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HomeMy WebLinkAbout13-7074 # N F, P D - OH WE E 13 NOV 27 PH 2.14 CUMBLERLA D COUNTY �'LNNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA n STATOD ENTERPRISES, INC. d/b /a No. 13 - 794 1V i l T erm HARRISBURG AUTO AUCTION, Plaintiff VS. CIVIL ACTION -LAW EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant JURY TRIAL DEMANDED PRAECIPE TO ENTER JUDGMENT ENTER JUDGMENT in the above case pursuant to the attached Notice of Judgment/Transcript filed with District Justice 09 -3 -05 in favor of Plaintiff, Statod Enterprises, Inc. d/b /a Harrisburg Auto Auction in the sum of $7,402.39 together with interest and costs of suit Total: $7,402.39 together with interest and costs of suit Dated: N0,A Z , 2013 ROBERT W. MELICK, ESQ., ID 205972 Attorney for Plaintiff %Ewaa r] , 2013 Judgment entered by the Prothonotary this day according to the tenor of the above statement. 43i j5 PD ATTY ���to451 ag8r Cum erland County Prothonotary COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ- 09 -3 -05 Statod Enterprises Inc. d /b /a Harrisburg Auto MDJ Name: Honorable Mark Martin Auction Address: 507 North York Street V. Mechanicsburg, PA 17055 Exotic Carriers, Inc., Bumblebee Transport, Inc. Telephone: 717- 766 -4575 Robert William Melick, Esq. Docket No: MJ- 09305 -CV- 0000151 -2013 Griffith Strickler ET Al' Case Filed: 9/3/2013 110 S Northern Wy York, PA 17402 Disposition Summ ary cross complaint) .... Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09305 -CV- 0000151 -2013 Statod Enterprises, Inc. d /b /a Exotic Carriers, Inc. Default Judgment for Plaintiff 10/11/2013 Harrisburg Auto Auction MJ- 09305 -CV- 0000151 -2013 Statod Enterprises, Inc. d /b /a Bumblebee Transport, Inc. Default Judgment for Plaintiff 10/11/2013 Harrisburg Auto Auction Judgment Summary Participant Joint/Several Liability Individual Liability Amount Bumblebee Transport, Inc. $7,402.39 $0.00 $7,402.39 Exotic Carriers, Inc. $7,40239 $0.00 $7,402.39 Statod Enterprises, Inc. d /b /a Harrisburg Auto $0.00 $0.00 $0100 Auction Judgment Finding ( 'PostJudgment) In the matter of Statod Enterprises, Inc. d /b /a Harrisburg Auto Auction vs. Exotic Carriers, Inc.; Bumblebee Transport, Inc. on 10/1 V2013 the judgment was awarded as follows: Judgment Component Joint /Several Liability Individual Liability Deposit Applied Amount Filing Fees $170.50 $0.00 $170.50 Civil Judgment $7,231.89 $0.00 $7,231.89 Grand Total: $7,402.39 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY /CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT /TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. r 1 � • ./� i'� /�����" l„r Mary �ai Date Magisterial District Judge Mark Martin certify that this is a true and correct copy of the record of the proceedings cont a mgt the lu ment. Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 10/11/2013 9:22:10AM N0�1 1 2013 Statod Enterprises, Inc. d /b /a Harrisburg Auto Docket No.: MJ- 09305 -CV- 0000151 -2013 Auction V, Exotic Carriers, Inc., Bumblebee Transport, I:nc. Participant List Private(s) Robert William Melick, Esq. Griffith Strickler ET AI' 110 S Northern Wy York, PA 17402 Plaintiff(s) Statod Enterprises, Inc. d /b /a Harrisburg Auto Auction 987 W. Trindle Rd. Mechanicsburg, PA 17055 Defendant(s) Bumblebee Transport, Inc. 1023 S. Rosina Avenue Somerset, PA 15501 Exotic Carriers, Inc. 92 Railroad St. Hasbrouck Heights, NJ 07604 MDJS 315 Page 2 of 2 Printed: 10/11/2013 9 :22:10AM IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STATOD ENTERPRISES, INC. d/b /a No. HARRISBURG AUTO AUCTION, Plaintiff VS. CIVIL ACTION -LAW EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this Z60 day of �+�^�� , 2013, I, Robert W. Melick, a I member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Praecipe to Enter Judgment by United States Mail, addressed to the party or attorney of record as follows: Exotic Carriers, Inc. 92 Railroad Street Hasbrouck Heights, NJ 07604 Bumblebee Transport, Inc. 1023 South Rosina Avenue Somerset, PA 15501 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: R W. MELICK, ESQ., ID 05972 110 South Northern Way York, PA 17402 Telephone (717) 757 -7602 Fax No. (717) 757 -3783 rmelickggslsc.com Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STATOD ENTERPRISES, INC. d/b /a No. O_Avimew HARRISBURG AUTO AUCTION, Plaintiff VS. CIVIL ACTION -LAW EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant JURY TRIAL DEMANDED NOTICE OF ENTRY OF JUDGMENT (X) Notice is hereby given that a JUDGMENT in the above - captioned matter has been entered against you in the amount of $7,402.39 plus interest, costs of suit and attorney's fees on Dx) on 5 2013. (X) A copy of all documents filed with the Prothonotary ir`, f th *thin judgme s enclosed. A Prothonotary Civil Div. BY: If you have any questions regarding this Notice, please contact the filing party: NAME: ROBERT W. MELICK, ESQUIRE ADDRESS: 110 South Northern Way York, Pennsylvania 17402 TELEPHONE: (717) 757 -7602 (This Notice is given in accordance with Pa.R.C.P.236) Notice sent to: Bumblebee Transport, Inc. 1023 South Rosina Avenue Somerset, PA 15501 Lte-12-2013 15:57 GRIFFITH STRICKLER 7177573783 P.003 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA • STATOD ENTERPRISES,INC. d/b/a • No. 13 - '1O74 0-;1V'l�i''t HARRISBURG AUTO AUCTION, • Plaintiff vs. CIVIL ACTION-LAW • EXOTIC CARRIERS,INC., BUMBLEBEE TRANSPORT,INC., Defendant • JURY TRIAL DEMANDED NOTICE OF ENTRY OF JUDGMENT (X) Notice is hereby given that a JUDGMENT in the above-captioned matter has been entered against you in the amount of $7,402.39 plus interest, costs of suit and attorney's fees on . Nlov. 01:7 , 2013. (X) A copy of all documents filed with the Prothono . • ' sup- of. • within judo, it is enclosed. Pro w:onotary Civil Div. BY: If you have any questions regarding this Notice, please contact the filing party: NAME: ROBERT W. MELICK,ESQUIRE ADDRESS: 110 South Northern Way York,Pennsylvania 17402 TELEPHONE: (717)757-7602 (This Notice is given in accordance with Pa.R.C.P.236) Notice sent to: Exotic Carriers, Inc. 92 Railroad Street Hasbrouck Heights,NJ 07604 TfTAT n ^^^ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, ❑Confessed Judgment Plaintiff [ Other VS. File No. 13-707",4 Civil Text EXOTIC CARRIERS, INC. - � BUMBLEBEE TRANSPORT, INC. Amount Due $7,402.39 r '� .� Defendant Interest $148.05 n� crp s- Address: .� s y�a5tka.Apt Atty s Comm �-P C CD $0.00 u) Sb A CI-51.1 P ITOI Costs $210.25 TP %r-r �� Rw1roQ� S-F co . TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,or account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs,upon the following described property of the defendant(s) PRAECIPE FOR ATTACHMENT EXEC TION Issue writ of attachment to the Sheriff of County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property (if real estate,supply six copies of the description;supply four copies of lengthy personalty list) flu C �L 10- N o�I-� WJ (C--/- ( l'�� and all other property of the defendant(s)in the possession,custody or control of the said gamishee(s). E] (Indicate)Index this writ against the garnishee(s)as;a lis pendens against real estate of the defendant(s)described in the attached exhibit. Date �Q, Y Signature:: /,�/ Print Name: sa 9.4D �� �r�'(`d'T= "� Address: Ck-A- X760 Attorney for: 0 1 -7 7-6 6 Telephone: Supreme Court ID No: $ L&e. Cn WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-7074 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due STATOD ENTERPRISES,INC.D/B/A HARRISBURG AUTO AUCTION Plaintiff(s) From EXOTIC CARRIERES,INC.,92 RAILROAD AVE.,HASBROUCK HEIGHTS,NJ 070604 AND BUMBLEBEE TRANSPORT,INC., 10235 ROSINA AVE.,SOMERSET,PA 15501 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: PNC BANK, 105 NOBLE BLVD.,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; (2) 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$7402.39 Plaintiff Paid$ Interest$148.05 Attorney's Comm. % Law Library$.50 Attorney Paid$60.25 Due Prothonotary$2.25 Other Costs$ Date: 2/25/14 David D.Buell,Prothonotary 0'a I", Deputy REQUESTING PARTY: Name : ROB MELICK,ESQ. Address: GRIFFITH,STRICKLER,LERMAN,SOLYMOS&CALKINS, 110 S.NORTHERN WAY,YORK,PA 17402 Attorney for: PLAINTIFF Telephone: 717-757-7602 Supreme Court ID No. 205972 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ! ;, I f d . !. qv 01 Culutierf Jody S SmithjlUC Ar Chief Deputy 4 Richard W Stewart � _ .i ir' l� j '` Solicitor �.« PENNSYLVANIA Statod Enterprises, Inc. Case Number vs. Exotic Carriers, Inc. (et al.) 2013-7074 SHERIFF'S RETURN OF SERVICE 03/03/2014 09:55 AM - Ryan Burgett, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Beth Ann Eppley, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 4, 2014 to Exotic Carriers, Inc. at 92 Railroad Avenue, Hasbrouch Heights, NJ 07064 and to Bumblebee Transport, Inc. at 10235 Rosina Avenue, Somerset, PA 15501. RYAN BURGETT, DEPUTY SO ANSWERS, March 04, 2014 RONNY R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA STATOD ENTERPRISES, NC, d/b /a CIVIL ACTION - LAW HARRISBURG AUTO AUCTION, NO.: 13 -7074 Plaintiff, vs. ANSWERS TO INTERROGATORIES IN ATTACHMENT INCLUDING EXOTIC CARRIERS, INC., NEW MATTER BUMBLEBEE TRANSPORT, INC., PNC BANK, Defendants, and Garnishee Filed on behalf of PNC Bank, Association Joel B. Gold, Esquire Sr. Counsel for PNC Bank, National Association Pa. I.D. #42090 PNC Bank, National Association Firm #862 One PNC Plaza, 20th Floor 249 Fifth Avenue Pittsburgh, Pennsylvania 15222 -2707 (412) 762 - 2801/6763 (facsimile) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA STATOD EN'.LERPRISES, II�TC, d.fb /a CIVIL ACTION - LAW HARRISBURG AUTO AUCTION, NO.: 13 -7074 Plaintiff. vs. ANSWERS TO INTERROGATORIES IN Al I ACHMENT LNCLUDING EXOTIC CARRIERS, INC., NEW MATTER BUMBLEBEE TRANSPORT, INC., Defendants, and PNC BANK, N.A. Garnishee NOTICE TO PLEAD TO: Plaintiff and Defendant: F You are hereby notied to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. PNC Bank, N By: Gold A,rNSW'ERS TO INTERROGATORIES IN ATTACHMENT INCLUDING NEW MATTER AND NOW, PNC Bank, N.A. the Garnishee ( "Bank "), files this response stating as follows: Unknown. • There arc no accounts of Bumblebee Transport. The identity describes on the Writ "Exotic Carrieres, Inc.." There are no accounts of Exotic Carneres, Inc. The Interrogatories to Garnishee identify a defendant as Exotic Carriers, Inc. (underlining added). The Bank does not have an account of Exotic Carriers, Inc. The bank has two accounts titled to a similarly named business entity, not identical to the judgment defendant and not identical. to Exotic Carriers, Inc.: Exotic Carrier, Inc. See New Matter 2. No. 3. No. 4. No. 5. Unknown, see no. 1 and New Matter. 6. No. 7.. Unknown, see no. 1 and New Matter. 8. No. NEW MATTER 9. Paragraphs numbered 1 through 8, inclusive are incorporated herein as if set forth at length. 10. By way of further response to nos. 1 above, the accounts identified in response No. 1 of the similarly named entity, had at the time of purported delivery of the Writ an aggregate balance of negative $847.19, deposit and withdrawal activity followed including $5,352.70 in withdrawals. 11, Garnishee believes and therefore avers that at all times relevant hereto judgment defendant knew of the plaintiff's Writ of Execution. 12. In the event Garnishee is liable to the plaintiff in any amount, by reason of sums demanded by judgment defendant from the Garnishee after service in violation of the mandate and injunctive order of a writ of execution, then the judgment defendant is liable over to Garnishee in the same amount. 13. The account identified in this response is subject to the terms and conditions of deposit agreement between Garnishee and its customer. 14. Under the terms and conditions of the deposit account agreement in the event Garnishee is liable to the plaintiff in any amount by reason for sums obtained by judgment defendant from Garnishee after service, then the judgment defendant is liable over to Garnishee in the same amount plus costs, expenses and including reasonable attorney fees. 15. It is unknown to Bank whether the funds deposited and or funds withdrawn from accounts of Exotic Carrier, Inc. were exempt or immune from attachment. WHEREFORE, PNC Bank, N.A. does not admit owing a debt to a judgment defendant or to holding tangible personal property of a judgment defendant.. Respectfully submitted, PNC BANK, NATIONAL ASSOCIATION Lit/garnishee answers/Exotic Carriers Inc Bumblebee Transport 3202014 VERIFICATION The undersigned hereby verifies that I am an authorized representative of PNC Bank, N.A.; that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information and belief and that these statements are made subject to the penalties of 18Pa. C.S. s4904, relating to unsworn falsification to authorities. RE Statod Enterprises Inc d /b /a Harrisburg Auto Auction vs Exotic Carriers Inc Bumblebee Transport Inc DOCKET NO 13 -7074 i i; f Theresa A Dusch Team Lead, Garnishment Processing Position DATE: March 26, 2014 Lit - 233946.1 CERTIFICATE OF SERVICE PNC BANK, Garnishee, certifies that on March 27, 2014, a copy of the Answers to Interrogatories in Attachment was served via first -class U.S. mail to: the court where the Writ of Execution was filed; the plaintiff or counsel representing the plaintiff; and to the defendant(s). Date: 3/27/14 i/(7 Kristen Kinander Paralegal A PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, Plaintiff vs. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant No. 13-7074 CIVIL ACTION -LAW JURY TRIAL DEMANDED MOTION TO COMPEL RESPONSES TO POST JUDGMENT INTERROGATORIES OF PLAINTIFF TO DEFENDANT, EXOTIC CARRIERS, INC. SET NO. 1 AND NOW, comes Plaintiff, Statod Enterprises, Inc. d/b/a Harrisburg Auto Auction, by and through their undersigned counsel, Robert W. Melick, Esquire and Griffith, Strickler, Lerman, Solymos & Calkins, who hereby files this Motion to Compel and in support thereof states as follows: 1. On August 30, 2013, a District Justice action was filed against Exotic Carriers, Inc. ("Exotic"). 2. Plaintiff obtained a verdict against Exotic from the District Justice, which was never appealed by Exotic. 3. On November 27, 2013, a Notice of Entry of Judgment was entered against Exotic in the amount of $7,402.39. 4. On April 17, 2014, Defendant served Post Judgment Interrogatories upon Exotic. A true and correct copy of this document is attached hereto as Exhibit "A." 5. More than 30 days have elapsed since service of this document. 6. Despite multiple attempts to contact Exotic, Plaintiff's counsel has been unable to reach Exotic, and therefore it is assumed that Exotic does not concur with this Motion. WHEREFORE, Plaintiff, Statod Enterprises, Inc. d/b/a Harrisburg Auto Auction, respectfully requests that this Court grant its Motion to Compel Responses to Post Judgment Interrogatories of Plaintiff to Defendant, Exotic Carriers, Inc. Set No. 1 within 20 days of the execution of the Order, or face sanctions, along with any other relief that this Court deems just and proper. Dated: GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS , 2014 By: 2 ROBERT W. MELICK, ESQUIRE Attorney I.D. No. 205972 110 South Northern Way York, Pennsylvania 17402 Telephone (717) 757-7602 Fax (717) 757-3783 rmelicka,gslsc.com Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, Plaintiff vs. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant . No. 13-7074 CIVIL ACTION -LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this C day of , 2014, I, Robert W. Melick, a member of the firm of GRIFFITH, STRICKLER, L AN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Post Judgment Interrogatories of Plaintiff to Defendant, Exotic Carriers, Inc., by United States Mail, addressed to the party or attorney of record as follows: Exotic Carriers, Inc. 92 Railroad Street Hasbrouck Heights, NJ 07604 Bumblebee Transport, Inc. 1023 South Rosina Avenue Somerset, PA 15501 By: 3 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS ROBERT W. MELICK, ESQ., ID 205972 110 S. Northern Way, York, PA 17402 (717) 757-7602 / (717) 757-3783 FAX rmelick@gslsc. corn Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STATOD ENTERPRISES, INC. d/b/a No. 13-7074 HARRISBURG AUTO AUCTION, Plaintiff vs. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant CIVIL ACTION -LAW JURY TRIAL DEMANDED POST JUDGMENT INTERROGATORIES OF PLAINTIFF TO DEFENDANT, EXOTIC CARRIERS, INC. SET NO. 1 To: Exotic Carriers, Inc. 92 Railroad Street Hasbrouck Heights, NJ 07604 The Plaintiff, by its counsel, Robert W. Melick, Esquire and GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby demands that the above-named Defendant answer the following Interrogatories, under oath, pursuant to the Pennsylvania Rules of Civil Procedure within thirty (30) days after date of service hereof. These Interrogatories shall be deemed continuing, so as to require supplemental answers if the affiant or anyone on Defendant's behalf obtains further information between the time the answers are served and the time of execution on the judgment. The foregoing instructions are deemed to be incorporated in the Interrogatories,. which must be answered strictly in accordance with those instructions. GENERAL INSTRUCTIONS A. If the Interrogatory is answered based upon information not within the affiant's direct personal knowledge, identify the person and records supplying the information in accordance with all of the following instructions concerning the identification of persons and records. B. The word "Describe" when referring to an inspection, which is deemed to include the terms analysis, comparison, evaluation, test or investigation request the following information: 1. Identify the person or persons conducting the inspection in accordance with the instructions for identifying persons; 2. State the purpose of the inspection; 3. Summarize the method and procedure used in conducting the inspection; 4. Set forth the result of the inspection; 5. Give the date of the inspection; 6. State if a report or other writing was made of or concerning the inspection; 7. Identify the report or other writing in accordance with the instructions for identifying documents; and 8. State whether the inspection was conducted in the ordinary course of the Defendant's business. C. The word "Identify" when referring to persons request the following information about the person: 1. Name, nicknames, maiden name, married name and alias; 2. Residence and business addresses; 2 3. Residence and business telephone numbers; 4. Job title, position and description of association with any party; 5. Duties with any party; 6. Dates of association with any party; 7. Name, address and telephone number current association if no longer associated with the Defendant; 8. Educational and professional background; and 9. If an outside consultant, state the name and address of persons, employer and the dates that he/she performed the service for the Defendant. D. The word "Identify" when referring to a corporation, partnership, proprietorship, unincorporated association, trust, government agency, or other entity, request the following about the entity: 1. Name and fictitious name registrations (including all information recorded in such registrations and the date and location of the registrations); 2. Addresses; 3. Type and form of entity; 4. Nature of relationship with any parties; and 5. Date and relationship with any party. E. The word "Identify" when referring to a record; which is deemed to include but not be limited to mean, any report, memorandum, writing, correspondence, tape, audio reproduction, computer program, notes, or other manual, stenographic, mechanical, or electronic form of record; request the following information: 3 1. Description of the type of record; 2. Title of record and date it was made; 3. Detailed description on the contents and subject matter of the record (or provide a copy of the record); 4. Identification of the person or persons contributing to drafting and making the record; 5. Identification of the custodian of this record in accordance with the instructions for identifying persons; 6. The current location of the records; 7. Whether the record was made in the ordinary course of business and, if not, the circumstances under which it was made; 8. The reason why the record was kept or not kept. Each Interrogatory and subpart is deemed severable. If an objection is made to answering any Interrogatory or subpart thereof, the remainder should be answered. Your answers are not limited by the space provided. Attach additional sheets referencing your answer to each Interrogatory as needed. INTERROGATORIES 1. Identify all persons who contributed to the preparation of the responses to these Interrogatories. ANSWER 2. List the names and home addresses of all shareholders, officers, directors, members of the Defendant from August 1, 2008 to the present, indicating the status of each person. ANSWER 5 3. Identify any accountant who provided services to the Defendant from August 1, 2008 to the present. ANSWER 4. Did the Defendant sell its business within the past 18 months? ANSWER 6 5. If the answer to the preceding Interrogatory is in the affirmative, state: a) Identify the buyer of the business; b) Identify the selling price of the business; and c) Identify the form of consideration (i.e. cash, check or some other method of payment); ANSWER 6. Were the proceeds of the sale placed in a checking, savings or other type of an account with a financial institution? ANSWER 7 7. If the answer to the preceding Interrogatory is in the affirmative, state: a) The date and the amount of the initial deposit; b) The name and address of the financial institution in which it was deposited; c) The name or names and account numbers in which the account was maintained; and List the dates and amounts of all deposits and disbursements since the initial deposit and to whom the disbursements were paid. ANSWER 8 8. Identify all bank accounts, savings accounts, certificates of deposit, trusts, annuities and/or brokerage accounts of any kind maintained by you or any related entity that are not listed above during the period of August 1, 2008 to the present, including without limitation: a) The institution's name; b) The institution's address; c) The account number; d) Each name in which the account was/is held; and e) The value of the account for each month from January 1, 2008 through the present. ANSWER 9 9. Describe any and all transfers of assets other than those described above that you made during the period of August 1, 2008 to the present, including but not limited to: a) The identity of each asset transferred; b) The name and address of each transferee; and c) The consideration that you received. ANSWER 10. Identify any and all judgments against you, other than the one in this action, including, but not limited to: a) The name and address of the creditor; b) The name and address of creditor's attorney; c) The amount of the judgment; d) The name of the Court that entered the judgment; and e) The docket number. ANSWER 10 11. Identify any and all judgments entered in your favor including but not limited to: a) The name and address of the debtor; b) The name and address of debtor's attorney; c) The amount of the judgment; d) The name of the Court that entered the judgment; and e) The docket number. ANSWER 12. State the names and addresses of any and all persons whom the Defendant believes owes the Defendant money, and set forth in detail the amount of money owed, the terms of payment, and whether or not the Defendant has written evidence of this indebtedness, and if so, the location thereof. ANSWER 11 13. State whether or not the Defendant maintains any safety deposit boxes. If so, include the name of the institution, branch or branches, and the identification number or other designation of the box or boxes. Include a full description of the contents and the amount of cash among those contents. If the Defendant maintains any of these jointly with another person/entity, give the full name and address of that person/entity. ANSWER 14. Identify any and all vehicles owned by Defendant, including but not limited to: a) The year, make, model of the vehicles; h) Any liens held against the vehicles by any financing company; c) The date and location of purchase of the vehicles; and d) Whether the vehicles are used exclusively for the Defendant's work. ANSWER 12 15. State the name, residence and relationship with Defendant of the person who is verifying these answers. ANSWER Dated: GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS I (- , 2014 By: -77 13 ROBERT W. MELICK, ESQUIRE Attorney I.D. No. 205972 110 South Northern Way York, Pennsylvania 17402 Telephone (717) 757-7602 Fax (717) 757-3783 rmelick@gslsc.com Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, Plaintiff vs. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant No. 13-7074 CIVIL ACTION -LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 1day of 4.0 , 2014, I, Robert W. Melick, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Post Judgment Interrogatories of Plaintiff to Defendant, Exotic Carriers, Inc., by United States Mail, addressed to the party or attorney of record as. follows: Exotic Carriers, Inc. 92 Railroad Street Hasbrouck Heights, NJ 07604 By: 15 Bumblebee Transport, Inc. 1023 South Rosina Avenue Somerset, PA 15501 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS ROBERT W. MELICK, ESQ., ID 205972 110 S. Northern Way, York, PA 17402 Telephone (717) 757-7602 Fax No. (717) 757-3783 rmelick@gslsc.com Attorney for Plaintiff STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, Plaintiff v. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendants Couutp of €umberianb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2013-07074 CIVIL TERM IN RE: MOTION TO COMPEL RESPONSES TO POST JUDGMENT INTERROGATORIES OF PLAINTIFF TO DEFENDANT, EXOTIC CARRIERS, INC. SET 1 or ORDER OF COURT AND NOW, thisday of June 2014, upon consideration of Plaintiff's Motion to Compel Responses to Post Judgment Interrogatories of Plaintiff to Defendant, Exotic Carriers, Inc. Set 1, a RULE is issued upon Defendant Exotic Carriers, Inc. to show cause why the relief requested should not be granted. PLAINTIFF shall effectuate service of this Order of Court upon Defendants. Plaintiff shall file proof of service prior to this Court entertaining a Motion to Make Rule Absolute. Plaintiff SHALL include a proposed Order with her response. RULE RETURNABLE twenty (20) days from the date of service. Distribution: , 1 obert W. Melick, Esq. Exotic Carriers, Inc. ,—Bumblebee Transport, Inc. C.c'p eS 1 i 1../ fr) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, Plaintiff vs. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant No. 13-7074 CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in this matter for Plaintiff Statod Enterprises, Inc. d/b/a Harrisburg Auto Auction. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By Charles T. Yog; Jim Attorney I.D. No. 80680 110 S. Northern Way York, PA 17402 Phone: 717-757-7602 Fax: 717-757-3783 E-mail: cyoung@gslsc.coin Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, Plaintiff vs. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant No. 13-7074 CIVIL ACTION -LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Charles T. Young, Jr., hereby certify that on this I / " day of June 2014, a true and correct copy of the foregoing Praecipe for Entry of Appearance was served by U.S. first-class mail, postage prepaid, upon the following: Exotic Carriers, Inc. 92 Railroad Street Hasbrouck Heights, NJ 07604 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By Charles T. Yng, 4r. Attorney I.D. No. 80680 110 S. Northern Way York, PA 17402 Phone: 717-757-7602 Fax: 717-757-3783 E-mail: cyoung@gslsc.com Attorneys for Plaintiff PROTH N '1,=,i 20 1 fs JUN 12 PM 12: , 7 CUMBERLAND COUNTY IN THE COURT OF coatiO M§ A OF CUMBERLAND COUNTY, PENNSYLVANIA STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, Plaintiff vs. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant No. 13-7074 CIVIL ACTION -LAW JURY TRIAL DEMANDED PROOF OF SERVICE OF THE COURT'S ORDER OF JUNE 5, 2014 I, Charles T. Young, Jr., hereby certify that on the 11 / day of June 2014, a true and correct copy of the Court's Order of June 5, 2014 (See Exhibit "A"), was served upon Defendant Exotic Carriers, Inc., 92 Railroad Street, Hasbrouck Heights, New Jersey 07604, by United States first-class mail, postage prepaid. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By Charles T. o ng; Jr. Attorney I.D. No. 80680 110 S. Northern Way York, PA 17402 Phone: 717-757-7602 Fax: 717-757-3783 E-mail: cyoung@a,gslsc.com Attorneys for Plaintiff EXHIBIT "A" LAW OFFICES GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS ROBERT M. STRICKLER ROBERT A. LERMAN° PETER D. SOLYMOS CHARLES 8. CALKINS PAUL G. LUTZ' MICHAEL B. SCHEIB* THOMAS B. SPONAUGLE°+ °Also Member MD Bar 'LL.M (Taxation); also Member CT Bar "Also Member NY and D.C. Bars +Board Certified Civil Trial and Pretrial Practice Advocate by the National Board of Trial Advocacy June 11, 2014 Exotic Carriers, Inc. 92 Railroad Street Hasbrouck Heights, NJ 07604 110 S. NORTHERN WAY YORK, PENNSYLVANIA 17402-3737 TELEPHONE (717) 757-7602 FAX: (717) 757-3783 EMAIL: infol0aslsc.com WEBSITE: www.asisc.com Charles T. Young's EMAIL: cyounclOosIsc.com ROBERT H. GRIFFITH (1928-2009) ANN MARGARET GRAB JOHN C. PORTER— ROBERT D. O'BRIEN CHARLES T. YOUNG, JR.k -Also Member NJ Bar nAlso Member NY Bar Re: Statod Enterprises, Inc., d/b/a Harrisburg Auto Auction vs. Bumblebee Transport, Inc. and Exotic Carriers, Inc.; Cumberland County C.C.P. No. 13-7074 Civil Term Dear Sir/Madam: Enclosed please find a copy of the Court's Order of June 5, 2014. Very tfu/l.y youfs, CHARLES T. YOUNG, JR. Enclosure STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, Plaintiff v. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendants Countp af Cumbertanb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2013-07074 CIVIL TERM IN RE: MOTION TO COMPEL RESPONSES TO POST JUDGMENT INTERROGATORIES OF PLAINTIFF TO DEFENDANT, EXOTIC CARRIERS, INC. SET 1 tor ORDER OF COURT AND NOW, this day of June 2014, upon consideration of Plaintiff's Motion to Compel Responses to Post Judgment Interrogatories ofPlaintiff to Defendant, Exotic Carriers, Inc. Set 1, a RULE is issued upon Defendant Exotic Carriers, Inc. to show cause why the relief requested should not be granted. PLAINTIFF shall effectuate service of this Order of Court upon Defendants. Plaintiff shall file proof of service prior to. this Court entertaining a Motion to Make Rule Absolute. Plaintiff SHALL include a proposed Order with her response. RULE RETURNABLE twenty (20) days from the date of service. Distribution: Robert W. Melick, Esq. Exotic Carriers, Inc. Bumblebee Transport, Inc. Tho A. Placey C.RJ. 3n. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, Plaintiff vs. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC., Defendant � L; Clibt8F:R4 AND/ YL, VA IfilA No. 13-7074 CIVIL ACTION -LAW JURY TRIAL DEMANDED PROOF OF SERVICE OF THE COURT'S ORDER OF JUNE 5, 2014 ON BUMBLEBEE TRANSPORT I, Charles T. Young, Jr., hereby certify that on the (� day of June 2014, a true and correct copy of the Court's Order of June 5, 2014 (See Exhibit "A"), was served upon Defendant Bumblebee Transport, 220 Hedges Avenue, East Patchogue, New York 11772, by United States first-class mail, postage prepaid. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By Charles T. Y • r. Attorney I.D. No. 80680 110 S. Northern Way York, PA 17402 Phone: 717-757-7602 Fax: 717-757-3783 E-mail: cyoung@gslsc.coin Attorneys for Plaintiff EXHIBIT "A" LAW OFFICES GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS ROBERT M. STRICKLER ROBERT A. LERMAN° PETER D. SOLYMOS CHARLES B. CALKINS PAUL G. Luiz' MICHAEL B. SCHEIB* THOMAS B. SPONAUGLE°+ °Also Member MD Bar 'LL.M (Taxation); also Member CT Bar 'Also Member NY and D.C. Bars +Board Certified Civil Trial and Pretrial Practice Advocate by the National Board of Trial Advocacy June 18, 2014 Kamil N. Pilip Bumble Bee Transport 220 Hedges Avenue East Patchogue, NY 11772 110 S. NORTHERN WAY ROBERT H. GRIFFITH (1928-2009) YORK, PENNSYLVANIA 17402-3737 TELEPHONE: (717) 757-7602 FAX: (717) 757-3783 EMAIL: infoeoslsc.corn WEBSITE: www.oslsc.com ANN MARGARET GRAB JOHN C. PORTER - ROBERT D. O'BRIEN CHARLES T. YOUNG, JR .» Charles T. Young's EMAIL: cyouno(Ct7osIsc.corn -Also Member NJ Bar »Also Member NY Bar Re: Statod Enterprises, Inc., d/b/a Harrisburg Auto Auction vs. Bumblebee Transport., Inc. and Exotic Carriers, Inc.; Cumberland County C.C.P. No. 13-7074 Civil Term Dear Mr. Pilip: Enclosed please find a copy of the Court's Order of June 5, 2014. Very lyyyo CHARLES T. OUNG, JR. Enclosure 5' STATOD ENTERPRISES, INC. d/b/a HARRISBURG AUTO AUCTION, Plaintiff V. EXOTIC CARRIERS, INC., BUMBLEBEE TRANSPORT, INC„ Defendants Coat? of Cumberiamb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2013-07074 CIVIL TERM IN RE: MOTION TO COMPEL RESPONSES TO POST JUDGMENT INTERROGATORIES OF PLAINTIFF TO DEFENDANT, EXOTIC CARRIERS, INC. SET 1 0. ORDER OF COURT AND NOW, this day of June 2014, upon consideration of Plaintiff's Motion to Compel Responses to Post Judgment Interrogatories of Plaintiff to Defendant, Exotic Carriers, Inc. Set 1, a RULE is issued upon Defendant Exotic Carriers, Inc. to show cause why the relief requested should not be granted. PLAINTIFF shall effectuate service of this Order of Court upon Defendants. Plaintiff shall file proof of service prior to this Court entertaining a Motion to Make Rule Absolute. Plaintiff SHALL include a proposed Order with her response. RULE RETURNABLE twenty (20) days from the date of service. Distribution: Robert W. Melick, Esq. Exotic Carriers, Inc. Bumblebee Transport, Inc. Thom -s A. Placey C.P.J. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY of Climb , 4 4' OFF ;GE QF THE KRFF FILED -OFFICE OF THE PROTHONOTARY 2tI4 OCT Al AIM CUMBERLAND COUNTY PENNSYLVANIA Statod Enterprises, Inc. vs. Exotic Carriers, Inc. (et al.) Case Number 2013-7074 SHERIFF'S RETURN OF SERVICE 03/03/2014 09:55 AM - Ryan Burgett, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Beth Ann Eppley, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 4, 2014 to Exotic Carriers, Inc. at 92 Railroad Avenue, Hasbrouch Heights, NJ 07064 and to Bumblebee Transport, Inc. at 10235 Rosina Avenue, Somerset, PA 15501. 10/08/2014 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. SHERIFF COST: $100.95 SO ANSWERS, October 08, 2014 RONNY R ANDERSON, SHERIFF • s -V ad/ 9,7go 34)-00 (c) CountySeite Sheriff, Teleosoft, Inc.