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HomeMy WebLinkAbout13-7082 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW C.A. CUR T CO d /b /a SPECIALTY STEAK SERVICE �V,r Plaintiff No. vs , ENOLA DINER, LLC and rn tn r iM' MOHAMED KHALIL C n CIVIL ACTION 3> ry Defendants : d-- = P - ) CONFESSION OF JUDGMENT Pursuant to the authority contained in the confession of judgment provision set forth in the Agreement attached as Exhibit "A" of the Complaint filed in this action, I appear for the Defendants, ENOLA DINER, LLC and MOHAMED KHALIL, and confess judgment in favor of Plaintiff and against the Defendants as follows: Principal $6,314.33 Interest $214.86 Attorneys fees $1.262.86 TOTAL $7,792.05 AMATO KEATING AND LESSA, P.C. By: Mic ael R. Lessa, Esq., Atty ID #88617 Attorney for Plaintiff 107 North Commerce Way Bethlehem PA 18017 (610) 866 -0400 `JUDGMEN N . - D "BOVE Prathono ary /Clerk -of Court "L — Civil Division _ C �44/ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW C.A. CURTZE CO d /b /a : SPECIALTY STEAK SERVICE No. rrj Plaintiff °C--4 - L vs ENOLA DINER, LLC and MOHAMED KHALIL 2-- c a CD — c CIVIL ACTION p - Defendants : = COMPLAINT FOR CONFESSION OF JUDGMENT FOR MONEY UNDER RULE 2951(b) Plaintiff files this civil action pursuant to Pennsylvania Rule of Civil Procedure 2951 (b) for judgment by confession and avers the following: I. The Plaintiff, C.A. CURTZE CO d /b /a SPECIALTY STEAK SERVICE, is located at 1717 East 12` Street, Erie PA 16512. 2. The Defendant, ENOLA DINER, LLC, is located at 700 Valley Road, Enola PA 17024. 3. The Defendant, MOHAMED KHALIL, is an adult individual with a last known address of 700 Valley'Road, Enola PA 17024. COUNT C.A.; CURTZE CO d /b /a SPECIALTY STEAK SERVICE vs ENOLA DINER, LLC 4. On or about April 10, 2013, Defendant, ENOLA DINER, LLC, for good . and valuable consideration received, executed and delivered to Plaintiff a written Application/Credit Agreement ( "Agreement "), a true and correct copy of which is attached hereto, made a part hereof and marked Exhibit "A." 5. Pursuant to the Agreement, Defendant, ENOLA DINER, LLC, agreed to make timely monthly payments to Plaintiff. i 6. Defendant, ENOLA DINER, LLC, has failed to make timely payments to Plaintiff under the Agreement. 7. Defendant, ENOLA DINER, LLC, is currently in default of the Agreement by virtue of its failure to make timely payments to Plaintiff under the Agreement. 8. As a consequence of the foregoing default, Defendant, ENOLA DINER, LLC, is indebted to Plaintiff in the following amount: Principal $6,314.33 Interest $214.86 Attorneys fees $1.262.86 TOTAL $7,792.05 9. A Statement of Account, showing the principal balance(s) due, is attached hereto, made a part hereof and marked Exhibit "B." 10. Pursuant to the terms and provisions of the Agreement, Plaintiff exercises its option to confess judgment for the entire sum of money which may be due or become due under the attached Agreement. 11. The attached Agreement has not been assigned by Plaintiff. 12. Judgment has not been entered on the attached Agreement in any jurisdiction. 13. Judgment is not being entered against a natural person in connection with a consumer credit transaction. WHEREFORE, Plaintiff demands judgment against Defendant, ENOLA DINER, LLC, in the sum of $7,792.05, plus costs as authorized by the confession of judgment provision of the attached Agreement. COUNT II C.A. CURTZE CO d /b /a SPECIALTY STEAK SERVICE vs MOHAMED KHALIL 14. Plaintiff, C.A. CURTZE CO d /b /a SPECIALTY STEAK SERVICE, incorporates the allegations of every paragraph enumerated above of this Complaint as if said paragraphs were fully set forth here at length. 15. The aforementioned Agreement contained a Personal Guarantee wherein Defendant, MOHAMED KHALIL, ( "Guarantor ") personally guaranteed the repayment of any and all money due under the attached Agreement. 16. In reliance upon the written representations, promises and guarantee of Guarantor, Plaintiff provided the financial consideration in the attached Agreement to Defendant, ENOLA DINER, LLC, in the amounts indicated below. 17. As a result of the aforesaid breach by Guarantor of his representations, promises and guarantee to repay Plaintiff, Plaintiff has suffered damages in the following amount: Principal $6,314.33 Interest $214.86 Attorneys fees $1 TOTAL $7,792.05 18. Pursuant to the terms and provisions of the Agreement, Plaintiff exercises its option to confess judgment for the entire sum of money which may be due or become due under the attached Agreement. 19. The attached Agreement has not been assigned by Plaintiff. 20. Judgment has not been entered on the attached Agreement in any jurisdiction. 21. Judgment is not being entered against a natural person in connection with a consumer credit transaction. WHEREFORE, Plaintiff demands judgment against Defendant, MOHAMED KHALIL, in the sum of $7,792.05, plus costs as authorized by the confession of judgment provision of the attached Agreement. AMATO KEATING AND LESSA, P.C. By: J ichael R. Lessa, Atty ID #88617 Attorney for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866 -0400 VERIFICATION i the �� �� M of tl+, hereby states that he/she s l -�J � 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. Section 4904 relating to unsworn falsification to authorities. F CAA'. CIARM E CO. / SP,ECIALTY 5 7'EAdC SERVICE 1717 EAST 12TH ST., ERIE, PA. 16611 CREDIT APPLICATION BUSINESS INFORMATION: _ Legal Name of Business Entity ( "Purchaser~'): o5ne La f`` %n e Y Trade Name (Doing Busines as): Federal Emp foyer ID No. BILL TO ' SNIP TO Name: Name: en . 4 `'�Attdress: _ id CA �Y � ' "V - '. Address: City, State ZIP: f102 City, State le 6 1 zIP: _ z� Tel. No.: x No.: Tel. No.: ( Fax No.: E -mail Address: E -mail Address: Length of time doing business under above name and IJEL—j 6- S 0%je5S List of other names and addresses under which you have operated within the last 5 (five) years OWNERSHIP (I One) Individu Proprietorship Partnership Corporation LLC If Corporation or LLC , give date of Ariicl nd state: Date State: If Partnership, Is Certification filed? YesNO__-_ Date City, State Total Purchases are approximately $ (d One) weekly monthly Complete the following information for (Corporate Officers, Principal Stockholder(s), Partners, or Individual Owner(s): Name & Tide: d LZ l4 �n t P Name & •Title: {�� 8- t o� Home Address: 3 Home Address _o ?7 Cisi►YG)b C.1M'm �— City, State, Zip: j21 City, State, Zip: How long associated wt business: How long associated w/ business: Tel. No.. SS #: ' Io?�' Tel. No.: SS #: Have you or any other principal participated in either a corporate or personal bankruptcy within the last five years? yes. �Gno. If so, under what name? Have you or any of the other principals been a customer of C. A. Curtze Co under a different name or address? yes. _no. If so, please complete the following: Dates: FROM Mo. Yr. T17' Mo. Yr. Name: Address: City State BUSINESS REAL ESTATE: Business Real Estate is (check one): Owned Mortgaged Leased Premises is mortgaged /leased from: Name: Address: EXHIBIT Contact: Tel No. • J Q Q i BUSINESS EQUIPMENT: Business Equipment/Personal Property is: K Owned Leased Subject to Lien Name of Lessor/Llen holder: Name: Address: Contact Tel No. TRADE REFERENCES (preferably food distributors: cannot accept beer or liquor distributors as references) c�i2tl - /ZD Hr4 nos u/ 'ob 33 tz< Business Name Address Tel. No. © .aJ -e 1 — SAY RCA Business Name Address let. No. Business Name Address Tel. No. Business Name Address Tel. No. BANK REFERENCES Please attach voided check from business ac ;N Name: J�t1 �.'`'i� f�-s � / Account No.: � `�y ��Q Address: 4 C Te(. No_ IJ 2 .3 Contact: 13 t �c� GENERAL INFORMATION: No. of Employees: Seating Capacity. Estimated. Monthly Sales Buyer[Purchaser Contact Accounts Payable Contact Name: Name: Phone: Phone: INFORMATION REGARDING TAX EXEMPTION - ' 13l. AN KET -SALESTAX "12ESAL!~,CERTIFIGAtE. :. PUFZCHASirR HEREBY CEkT1.F.iES Ta : cu R - CO THRT;::' c :' {( f) ,:.• .: Purchaser •holds dar�ti regisfon, peiiit huber - ' a r fertba:Sales Tex tdw" oCtAe Sta__te of 7tl4 tan purCha;ed: n'eacb order giYe,''utllpz%'suoh order Shall olhervrlse specify teal until tots notice -, is;reVOked by:us in wrl6ri�.is hecl(oriB�. ,;• ,? . , . _ iQr resate.reposted on,s�l0s'thx illh2i. As dales -of taA6iblo personal property - ' •• Exempt gi:carise:we are:Tax Exempt- Instttutton, (1 attach-copy of Tax Exempt Letter), 00 9! otlierreasons, °: Please explain: 'The hawill asst rhe:liabili for payment'of tax ii. he uses or consumes the property.he(eln purchased iri such manlier as to render the. sales subject to tax. REGUTATIONS PR[?VtOE THAT CERTIFICATE Ml1S,T H/1VE.REG[$TftATION NUMBER ADDRESS AND SIGNATURE IN prtt}ER _ TO SE EFFECTIVE. (This certificate is to be considered a part of each of Purchasers. orders). ; Pu► Name and Address: " BY' Print 'Title: Date: TERMS OF SALE ON CREDIT /CREDIT AGREEMENT /PERSONAL GUARANTEE (PLEASE READ THIS SECTION BEFORE SIGNING) 1. The Undersigned hereby represents that he is duty authorized to sign this Application /Credit Agreement on behalf of the above named Purchaser and the terms of this Application /Credit Agreement will be binding upon such entity. 2. The Undersigned attest the above statements are true, and authorize the investigation of all information listed in this Application/Credit Agreement. 3. The Purchaser agrees to notify C. A. Curtze Co. / Specialty Steak Service ('Curtze ") by certified mail of any change in ownership of Purchaser. Q. ' All amounts due Curtze'are payable In accordance with the payment terms granted by Curtze's Credit Department. Any amount due Curtze not paid In accordance with such payment terms will be assessed a finance charge of one and one -half percent(1.5 %) per month. Purchaser shall pay for all attorneys fees, collection costs, and court costs incurred by Seller in the event the account is turned over, to an attorney or other agency for collection, suit Is brought or the account is collected through any judicial proceeding whatsoever. ,5. Purchaser shall pay on each occurrence of checks returned unpaid by Purchaser's bank, a service charge of twenty -five dollars ($25.00). 8. In the event the Purchaser violateslhe terms.of this Agreement the Undersigned authorizes any Prothonotary, or any attorney of any court of. record In this State or etsowhere, to confess judgment or judgments against the Undersigned and Purchaser and in favor•of the. holder hereof for the balance due, together with the costs of suit and reasonable attorney's fees, with or without declaration, release of errors and without stay of execution; and for value received does waive the right and benefit of any present or future law of this or any other state exempting property, real or personal, from levy and sale on execution; and, if levy be made on real estate, does also waive the right of inquisition and consents to the condemnation thereof with full liberty to sell the same on Writ of Execution, with release of errors thereon. 7. Credit terms are subject to change at Seller's discretion at any time. 8. As a condition of C.A. Curtze Co, a /d/b /a Specialty Steak Service extending credit to Purchaser, the Undersigned hereby personally guarantees payment in full to C. A. Curtze Co. a /d /b/a Specialty Steak Service including delinquency charges, collection costs and attorneys fees, and waive any presentment, demand, protest, and any other notice from C. A. Curtze Co. a /d/b /a Specialty Steak Service regarding this guarantee of payment. It is further agreed the use of titles with respect to the individual signatures below shall have no legal significance and in no way be construed to relieve the undersigned from personal obligations under this paragraph. 9. As consideration for Curtze extending credit to Purchaser, and in accordance with the Pennsylvania Uniform Written Obligations Act, the Undersigned and the Purchaser agree to be legally bound by the terms and conditions in this Application /Credit Agreement including the personal guarantee provisions contained herein. The Undersigned hereby certifies that all the'information on this Credit Application is correct, and that Itwe fully understand credit terms and conditions set forth above, and agree to the terms and conditions as consideration for credit extended by Curtze, Account -=a Name: Gylo Ay L4b(f6Q L- Signature: °--°`^ "Date: t "i � (Type or Print Name of "Purchaser") (INDIVIDUALLY) Print Name: /li Signature: Date: (INDIVIDUALLY) Print Name: 12 40ER OM e acmenuASED CHARGE PAYMENT SUMMARY m 1 INVOICE INVOICE MEW EW 31-9 61-'% WEt-98 PYp M NXMM DATE INMCE IWICE IMCE INVOICE CRB175 CD RIF. DATE m BXM '� EMU DItF1� 12290 7/81113 67.67 67.67 67.67 IS$ 717 - 888 -9156 149MS 8/61/13 68.68 mum 977327 5115/13 68.68 136.35 1284.12 1284.12 PY 1116 6187/13 x,35 -48.88 RV ills 6112/13 176.35 -4t8A RV 1118 6/18/13 21&35 -M&el RV 1118 6!21/13 2448.88 2576.35 486295 5/24/13 788.38 725.14 PY 1118 6/87113 53.24 2631,98 991818 5/31113 2816.87 . CiR?7ZE LUSTO:EI{ TUT& S t 68.68 2816.87 2815.87 4647.66 4647.66 - 67.67 . 2495.24 EnA DDER 367556 5124113 7EL97 31.98 CR 29927 5/28/13 673.99 67399 SSS 717 ,888 -SL% 378991 SI31 /13 943.78 Nmm 6161955 7/81/13 24.27 94378 1617.77 6335815 8181/13 24.63 24.27 1642.84 3/S CUSiDN`it TTJ u em 24.63 9Q78 24.63 1556.67 2427 SM 94 1666.67 COJ48m CUmpo mm 9331 2959.85 6314.33 31.94 3169.23 CFEDI7 LDIIf...... lease se i II . ALL -STATE LEGAL® i m' x MRM SM 7DT9L tsi 68.68 2816.87 4647.66 67.67 2495.24 &7-Cf1f82EM 68.68 67 31-M 67.67 61 -51-98 2016.@7 8T -{BiER 98 249124 6PEDWY 6W MT(L 24.63 94378 1665.67 24.27 67399 &T- Qlf8ttl+if ?4.53 BT -31-W 24.27 63 -61-98 943.78 BT -0V£R 673.99 COMM Bf81ND TUFL 9131 2959.85 6314.33 91.94 3169.23 User: ahalces Host: csrtze Class: cm-tze Soh: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW C.A. CURTZE CO d/b /a SPECIALTY STEAK SERVICE No. Plaintiff vs ENOLA DINER, LLC and MOHAMED KHALIL CIVIL ACTION Defendants CERTIFICATION OF ADDRESSES OF PARTIES I, Michael R. Lessa, attorney for Plaintiff, hereby certify that the last known address for the Plaintiff and Defendants are as follows: C.A. CURTZE CO d /b /a SPECIALTY STEAK SERVICE 1717 East 12`" Street Erie PA 16512 ENOLA DINER, LLC 700 Valley Road Enola PA 17024 a:) , MOHAMED KHALIL 700 Valley Road Enola PA 17024 c CD =C:) AMATO KEATING AND LESSA, P.C. By: Mich el R. Lessa, Esq., Atty ID 488617 Attorney for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866 -0400 i COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW C.A. CURTZE CO d/b /a j SPECIALTY STEAK SERVICE j No. Plaintiff vs ENOLA DINER, LLC and MOHAMED KHALIL CIVIL ACTION Defendants AFFIDAVIT OF NON - MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON The undersigned, being duly sworn, according to law, deposes and says that he is unable to determine whether or not the above Defendant is /is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of The Servicemembers Civil Relief Act; That Mohamed Khalil is over 18 years of age, is located at 700 Valley Road, Enola PA 17024 and is employed. G " r,,, CD. = C, Sworn to and subscribed CD k before me this,;j)- of fJn - 2013 A.D. : NOTARY PUBLU COMMONWEALTH OF PENNSYLVANIA Notarial seat public Michelle C. Bright, Notary City of Bethlehem, Northampton County My Commission Expires June 6, 2015 MgMBERi pEryhgpEyARiA A ggOEIAT{ON OF NOTARIES COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW C.A. CURTZE CO. d/b /a SPECIALTY STEAK SERVICE No. Plaintiff vs ENOLA DINER, LLC and MOHAMED KHALIL CIVIL ACTION Defendants AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON The undersigned hereby certifies that the attached Complaint for Confession of Judgment for Money Under Rule 2951(b) is not being entered against a natural person in connection with a consumer credit transaction. This action does not arise out of a retail installment sale, contract or account. The transaction upon which the judgment is being entered was a business transaction. SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF �J uA-- � 013 NOTARY PUBLIC r" r r, C Ws cra r { "" LTH OF .PENNSYLVANIA ;, COMMON JEA > a'o , Notarial seat Public Michelle C. Bright, Notary ; Northampton County �y City of Bethlehem, Tres ]une 6,2015 ,� My Commission Exp 9. MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW C.A. CURTZE CO d /b /a SPECIALTY STEAK SERVICE No. I - Plaintiff vs ENOLA DINER, LLC and MOHAMED KHALIL Defendants CIVIL ACTION NOTICE OF JUDGMENT To: ENOLA DINER, LLC 700 Valley Road Enola PA 17024 Pursuant to Pa. R.C.P. No. 236, you are hereby notified that judgment by confession has been entered against you for $7,792.05 in the above captioned matter. A copy of all documents filed with the prothonotary in support of the within judgment are enclosed. Date: 113 ins_ l PROTHONOT RY - MTY Per: If you have any questions concerning the above, please contact the undersigned. AMATO KEATING AND LESSA, P.C. By: ` /J Michael R. Leesssd, Esq., Atty ID 488617 Attorney for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866 -0400 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW C.A. CURTZE CO d/b /a SPECIALTY STEAK SERVICE D �� Plaintiff . ff vs ENOLA DINER, LLC and MOHAMED KHALIL CIVIL ACTION Defendants NOTICE OF JUDGMENT To: MOHAMED KHALIL 700 Valley Road Enola PA 17024 Pursuant to Pa. R.C.P. No. 236, you are hereby notified that judgment by confession has been entered against you for $7,792.05 in the above captioned matter. A copy of all documents filed with the prothonotary in support of the within judgment are enclosed. Date: /X/ 3 PROTHONOTA - C BE ND COUN Per: If you have any questions concerning the above, please contact the undersigned. AMATO KEATING AND LESSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 Attorney for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866 -0400 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW • C.A. CURTZE CO d/b/a • SPECIALTY STEAK SERVICE Plaintiff : No. 13-7082 Civil • vs. • • t-) ENOLA DINER, LLC and • MOHAMED KHALIL ` ' -� rn CIVIL ACTION c:" Eefendant(s) CP� `r W cJ "'rs NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEI#61■1 NOTICE OF DEFENDANT'S RIGHTS � ....[ c. TO: MOHAMED KHALIL A judgment in the amount of $7,792.05 has been entered against you and in favor of the Plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper allegedly signed by you. The sheriff may take your money or other property to pay the judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the judgment or to prevent your money or property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR 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 LESSA, P.C. By: � J Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW C.A. CURTZE CO d/b/a SPECIALTY STEAK SERVICE Plaintiff : No. 13-7082 Civil m ="t • vs. cta C C • ENOLA DINER, LLC and MOHAMED KHALIL • : CIVIL ACTION 171 Lefendant(s) • NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON NOTICE OF DEFENDANT'S RIGHTS TO: ENOLA DINER, LLC A judgment in the amount of $7,792.05 has been entered against you and in favor of the Plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper allegedly signed by you. The sheriff may take your money or other property to pay the judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the judgment or to prevent your money or property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR 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 LESSA, P.C. By: \) )`X- Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff I IO'N ; ff,. 0 Cumber/4. Jody S Smith 2'0 FEB 28 PM 3: 3c°w. Chief Deputy , ° _ Richard W Stewart /r UMBERLANJ COUNTY Solicitor PENNSYLVANIA C.A. Curtze Co. Case Number vs. Enola Diner LLC (et al.) 2013-7082 SHERIFF'S RETURN OF SERVICE 02/25/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Enola Diner LLC, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice as"Not Found"at 700 Valley Road, East Pennsboro, Enola, PA 17024. Valley Road Diner is located at this addres and per George the owner he has no affliation with Enola Diner. 02/25/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Mohamed Khalil, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice as"Not Found" at 700 Valley Road, East Pennsboro, Enola, PA 17025.Valley Road Diner is located at this addres and per George the owner he has no affliation with Enola Diner and does not know the defendant. SHERIFF COST: $70.95 SO ANSWERS, February 25, 2014 RONNY R ANDERSON, SHERIFF .nan:y a 0 r? t ^sr.ti