Loading...
HomeMy WebLinkAbout04-5925COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC 11? Plaintiff No. VS. JOHN E. FAIR : CIVIL ACTION Defendant NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013 (717) 249-3166 AMATO AND MARGLE, P.C. By: Ronald Amato, Atty ID #32323 Michael Kennedy, Atty ID #72412 Michael Lessa, Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff vs. JOHN E. FAIR Defendant(s) No. CIVIL ACTION COMPLAINT The above Plaintiff brings this action against the above Defendant to recover the sum of $27,200.76, with interest thereon as hereinafter stated, upon the following cause of action: 1. The Plaintiff, HUDSON & KEYSE, LLC is located at 382 Blackbrook Road, PAINESVILLE OH 44077. 2. The Defendant, JOHN E. FAIR is located at 7 Appalachian Trail Road, GARDNERS PA 17324. 3. At the special instance and request of the Defendant, Household Finance Corporation, issued credit to Defendant a true and correct copy of Defendant's Statement of Account is attached hereto, made a part hereof and marked Exhibit "A". 4. For value received, Household Finance Corporation assigned, transferred and set over to Plaintiff all its rights, title and interest in this claim. 5. By virtue of said assignment, Plaintiff acquired legal title to said Account, and became the legal holder of the claim against the Defendant. 6. Defendant has not adhered to the agreed repayment obligations that govern the aforesaid account, by reason of which Defendant is in default thereof. 7. The total amount which became due as a result thereof, after allowance for all proper credits for payments and/or adjustments, if any, was $18,311.71. 8. Plaintiff is entitled to receive interest on the above amount determined by applying the agreed interest rate of 14.99 % per annum to the past due balance. As of November 11, 2004 the total amount of interest due to plaintiff is $8,889.05. 9. Plaintiff is entitled to have the 14.99% interest charge continue to accrue as set forth above, from November 11, 2004 on down to the date of judgment in this matter. 10. The Plaintiff has made demand against the Defendant for the aforesaid sum, but Defendant failed or refused to pay the same or any part thereof. WHEREFORE, Plaintiff demands judgment against the Defendant for $27,200.76 together with the continually accruing interest charge at the agreed rate of 14.99% per annum from November 11, 2004, and cost of suit. COUNT II Alternative to Count I - Unjust Enrichment 11. Plaintiff incorporates the allegations of every paragraph enumerated above of this Complaint as if said paragraphs were fully set forth here at length. 12. The goods, wares, merchandise, and/or services, described in the exhibits attached hereto were purchased by Defendant, and Defendant received and accepted the benefit of such goods, wares, merchandise, and/or services provided by Plaintiff. 13. At all times material hereto, Defendant was aware that Plaintiff was providing the aforesaid goods, wares, merchandise, and/or services to Defendant, and that Plaintiff expected to be paid for such. 14. At all times material hereto, Defendant, with the aforesaid knowledge, permitted Plaintiff to provide and/or deliver said goods, wares, merchandise, and/or services, and to incur damages. 15. At all times material hereto, Defendant was unjustly enriched by retaining the benefit of receiving said goods, wares, merchandise, and/or services without paying Plaintiff fair and reasonable compensation. 16. By reason of the aforesaid unjust enrichment of Defendant at Plaintiff's expense, an implied contract exists between Plaintiff and Defendant, and Defendant is obligated to pay Plaintiff the quantum meruit value of the value of the goods, wares, merchandise, and/or services described in the exhibits attached hereto, in the amount of $18,311.71. WHEREFORE, Plaintiff demands judgment against Defendant for $18,311.71 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from November 11, 2004, costs of suit and all other relief to which Plaintiff may be justly entitled. AMATO AND MARGLE, P.C. By: Ronald Amato, Atty ID #32323 Michael Kennedy, Atty ID #72412 Michael Lessa, Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 VERIFICATION hereby states that he/she is the 4eeeuAi T e4,x.,a43 of ?u? s?N k //V; z G e- , Plaintiff in this action, and verifies that the statements made in the attached Complaint are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 PA C.S. §4804 relating to unsworn falsification to authorities. ,UDSON SE, LL.C. 1.1 IiIE ?I .?? ?I: ??!?1?: `: i? . 11.1i : ?.? . 1 . o In I t..I STATEMENT OF ACCOUNT CREDITOR NAME: Hudson & Keyse, L.L.C. CREDITOR ADDRESS: 382 Blackbrook Road, Painesville, Ohio, 44077 ORIGINAL CREDITOR: HOUSEHOLD FINANCE ORIGINAL ACCOUNT NUMBER: 71171500536334 HUDSON & KEYSE, L.L.C. ACCOUNT NUMBER: 230884*1 DEBTOR NAME: JOHN E. FAIR DEBTOR ADDRESS: 7 APPALACHIAN TRAIL ROAD, GARDNERS, PA, 17324 DATE ACCOUNT OPENED: DEC 18 1995 DATE LAST PAID TO ORIGINAL CREDITOR: 17 AUG 2001 DATE LAST PAID TO HUDSON & KEYSE, L.L.C.: PRINCIPAL BALANCE DUE: $18,311.71 INTEREST BALANCE DUE: $6,963.84 TOTAL BALANCE DUE: $25,275.55 INTEREST RATE: 14.99% LAST DATE INTEREST CHARGED: FEB 29 2004 EXHIBIT LOCAL: (440)354-6978 FAX: (440)354-1336 T HTTP: www.HKLLC.BIz TOLL FREE: 1(800)654-5391 & 1(800)654-1660 EMAIL: COLLECTIONS@HKINC.COM PLEASE SEND CORRESPONDENCE TO: ' 1147.4 1. 1 ? 1 t 1 .-MI l ? ? ? tea C? 1 cn C7 N c=p c n Y, -n s- jq3 -? ID ?Ti w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff : No. 04-5925 Civil vs. JOHN E. FAIR CIVIL ACTION Defendant PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment by default for want of an answer in favor of Plaintiff and against the above-named defendant(s) only and assess damages as follows: Debt $27,200.76 Interest (from November 11, 2004 to January 11, 2005 at 14.99% per annum) 65218 Payments Total $27,853.57 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. Pursuant to RCP 237.1, 1 certify that a copy of the annexed written notice(s) of intention to file this praecipe was mailed or delivered to all parties against whom judgment is to be entered and to their attorney of record, if any, after the default occurred, and at least ten days prior to the date of filing of this praecipe. Please note that said notice was mailed to all parties on December 29, 2004. Dated: 2005 AMATO AND MARGLE, P.C. By: Ronald Amato, Atty ID #32323 Michael Kennedy, Atty ID #72412 Michael Lessa, Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 2041118 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC' Plaintiff . No. 04-5925 Civil VS. JOHN E. FAIR CIVIL ACTION Defendant CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: 382 Blackbrook Road PAINESVILLE OH 44077 I do certify that the precise last known address of the within named defendant is: 7 Appalachian Trail Road GARDNERS PA 17324 AMATO AND MARGLE, P.C. By. Ronald Amato, Atty ID #32323 Michael Kennedy, Atty ID #72412 Michael Lessa, Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff : No. 04-5925 Civil VS. JOHN E. FAIR CIVIL ACTION Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF NORTHAMPTON : The undersigned, being duly sworn, according to law, deposes and says that the Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers and Sailor' Civil Relief Act of Congress of 1940 as amended; That John E. Fair is over 18 years of age, resides at 7 Appalachian Trail Road, GARDNERS PA 17324 and is employed Sworn to and subscribed before me this l-? day of')Z.r 200 A.D. NOTAR UBLIC NOTARIAL SEAL GEOFFREY O SCHOENICK Notary Public HANOVER TOWNSHIP, NORn"PTON CNTY My Commission Expim MW 29, 2008 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff : No. 04-5925 Civil VS. JOHN E. FAIR Defendant(s) TO: John E. Fair 7 Appalachian Trail Road GARDNERS PA 17324 Date of Notice: December 29, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO AND MARGLE, P.C. By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 File # 2041118 (610)866-0400 C d ? G f7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff : No. 04-5925 Civil VS. JOHN E. FAIR Defendant CIVIL ACTION NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s) IN THE AMOUNT OF $27,853.57 ON,J?jZ , 2005. ( I A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTH-O/N-O?TA CUM LAND COUNTY PR 04'x' u - ?/-r - If you have any questions concerning the above, pleasd-contact the undersigned. AMATO AND MARGLE, P.C. By: Ronald Amato, Atty ID #32323 Michael Kennedy, Atty ID #72412 Michael Lessa, Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 SHERIFF'S RETURN - REGULAR CASE NO: 2004-05925 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HUDSON & KEYSE LLC VS FAIR JOHN E DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FAIR JOHN E the DEFENDANT , at 1315:00 HOURS, on the 8th day of December-, 2004 at 7 APPALACHIAN TRAIL ROAD GARDNERS, PA 17324 JOHN FAIR by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.66 Affidavit .00 Surcharge 10.00 .00 34.66 Sworn and Subscribed to before me this day of 't ,fGn ww , Itr? bl A.D. `P othonotary - ,- So Answers: R. Thomas Kline 12/10/2004 AMATO & MARGLE By: Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff . No. 04-5925 Civil VS. JOHN E. FAIR PRAECIPE FOR WRIT EXECUTION (MONEY JUDGMENT) Defendant(s) To the Prothonotary - Cumberland County: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) All cash on hand or in the Possession of the defendant(s) accounts receivables, furniture, furnishings, eguioment, inventory, tools, vehicles, electronic equipment, any and all other personal property belonging to the above- named defendant(s). (2) against JOHN E. FAIR, Defendant(s) (3) and against ........................................Garnishee(s) (4) and index this writ (a) against ..................................Defendant(s) and (b) against .......................................Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows:(Specifically describe the property) (5) Amount Due $ 27,853.57 Statutory Interest From January 20, 2005 $ 873.03 Less Payment $ 0.00 Costs $ Poundage $ Total $ 28,726.60 AMATO AND MARGLE, P.C. By: 2 Date:July 29. 2005 Ronald Amato Attorney I.D. No. 32323 Attorney File#: 2041118 Attorneys for Plaintiff -f- '# n c ? p r o cc c ?D' a VC) °. ? 't7 t G7 1 ' Ll ? - 7 D P C b ? ?? v J V ?s l' N ? l ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. 04-5925 Civil VS. JOHN E. FAIR Defendant(s) CIVIL ACTION CERTIFICATION OF DEFENDANT(s) ADDRESS FOR SERVICE I do certify that the precise last known address of the within named defendant(s) is the address provided below, and request that the Sheriff serve the above named defendant(s) at: 7 Appalachian Trail Road GARDNERS PA 17324 AMATO AND MARGLE, P.C. By: Dated:July 29, 2005 Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Attorney File #:2041118 ? n; t ? CO ? t.J i7 r :t Ln WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5925 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC, Plaintiff (s) From JOHN E. FAIR, 7 APPALACHIAN TRIAL ROAD, GARDNERS, PA 17324 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CASH ON HAND OR IN THE POSSESSION OF THE DEFENDANT(S), ACCOUNTS RECEIVABLES, FURNITURE, FURNISHINGS, EQUIPMENT, INVENTORY, TOOLS, VEHICLES, ELECTRONIC EQUIPMENT, ANY AND ALL OTHER PERSONAL PROPERTY BELONGING TO THE ABOVE- NAMED DEFENDANT(S). (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 $27,853.57 L.L. $.50 Interest STATUTORY INTEREST FROM 1/2 0/05 - $873.03 Atty's Comm % Due Prothy $1.00 Arty Paid $116.66 Other Costs Plaintiff Paid Date: AUGUST 8, 2005 CURTIS R. LONG Prothonotary (Seal) - Bv' A (In P Deputy L, REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND MARGLE, P.C. 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5925 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC, Plaintiff (s) From JOHN E. FAIR, 7 APPALACHIAN TRIAL ROAD, GARDNERS, PA 17324 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CASH ON HAND OR IN THE POSSESSION OF THE DEFENDANT(S), ACCOUNTS RECEIVABLES, FURNITURE, FURNISHINGS, EQUIPMENT, INVENTORY, TOOLS, VEHICLES, ELECTRONIC EQUIPMENT, ANY AND ALL OTHER PERSONAL PROPERTY BELONGING TO THE ABOVE- NAMED DEFENDANT(S). (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 $27,853.57 L. L. $30 Interest STATUTORY INTEREST FROM 1/2 0/05 - $873.03 Atty's Comm % Due Prothy $1.00 Atty Paid $116.66 Other Costs Plaintiff Paid Date: AUGUST 8, 2005 CURTIS R. LONG Prothonotar (Seal) Deputy REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND MARGLE, P.C. 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 homas Kline, Sheriff, who being duly sworn according to law, states this `Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Advance Costs: 150.00 Sheriff's Costs 125.57 Docketing 18.00 24.43 Poundage 2.47 Advertising 20.00 Law Library .50 Prothonotary 1.00 Refunded to Atty on 09/20/06 Mileage 13.60 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale 30.00 Certified Mail Postage Garnishee ;,.TOTAL 125.57 ? i? ?"'w• So s• ?. R. Thomas Kline, Sheriff s _n By (?Q-Ljo - cv t, R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff s Costs: Advance Costs: 150.00 139.10 Docketing 18.00 $ 10.90 Poundage 6.00 Advertising 20.00 Law Library .50 Prothonotary 1.00 Refunded to Atty on 05/23/07 Mileage 23.60 Surcharge 20.00 Levy 20.00 Certified Mail Post Pone Sale 30.00 Garnishee Postage TOTAL $ 139.10 ,/ s 9 ° ? So Ans er R. omas Kline, Sheriff r By Claudia A. Brewbaker v g Z l I d ' A09 9001 i! Ti 193agy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5925 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC., Plaintiff (s) From JOHN E. FAIR, 7 APPALACHIAN TRAIL ROAD, GARDNERS, PA 17324 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CASH ON HAND OR IN THE POSSESSION OF THE DEFENDANT(S), ACCOUNTS RECEIVABLES, FURNITURE, FURNISHINGS, EQUIPMENT, INVENTORY, TOOLS, VEHICLES, ELECTRONIC EQUIPMENT, ANY AND ALL OTHER PERSONAL PROPERTY BELONGING TO THE ABOVE-NAMED DEFENDANT(S). (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 $26,278.57 L.L. $.50 Interest FROM 1/20/05 - $2,791.54 Atty's Comm % Atty Paid $242.23 Plaintiff Paid Due Prothy $1.00 Other Costs Date: OCTOBER 19, 2006 (Seal) REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND ASSOCIATES, P.C. 107 N. COMMERCE WAY, SUITE 100 BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 1 11, ?, IAi A It 14 Now C $s R. Long, on ry By: Deputy COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff VS. JOHN E. FAIR No. 04-5925 Civil Defendant(s) CIVIL ACTION ASSIGNMENT OF JUDGMENT For value received, this a; q day of t ,rn D = , 2008, Hudson & Keyse, LLC, Plaintiff in the above-captioned matter, hereby sells, transfers, sets over and assigns all of its right, title and interest in the judgment, debt, interest and costs in the above-captioned matter to Bluestone Investments, Inc. Mark Finston Chief Financial Officer Hudson & Keyse, LLC Sworn and subscribed to before me this day of St4 eC M V tN- , 2008 lie M. Hostetler Notary Public JULIE M. HOSTETLF..ft i Notary Public, State of Ohio Aa My Commission Expires March 20, 2012 ''E of (Recorded in Cuvahoga County) My Commission Expires: X Zu (Z 2041118 \" N ?` =;