HomeMy WebLinkAbout13-1955 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC,
Debtor. Civil Action No. 15. —195 1 Me im
JANET M. MEIBURGER, Trustee,
Plaintiff,
VS.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants. PRAECIPE TO FILE FOREIGN JUDGMENT
AS TO TRUCK MART, LLC ONLY
M r.a
c
FILED ON BEHALF OF - :r zz —°
Plaintiffm r
COUNSEL OF RECORD OF THIS r te -- ^' c,
PARTY: c ° -+-
Tr} C - ) C3 -,
SHAWN P. MCCLURE, ESQUIRE
PA ID #205951 --
JENNIFER L. TIS, ESQUIRE
PA ID #203751
RAYMOND P. WENDOLOWSKI, JR., ESQUIRE
PA ID #311415
Bernstein - Burkley, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412 - 456 -8100
BERNSTEIN FILE NO. C0077305
* 33.50 Ph A77"/
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NACe Mailed
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H &J AUTO TRANSPORT, LLC,
Debtor. Civil Action No.
JANET M. MEIBURGER, Trustee,
Plaintiff,
VS.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants.
PRAECIPE TO FILE FOREIGN JUDGMENT AS TO TRUCK MART, LLC ONLY
TO THE PROTHONOTARY:
Please file the enclosed certified transcript of Judgment of the United States Bankruptcy Court for
the Eastern District of Virginia, Alexandria Division in accordance with Section B of the Uniform
Enforcement of Foreign Judgment Act (42 Pa. C.S.A. §4306), and also mail notice of the filing of the
Judgment to the Judgment- Debtor, Truck Mart, LLC at the address shown on the attached verification.
Amount of Judgment computed as follows:
Amount of Judgment $18,000.00
BERNSTEIN- BURKLEY, P. .
Date: March 2013 B y :
RaymonJ P. Wendolowski, Jr., Esquir
PA ID #311415
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
(412) 456 -8100
Case 12- 01184 -BFK Doc 19 Filed 11/06/12 Entered 11/06/1214:15:17 Desc Main
Document Page 1 of 3 �-
UNITED STATES BANKRUPTCY COURT
FOR THE EASTERN DISTRICT OF VIRGINIA SCANNED
ALEXANDRIA DIVISION
MAR 2 5 1013
IN RE: )
H&J AUTO TRANSPORT LLC ) Case No. 11- 17824 -BFK
Chapter 7
Debtor )
JANET M. MEIBURGER, Trustee, )
Plaintiff, )
V. ) Adv. Pro. No. 1 2 -0 1 1 84 -BFK
JOHAN PONSEN )
and )
TRUCK MART LLC )
Defendants. )
ORDER GRANTING PLAINTIFF'S MOTION FOR
SUMMARY JUDGMENT AGAINST TRUCK MART LLC
Upon consideration of the Complaint (the "Complaint ") (Docket No. 1) and the Plaintiff's
Motion for Summary Judgment Against Truck Mart, LLC and Memorandum in Support Thereof
(the "Motion') (Docket No. 11), filed by Janet M. Meiburger, Chapter 7 Trustee, Plaintiff herein,
and Truck Mart LLC , one of the Defendants herein, having failed to answer the Motion within the
allocated time period and the Motion appearing to be proper and no objection to the Motion having
been filed, and the period to object to the Motion having expired, and a hearing having been held
thereon, it is hereby
Case 12- 01184 -BFK Doc 19 Filed 11/06/12 Entered 11/06/12 14:15:17 Desc Main
Document Page 2 of 3
ORDERED summary judgment is entered against Truck Mart, LLC as to Count Two of the
Complaint; and it is further
ORDERED that judgment is entered for Truck Mart, LLC in the amount of $18,000.00, plus
interest from the date of judgment.
Date: Nov 5 2012 /s/ Brian F. Kenney
U.S. Bankruptcy Judge
Entered on Docket: November 6, 2012
I ASK FOR THIS:
/s/ Janet M. Meiburger A TRUE COPY TESTE:
Janet M. Meiburger, Esq., VSB No. 31842 w1w C-
The Meiburger Law Firm, P.C.
1493 Chain Bridge Road, Suite 201 CEPU
McLean, Virginia 22101
Phone: (703) 556 -7871
Counsel to the Chapter 7 Trustee
/hnnt/orders/ Attachments /doctopdf /aildocs/1 2 -01 1 84- 20 1 21 0260 1 4447906.doc
Case 12- 01184 -BFK Doc 19 Filed 11/06/12 Entered 11/06/12 14:15:17 Desc Main
Document Page 3 of 3
PARTIES TO RECEIVE COPIES BY MAIL:
Truck Mart, LLC
26 Truck Tech Way
Shippensburg, Pennsylvania 17257
Robert M. Marino
Redmon Peyton & Braswell, LLP
510 King Street, Suite 301
Alexandria, Virginia 22314 -3143
Counsel for Truck Mart, LLC
J. McDowell Sharpe
257 Lincoln Way East
Chambersburg, PA 17201
Counsel for Truck Mart, LLC
Johan Ponsen
4015 Squire Lane
Triangle, VA 22172
/ /mnt/ orders / Attachments/ doctopdf/ alldocs /1 2 -01 1 84-20 1 21 02601 4447906.doc
Eistern District of Virginia - LIVE Page 1 of 5
FeeDeferred, CLOSED
U.S. Bankruptcy Court
Eastern District of Virginia (Alexandria)
Adversary Proceeding #: 12- 01184 -BFK
Assigned to: Brian F. Kenney Date Filed: 05/04/12
Lead BK Case: 11 -17824 Date Terminated: 12/19/12
Lead BK Title: H &J Auto Transport LLC
Lead BK Chapter: 7
Demand: $23000
Nature[s] of Suit: 13 Recovery of money /property - 548 fraudulent transfer
14 Recovery of money /property - other
Plaintiff
Janet Meiburger represented by Janet M. Meiburger
The Meiburger Law Firm, P.C. The Meiburger Law Firm, P.C.
1493 Chain Bridge Road, Suite 201 1493 Chain Bridge Road, Suite 201
McLean, VA 22101 McLean, VA 22101 -5726
703 -556 -7871 703 -556 -7871
Fax : 703 -556 -8609
Email: trustee(&meiburcerlaw.com
JohnPaul M. Callan
The Meiburger Law Firm, P.C.
1493 Chain Briad Road, Suite 201
McLean, VA 22101
703 -556 -8611
Email: JohnPaulC(&meiburgerlaw.com
V.
Defendant
Johan Ponsen represented by Johan Ponsen
4015 Squire Lane PRO SE
Triangle, Va 22172 TW`
Defendant Q GY
Truck Mart LLC represented by Robert M. Marino
26 Truck Tech Way Redmon Peyton & Braswell__, UP
Shippensburg, PA 17257 510 King Street
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Eastern District of Virginia - LIVE Page 2 of 5
Suite 301
Alexandria, VA 22314 -3143
703 - 684 -2000
Fax : 703 - 684 -5109
Email: rmmarino(&rpb- law.com
Filing Date # Docket Text
Adversary case 12- 01184. Complaint against Johan Ponsen,
Truck Mart LLC (Fee Amount of $293 is Deferred) filed by
Janet Meiburger. Nature of Suit: (13 (Recovery of
money /property - 548 fraudulent transfer)), (14 (Recovery of
money /property - other)) Associated Bankruptcy Case Number:
05/04/2012 Gi 1 1:l 1 -bk -17824 ( Meiburger, Janet)
Adversary Proceeding Cover Sheet filed by Janet M. Meiburger
of The Meiburger Law Firm, P.C. on behalf of Janet Meiburger.
05/04/2012 @ 2 ( Meiburger, Janet)
I certify that I am trustee /debtor -in- possession in this case and
have filed 1:12 -ap -1184, as trustee; that the estate is without
funds for payment of the required fee in the amount of $293.00
and the money on deposit in the debtor's estate is presently less
than the fee for this Complaint; and, this deferral was not
initiated by a creditor I hereby defer payment of this filing fee
until the conclusion of the case and the determination that there
is any estate realized. A deferred fee (liability) shall be
disclosed in the final report (Re: related document(s)1
Complaint filed by Janet Meiburger) filed by Janet M.
Meiburger of The Meiburger Law Firm, P.C. on behalf of Janet
05/04/2012 03 Meiburger. ( Meiburger, Janet)
Summons and Notice of Pre -Trial Conference. Summons Issued
to Johan Ponsen Answer Due 6/4/2012; Truck Mart LLC
Answer Due 6/4/2012 (Re: related document(s) l Complaint
filed by Janet Meiburger) Pre -Trial Conference set for
9/10/2012 at 09:30 AM at Judge Kenney's Courtroom, 200
South Washington Street, 2nd Floor, Courtroom I1, Alexandria,
05/04/2012 04 VA, (Voehl, Elizabeth)
05/04/2012 45 Initial Scheduling Order (Voehl, Elizabeth)
Certificate of Service for Summons and Related Documents
(Re: related document(s)4 Summons and Notice of Pre -Trial
Conference) filed by Janet M. Meiburger of The Meiburger
Law Firm, P.C. on behalf of Janet Meiburger. ( Meiburger,
05/09/2012 46 Janet)
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Eastern District of Virginia - LIVE Page 3 of 5
Answer to Complaint (Related Doc #j) filed by Robert M.
Marino of Redmon Peyton & Braswell, LLP on behalf of Truck
Mart LLC. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Marino,
06/22/2012 07 Robert)
Motion for Default Judgment Against Johan Ponsen filed by
Janet M. Meiburger of The Meiburger Law Firm, P.C. on behalf
08/07/2012 08 of Janet Meiburger. ( Meiburger, Janet)
Notice of Hearing on Motion for Default Judgment Against
Johan Ponsen (Re: related document(s)8 Motion for Default
Judgment filed by Janet Meiburger) filed by Janet M.
Meiburger of The Meiburger Law Firm, P.C. on behalf of Janet
Meiburger. Hearing scheduled 8/28/2012 at 09:30 AM at Judge
Kenney's Courtroom, 200 South Washington Street, 2nd Floor,
08/07/2012 49 Courtroom I, Alexandria, VA. ( Meiburger, Janet)
Hearing continued; (related document(s): 8 Motion for Default
Judgment) Appearance : Janet M. Meiburger Hearing to be held
08/28/2012 010 on 09/25/2012 at 09:30 AM (Al2)
Plaintiff s Motion for Summary Judgment Against Truck Mart
LLC and Memorandum In Support Thereof filed by Janet M.
Meiburger of The Meiburger Law Firm, P.C. on behalf of Janet
Meiburger. (Attachments: # 1 Exhibit(s) Exhibits A -C)
09/07/2012 011 ( Meiburger, Janet)
Notice of Hearing on Plaintiffs Motion for Summary Judgment
Against Truck Mart LLC and Memorandum in Support Thereof
(Re: related document(s)11 Motion for Summary Judgment
filed by Janet Meiburger) filed by Janet M. Meiburger of The
Meiburger Law Firm, P.C. on behalf of Janet Meiburger.
Hearing scheduled 9/25/2012 at 09:30 AM at Judge Kenney's
Courtroom, 200 South Washington Street, 2nd Floor,
09/07/2012 012 Courtroom I, Alexandria, VA. ( Meiburger, Janet)
Pre -Trial Conference Continued; (related document(s): 1
Complaint) Appearances : Robert M. Marino, Janet M.
Meiburger Pre -Trial Conference set for 10/15/2012 at 09:30
AM at Judge Kenney's Courtroom, 200 South Washington
09/10/2012 013 Street, 2nd Floor, Courtroom 1, Alexandria, VA (lawsont)
Hearing continued; (related document(s): 8 Motion for Default
Judgment) Appearance : Janet M. Meiburger Hearing to be held
09/25/2012 014 on 11/06/2012 at 09:30 AM (lawsont)
Hearing held; motion granted; Order to be submitted (related
document(s): 11 Motion for Summary Judgment) Appearance
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Eastern District of Virginia - LIVE Page 4 of 5
09/25/2012 @ 15 Janet M. Meiburger (lawsont)
Pre -Trial Conference Continued; (related document(s): 1
Complaint) Appearance : Janet M. Meiburger Pre -Trial
Conference set for 11/05/2012 at 09:30 AM at Judge Kenney's
Courtroom, 200 South Washington Street, 2nd Floor,
10/15/2012 416 Courtroom I, Alexandria, VA (lawsont)
Pre -Trial Conference Continued; (related document(s): 1
Complaint) Pre -Trial Conference set for 12/10/2012 at 09:30
AM at Judge Kenney's Courtroom, 200 South Washington
11/05/2012 417 Street, 2nd Floor, Courtroom I, Alexandria, VA (lawsont)
Hearing continued; (related document(s): 8 Motion for Default
Judgment) Appearance: Janet M. Meiburger Hearing scheduled
for 11/27/2012 at 09:30 AM at Judge Kenney's Courtroom, 200
South Washington Street, 2nd Floor, Courtroom I, Alexandria,
11/06/2012 418 VA. (chandlerkj)
Order Granting Plaintiffs Motion for Summary Judgment
11/06/2012 419 Against Truck Mart LLC (Related Doc # 1 J1 (Voehl, Elizabeth)
BNC certificate of mailing of order (Re: related document(s)19
Order on Motion for Summary Judgment) (Admin.) (Entered:
11/08/2012 420 11/09/2012)
Order Granting Motion for Default Judgment Against Johan
11/26/2012 421 Ponsen(Related Doc # 8) (Voehl, Elizabeth)
Hearing Cancelled Removed/ Consent Order submitted (related
11/27/2012 422 document(s): 8 Motion for Default Judgment) (lawsont)
BNC certificate of mailing of order (Re: related document(s)21
Order on Motion for Default Judgment) (Admin.) (Entered:
11/28/2012 023 11/29/2012)
Pre -Trial Conference Cancelled - Removed/ Order entered
12/10/2012 424 (related document(s): 1 Complaint) (lawsont)
12/19/2012 4 25 Adversary Proceeding Closed (Voehl, Elizabeth)
Statement Satisfaction of Default Judgment Against Johan
Ponsen (Re: related document(s)21 Order on Motion for
Default Judgment) filed by JohnPaul M. Callan of The
Meiburger Law Firm, P.C. on behalf of Janet Meiburger.
03/18/2013 4 26 (Callan, JohnPaul)
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Eastern District of Virginia - LIVE Page 5 of 5
Judgment Satisfied (Re: related document(s)21 Order on
Motion for Default Judgment) filed by JohnPaul M. Callan of
The Meiburger Law Firm, P.C. on behalf of Janet Meiburger.
03/18/2013 1327 (Callan, JohnPaul)
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VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. §4904 relating to unworn
falsification to authorities, that the undersigned is the attorney for the Judgment Creditors, H &J Auto
Transport, LLC and Janet M. Meiburger, Trustee; that the last known address of the Judgment Creditors is
c/o Bernstein - Burkley, P.C., Suite 2200 Gulf Tower, Pittsburgh, Pennsylvania 15219; and that the last
known address of the Judgment Debtor, Truck Mart, LLC is, 26 Truck Tech Way, Shippensburg, PA 17257;
that the Foreign Judgment is valid, enforceable and unsatisfied, and that the facts set forth in the foregoing
Praecipe are true and correct to the best of the undersigned's knowledge information and belief.
- 4t4 P 4 1
Raymond P. Wendolowski, Jr., Esqui
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC,
Debtor. Civil Action No.
JANET M. MEIBURGER, Trustee,
Plaintiff,
VS.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants.
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following Order or
Judgment was entered against you on
(xx) Assumpsit Judgment in the amount
of $18,000.00, plus costs.
() Trespass Judgment in the amount
of $ plus costs.
() If not satisfied within sixty (60) days, your
motor vehicle operator's license and/or
registration will be suspended by the
Department of Transportation, Bureau of
Truck Mart, LLC Traffic Safety, Harrisburg, PA.
76 Truck Tech Way (xx) Entry of Judgment of
Shippenburg, PA 17257 (xx) Court Order
( ) Non -Pros
( ) Confession
( ) Default
() Verdict
( ) Arbitration Award
Prothonotary
By:
PROTHONOTARY (OR DEPUTY)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H &J AUTO TRANSPORT, LLC,
Debtor. Civil Action No. 15 - Ig55 C ► v ► i Yen*
JANET M. MEIBURGER, Trustee,
Plaintiff, C-)
VS. C.n
r
tom'- fV CID
JOHAN PONSEN and TRUCK MART, LLC, <=. -;,
x' ra D - . r'
Defendants, PRAECIPE FOR WRIT OF
EXECUTION
and
FILED ON BEHALF OF
M &T BANK and SOVEREIGN BANK, Plaintiff
Garnishees. COUNSEL OF RECORD OF THIS
PARTY:
SHAWN P. MCCLURE, ESQUIRE
PA ID #205951
JENNIFER L. TIS, ESQUIRE
PA ID #203751
RAYMOND P. WENDOLOWSKI, JR., ESQUIRE
PA ID #311415
Bernstein - Burkley, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412 - 456 -8100
BERNSTEIN FILE NO. C0077305
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H &J AUTO TRANSPORT, LLC,
Debtor. Civil Action No. 13 —1 q55
JANET M. MEIBURGER, Trustee,
Plaintiff,
vs.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants,
and
M &T BANK and SOVEREIGN BANK,
Garnishees. pI�
To the Prothonotary: PRAECIPE FOR WRIT OF EXECUTION r 1
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of Cumberland County: to
2. against Defendant: Truck Mart, LLC
26 Truck Tech Way, Shippensburg, PA 17257
3. against Garnishee: M &T Bank
28 Walnut Bottom Road, Shippensburg, PA 17257
Sovereign Bank
397 Baltimore Road, Shippensburg, PA 17257
*aq. Pb art
4. JUDGMENT $18,000.00 33.50 @$F
Interest from 11/6/12 to 3/28/13 at 6 %: $ 426.00 P A-"
SUBTOTAL: $18,786.00
Costs (to be added by Prothonotary): $
BERN EIN- EY, P C.
Date: March �, 2013 B
Raymon P. Wendolowski, Jr., Esquire
PAID #311415
Attorney for Plaintiff
Suite 2200 Gulf Tower 50 LL
Pittsburgh, PA 15219 C 71o1q/�!
BERNSTEIN FILE NO. C0077305
R! a8q 15(v
WRIT OF EXECUTION and /or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 13 -1955 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION – LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due J &J AUTO TRANSPORT, LLC; JANET M.
MEIBURGER, Trustee, Plaintiff (s)
From JOHAN PONSEN, 4015 Squire Lane, Triangle, VA 22172
TRUCK MART LLC, 26 Truck Teck Way, Shippensburg, PA 17257
(1) You are directed to levy upon the property of the defendant (s)and to sell all personal property of
Defendant Truck Mart LLC
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of GARNISHEES) as follows:
M &T BANK, 28 Walnut Bottom Road, Shippensburg, PA 17257
SOVEREIGN BANK, 397 Baltimore Road, Shippensburg, PA 17257
Any and all accounts
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 $18,000.00 Plaintiff Paid $
Interest from 11/6/12 to 3/28/13 @ 6% -- $426.00
Attorney's Comm. % Law Library $.50
Attorney Paid $62.50 Due Prothonotary $2.25
Other Costs $
Date: 4 /12 /13 j i p ` �
David D. Buell, Prothonotary
--lay —04 &'0% 0
JAE
Deputy
REQUESTING PARTY:
Name: RAYMOND P. WENDOLOWSKI, ESQUIRE
Address: BERNSTEIN- BURKLEY, P.C. / FIRM #718
SUITE 2200 GULF TOWER
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412- 456 -8100
Supreme Court ID No. 311415
Y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC, 2 a�
Debtor. Civil Action No. 2 O J
5.
JANET M. MEIBURGER, Trustee,
Plaintiff,
rnco --v
vs. ,,r- ry 7
JOHAN PONSEN and TRUCK MART, LLC, 5-1
=C) ca
Defendants. PRAECIPE FOR WRIT OF n _ "
EXECUTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF THIS
PARTY:
SHAWN P. MCCLURE, ESQUIRE
PA ID #205951
JENNIFER L. TIS, ESQUIRE
PA ID #203751
RAYMOND P. WENDOLOWSKI, JR., ESQUIRE
PA ID #311415
Bernstein-Burkley, P.C.
Firm#718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
S BERNSTEIN FILE NO. C0077305
:56` Q
so C,6F
r)(2 . P1/1 11 L t
oo - 2.a
F--TFq W4
• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC,
Debtor. Civil Action No.
JANET M.MEIBURGER, Trustee, Z / 3 ~0 t -c'—
Plaintiff,
VS.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants.
To the Prothonotary: PRAECIPE FOR WRIT OF EXECUTION
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of Franklin County:
2. against Defendant: Truck Mart, LLC
26 Truck Tech Way, Shippensburg,PA 17257 and Q.L 1 Q.SS�s 15
3. against Garnishee:
4. JUDGMENT $18,000.00
Interest from 11/6/12 to 4/17/13 at 6%: $ 486.00
$ ';Py a
SUBTOTAL: $18,846.00
Costs(to be added by Prothonotary): $
BERN TEIN- UIWLEY, P.
Date: April , 2013 Q ,
By:
Raymon P. Wendolowski,Jr.,Esquire
PA ID#311415
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh,PA 15219
BERNSTEIN FILE NO. C0077305
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 13-1955 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF FRANKLIN COUNTY:
To satisfy the debt, interest and costs due H&J AUTO TRANSPORT,LLC,JANET M.
MEIBURGER,TRUSTEE Plaintiff(s)
From JOHAN PONSEN AND TRUCK MART,LLC
(1) You are directed to levy upon the property of the defendant(s)and to sell TRUCK MART,LLC,26
TRUCK TECH WAY,SHIPPENSBURG,PA 17257
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEE(S)as follows:
and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s) and from delivering any property of the
defendant(s)or otherwise disposing thereof,
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due$18,000.00 Plaintiff Paid$
Interest FROM 11/6/12 TO 4/17/13 AT 6%-$486.00
Attorney's Comm. % Law Library$
Attorney Paid$91.00 Due Prothonotary$2.25
Other Costs$
Date: 4/2 /20413
David D.Buell,Prothonotary
(,°s�,i3
Deputy
REQUESTING PARTY:
Name : RAYMOND P.WENDOLOWSKI,JR.,ESQUIRE
Address: BERNSTEIN-BURKLEY,P.C.
SUITE 2200 GULF TOWER
PITTSBURGH,PA 15219
Attorney for: PLAINTIFF
Telephone: 412-456-8100
Supreme Court ID No.311415
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION 1
H&J AUTO TRANSPORT LLC, - -}' :7---n
Debtor. Civil Action No. 13-1955 c� --4 Cn
--0
JANET M. MEIBURGER, Trustee, y>
:z C) am
Plaintiff,
vs.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants, PRAECIPE TO SETTLE,DISCONTINUE
AND END AS TO GARNISHEE,
and SOVEREIGN BANK ONLY
M&T BANK and SOVEREIGN BANK,
FILED ON BEHALF OF
Garnishees. Plaintiff
COUNSEL OF RECORD OF THIS
PARTY:
SHAWN P. MCCLURE,ESQUIRE
PA ID#205951
JENNIFER L. TIS, ESQUIRE
PA ID#203751
RAYMOND P. WENDOLOWSKI,JR.,ESQUIRE
PA ID#311415
Bernstein-Burkley, P.C.
Firm#718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
BERNSTEIN FILE NO. C0077305
kk4ol'Spd a
596593 .doc
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC,
Debtor. Civil Action No. 13-1955
JANET M. MEIBURGER,Trustee,
Plaintiff,
vs.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants,
and
M&T BANK and SOVEREIGN BANK,
Garnishees.
PRAECIPE TO SETTLE,DISCONTINUE AND END
AS TO GARNISHEE,SOVEREIGN BANK ONLY
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
SIR:
Settle,Discontinue and End the above-captioned matter upon the records of the Court and mark the
costs paid as to Garnishee, Sovereign Bank, only.
BERNSTEIN-BURKLEY, P.C.
By: P_
Raymo d P. Wendolowski, Jr.,Esqui e
PA ID#311415
Attorney for Plaintiff
Commonwealth of Pennsylvania Suite 2200 Gulf Tower
County of Allegheny Pittsburgh,PA 15219
(412) 456-8100
Sworn to and s ibed
before me this day
ay, 2013 AAA
r ✓
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Wndi Tuoci,Notify Public
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596593 .doc
Sovereign 4o-Santander
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Court..Ordered Processing - MA1-MB3-02-10 - P.O.Box 841005 - Boston,MA 02284
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APR,3 0 2013
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�F RAYMOND P WENDOLOWSKI, ESQ.
BERNSTEIN-BURKLEY P.C.
STE. 2200 GULF TOWER
PITTSBURGH, PAS 15219
RE: H&J AUT G T RANSP., LLC & JANE-1 10 MEIBURGER
vs.
JOH ,N,PgNS�EN & TRUCK MART, LLC
No.: 13-1955
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Dear RAYMOND P WENDOLOWSKI, ESQ.:
On April 24, 2013, Sovereign Bank was served with a PA WRIT OF EXECUTION
narnhig jo'HAN P ONSEN , T�� 'e.�u: s BART, LL , i(sy in an adtoo bi�,u�
by H&J AUTO TRANSP., LLC & JANET M MEIBURGER which requires that the bank
a
hold funds pending resolution of the action.
Please be advised that Sovereign Bank has No Account(s) in the name(s) of the
defendant(s). I therefore assume that you will be dissolving the attachment and
forwarding to me a time-stamped copy of the Praecipe accomplishing the same. If that
is not the case, please let me know immediately.
d
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ery truly yours,
a
a
ie Lewis
C.O.P. Process Specialist
Phone: 617-514-5189
Fax: 617-533-1188
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT,LLC,
Debtor. Civil Action No. 13-1955
JANET M. MEIBURGER, Trustee,
Plaintiff,
vs.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants,
and
M&T BANK and SOVEREIGN BANK,
Garnishees.
CERTIFICATE OF SERVICE
I,Raymond P. Wendolowski,Jr.,Esquire,hereby certify that a true and correct copy of the
foregoing PRAECIPE TO SETTLE,DISCONTINUE AND END AS TO GARNISHEE, SOVEREIGN
BANK ONLY was served on the Defendants and Garnishees by regular U. S. Mail, postage prepaid, this
day of May, 2013, addressed as follows:
Truck Mart, LLC
26 Truck Tech Way
Shippensburg, PA 17257
M&T Bank
28 Walnut Bottom Road
Shippensburg, PA 17257
Sovereign Bank
397 Baltimore Road
Shippensburg, PA 17257
1
Raymond P. Wendolowski, Jr., Esquire
596593 .doc
S
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC,
Debtor.
Civil Action No.
--t
JANET M. MEIBURGER, Trustee, '
n,
Plaintiff, -.e> CD CD
r —t ;
vs. a V.
-C--)-� 1.
JOHAN PONSEN and TRUCK MART, LLC, cn
Defendants, INTERROGATORIES IN
and
ATTACHMENT
M&T BANK and SOVEREIGN BANK, FILED ON BEHALF OF
Plaintiff
Garnishees. COUNSEL OF RECORD OF
THIS PARTY:
SHAWN P. MCCLURE, ESQUIRE
PA ID #205951
JENNIFER L. TIS, ESQUIRE
PA ID #203751
RAYMOND P. WENDOLOWSKI, JR., ESQUIRE
PA ID #311415
BERNSTEIN-BURKLEY, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
BERNSTEIN FILE NO. C0077305
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC,
Debtor. Civil Action No.
JANET M. MEIBURGER, Trustee,
Plaintiff,
VS.
JOHAN PONSEN and TRUCK MART, LLC,
26 Truck Tech Way
Shippensburg, PA 17257
Defendants.
TO: M&T Bank
28 Walnut Bottom Road
Shippensburg, PA 17257
IMPORTANT NOTICES TO GARNISHEE!
A. You are required to file answers to the following interrogatories within twenty(20) days
after service upon you. Failure to do so may result in judgment against you:
B. Herein, the word"defendant"means any one or more of the defendants against whom the
Writ of Execution is issued.
C. While service of Writ upon the Garnishee attached all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attached all property of the defendant which
comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For
example,the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's
account, either at the time of service of the Writ or at the time of Judgment against the Garnishee,but
rather by the amounts deposited and withdrawn during the intervening period.
D. If any Defendant above named is an individual, and if Social Security funds are directly
deposited into an account of the Defendant, the levy and attachment shall not include any funds that may
be traced to Social Security direct deposits.
,E. In your answers to these Interrogatories in Attachment, please state whether the account
includes Social Security direct deposits or that you have identified the duns in the account as being from
sources other than Social Security direct deposits.
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 rqason?
2. At the time you were served or at any subsequent time was there in your possession,
custody, or control or in the joint possession, custody or control of you f and we or more other persons
NS 4f -
any property of any nature owned solely or in part by the defendant? 44o 44
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40,
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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?
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?
S. 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 therefore?
6. At any time after you were served did you pay,transfer or deliver any money or property
to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any
claim of the defendant against you?
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 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. OU
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 in an
account in which the fund son deposit, not including any otherwise exempt funds, did not exceed the
amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, edify each account.
-114004'
4, 4*
Ok 4��� .
BERNSTEIN-BURKLEY, P.C.
By:
UV �
RaymAd P. Wendolowski, Jr., Esquiri
PA ID#311415
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh,PA 15219
(412) 456-8100
BERNSTEIN FILE NO. C0077305
L
f
VERIFICATION
The undersigned does hereby verify under penalty of perjury, that he/she is the legal representative
M&T BANK
of LEGAL DOCUMENT PROCESSING
, Garnishee herein, that he/she is duly authorized to
BUFFALO, NY 14240
make this Verification and that the facts set forth in the foregoing INTERROGATORIES are true and
correct to the best of his/her knowledge, information and belief.
Alleii�����ers
MAY 14 2013
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC, ,
Debtor. Civil Action No. 13-1955
JANET M. MEIBURGER, Trustee,
-< co ca
Plaintiff,
=o
vs. X-
JOHAN PONSEN and TRUCK MART, LLC,
Defendants, PRAECIPE TO SETTLE,DISCONTINUE
AND END AS TO GARNISHEE,
and M&T BANK ONLY
M&T BANK and SOVEREIGN BANK,
FILED ON BEHALF OF
Garnishees. Plaintiff
COUNSEL OF RECORD OF THIS
PARTY:
SHAWN P. MCCLURE, ESQUIRE
PA ID#205951
JENNIFER L. TIS, ESQUIRE
PA ID#203751
RAYMOND P. WENDOLOWSKI, JR., ESQUIRE
PA ID #311415
Bernstein-Burkley, P.C.
Firm#718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
BERNSTEIN FILE NO. C0077305
a'a ar9. s4npc/ GT
6 0 212 0.d o c C" q?qe�
,� aalbc�S
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC,
Debtor. Civil Action No. 13-1955
JANET M. MEIBURGER, Trustee,
Plaintiff,
VS.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants,
and
M&T BANK and SOVEREIGN BANK,
Garnishees.
PRAECIPE TO SETTLE,DISCONTINUE AND END
AS TO GARNISHEE,M&T BANK ONLY
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
SIR:
Settle, Discontinue and End the above-captioned matter upon the records of the Court and mark the
costs paid as to Garnishee, M&T Bank, only.
BERNSTEIN-BURKLEY,P.C.
By: w
Raymond P. Wendolowski, Jr., Es wire
PA ID #311415
Attorney for Plaintiff
Commonwealth of Pennsylvania Suite 2200 Gulf Tower
County of Allegheny Pittsburgh, PA 15219
(412) 456-8100
Sworn to and subscribed
before me this f day
May, 2013
M� &�
ota Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Wand)Tucei,Notary Public
City of R*"h,AkghwW CounW
6 0 21 ' P1 CofiinU!l M Dec 2s,2014
8. ON OF WrARTES
05-17-"13 15:13 FROM- T-095 P0003/0007 F-967
IN THE COURT OF COMMC}N FLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
14&1 AUTO TRANSPORT,LLC,
Debtor. Civil Action No.
JANET M. ME19UR.GER,Trustee,
Plaintiff,
vs
JOjjAN PONSEN and TRUCY,MARS', LLC,
Defendants, INTERROGATORIES IN
ATTACHMENT
and FILED ON BEHALF OF
M&T BANK and SOVEREIGN BANX, Plaintiff
Gar$ishees. COUNSEL OF RECORD OF
THIS PARTY:
SHAWN P•MCCLURE,ESQUIRE
PA.ID#205951
JENNIFER.L.TTS,ESQUIRE
PA ID #203751
RAYMOND P.WENDOLOWSKT,JR.,ESQUIRE
PA ID#311415
BERNSTEIN-BURKLEY,]?.C-
Firm#718
Suite 2200 Gulf Tower
Pittsburgh,PA 15219
412- 456-8100
'BERNSTEIN BILE NO. C0077305
05-17--'13 15:18 FROM-
T-095 P0004/0007 F-967
H&J AU TO TRANSPORT,LLC,
Debtor, Civil Action No.
JANET M.MEIBUPLGER,Trustee,
plaintiff,
V$.
JOHAN PONSEN and TRUCK MART,LLC,
26 Truck Tech Way
Shippensbur&PA 17257
Defendants.
TO: M&T Bank
28 Walnut Bottom Road
Shippensburg,PA 17257
MQEXANT NQT_ICFS TO_GARNISRE-91
A. You are required to file answers to the following interrogatories within twenty(20) days
after service upon you.Failure to do so may result in judgment against you;
B. Herein,the word"defendant"mews any one or more of the defendants against whom the
Writ of Execution is issued.
C. While service ofWrit upon the Garnishee attached all property of the Defendant subject to
attachment which is then in the hands of the garnishee,it also attached all property of the defendant which
comes into the Garnishee's possession_thereafter,until Judgment is entered against the Garnishee. For
example,the resultant liability of a Gamishee-Bank would not be measured by the balance in the debtor's
account,either at the time of service of the Writ or at the time of Judgment against the Garnishee,but
rather by the amounts deposited and withdrawn during the intervening period,
D. If any Defendant above named is an individual,and if Social Security f=ds are directly
deposited into an account of the Defendant,the levy and attachment shall not include any funds that may
be traced to Social Security direct deposits.
E. in your answers,to these Interrogatories in Attachment,please state whether the account
includes Social Security direct deposits or that you have identified the duns in the account as being frorn
sources other than Social Security direct deposits.
05-17-'13 15:18 FROM- T-095
T�bney or were you liable to the clelenciant on uay ucrvuaviv�L'* ....... P6 M/0007 F-967
defendant claim that you owed the defendant any money or were liable to the defendant for any r ason?
2. At the time you were served or at any subsequent tune was there in your possession,
custody,or control or in the joint possession,custody or control of yours
,gf and We or more other persons
any property of any nature owned solely or in part by the defendant?
'
4pn"' Aok
3. At the titoo 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?.
0k.�
4, At the time you were served or at any subsequent time did you hold as fidnciary any
property in which the defendant had an interest?
S. At any time before or after you were served did the defendant transf r 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?
,6. At any time after you were served did you pay,transfer or deliver any money or property
to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any
claim of the defendant against you?
Vy
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 on deposit in an account in which fancis 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 tinder each exemption and the entity
electronically depositing those funds on a recurring basis.
05-17-'13 15:18 FROM- T-005 P0006/0007 F-967
subsequent time did the defendant have ftmds on deposit in an account in which the funds on deposit in an
account in which the fund son deposit,not including any otherwise exempt funds,did not exceed the
amount of the general monetary exemption under 42 Pa>C.S= § 8X23?If so,idqfy each account.
eq
BERNSTEIN-BURKLEY,P.C.
By:
Raymond P. W mtdolowski, Yr.,Esquir
PAM#3114 15
Attorney for Plairitiff
Suite 2200 Gulf Tower
Pittsburgh,PA 15219
(412)456-8100
BERNSTEIN FILE NO.C0077305
05-17-'13 15:19 F ROM- T-095 P0007/0007 F-967
LIERMLCATION
The undersigned does hereby verify'under penalty of perjury,that he/she is the legal representative
M&TBANK
of LEGAL DOCUMENT PROCESSING
Garnishee herein,that he/she is duly authorized to
BUFFALO, NY 14240
make this Verification and that the facts set in the foregoing INTERROGATORIES are true and
correct to the best of his/her knowledge, information and belief.
Melsa is M-Peters
M-&-[, dank
MAY 1.4 2013
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT,LLC,
Debtor. Civil Action No. 13-1955
JANET M.MEIBURGER,Trustee,
Plaintiff,
vs.
JOHAN PONSEN and TRUCK MART,LLC,
Defendants,
and
M&T BANK and SOVEREIGN BANK,
Garnishees.
CERTIFICATE OF SERVICE
I,Raymond P.Wendolowski,Jr.,Esquire,hereby certify that a true and correct copy of the foregoing
PRAECIPE TO SETTLE,DISCONTINUE AND END AS TO GARNISHEE,M&T BANK ONLY was served on
the Defendants and Garnishees by regular U. S.Mail,postage prepaid,this 4 day of May,2013,addressed as
follows:
Truck Mart,LLC
26 Truck Tech Way
Shippensburg,PA 17257
M&T Bank
28 Walnut Bottom Road
Shippensburg,PA 17257
M&T Bank
c/o Legal Document Processing
P.O.Box 844
Buffalo,NY 14240
Sovereign Bank
397 Baltimore Road
Shippensburg,PA 17257
�
Raymond P.Wendolowski, Jr.,Esquire
602120.doc
SHERIFF'S OFFICE OF C"MBERLAND COUNTY
Ronny RAnderson �,a 1-14E P�-Thon
Sheriff
of C:iron�, r/;ny er(
I.G�J �� '
Jody S Smith
Chief Deputy * - M 1 ,
Richard W Stewart CUMBERLAND COUNTY
Solicitor OFF IGE OFTPE SHERIFF PENNSYLVANIA
H&J Auto Transport, LLC (et al.)
Case Number
vs.
Johan Ponsen (et al.) 2013-1955
SHERIFF'S RETURN OF SERVICE
04/24/2013 09:00 AM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April
24, 2013 at 0855 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendants, to wit: Johan Ponsen and Truck Mart LLC, in the hands,
possession, or control of the within named garnishee, M &T Bank, 1 W High Street, Carlisle,
Cumberland County, Pennsylvania, by handing to Joan Crowl,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.
04/24/2013 09:05 AM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April
24, 2013 at 0902 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendants, to wit: Johan Ponsen and Truck Mart LLC, in the hands,
possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle,
Cumberland County, Pennsylvania, by handing to Denise Beecher, 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 April 26, 2013 to John Ponsen, 4015 Squire
Lane, Triangle, VA 22172 and to Truck Mart, LLC, 76 Truck Tech Way, Shippensburg, PA 17257.
08/29/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states this writ of execution is
returned as STAYED at request of plaintiffs attorney.
SHERIFF COST: $156.39 SO ANSWERS,
August 29, 2013 RONNY R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Teleosoft,Inc.
SHERIFF' S RETURN - REGULAR
CASE NO: 2013-01814 P
COMMONWEALTH OF PENNSYLVANIA: c
COUNTY OF FRANKLIN .a3 w
rnC0 3210
� r-i
H&J AUTO TRANSPORT LLC ET AL -arl cD
-< CD ,
VS ro
JOHAN PONSEN ET AL D� `r
.Ire
����.z,....yy 3
JONATHAN NALEWAK Deputy Sheriff of FRANKLIN
County, Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF EXECUTION was served upon
TRUCK MART LLC _ _. the. _ _
DEFENDANT at 1120 : 00 Hour, on the 9th day of May 2013
at 26 TRUCK TECH WAY
SHIPPENSBURG, PA 17257 by handing to
AUDRY BAUMGARDNER
a true and attested copy of WRIT OF EXECUTION together with
and at the same time directing Her attention to the contents thereof .
Sheriff ' s Costs : So Answers :
Docketing . 00
Service . 00 JONATHAN NALEWAK
Affidavit . 00
Surcharge . 00 By
. 00 puty Sheriff
. 00 08/20/2013
BERNSTEIN-BURKLEY PC
-.Sworn and Subscribed to before
me this � p`' t_, day of COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
ao ta A.D. RICHARD D. McCARTY, Notary Publk
1_ Chambsrsburg Boro., Franklin County
My Commission Expires Jan. 29, 2015.
Notary/
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIAN::
CIVIL DIVISION `
M G
H&J AUTO TRANSPORT, LLC, =-n - t
Debtor. Civil Action No -
75 n r
JANET M. MEIBURGER,Trustee,
Plaintiff,
VS.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants. PRAECIPE FOR SATISFACTION OF
JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF THIS-,.
PARTY:
SHAWN P. MCCLURE, ESQUIRE
PA ID #205951
JENNIFER L. TIS, ESQUIRE
PA ID#203751
RAYMOND P. WENDOLOWSKI,JR.,ESQUIRE
PA ID#311415
Bernstein-Burkley, P.C.
Firm#718
Suite 2200 Gulf Tower
Pittsburgh,PA 15219
412-456-8100
BERNSTEIN FILE NO. C0077305
a�
k
C1
-�a�q
S14
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC,
Debtor. Civil Action No. .
JANET M. MEIBURGER,Trustee,
Plaintiff,
VS.
JOHAN PONSEN and TRUCK MART, LLC,
Defendants.
PRAECIPE FOR SATISFACTION OF JUDGMENT
At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the
above-captioned Judgment.
BERNSTEIN-BURKLEY, P.C.
By:
W
Raymond . Wendolowski, Jr., Esquire
PA ID #311415
Attorneys for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
Commonwealth of Pennsylvania (412)456-8100
County of Allegheny BERNSTEIN FILE NO: C0077305
Sworn to and su C ed
before me
of August, 201
Nota &yWj*_OF PENNSYLVANIA
NotaAai Seal
:Bran�dl Tuaal,Notary Public
GYf mbu h,AN�heny County my m 261 2014
MEMBER, DES
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
H&J AUTO TRANSPORT, LLC,
Debtor. Civil Action No. -
JANET M. MEIBURGER,Trustee,
Plaintiff,
VS.
JOHAN PONSEN and'TRUCK MART, LLC, -
Defendants.
CERTIFICATE OF SERVICE
1, Raymond P.Wendolowski,Jr., Esquire, hereby certify that a true and correct copy of the
foregoing PRAECIPE FOR SAQT�ISFACTION OF JUDGMENT was served on the Defendants by regular U.
S. Mail,postage prepaid, this v day of August, 2013, addressed as follows:
Truck Mart, LLC
26 Truck Tech Way
Shippensburg, PA 17257
i
I
Raymond P. Wendolowski,Jr., Esquire
I