Harrisburg, PA 17104-2501 (717) 783-4467 (Phone) (717) 783-4469 (Fax) 0?.025 le Co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 12-6679 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR AND INDUSTRY To the use of the UNINSURED EMPLOYERS GUARANTY FUND, Plaintiff v. ON THE RUN MART,INC., Defendant And WELLS FARGO BANK, Garnishee INTEGRITY BANK, Garnishee PRAECIPE FOR WRIT OF EXECUTION Erich M. Diehl (Attorney I.D. #40388) Assistant Counsel Bureau of Workers' Compensation Legal Division — Room 327 1171 South Cameron Street Harrisburg, PA 17104 (717) 783-4467 (Phone) (717) 783-4469 (Fax) THE COURT OF COMMON. PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net Commonwealth of Pennsylvania Department of Labor & Industry, Uninsured Employers Guaranty Fund Vs. NO 12-6679 Civil Term CIVIL ACTION — LAW On the Run Mart, Inc. 101 North Walnut Street Mechanicsburg, PA 17055 WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against On the Run Mart, Inc. Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of Wells Fargo Bank & Integrity BankGARNISHEE(S), as garnishee, Wells Fargo Bank - 604 East High Street, Carlisle, PA 17013 -2608 & Integrity Bank - 3345 Market Street, Camp Hill, PA 17011 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $9,964.54 Interest Attorney's Comm. % Attorney Paid Date: 5/12/2014 REQUESTING PARTY: Name : Erich M. Diehl, Esq. Address: Commonwealth of Pennsylvania Department of Labor & Industry Bureau of Workers' Compensation Legal Division - Room 327 1171 S. Cameron Street, Harrisburg, PA 17104-2501 Attorney for: Plaintiff Telephone: 717-783-4467 Supreme Court ID No. 40388 Plaintiff Paid $79.50 Law Library Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY E.- L..f 1 ; C� ::.. .. HE =ROTHQNQTAR 2 R HAY 22 PH 2: 42 CUMBERLAND Camp( PENNSYLVANIA OH ICE OF•TF e SHERIFF Commonwealth of PA, Dept of Labor and Industry vs. Case Number On the Run Mart Inc 2012-6679 SHERIFF'S RETURN OF SERVICE 05/19/2014 11:11 AM - William Cline, Deputy, who being duly swbrn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Jennifer Krug, Teller, personally three copi=. of interrogatories together with three true and attested copies of the Writ of Execution and made a .. ents there of known to her. May 20, 2014 (c) CeuntySuite Sheriff, Teieosoft inc. AM CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY «x,+, bet, `411 OF!,ICF, FTP $' RIFF Commonwealth of PA, Dept of Labor and Industry vs. On the Run Mart Inc Case Number 2012-6679 SHERIFF'S RETURN OF SERVICE 05/20/2014 01:55 PM - Jeff Kolodzi, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Integrity Bank, 3345 Market Street, Camp Hill Borough, Camp Hill, PA 17011, Cumberland County, by handing to Anastasia Acre, Lead 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. The writ of execution and notice to defendant was mailed on May 21, 2014 to On the Run Mart, Inc. at 101 N Walnut Street, Mechanicsburg, PA 17055. May 21, 2014 (CO CcuntySuite Sheriff, Teleosoft, Inc. "T JEFJ ODZI, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864 -9700 Attorney for Garnishee COMMONWEALTH OF PENNSYLVANIA : COURT OF COMMON PLEAS DEPARTMENT OF LABOR AND INDUSTRY, : COUNTY OF CUMBERLAND UNINSURED EMPLOYERS GUARANTY FUND : vs. ON THE RUN MART, INC. : NO. 12 -6679 and WELLS FARGO BANK, GARNISHEE ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf Wells Fargo Bank, Garnishee in the above - captioned matter. Date: 5. JON C. SIRLIN Attorney fox :Garnishee e1 SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee t;jjj�, ,_ -5 P ; PENNSYLVANIA T )> COMMONWEALTH OF PENNSYLVANIA : COURT OF COMMON PLEAS DEPARTMENT OF LABOR AND INDUSTRY, : COUNTY OF CUMBERLAND UNINSURED EMPLOYERS GUARANTY FUND : vs. ON THE RUN MART, INC. : NO. 12-6679 and WELLS FARGO BANK, GARNISHEE ANSWERS TO INTERROGATORIES IN ATTACHMENT TO: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR AND INDUSTRY, UNINSURED EMPLOYERS GUARANTY FUND, Plaintiff 1.- 6. Wells Fargo Bank holds no assets of and owes no debt to the Judgment Debtor herein. Dated: cc> 3 '�� LIS :...:GO. e Wells Fargo Bank, N.A. Liens, Levies & Garnishments 101 N. Independence Mall East MAC Code# Y1372-113 Philadelphia, PA 19106 VERIFICATION Phyllis Brummett, being duly sworn according to law, deposes and says that she is the Legal Order Processing Associate of Wells Fargo Bank, NA Garnishee herein, and verifies that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made subject to penalties of i8 Pa. C.S. Section 4904, relating to sworn falsification to authorities. Date: CA° ,64„) Phylli Brummett Legal Order Processing Associate COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS DEPARTMENT OF LABOR AND INDUSTRY, COUNTY OF CUMBERLAND UNINSURED EMPLOYERS GUARANTY FUND VS. ON THE RUN MART, INC. : NO. 12-6679 and WELLS FARGO BANK, GARNISHEE ATTORNEY I.D.# ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, Wells Fargo Bank, Garnishee, discontinued,upon payment of your costs only. J ERICH M. DIEHL Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND vs. ON THE RUN MART, INC. 101 NORTH WALNUT STREET MECHANICSBURG, PA 17055 Defendant No. 12-6679 cD PRAECIPE TO MARK LIEN SATISFIED TO THE PROTHONOTARY OF SAID COURT: Kindly mark the lien in the matter captioned above as satisfied in full as to all named parties. Your assistance in this issue is most appreciated. Dated: November 5, 2014 Respectfully submitted, rn Er M. Diehl (Attorney I.D. #40388) Assistant Counsel Office of Chief Counsel Workers' Compensation Division 1171 South Cameron Street Harrisburg, PA 17104 Attorney for the Plaintiff Ofitui poi p,4 etff w 66 R-11- 311 CERTIFICATE OF SERVICE I, Erich M. Diehl, attorney for the Plaintiff, hereby certify that on this date I served a copy of the foregoing Praecipe to Mark Lien Satisfied on the following individuals, by mailing same to them by regular first class United States Mail, postage prepaid, at the following addresses: ON THE RUN MART, INC. 11 NORTH WALNUT STREET MECBANlCSBlJQG,P&l7055 Date 1114) Erich M.Diehl (Attorney iD.#4O]Q8) Assistant Counsel Office of Chief Counsel Workers' Compensation Division 1171 South Cameron Street Harrisburg, PA 17104 Attorney for the Plaintiff Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF77h V-,ERIFF ar 1 2 •.1 • GUM3E LAND PENNSYLVANIA Commonwealth of PA, Dept of Labor and Industry vs. On the Run Mart Inc Case Number 2012-6679 SHERIFF'S RETURN OF SERVICE 03/14/2013 01:02 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on March 14, 2013 at 1300 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: On The Run Mart, Inc., in the hands, possession, or control of the within named garnishee, Citizens Bank, 665 North East Street, Carlisle, Cumberland County, Pennsylvania, by handing to Tabitha Zarichansky, 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. The writ of execution and notice to defendant was mailed on March 15, 2013 to On The Run Mart, Inc. at 101 N Walnut Street, Mechanicsburg, PA 17055. 01/08/2015 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.46 SO ANSWERS, January 08, 2015 RONNY R ANDERSON, SHERIFF (c) CountySuile Sheriff, Tuizosott. Inc. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 12-6679 Civil CIVIL ACTION – LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY, UNINSURED EMPLOYERS GUARANTY FUND Plaintiff (s) From ON THE RUN MART, INC., 101 NORTH WALNUT STREET, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: CITIZENS BANK, 4301 CARLISLE PIKE, CAMP HILL, PA 17011 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$9,964.53 Interest Atty's Comm % Atty Paid $50.50 Plaintiff Paid Date: MARCH 11, 2013 (Seal) L.L. $.50 Due Prothy $2.25 Other Costs David D. Buell, Prothonotary 492/2G14.7— Deputy REQUESTING PARTY: Name : ERICH M. DIEHL, ESQUIRE Address: COMMONWEALTH OF PA, DEPT OF LABOR & INDUSTRY LEGAL DIVISION- ROOM 327 1171 S. CAMERON STREET HARRISBURG, PA 17104-2501 Attorney for: PLAINTIFF Telephone: 717-783-4467 Supreme Court ID No. 40388 TRUE COPY FROM, RECORD In Testirriony.w.hereof, I here unto set my hand and the seal of said Co rt at Carlisle, Pao? This...al—day (4,w ; 20►onotary Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OFTk E 'E AFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY 01 COI litberfo 1_, 12 1 -Ti 3: 1 ilBER /=#'.l 1. t w ! PENNSYLVANIA Commonwealth of PA, Dept of Labor and Industry vs. On the Run Mart Inc Case Number 2012-6679 SHERIFF'S RETURN OF SERVICE 05/19/2014 11:11 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Jennifer Krug, 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. 05/20/2014 01:55 PM - Jeff Kolodzi, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Integrity Bank, 3345 Market Street, Camp Hill Borough, Camp Hill, PA 17011, Cumberland County, by handing to Anastasia Acre, Lead 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. The writ of execution and notice to defendant was mailed on May 21, 2014 to On the Run Mart, Inc. at 101 N Walnut Street, Mechanicsburg, PA 17055. 01/08/2015 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $156.01 SO ANSWERS, January 08, 2015 RONNY R ANDERSON, SHERIFF Oleo 993,c7 Aft 3 /5--S--< (c) CounlySui!o Sheriff, T©leosoft, inc, THE COURT OF COMMON PLEAS CUMBERLAND. COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net Commonwealth of Pennsylvania Department of Labor & Industry, Uninsured Employers Guaranty Fund Vs. On the Run Mart, Inc. 101 North Walnut Street Mechanicsburg, PA 17055 WRIT OF EXECUTION (Pa R.C.P. 3252) NO 12-6679 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against On the Run Mart, Inc. Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in. thepossession of Wells Fargo Bank & Integrity BankGARNISHEE(S), as garnishee, Wells Fargo Bank - 604 East High Street, Carlisle, PA 17013 -2608 & Integrity Bank - 3345 Market Street, Camp Hill, PA 17011 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in thepossession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $9,964.54 Interest Attorney's Comm. % Attorney Paid Date: 5/12/2014 Plaintiff Paid $79.50 Law Library Due Prothonotary $2.25 Other Costs G David D. Buell, Prothonotary REQUESTING PARTY: Name : Erich M. Diehl, Esq. Address: commonwealth of Pennsylvania Department of Labor & Industry Bureau of Workers' Compensation Legal Division - Room 327 1171 S. Cameron Street, Harrisburg, PA 17104-2501 Attorney for: Plaintiff Telephone: 717-783-4467 Supreme Court ID No. 40388 . MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law TRUE COPY FROM RECORD In Testimony whereof, 1 here unto set my hand and the seal of said Court at Carlisle, Pa. This.[ —•day of–� �.1--, 20%Y Prothonotary 2