HomeMy WebLinkAbout13-2891 2165015
GORDON & WEINBERG, P.C. `ILE - OFFIC
BY: FREDERIC I. WEINBERG, ESQUIRE 0 F THE PRQTHON TAR'i
Identification No.: 41360 2013 [JAY 21 AM 11: 19
JOEL M. FLINK, ESQUIRE
Identification No.: 41200 CUMBERLAND COUNTY
1001 E. Hector Street, Ste 220 PENNSYLVANIA
Conshohocken, PA 19428
484/351 -0500
Eugene I. Davis, as Litigation COURT OF COMMON PLEAS
Trustee for the Quebecor World CUMBERLAND COUNTY
Litigation Trust
VS. DOCKET N0.
Keystone Logistics Solutions,
Inc.
1550 Harrisburg Pike
Carlisle, PA 17013
ENTRY OF APPEARANCE, ORDER FOR JUDGMENT
AND ASSESSMENT OF DAMAGES
(FOREIGN JUDGMENT PROCEEDINGS)
TO THE PROTHONOTARY:
Kindly enter my appearance for the plaintiff in the above matter,
enter judgment in favor of the plaintiff and against the Defendant(s),
on the foreign judgment entered in the United States Bankruptcy Court,
Southern District of New York, for monetary damages, a duly
authenticated copy of the judgment being filed herewith, and assess
damages as follows:
Amount of Foreign Judgment $55,765.86
Interest @ 0.17% from 11/20/12:
to 04/25/13 $40.52
Costs $33.50
Attorney Fees
Real Debt $55,839.88
GORDON & WEINBERG, P.C.
BY:
FREDER I W INBERG, ESQUIRE
JOEL FLINK, ESQUIRE
Atto y for Plaintiff
Damages sse d a5) Abov
Pr othonotary � ya
�� agb t d
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 81894
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
48 4/351 -0500
Eugene I. Davis, as Litigation COURT OF COMMON PLEAS
Trustee for the Quebecor World CUMBERLAND COUNTY
Litigation Trust
. J
a ►� ���
VS. DOCKET N0. : 1
Keystone Logistics Solutions,
Inc.
1550 Harrisburg Pike
Carlisle, PA 17013
AFFIDAVIT
JOEL M. FLINK, ESQUIRE, being duly sworn according to law,
deposes and says that he is the Attorney for the Plaintiff in the
above captioned matter; that the defendant Keystone Logistics
Solutions, Inc and the last known address of the defendant is
1550 Harrisburg Pike, Carlisle, PA 17013 and the plaintiff
isEugene I Davis, as Litigation Trustee for the Quebecor World
Litigation Trust, and last known address of the plaintiff is 150
42ns Street, New York, NY, 10034. The foreign judgment is entered
by the plaintiff against the defendant(s) in the United States
Bankruptcy Court, Southern District of New York in the sum of
$55,765.86 no part of which has been paid, is valid, enforceable
and unsatisfied.
GORDON & WEINBERG, P.
BY:
FREDER W INBERG, ESQUIRE
JOEL INK, ESQUIRE
Attor for Plaintiff
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 81894
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484 /351 -0500
Eugene I. Davis, as Litigation COURT OF COMMON PLEAS
Trustee for the Quebecor World CUMBERLAND COUNTY
Litigation Trust
VS. DOCKET NO.
Keystone Logistics Solutions,
Inc.
1550 Harrisburg Pike
Carlisle, PA 17013
TO Keystone Logistics Solutions, Inc
1550 Harrisburg Pike
Carlisle, PA 17013
NOTICE
PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU
ARE HEREBY NOTIFIED THAT A JUDGMENT HAS BEEN ENTERED AGAINST YOU
IN THE ABOVE PROCEEDING.
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL
GORDON & WEINBERG, P.C. AT 484/351 -0500.
B 131
United States Bankruptcy Court
SOUTHERN DISTRICT OF NEW YORK
In re
Quebecor World (USA) Inc.
Bankruptcy Case No.
Debtor
Eugene I. Davis, as Litigation Trustee for 0 8-10152 (JMP)
the Quebecor World Litigation Trust,
Plaintiff
VS.
Adv. No. 10 -02412 (SHL)
Keystone Logistics Solutions, Inc.,
Defendant
EXEMPLIFICATION CERTIFICATE
1, _ yitn Canna , clerk of the bankruptcy court for this district and keeper of the records and seal
of the court certify that documents attached are true copies of
Adversary No. 10 -02412 (SHL) ORDER FOR DEFAULT JUDGMENT dated November 20, 2012.
now remaining among the records of the court. In testimony of this statement, I sign my name, and affix
the seal of this c rI at , in the state of Ynrk
this / /r-r 10/-
[Seal of Court]
Clerk of the Bankruptcy Court
I Scan u L ane . , bankruptcy judge for this district certify that vita Cann
[attestation e date of the above certificate clerk of the bankruptcy court for this district, duly appointeed s o t
d keeper of the records and seal of the court, and that the above certificate of clerk and the clerk's
is in due form of law.
Bate /� G1. / alJi'�i By.
Bankru tc Jud e
I, Vito r*Pnna , clerk of the bankruptcy court for this district and keeper seal of the court certify
that the Honorable Caan J Tana is and was at the date of the above certificate a judge of this court,
duly appointed and sworn; and that I am well acquainted with this handwriting and official signature and
know and certify the signature written above to be that of the judge.
In testimony of this statement, I sign my n e mid affix the seal of the court at N Ynrk in
rte 0, NPR= ynr>t , this _ -� /�/ %3
Clerk of the Bankruptcy Court
•
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
In re
Bk. No. 08- 10152 -JMP
Quebecor World (USA), Inc., et al. Debtors
',
Chapter 11
Debtors.
Sean H. Lane
Eugene I. Davis, Liti Trustee for the
Quebecor World Litigation Trust, Adv No. 10- 02412 -SHL
vs. Plaintiff,
Keystone Logistics Solutions, Inc.,
Defendant.
ORDER FOR DEFAULT JUDGMENT
This action was commenced on or about January 16, 2010 by the filing of a Summons and
Complaint. Copies of the Summons and Complaint in the above - referenced adversary proceeding were
served on the above -named Defendant, Keystone Logistics Solutions, Inc., through service by mail,
pursuant to Federal Rule of Bankruptcy Procedure 7004, on June 9, 2010. The Certificate of Service was
filed with this Court and the Defendant has failed to answer or otherwise defend.
The Clerk's Entry of Default was filed on or about March 8, 2012. Defendant was served with
Plaintiffs Application for Default Judgment and has failed to answer, object or otherwise defend.
NOW THEREFORE, upon reading the annexed Application for Default Judgment sworn on
November 7, 2012, it is
ORDERED, ADJUDGED AND DECREED: that the Plaintiff Eugene I. Davis,
Litigation Trustee for the Quebecor World Litigation Trust, be awarded a default judgment against the
Defendant, Keystone Logistics Solutions, Inc., in the amount of $54,975.00, plus interest of $540.86 and
I The Debtors are the following entities: Quebecor World (USA) Inc., Quebecor Printing Holding company,
Corporation, Quebecor World Capital II GP, Quebecor World Capital II LLC, WCZ, LLC, Quebecor W
Lease LLC, QW Memphis Corp., The Webb Company, ebecor World Loveland Inc.,
Quebecor World Capital
Quebecor World Systems Inc. Quebecor World San Jose Inc.Quebecor W orld Printing (USA) Corp., Quebecor World Buffalo In u world Lease GP, Quebecor World
Q
Quebecor World Northeast Graphics Inc., Quebecor World UP Graphics Inc., Quebecor World Gr Western Publishing Inc., Quebecor
World DB Acquisition ue ecor World Johnson &Hardin Co.,
Corp., >p W Quebec World Retail Printing Corporation,
INC., Quebecor World Taconic Holdings Inc., Quebecor
Quebecor World Arcata Corp., Quebecor World Nevada Inc., Quebecor World Atglen Inc., Quebecor World Krueger Acquisition Corp.,
Quebecor World Book Sery ices LLC, Quebecor World Dubuque Inc., Quebecor World Pendell Inc., Quebecor World Fairfield Inc., QW
New York Corp., Quebecor World Dallas II Inc. Quebecor World Nevada II LLC, Quebecor World Dallas, L.P., Quebecor World Mt.
Morris II LLC, Quebecor World Petty Printing Inc., Quebecor World Hazleton Inc., Qubecor World Dittler Brothers Inc., Quebecor World Atlanta II LLC, Quebecor World RAI lnnc.eQuebecoorrlWO�a KBRran Inc., ueb Wo
C G Corporation, Quebecor World Waukee Inc., Quebecor World Logistics Inc., Quebecor In Press
Corporati Quebecor Printing Aviation Inc., Quebecor World Eusey Press Inc., Quebec World Mid-South World Infiniti Graphics Inc., Quebecor
World Magna Graphic Inc., Quebecor World Lincoln Inc, and Quebecor World Memphis LLC.
QBCKEY004 s�,y(„ Logistics solulio . n,C.. 10 -014 PME -1- ORDER FOR DEFAUL'
MORD024I2.130C /
•
costs in the sum of $250.00, which results in a total judgment of $55,765.86 as of today's date with interest
continuing to accrue at the Federal Rate.
DATED: November 20, 2012
Al Sean H. Lane
UNITED STATES BANKRUPTCY JUDGE
QBCKEYM4 _ Kc. 1-8'sGce Solutirnss. Inc. - 1"2412. RFDE _2 ORDER FOR DEFAuu
MORD02412.DOC /
,New York Southern Live System
Page 1 of 7
PENAP
U.S. Bankruptcy Court
Southern District of New York (Manhattan)
Adversary Proceeding #: 10- 02412 -shl
Assigned to: Judge Sean H. Lane
Lead BK Case: 0808__? Date Filed: 01/16/10
Lead BK Title: Quebecor World (USA) Inc.
Lead BK Chapter.- 11
Demand.- $55000
NatureN ofSuit.• 12 Recovery of money /property - 547 preference
13 Recovery of money /property - 548 fraudulent transfer
14 Recovery of money /property - other
14
14
Plaintiff
Eugene I. Davis, as Litigation Trustee for the represented by Ga D. Un
Quebecor World Litigation Trust 1 "3' derdahl
ASK LLP
2600 Eagan Woods Drive
Suite 400
St. Paul, MN 55121
(651) 406 -9665
1 hereby attest and certify on ` - }.3 Fax: (651) 406 -9676
that this document is a full, true and correct Email: underdahl(�z)askllp com
COPY of the original filed on our court's LEAD ATTORNEY
electronic case filing syste
Clerk US Bankruptcy Coin, SONY Joseph L. Steinfeld, Jr.
B ASK LLP
Deputy Clerk 2600 Eagan Woods Drive
Suite 400
St. Paul, MN 55121
(651) 289 -3850
Fax: (651) 406 -9676
Email: jsteinfeld(0)askllp com
Karen M. Scheibe
A S K Financial, LLP
2600 Eagan Woods Drive
Suite 400
Eagan, MN 55121
(651) 406 -9665
Fax: (651) 406 -9676
Email: kscheibenr askfinancia1.com
ATTORNEY TO BE NOTICED P ,t�S Bq
https:// ecf. nysb .circ2.dcn/cgi- bin/DktRpt.pl ?441809834703411 -L 1 0 -1
- - 3/1 t...
New York Southern Live System
Page 2 of 7
V.
Defendant
----------------- - - - - --
Keystone Logistics Solutions, Inc. represented by Keystone Logistics S o l u ti ons,
'
PRO SE
Filing Date #
Docket Text
Adversary case 10- 02412. Complaint against Keystone
Logistics Solutions, Inc. To Avoid and Recover Transfers
Pursuant to 11 U.S. C. ss 547, 548, 549 and 502 and Recover
Property Transferred Pursuant to U.S. C. ss 550. Nature(s) of
Suit: (12 (Recovery of money /property - 547 preference)), (13
(Recovery of money /property - 548 fraudulent transfer)), (14
(Recovery of money /property - other)), (14 (Recovery of
money /property - other)), (14 (Recovery of money /property -
other)) Filed by Gary D. Underdahl, Eugene I. Davis, as
Litigation Trustee for the Quebecor World Litigation Trust on
behalf of Eugene I. Davis, as Litigation Trustee for the
01/16/2010 Quebecor World Litigation Trust. (Attachments: 1 Exhibit A)
( Underdahl, Gary) (Entered: 01/16/2010)
Receipt of Complaint(10 -02412 jmp) [cmp,cmp] ( 250.00)
01/18/2010 Filing Fee. Receipt number 6543066. Fee amount 250.00. (U.S.
Treasury) (Entered: 01/18/2010)
Motion to Approve Notice of Plaintiffs Motion for an Order
Establishing Streamlined Procedures Governing Adversary
Proceedings Brought by Eugene I. Davis, as Litigation Trustee
for the Quebecor World Litigation Trust, Pursuant to Sections
502, 547, 548, 549 and 550 of the Bankruptcy Code and
Extending the 120 -Day Time Limit for Service of the
Summonses and Complaints filed by Joseph L. Steinfeld Jr. on
behalf of Eugene I. Davis, as Litigation Trustee for the
Quebecor World Litigation Trust. with hearing to be held on
3/16/2010 at 10:00 AM at Courtroom 601 (JMP) Responses due
by 3/9/2010, (Attachments: 1 Pleading Motion for an Order
Establishing Streamlined Procedures Governing Adversary
Proceedings2 Exhibit A - List of Adversary Proceedings3
Exhibit B - Proposed Order Establishing Streamlined
Procedures Governing Adversary Proceedings4 Exhibit C -
Other Defendant Notice Exhibit D - Mediator List Exhibit E -�
Information Form and Notice) ( Steinfeld, Joseph) (Entered: �Q'C BA
co , G
o V
https:// ecf. nysb .circ2.dcn/cgi- bin/DktRpt.pl ?441809834703411 -L 1 0 -1
— — 3/1
°� 11A 0
New York Southern Live System
Page 3 of 7
02/01/2010 42 02/01/2010)
Summons with Notice of Pre -Trial Conference issued by
Clerk's Office with Pre -Trial Conference set for 5/20/2010 at
02/04/2010 10:00 AM at Courtroom 601 (JMP), Answer due by 3/8/2010,
(Porter, Minnie) (Entered: 02/04/2010)
Certificate of Service (related document(s)2 3 j) filed by Gary
D. Underdahl on behalf of Eugene I. Davis, as Litigation
02/16/2010 (14 Trustee for the Quebecor World Litigation Trust. ( Underdahl,
Gary) (Entered: 02/16/2010)
04/06/2010 Certificate of Service filed by Karen M. Scheibe on behalf of
5 ASK Financial. (Scheibe, Karen) (Entered: 04/06/2010)
Order Signed on 3/19/2010 Establishing Streamlined
Procedures Governing Adversary Proceedings Brought by
Eugene I. Davis, as Litigation Trustee for the Quebecor World
Litigation Trust and Extending the 120 -Day Time Limit for
05/27/2010 - Service of the Summonses and Complaints. (Related Doc # 2)
06 (Nulty, Lynda) (Entered: 05/27/2010)
r - I Notice of Adjournment of Hearing IlNotice of Continuance of
Status Conference filed by Alex Govze on behalf of ASK
Financial. with hearing to be held on 8/26/2010 at 10:00 AM at
05/28/2010 Courtroom 601 (JMP) (Attachments: 1 Certificate of Service)
47 (Govze, Alex) (Entered: 05/28/2010)
Notice of Presentment ANotice Of Presentment OfAmended
Order Establishing Streamlined Procedures Govering
Adversary Proceedings Brought By Eugene I. Davis, As
Litigation Trustee For The Quebecor World Litigation Trust,
Pursuant To Sections 502, 547, 548 And 550 Of The
Bankruptcy Code And Extending The 120 -Day Time Limit For
Service Of The Summons And Opportunity For Hearing filed by
Alex Govze on behalf of ASK Financial. with presentment to be
held on 6/15/2010 (check with court for location) Objections
06/02/2010 due by 6/14/2010, (Attachments: 1 Exhibit B Certificate of
8 Service)(Govze, Alex) (Entered: 06/02/2010)
Request for a Second Summons filed by Karen M. Scheibe on
behalf of Eugene I. Davis, as Litigation Trustee for the
06/03/2010 Quebecor World Litigation Trust. (Scheibe, Karen) (Entered:
06/03/2010)
SECOND Summons with Notice of Pre -Trial Conference issued
by Clerk's Office with Pre -Trial Conference set for 8/26/201 A/V
10:00 AM at Courtroom 601 (JMP), Answer due by 7/6/20 G,
� n
https:// ecf. nysb .circ2.dcn/cgi- bin/DktRpt.pl ?441809834703411 -L 1 0 -1
3/1 WN 3 EAL �p�
New York Southern Live System
Page 4 of 7
06/04/2010 0 9 (Campbell, Tiffany) (Entered: 06/04/2010)
Certificate of Service (related document(s)o filed by Joseph L.
Steinfeld Jr. on behalf of ASK Financial. (Steinfeld, Joseph)
06/08/2010 0 10 (Entered: 06 /08/2010)
Statement /Notice (related document(s)2) filed by Karen M.
Scheibe on behalf of Eugene I. Davis, as Litigation Trustee for
the Quebecor World Litigation Trust. Objections due by
06/09/2010 011 6/29/2010, (Scheibe, Karen) (Entered: 06/09/2010)
Certificate of Service (related document(s)9 2 11 1) filed by
Karen M. Scheibe on behalf of Eugene I. Davis, as Litigation
Trustee for the Quebecor World Litigation Trust. (Scheibe,
06/09/2010 012 Karen) (Entered: 06/09/2010)
Amended Order Signed on 7/1/2010 Establishing Streamlined
Procedures Governing Adversary Proceedings Brought by
Eugene I. Davis, as Litigation Trustee for the Quebecor World
Litigation Trust and Extending the 120 -Day Time Limit for - Service of 09/02/2010 013 (Entered the Summonses and Complaints. (Nulty, Lynda).
Notice of Adjournment of Hearing with hearing to be held on
11/29/2010 at 10:00 AM at
09/24/2010 014, Joseph) (Entered: 09/24/2010) Co urtroom 701 (PCB). (Steinfeld,
09/24/2010 015 Affidavit of Service. (Underdahl, Gary) (Entered: 09/24/2010)
Request for Case Reassignment Notice. Judge James M. Peck
Terminated from the case. 10/04/2010 0 16 case. (Richards, Beverly). (Entered: ed 10 04 /2010)dded to the
Certificate of Mailing Re: Case Reassignment Notice. (related
document(s) (Related Doc # 16)) . Service Date 10/06/2010.
10/06/2010 01.7 (Admin.) (Entered: 10/07/2010)
Notice of Adjournment of Hearing with hearing to be held on
2/28/2011 at 10:00 AM at Courtroom 701 (SHL). (Steinfeld,
12/07/2010 018 Joseph) (Entered: 12/07/2010)
Affidavit of Service Re: Notice ofAdjournment. (Steinfeld,
12/07/2010 019 Joseph) (Entered: 12/07/2010)
Notice of Adjournment of Hearing. (Underdahl Gary) 5 N
03/28/2011 020 (Entered: 03 /28/2011)
o �
w <
�j SEA O �
htt ecf nysb .circ bin/DktRpt.pl ?441809834703411 -L 1 1 �
3/12/ � �
New York Southern Live System Page 5 of 7
03/28/2011 421 Affidavit of Service . (Underdahl, Gary) (Entered: 03/28/2011)
Affidavit of Service Requesting Clerk's Entry for Default filed
by Gary D. Underdahl on behalf of Eugene I. Davis, as
Litigation Trustee for the Quebecor World Litigation Trust.
06/06/2011 22 (Underdahl, Gary) (Entered: 06/06/2011)
Certificate of Service (related document(s)22) filed by Gary D.
Underdahl on behalf of Eugene 1. Davis, as Litigation Trustee
for the Quebecor World Litigation Trust. (Underdahl, Gary)
06/06/2011 023 (Entered: 06/06/2011)
Notice of Adjournment of Hearing with hearing to be held on
9/6/2011 at 10:00 AM at Courtroom 701 (SHL). (Steinfeld,
06/13/2011 0124 Joseph) (Entered: 06/13/2011)
Affidavit of Service RE: Notice ofAdjournment. (Steinfeld,
06/13/2011 025 Joseph) (Entered: 06/13/2011)
Notice of Adjournment of Hearing with hearing to be held on
9/6/2011 at 02:00 PM at Courtroom 701 (SHL). (Steinfeld,
06/23/2011 026 Joseph) (Entered: 06/23/2011)
Affidavit of Service RE: Notice ofAdjournment. (Steinfeld,
06/23/2011 027 Joseph) (Entered: 06/23/2011)
Notice of Hearing On The Supplemental Order Establishing
Streamlined Procedures Governing Adversary Proceedings
Brought By Eugene I. Davis, As Litigation Trustee For The
Quebecor World Litigation Trust, Pursuant To Sections 502,
547, 548, 549 And 550 Of The Bankruptcy Code filed by Joseph
L. Steinfeld Jr. on behalf of Eugene 1. Davis, as Litigation
Trustee for the Quebecor World Litigation Trust. with hearing
to be held on 7/29/2011 at 10:00 AM at Courtroom 701 (SHL)
Objections due by 7/22/2011, (Attachments: 1 Exhibit A - To
Notice Exhibit B - To Notice3 Exhibit A - To Order)
07/05/2011 (328 (Steinfeld, Joseph) (Entered: 07/05/2011)
Affidavit of Service RE: Notice Of Hearing On The
Supplemental Order Establishing Streamlined Procedures
Governing Adversary Proceedings Brought By Eugene 1. Davis,
As Litigation Trustee For The Quebecor World Litigation Trust,
Pursuant To Sections 502, 547, 548, 549 And 550 Of The
07/06/2011 0 29 Bankruptcy Code. (Steinfeld, Joseph) (Entered: 07/06/2011)
Supplemental Order Establishing Streamlined Procedures gp
Governing Adversary Proceedings Brought By Eugene 1. Dav'�'��'�'F
a
https:// ecf. nysb .circ2.dcn/cgi- bin/DktRpt.pl ?441809834703411-L 3/12/
SEAS nC
New York Southern Live System Page 6 of 7
As Litigation Trustee For The Quebecor World Litigation Trust
signed by the Honorable Judge Sean H. Lane on 7/29/2011.
08/02/2011 t30 (Related Document 6). (Marano, Kelly) (Entered: 08/02/2011)
Notice of Adjournment of Hearing with hearing to be held on
12/6/2011 at 02:00 PM at Courtroom 701 (SHL). (Steinfeld,
09/29/2011 431 Joseph) (Entered: 09/29/2011)
Affidavit of Service Re: Notice ofAdjournment of Hearing.
09/29/2011 X32 (Steinfeld, Joseph) (Entered: 09/29/2011)
Clerk's Entry of Default against Keystone Logistics Solutions,
Inc. (related document(s)22) (Rouzeau, Anatin) (Entered:
03/08/2012 033 03/08/2012)
Notice of Adjournment of Hearing with hearing to be held on
4/18/2012 at 10:30 AM at Courtroom 701 (SHL). (Underdahl,
03/16/2012 034 Gary) (Entered: 03/16/2012)
Affidavit of Service / /Notice of Service. (Underdahl, Gary)
03/16/2012 035 (Entered: 03 /16/2012)
Certificate of Service (related document(s)33) filed by Clerk of
Court, United States Bankruptcy Court, SDNY. (Brown,
Tenille) Additional attachment(s) added on 4/12/2012
03/26/2012 036 (Richards, Beverly). (Entered: 03/26/2012)
Notice of Returned Mail from Keystone Logistics Solutions Inc
04/16/2012 437 (related document(s)_33) (Su, Kevin). (Entered: 04/17/2012)
Notice of Presentment Of Order For Default Judgement
(related document(s)33) filed by Joseph L. Steinfeld Jr. on
behalf of Eugene I. Davis, as Litigation Trustee for the
Quebecor World Litigation Trust. with presentment to be held
on 12/14/2012 at 12:00 PM at Courtroom 701 (SHL) Objections
11/07/2012 438 due by 12/13/2012, (Steinfeld, Joseph) (Entered: 11/07/2012)
Motion for Default Judgment (related document(s)33, 38J filed
by Joseph L. Steinfeld Jr. on behalf of Eugene I. Davis, as
Litigation Trustee for the Quebecor World Litigation Trust.
(Attachments: # 1 Application For Default Judgment)
11/07/2012 X39 (Steinfeld, Joseph) (Entered: 11/07/2012)
Certificate of Service (related document(s)39 38) filed by
Joseph L. Steinfeld Jr. on behalf of Eugene I. Davis, as
Litigation Trustee for the Quebecor World Litigation Trust. ��
11/07/2012 X40 (Steinfeld, Joseph) (Entered: 11/07/2012) �►�
C j� SEAL �O' J
https: / /ecf.nysb.circ2.dcn/cgi- bin /DktRpt.pl ?441809834703411- L_1_0 -1 3/12/2 1 * ��
New York Southern Live System Page 7 of 7
Order Signed On 11/20/2012, Granting Motion For Default
Judgment. (Related Doc # 39) (Ebanks, Liza) (Entered:
11 /20/2012 41 11/20/2012)
� n
c 6EAL Q�
https: / /ecf.nysb.circ2.dcn/cgi- bin /DktRpt.pl ?441809834703411- L_1_0 -1 3/12/2013
2165015
GORDON & WEINBERG, P.C.
BY: FREDERIC I . WEINBERG, ESQUIRE
Identification No. : 41360
JOEL M. FLINK, ESQUIRE
Identification No. : 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
mm- m
Eugene I . Davis, as Litigation Trustee COURT OF COMMON PLEAS
for the Quebecor World Litigation CUMBERLAND COUNTY
illTrust
vs.
EMEKeystone Logistics Solutions, Inc. DOCKET NO. : 2013-02891 n C
=1550 Harrisburg Pike
_Carlisle, PA 17013 x rn L..
2..7J m
and (.0 -' 77°cj
Susquehanna Bank �--
�330 York Road D>c) ac
ragCarlisle, PA 17013 %c - c`
GARNISHEE
m▪mm
PRAECIPE FOR WRIT OF EXECUTION
mmTO THE PROTHONOTARY:
EE- E
Issue writ of execution in the above matter,
mmm directed to the Sheriff of Cumberland County; er,
(1) against 7 Q
Keystone Logistics Solutions, Inc.
mmm defendant (s) and
mmm
mmm
(2) against
ra▪mm Susquehanna Bank -461C1.00 Pb H T1`{
garnishee (s)
6150.0o C8r
mm- m (3) AMOUNT DUE $55, 765. 86
INTEREST 3.3.50 '
from May 21, 2013 $4 . 42 5� ' iD ATT`/
COSTS
Prothonotary fee
Sheriff fee
(4) Less: Payments on Account ($ . 00)
TOTAL (6
(5/ •50 L1
01185151/
2eaa i 983
ci
FREDERIC I . WEINBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 13-2891 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due EUGENE I. DAVIS,as Litigation Trustee for the
QUEBACOR WORLD LITIGATION TRUST,Plaintiff(s)
From KEYSTONE LOGISTICS SOLUTION,INC., 1550 Harrisburg Pike,Carlisle,PA 17013
(1) You are directed to levy upon the property of the defendant(s)and to sell personal property.
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEE(S)as follows:
SUSQUEHANNA BANK,330 York Road,Carlisle,PA 17013
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$55,765.86 Plaintiff Paid$
Interest from 5/21/13 -- $4.42
Attorney's Comm. % Law Library$.50
Attorney Paid$312.50 Due Prothonotary$2.25
Other Costs$
Date: 6/17/13 .
David D.Buell,Prothonotary
Deputy
REQUESTING PARTY:
Name : FREDERIC I.WEINBERG,ESQUIRE
Address: GORDON& WEINBERG,PC
1001 E HECTOR STREET,STE 220
CONSHOHOCKEN,PA 19428
Attorney for: PLAINTIFF
Telephone: 484-351-0500
Supreme Court ID No. 41360
GORDON & WEINBERG, P.C.
BY: , FREDERIC I . WEINBERG, ESQUIRE
Identification No. : 41360
JOEL M. FLINK, ESQUIRE '
Identification No. : 41200 y 3
1001 E. Hector Street, Ste 220
rri
Conshohocken, PA 19428
484/351-0500 UD
<c -r)
Eugene I . Davis, as Litigation Trustee COURT OF COMMON PLEAS T-- ;:: -
for the Quebecor World Litigation Trust CUMBERLAND COUNTY - -- `: (
vs .
Keystone Logistics Solutions, Inc. DOCKET NO. : 2013-02891
1550 Harrisburg Pike
Carlisle, PA 17013
and
Susquehanna Bank
330 York Road
Carlisle, PA 17013
GARNISHEE
ANVW5
INTERROGATORIES IN ATTACHMENT
TO: Susquehanna Bank - GARNISHEE
You are required to file answers to the following Interrogatories within twenty
(20) days after service upon you. Failure to do so my result in judgment
against you.
1 . At the time you were served or at any subsequent time did you owe
the defendant (s) any money or were you liable to the defendant on
any negotiable or other written instrument, or did the defendant
claim that you owed the defendant any money or were liable to the
defendant for any reason?
See answer on attachment .
2 . At the time you were served or at any subsequent time was there
in your possession, custody or control or in the joint
possession, custody or control of yourself and one or more other
persons any property of any nature owned solely or in part by the
defendant.
No.
3. At the time you were served or at any subsequent time did you
hold legal title to any property of any nature owned solely or in
part by the defendant or in which defendant held or claimed any
interest.
No.
4 . At the time you were served or at any subsequent time did you
hold as fiduciary any property in which the defendant (s) had an
interest?
5. At any time before or after you were served did the defendant (s)
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?
No.
6. At any time after you were served did you pay, transfer or
deliver any money or property to the defendant (s) or to any
person or place pursuant to his (her, their) direction or
otherwise discharge any claim of the defendant (s) against you?
No.
a
7 . If you are a bank or other financial institution, at the time you
were served or at any subsequent time, did the defendant (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 federal law? If so, identify
each account and state the reason for the exemption, the amount
of funds in each account, the amount being withheld under each
exemption and the entity electronically depositing those funds on
a recurring basis .
No.
8 . If you are a bank or other financial institution, at the time you
were served or any subsequent time did the defendant (s) have
funds on deposit in an account in which the funds on deposit, not
including any otherwise exempt funds, did not exceed the amount
of the general monetary exemption under 42 Pa.C.S. §8123? If so,
identify each account.
No.
9. How much is the value of any property in your possession
belonging to the defendant (s) ?
See answer to interrogatory no . 1 on attachment .
r
FREDERIC I . ► s RG, ESQUIRE
JOEL M. FLI ' , ESQUIRE
Attorney for Plaintiff
DATED: (a ('4( 12
Attachment to Answers to Interrogatories
Re: Eugene I. Davis, as Litigation Trustee for the Quebecor World Litigation Trust vs.
Keystone Logistics Solutions, Inc.
Docket#: 2013-02891
#1 Answer:
Defendant has one checking account number XXXXXX2695 with an available balance
of$1,220.96 at time of service.
VERIFICATION
I, Grant W. Schonour, verify that the facts set forth in these Garnishee's Answers to
Interrogatories are true and correct to the best of my knowledge, information, and belief. This
statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. §
4904) related to unsworn falsification to authorities.
Dated: July 26, 2013
IF 6- •
Gra W. Schonour,
Ass'.tatt Secretary and
LegCounsel
Susquehanna Bank
26 North Cedar Street
Lititz, Pa 17543
(717) 625-6411
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff U
Jody S Smith 2.013JUL26 AM10: 29
Chief Deputy
Richard W Stewart CUMBERLAND CG-UNTY
Solicitor PENNSYLVANIA
Eugene I. Davis, as Litigation Trustee for the Quebacor World Litigati Case Number
V&
Keystone Logistics Solution, Inc. (et al.) 2013-2891 I
SHERIFF'S RETURN OF SERVICE
07/2412013 09:39 AM-Amanda Cobaugh, Deputy Sheriff,who being duly sworn according to law, states that on July
24, 2013 at 0939 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant,to wit: Ryan L. Traugh, in the hands, possession, or control of the
within named garnishee, Susquehanna Bank, 330 York Road, Cumberland County, Pennsylvania, by
handing to Cortney M. Marks, Branch Operations Supervisor 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 July 25,2013 to Keystone Logistics Solutions,
Inc., at 1550 Harrisburg Pike, Carlisle, PA 17013.
A:M-'AiqbA db-BAD61-1, DEPUTY U
SO ANSWERS,
July 25, 2013 RbNW FANDERSON, SHERIFF
(c)CounlySuilo Sheriff,Toleosoft,inc.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson "L 0-()i7 1-71 C F
Sheriff 4'-F THE PRO THONE IAF,'-
Jody S Smith
Chief Deputy 2013 JUL 26 PM 1: 5 7
Richard W Stewart
Solicitor OF F'4E OF 4E SKRIFr CUMBERLAND COUNTY
PENNSYLVANIA
Eugene I. Davis, as Litigation Trustee for the Quebacor World Litigati
Case Number
vs.
Keystone Logistics Solution, Inc. (et al.) 1 2013-2891
SHERIFF'S RETURN OF SERVICE
07/25/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Keystone Logistics Solution, Inc., but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Execution as"Not
Found"at 1550 Harrisburg Pike, Middlesex Township, Carlisle, PA 17013.
Business is closed and is no longer in operation.
SO ANSWERS,
July 25, 2013 RONW R ANDERSON, SHERIFF
(c)countysuite Sheriff,Teleosoft,ftic.
2165015 °E PhiO "t-1C
GORDON & WEINBERG, P.C.
J
BY: FREDERIC I . WEINBERG, ESQUIRE _r
Identification No. : 41360 F ;
JOEL M. FLINK, ESQUIRE
Identification No. : 41200 PEpj��SANDcoljjj7-�,
1001 E. Hector Street, Ste 220 YLVANIA
Conshohocken, PA 19428
484/351-0500
Eugene I . Davis, as Litigation COURT OF COMMON PLEAS
Trustee for the Quebecor World CUMBERLAND COUNTY
Litigation Trust
r
VS.
DOCKET NO. 2013-02891
Keystone Logistics Solutions, Inc.
and
Susquehanna Bank
Garnishee
PRAECIPE FOR JUDGMENT UPON ADMISSION
TO THE PROTHONOTARY:
Please enter judgment in favor of the Plaintiff, Eugene I . Davis,
as Litigation Trustee for the Quebecor World Litigation Trust and against
the Garnishee, Susquehanna Bank, in the amount of $1, 220 .96, admitted in
the Answer to Interrogatories to be in the Garnishee' s possession,
together with interest and costs which is not more than the amount of the
judgment of the Plaintiff against the Defendant together with post
judgment costs and post judgment interest which is $56, 062 . 84 .
Date: '� 1 � GORDON & WEINBERG, P.C.
BY:
FREDERIC I . WEI E , ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff CL V4
0R3 TV
`N Ace ���
2165015
GORDON & WEINBERG, P.C.
BY: FREDERIC I . WEINBERG, ESQUIRE
Identification No. : 41360
JOEL M. FLINK, ESQUIRE
Identification No. : 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
Eugene I. Davis, as Litigation COURT OF COMMON PLEAS
Trustee for the Quebecor World CUMBERLAND COUNTY
Litigation Trust
Vs . DOCKET NO. 2013-02891
Keystone Logistics Solutions, W
Inc.
and
Susquehanna Bank
Garnishee
NOTICE
PURSUANT TO RULE 236 OF THE SUPREME COURT-OF PENNSYLVANIA, YOU ARE HEREBY
NOTIFIED THAT A.JUDGMENT UPON ADMISSIONS HAS BEEN ENTERED AGAINST YOU IN
THE ABOVE PROCEEDING. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE,
PLEASE CALL FREDERIC I. WEINBERG, ESQUIRE AT 484/351-0500
RM/I a s
i
Susquehanna*.'
Susquehanna Bancshares,Inc.
26 North Cedar Street
Lititz,PA 17543-7000
Tel 717.626.4721
Fax 717.625.0331
July 26, 2013
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Re: Eugene 1. Davis, as Litigation Trustee for the Quebecor World Litigation Trust vs.
Keystone Logistics Solutions, Inc.
Docket#: 2013-02891
Dear Sir or Madam:
Please find enclosed Susquehanna Bank's Answers to Interrogatories from the Garnishee in the
above matter.
Thank you for your cooperation.
Sincerely,
jchonour
ecretary and Associate Counsel
GWS/veg
Enclosures
Cc: Frederic I. Weinberg, Esq. w/enclosures
Keystone Logistics Solutions, Inc. w/enclosures
JUL 2 9 2013 � .
,I
GORDON & WEINBERG, P.C.
BY: FREDERIC I . WEINBERG, ESQUIRE
Identification No. : 41360
JOEL M. FLINK, ESQUIRE
Identification No. : 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
Eugene I . Davis, as Litigation Trustee COURT OF COMMON PLEAS
for the Quebecor World Litigation Trust CUMBERLAND COUNTY
VS .
Keystone Logistics Solutions, Inc. DOCKET N0. 2013-02891
1550 Harrisburg Pike
Carlisle, PA 17013
and
Susquehanna Bank
330 York Road
Carlisle, PA 17013
GARNISHEE
INTERROGATORIES IN ATTACHMENT
TO: Susquehanna Bank - GARNISHEE
You are required to file answers to the following Interrogatories within twenty
(20) days after service upon you. Failure to do so my result in judgment
against you.
1 . At the time you were served or at any subsequent time did you owe
the defendant (s) any money or were you liable to the defendant on
any negotiable or other written instrument, or did the defendant
claim that you owed the defendant any money or were liable to the
defendant for any reason?
See answer on attachment .
2 . At the time you were served or at any subsequent time was there
in your possession, custody or control or in the joint
possession, custody or control of yourself and one or more other
persons any property of any nature owned solely or in part by the
defendant.
Dill.
3 . At the time you were served or at any subsequent time did you
hold legal title to any property of any nature owned solely or in
part by the defendant or in which defendant held or claimed any
interest.
No.
4 . At the time you were served or at any subsequent time did you
hold as fiduciary any property in which the defendant (s) had an
interest?
W.
5. At any time before or after you were served did the defendant (s)
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?
NO
At any time after you were served did you pay, transfer or
deliver any money or property to the defendant (s) or to any
person or place pursuant to his (her, their) direction or
otherwise discharge any claim of the defendant (s) 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 (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 federal law? If so, identify
each account and state the reason for the exemption, the amount
of funds in each account, the amount being withheld under each
exemption and the entity electronically depositing those funds on
a recurring basis .
No.
8 . If you are a bank or other financial institution, at the time you
were served or any subsequent time did the defendant (s) have
funds on deposit in an account in which the funds on deposit, not
including any otherwise exempt funds, did not exceed the amount
of the general monetary exemption under 42 Pa.C.S. §8123? If so,
identify each account.
No.
9. How much is the value of any property in your possession
belonging to the defendant (s) ?
See answer to interrogatory no. 1 on attachment.
FREDERIC I . I,W $'ERG, ESQUIRE
JOEL M. FLIN , ESQUIRE
Attorney for Plaintiff
DATED:
Attachment to Answers to Interrogatories
Re: Eugene I. Davis, as Litigation Trustee for the Quebecor World Litigation Trust vs.
Keystone Logistics Solutions, Inc.
Docket#: 2013-02891
#1 Answer:
Defendant has one checking account number XXXXXX2695 with an available balance
of$1,220.96 at time of service.
VERIFICATION
I, Grant W. Schonour;verify that the facts set forth in these Garnishee's Answers to
Interrogatories are true and correct to the best of my knowledge, information, and belief. This
statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. §
4904)related to unsworn falsification to authorities.
Dated: July 26, 2013
Grand W. Schonour,
Ass' taut Secretary and
Leg�fCounsel
Susquehanna Bank
26 North Cedar Street
Lititz, Pa 17543
(717) 625-6411
2165015
OF
GORDON & WEINBERG, P.C.
� ��QQ j i
BY: FREERIC � SFp 23 PN 2.
JOEL M. FLINK, ESQUIRE 'JRLA,°rp �U
Identification No. : 41200 S�'NoQ NTY
1001 E. Hector Street, Ste 220 !q
Conshohocken, PA 19428
484/351-0500
Eugene I . Davis, as Litigation COURT OF COMMON PLEAS
_ Trustee for the Quebecor World CUMBERLAND COUNTY
Litigation Trust
VS . DOCKET NO. : 2013-02891
Keystone Logistics Solutions,
Inc.
and
Susquehanna Bank
Garnishee
ORDER TO SATISFY JUDGMENT AGAINST GARNISHEE
TO THE PROTHONOTARY:
Kindly mark the judgment entered against garnishee
Susquehanna Bank in the above-captioned matter satisfied upon
payment of your costs only.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I . WEINBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff ^ I
P013 5L Q'_
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff `
� X52 o'z ;:11ar1 Z .. i' PRO
Jody S Smith
Chief Deputy
1jl FEB 26 2:
Richard W Stewart
Solicitor ;«€cc,. . -. . .,. CUMBERLAND CODA.t
PENNSYLVANIA
Eugene I. Davis, as Litigation Trustee for the Quebacor World Litigati Case Number
vs.
Keystone Logistics Solution, Inc. (et al.) 2013-2891
SHERIFF'S RETURN OF SERVICE
07/24/2013 09:39 AM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July
24, 2013 at 0939 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Ryan L. Traugh, in the hands, possession, or control of the
within named garnishee, Susquehanna Bank, 330 York Road, Cumberland County, Pennsylvania, by
handing to Cortney M. Marks, Branch Operations Supervisor 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 July 25, 2013 to Keystone Logistics
Solutions, Inc., at 1550 Harrisburg Pike, Carlisle, PA 17013.
07/25/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Keystone Logistics Solution, Inc., but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Execution as"Not
Found"at 1550 Harrisburg Pike, Middlesex Township, Carlisle, PA 17013.
Business is closed and is no longer in operation.
02/26/2014 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.
On August 5, 2013, attorney Weinberg did file a praecipe for judgment upon admission against
garnishee, Susquehanna Bank, in the amount of$ 1,220.96.
SHERIFF COST: $132.72 SO ANSWERS,
February 26, 2014 RONNY R ANDERSON, SHERIFF
s'b ups,
'i r
3 0.) /4 oir q