HomeMy WebLinkAbout05-3027
COMMONWEALTH OF PENNSYL.\/ANIA (l; ~(f) 7
COUNTY OF: ctlKBl:JlL.Il.W
09-3-04
NOTICE OF JUDGMENTfTRANSCRIPT
CIVil CASE
NAME and ADDRESS
TRAR'SPOllT, LLC
-,
Mag. Oisl. No.:
PLAINTIFF:
TB 6. B T01f:J:BG 6.
P.O. BOX 1698
I:LDDSBO'llG, MIl
L
21784
MDJ Name: Hon.
TROMAS A. PLACET
Add.,,, 104 S SPOllTXBG RXLL llD
MBCRARXCSBO'llG, PA
-l
17050
DEFENDANT: NAME and ADDRESS
fE. C. GAXDS, I:T AL.
2 APPOMATTOX COO'llT
MBCRARXCSBO'llG, PA 17050
L
VS.
. T,''''oo''. (717) 761-8230
-,
B 6. I: T01f:J:BG 6. TliUUfSPOllT, LLC
P.O. BOX 1698
I:LDDSBOllG, lID 21784
Docket No.: CV-0000127 -05
Date Filed: 3/14/05
-l
1&
""", ~., ,"
THIS IS TO NOTIFY YOU THAT:
""."". Judgment: xl_
[i] Judgment was entered for:
. nR"a.~~,. ,,'1nN~1l~,_, PL'nf
,
~,.
(Name) 'A... R 'I'nwTwa ... 'I'lu.WRPnV'I' T.T.l'
[i] Judgment was entered against: (Name) 'R c all.T_A
in the amount of $
2.207 00 on:
(Date of Judgment)
4/14/05
D Defendants are jointly and severally liable.
D Damages will be assessed on:
D This case dismissed without prejudice.
(Date & Time)
D Amount of Judgment Subject to
Attachment/42 Pa.C.S. 9 8127 $
o Portion of Judgment for physical
damages arising out of residential
lease $
Amount of Judgment $ 2.075.00
Judgment Costs $ . 132.00
Interest on Judgment $ .00
Attomey Fees $ .00
Total $ 2.207.00
Post Judgment Credits $
Post Judgment Costs $
------------
------------
Certified Judgment Total $
ANY PARTY HAS THE RIGHTTO~PPEAL WITHIN30pA YS 1FTERTHEli,NTRY OF JUpGMENT BY,FI!:!NG A N.oTICE
OF APPEAL WITH THE PROTHONOfAIlV1CLERK OFTRE COURT OFCOMMOll I'tEJlS;CIVlL D1VISIOfiIfVOU..' .
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT 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 MAYBE 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 COMPUES WITH THE JUDGMENT.
4\\4\ bG Date
M<).gisterial District Judge
t4
oceedings containing the judgment. .
~
, Magisterial District Judge
My commission expires first Monday of January. 2010 .
SEAL
AOPC 315-05
DATI: PllXRTBD:
4/14/05
2:57:56 PM
Q
~"
",,-
vlT:
IT'1;r-'
.-..,. '-I
~".,. .,',
"7'!
~~~",
~E::,
:Pc:
z
::;!
~-,
~
"'"
=
=
c.n
'-
c::
%
W
~
-<1
~::u
~~
~=H
0-
z~
8
:>
~
;r:>o
:x
'?
UI
ex>
~::f(,~.j !
, NOTICE OF JUDGMENTlTRANSCRIPT
PLAINTIFF: CIVIL CAN~~"dADDAESS
Is &: B TOWIKG &: TRARSPORT, LLC -,
P.O. BOX 1698
BLDBRSBORG, NO 21784
L ~
COMMONWEALTH OF PENNSYLVANIA
~COUNTY OF: ctJIIB~1.~
N
{ .)
Mag. Disl. No.:
09-3-04
MDJ Name: Hon
THOMAS A. PLACBY
Add,." 104 S SPORT:IJIG H:ILL lID
MBCJIAR:ICSBORG, PA
VS.
...... Te'.phone (71 '1) 76 i- 82 3 0
17050
DEFENDANT: NAME and ADDRESS
Ii:. c. GUBBS, BT AL.
2 APPOMATTOX .COORT
MBCBAR:ICSBURG, PA 17050
~.
B &: B TOWIKG &: TRARSPORT, LLC
P.O. BOX 1698
BLDBRSBORG, NO 21784
L
Docket No.: CV-0000127 - 05
Date Filed: 3/14/05
~
THIS IS TO NOTIFY YOU THAT:
. .._._-,..,Judgmem:-4".
,
~ Judgment was entereti for:
.:...,
D.KII'Il."tT ................ Pl:.'1'1I'
'R So. 'If 'l'l\VTW12. So. 'I"D".A'Pn'R'I'
T.T.""
(Name)
~ Judgment was entered against: (Name) .Tn1llRR, lI.nnJlJ.
-,
~
.
./1./0"
.
in the amount of $
(Date of Judgment)
2 207 00 on:
o Defendants are jointly and severally liable.
o Damages will be assessed on:
(Date & Time)
o This case dismissed withOut prej~dice.
Amount of Jl\9,gment
JudgmflntBosts
'!)terest on Judgment
Attomey Fees
,/ Total
O Amount of Judgment SUbject to.
Altachment/42 Pa.C.S. ~127 $;
o Portion of Judgment forphysicpI
damages arising out of residential
lease $
Post Judgment Credits
Post JudgmenlCosts
Certified Judgment Total $
$ 2.075.00
$ 132.00
$ ~OO
$ .00
$ 2.207.00
$
$
, I
==~::;;.::d:====.:::'=
A., NY P~R... TV. HA. ,S THE R..IGHTTO.."if'.... PPEAL'Y. ITHI~30... iDAys1FTE~ T':I./f.., ~.. N. .' !RY ()f JH. .DG~~. WBV".fJ~I.NGA NpT.ICE. .
.. .'.op.A:ppeA:tWITItTHe'PRI)THON(fTjI;R~K'O'F'mE'~F't:rlliI"rm:E1iS~1VlI:i D1V~1!lfl.. ylltJ'.......'..--...---.
MUST INpLUDE:4. COpy o~ THIS NOTICE OFJUDGMENTffRANSCRIPT FORM WITH YOUR NOTICE of APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT 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 MAYBE 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.
~\\4 \llS Date
Magi~te~ial District Judge
, C~~f~~h\~iS is a true a d correct copy of the record of the p oceedings containing the judgment.
<:\ . Date . Magisterial District Judge
My commission expires first Monday of January, 2010
SEAL
AOPC 315.05
DATB PR:IlIITBD:
4/14/05
2:58:16 PH
(")
,,;;
<;.,
-uCb
0; ~'~";
~ic
~..
~.E.~
>c
~
~
~
""
CJ"O
C-
c::::
:x:
~
~:JJ
"hi
:09
00
.....='"
::c "
00
2m
~
Si
-<
w
;po
:It
C?
(J'I
co
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CtJKBBllLAJID
,
i
NOTICE OF JUDGMENTfTRANSCRIPT
CIVIL CASE
NAME af1d ADDRESS
TRAlIISPOIl.T, LLC
-,
09-3-04
PLAINTIFF:
fj &: B TOWJ:lIlG &:
P.O. BOX 1698
BLDBIl.SBURG, MIl
L
21784
Mag. Dist. No.:
MDJ Name: Hon
THOMAS A. PLACBY
Add.." 104 S SPOIl.TI:RG HI:LL RD
IIBCllAJII'I:CSBURG, PA
-.J
VS.
T,I'phoo. (717) 761-8230
17050
DEFENDANT: NAME and ADDRESS
rj:. C. GAI:DS, BT AL.
2 APPOKATTOX COURT
IIBCllAJII'I:CSBURG, PA 17050
L
-,
.....
B &: B TOWIRG &: TRAlIISPOIl.T, LLC
P.O. BOX 1698
BLDBIlSBtJll.G, MIl 21784
Docket No.: CV-0000127-05
Date Filed: 3/14/05
-.J
.
~;'
THIS IS TO NOTIFY YOU THAT:
Judgment:
DI!:l!'Atn,T JtJDt:!InnI"I' PLTl!'
[i]
[i]
Judgment was entered for:
(Name)
'R. &. 11: 'l'nwT1I'r.! &. 'rlU~..J:I:'Dn'D'I'
T.T.I'
Judgment was entered against: (Name)
JOIIKS, RTJOR
.._~.........~
-:)
r
i
,
D
D
D
in the amount of $ 2 2n'7 nn
Defendants are jOin~d se~y hable.
..' '" I-~
....
,~t.-'-' ,
Damages will be as~~~d on",.:' J
".-" ,..' _..~..' ......-:
,."" -
/.. .
This case dismissed wtttr6Ut pre7udice.
on:
(Date of Judgment)
4/14/O!i
-;\"
(Date & Time)
---
-~
/-",
. "--?
D Amount of Judgment-&lPject to,.
Altachment/42 Pa.C.S. ~127 $;'
O Portion of Judgment fOt"'PhYSiGa.;"
damages arising out ofresid~1
iease $ "
--"\
Amount of Judgment $ 2.07-5..00
Judgment Costs $ 13~ro.O
Interest on Judgment $ / .00
Attomey Fees $ .])0
Total $ 2,207.00
Post Judgment Credits $ ,':-"1
Post Judgment Costs $ ~
.J
=============
Certified Judgment Total $ ..,
. -
7
/
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARYfCtERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COpy OF THIS NOTICE QnJUDGMENTrrRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN TM RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER 1liE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE 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.
L\ \ \Lt- \ tt; Date
I I
Magisterial District Judge
I certify that this is a true a d co
4 \ \1\ \ bS Date
eedings containing the judgment.
, Magisterial District Judge
My commission expires first Monday of January, 2010
SEAL
AOPC 315-05
DATB PIl.I:JlITBD:
4/14/05
2:58:33 PM
S
-:3f
(\
~
"":-"
~
~
~
"
/"1
,-r--
~
fJ
~ .~
-
~
~
~
~
~
o
c:::
S~
-oo:~_
rP.r"'-'
-"......,
~5j tJ_~,.
-". ,
r:: c'
!~:'
:PC
~
~ ~
~
~ ~:n
~ -o~
~ 78
~"""
::P" 0"'"
:::J: :O-o?m
'9 ~
()1 'i
c:l
-
--
~
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAN'O COUNTY, PENNSYLVANIA
CIVIL OIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
Bc:fE IOWI~ d-'rQw1fO",T ttt.C
vs.
Fe G-A-I,v~S
AtJJvc. J'OVlt j
flfI..Jfvt .J'o"'~,}
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 ell.... ~.r (h .... ~ County,
for debt, interest and costs, upon the following described property of the defendant(s)
Lt.",! alA h"uJ~k<J(J. 0"''''''' ~ 0-4vJOVl...1 iJl/()~'f''''l'' COMd"'lA.f/
_ - I J /'
E: tr-' J'"f" '" +-
r
PRAECIPE FOR ATTACHMENT EXECUTION
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)
and all other property of the defendant(s} in the possession, custody or control of the said garnishee(s}.
o (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
Signature:
Print Name:
Address:
~_ _ _€:/L.-L
,
f3 vve~ E: lie- \ lA e..1 J'l'
4rt:>D il'> ..,J_ L!>'t.(;~ tf 01
SyhN.(lf. ,.,rot znJXr
Attorney for:
Telephone:
Supreme Court ID No.:
tllO -9R~-cJ" Y6JY
(over)
. .
Notes: If real property, supply six copies of description including improvements and an original and copy of
affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
(") '"
p """ 0
c = ."
en
~ -r..1 t-'_~, <- ~
<P f])r :' c::
,J:., ;;;.:: m:!J
$ -- -Og
(f' 8~
~ .....: W
0'\ ~~~ <- """ ",-,.
:7 C~:' ".0.':0
,.::::-, ' 2 ~o
:1~~:.~ Om
--I
...:-. -,,;
-........ ;p :;:I S:J
~' 0 -<
d' J
~ &;-
\
WRIT OF EXECUTION and/or A TT ACHMENT
COMMONWEALTH OF PENNSYL VANTA)
COUNTY OF CUMBERLAND)
NO 05-3027 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due B & E TOWING & TRANSPORT LLC Plaintiff(s)
From E C GAINES, AUDRA JONES & HUGH JONE, 2 APPOMATTOX COURT,
MECHANICSBURG PA 17050
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON
HOUSEHOLD GOODS, PERSONAL PROPERTY AND COMPANY EQillPMENT .
(2) You are also directed to attach the property of the defendanl(s) not levied upon in the possession
of GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or othenvise disposing thereof;
(3) Ifproperty 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 himlh"r that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $2,207,00 L.L.
Interest
Ally'S Comm % Due Prothy $1.00
Ally Paid Other Costs
Plaintiff Paid $34.25
Date: JUNE 13, 2005
(Seal)
CURTIS R. LONG
proth~n 1
By: .(d-
Deputy
REQUESTING PARTY:
Name BRUCE E. HAINES, SR,
Address: 4500 LONDON BRIDGE ROAD
LONDON BRIDGE ROAD, SYKESVILLE MD 21784
Attorney for:
Telephone: (410) 984-8468
Supreme Court ID No.
~..,.
~
J
Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED, . _ ___,
Sheriff's Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Surcharge
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage
TOTAL $
Advance Costs:
Sheriff's Costs:
150.00
135.72
$ 14.28
18.00
44.14
1.00
11.84
40.00
20.00
Refunded to Atty on 06/30/05
.74
135.72
Sworn and Subscribed to before me
This 61[; day Of0..1~
2005A.D.~. Q ~,~.
thonotary
D}'~~#
~~~i
R. Thomas Kline, Sheriff
CJ~/O-J ~kdlf
By Claudia A. Brewbaker
c:
...,
~
~
-.l
bl :( d (I Nflf ~OOI
V1~M3tikU~1~1'Xo \~5m~J
(fJJ t It: ft '7'.
" 'I < -"
,_ 1-,
/.:
" ,15"
cJe. !:>'CJ 117
UlL.. /1,6'NQ
__..._.jJ-:-L._..7i!~vq}-"'::~e{~'y'C~C
In the Court of Common Pleas of
Cumberland County, Pennsylvania
------------------~-------------------~~f~P--------
w , -
C /' /' judgment in favor of Plaintiff on __n_n_~L2:_Q_~__
....___i'=':<".I.....--__!.!:dt#/;?L_.__.__..________.__ 'J -:) () 1. brJ
/ / ____..~_"_'_____~__________.___ for
.- .___.cU.'Jh__-!fl_0_l;..Lh_'_ .----- .---15,-0----.-- "( c..
fl ~,T No. ~2:__.}{) ~ ___.._iy_,~J.__ Term, 19______
..__.k_clY.t~.__;jQ_oIte). ------- ________m______ C:>'/ 3 ..r "'(0)
Entered __________________________________ ~-~---
.~;~~~~~~~~_:~__~~__;~~_~~-~;---------~~------------ PIainwl
$--------
in the abo....e Judgment, do appear and acknowledge tha.t ~ ~/.I ~ this day have had and received and
! rom . __ _ _ _. __ _. ~ (; _ _ _~dc'A.t'e.L _/ _ E_ 1". __ _Af:.~ _ _ __. _ _ _ - _ -. h -. -- - - -- - - - - -- - - - - - - - - -- - - - - - - - - --.-
the de~endant in the abo\-e Judgment, full payment and .~aisfaction of tbe so.r:te, wi.th interest and costs, and desired that
satisfaction therefore shall be entered upon the records thereof.
And further,.:;:t: do hereby authorize and empower __~_____t___~~____n_n__u___n.
___________._____.__ theProthonotary of said Court, to appear _.f>.:_'tt.__~1Q~{~_~__!._~~
and in OW' name and stead to enter full satisfaction upon the record of said Judgment, as fully and effectually, to all
intents and purposes, as VJ..e... could were ~ personally present in person to do so, And for so doing this shall be
your sufficient warrant of authority.
In testimoD)" whereof,~:::t have hereunto set our hands and seals this ----!-~~--------------------------,-
day of __~~'f:.---------------------------.-----, A.D.J:1'..i1J2??'S'
~A'r--a-:.-~----------------- (Seal)
__.___________________________________________ (Seal)
State of Pennsylvania
County of Cumberland,
}
(Seal]
Personally appeared before me, the subscriber, -------------------------------------------------------------
----------------------------------------------------------------------.------------------------------------
----------------.--------------.-----.--------..-----~~-~~-_._--~------------------------_._-
__c:3_<!_l;,,_]O_~i':!'J_~II!"I(lJIf&LLLk.'-------.:::.-' - ~------ the Plaintiff in the
above Judgment, and in due form of law acknowledged the within and foregoing Power of Attorney to satisfy the Judg~
ment set forth, to be
act and deed, and desired that the Sa.Il1C shall be filed of record in the office of the Prothon-
otary of the Court of Common Pleas of said County_
In testimony whereof, I have hereunto set my hand and seal this ~-_Q..::--__~~ _ --__________
day of -~--.~.7-_eAROl.YN"A~l'OOMr-um- "/f...riE?qy.) '""
N~:~:~~,~, S;:A:~,O: ~~~~ ]J11&ir--{L--~---------uu (Seal)
~
t:
..
"
%
c
~
~
~
"
"
..
..
<2-
\
1a
~
~
~
..
~
~
~
<2-
\
%
~.
j.
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
'Z.
\ ?
\
~~
o
trJ~
ll>
:;:-. 0
~ ~
:.~
~ 0
1 ~
~ ~
\
~
~
~
~
';D
,
,
,
,
Q
~.~
"1;~' \l
\~~,~-\
:[Jc{:.,
f~C'
)?.c,
-:?-; t...:~
"t-..,.c..
'~
:2
q,
~e
-0\3
~J.?, l..
(-:,..\S-,
.......--: -
,.
-" '(} <:
~ :'01
.-'
.~
:..
~
~
~
'"
~
~
.-
....J
~
~1<\N.$.o,~~ry
~
..
a
a
-.J
.....
=
.....
'io
,
U
I if
(
r
.
-
..
a
....
-
...
a
-
=
r
D"
-
..
U1
....
D"
a
a
U1
=
""
....
"
,
'fJ
I
!
!
,
l'
_..-.-..IM.
0"'''
~O)io
0...,<
~i
o
."
.~
~ ~
j; ~
:D oQ
(Jl ~
13>
I'f
ii,
.-/
".":"
"
'. III ., \
:,.,,/:/ ",.1
. ,n"-,' ~
:'.~'~;'
// ,,/' ,''1
.>.. "," <1
.. .;:;:.1:. /,' /)
% .. HI'" 'I
~ p''':'':~ -I'j
'. ~.~S: JJ
hi, .'5. !
'..'.,:,- :< . ~
I >: ~:- i
/' . j
J. )
> ,~
,1'/'
"
-c
'.
~'>
, '
o
~
rn
.<
/>>' ;
'......"'::.:
~//~...
':<-... .
// "
. )":~0~-.;J
. ,:..../,/// ."
......>>''''',.,:-...;:~' <I
,~,</..../z// ,l
,', .......... ",,,"' /,
>";.:):> ">~ ':-'1
>,-"" "'0. (-\
/,/", ,,-,' "",,
<.,' ./ /...< /!
.' ,~""""~"'- ~.,"" ,',
/,/.,://' ,'''':
" . '. '. " ." /..
,'>~.'>'~ ". "-
<.,/"'........'""
:.,,><,,-\:'
///,'/ '. i
" >" ',' ~:-'i
,
/ . ....;,:
" w-': ;-!
..,. '. '<Xl" .
! >Co\)~ ,'~
a: >, ~ ~
~ '~;
, ..~
. ,.
i
.
B & E Towing & Transport
4500 London Bridge Road
Sykesville, Md. 21784
410-549-2720
June 29, 2005
File # 05-3027 - P ".w~b:-p {Jf<0
B & E Towing & Transport vs. E. C. Jaines
To Whom It May Concern,
E. C. Gaines paid the full amount to which they owed B& E Towing &
Transport. Per your office I needed to request a Power of Attorney Form.
I already spoke to Claudia in the sheriff department.
Could you please send the form to the address listed above.
Thank you for your help in this matter.
B& E Towing & Transport
~+'~
Carolyn Haines
r~r~~~~~~
~ a..-t-l qwt p..... p~ ~~ ~ ;Q-rw
Jw ~ ~ ~ R.J?"(5'
,~(l ~,~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DANA G. GROSS, trading and doing
business as MID-STATE GUTTERPRO,
Plaintiff
v.
PEMFO PACKAGING CO., INC. and
COMPASS
INTERNATIONAL, INC.,
Defendants
CIVIL DIVISION
CASE NUMBER: 04-3027
ISSUE NUMBER:
PLEADING:
Response of Defendant, Compass
International, Inc. to Plaintiffs Motion to
Compel Discovery
CODE AND CLASSIFICATION:
FILED ON BEHALF OF:
Compass International, Inc., Defendants.
COUNSEL OF RECORD:
DENNIS J. BONETTI, ESQUIRE
Pa.ID# 34329
CIPRIANI & WERNER, P.C.
1011 Mumma Road
Lemoyne, P A 17043
(717) 975-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DANA G. GROSS, trading and doing
business as MID-STATE GUTTERPRO,
Plaintiff
v.
PEMFO PACKAGING CO., INC. and
COMPASS
INTERNATIONAL, INe.,
Defendants
) CASE NO: 04-3027
)
)
)
)
)
)
)
)
)
)
) JURY TRIAL DEMANDED
RESPONSE OF DEFENDANT. COMPASS INTERNATIONAL. INC.. TO PLAINTIFF'S
MOTION TO COMPEL DISCOVERY
AND NOW, comes, Compass International, Inc., hereinafter referred to as "Compass," by
and through its counsel, Cipriani & Werner, P.C., and files the following Response to Plaintiffs
Motion to Compel Discovery, and in support thereof states the following:
1. Admitted.
2. Denied. Compass is advised by counsel and therefore avers that the allegations
contained in paragraph 2 of Plaintiffs Motion to Compel state conclusions of law to which no
answer is required. To the extent that a further answer is required, Plaintiff s interpretation of
Pa.R.C.P. 4006(a)(2) is specifically denied.
3. Denied. Compass is advised by counsel and therefore avers that the allegations
contained in paragraph 3 of Plaintiffs Motion to Compel state conclusions of law to which no
answer is required. To the extent that a further answer is required, Plaintiffs interpretation of
Pa.R.C.P. 4009. 12(a) is specifically denied.
4. Admitted in part and denied in part. It is admitted that Compass did not provide
responses to Plaintiffs Second Set of Interrogatories and Second Set of Request for Production
of Documents on or before April 11 ,2005. It is specifically denied that Compass did not provide
full, complete and adequate responses to Plaintiff's Second Set ofInterrogatories and Second Set
of Request for Production of Documents, to the contrary, Compass did provide full complete and
adequate responses to Plaintiff s Second Set of Interrogatori(~s and Second Set of Request for
Production of Documents on or about May 4, 2005. A true and correct copy of Compass'
Response to Plaintiff s Second Set of Interrogatories and Second Set of Request for Production
of Documents is attached hereto as Exhibit "A" and Exhibit "B," respectively.
5. Admitted.
6. Admitted in part and denied in part. It is admitted that Compass provided full,
complete and adequate responses to Plaintiffs Second Set of Interrogatories and Second Set of
Request for Production of Documents on or about May 4, 2005. It is specifically denied that
Compass objected to any of the requests in Plaintiffs Second Set ofInterrogatories and Second
Set of Request for Production of Documents. To the contrary, Compass provided full, complete
and adequate responses.
7. Admitted in part and denied in part. It is admitted that cOWlsel for Plaintiff
forwarded a letter dated May 13, 2005 to counsel for Compass. Compass is advised by counsel
and therefore avers that the allegations contained in paragraph 7 of Plaintiffs Motion to Compel
state conclusions of law to which no answer is required. By way of further answer, it is
specifically denied that Compass provided anything other than full, complete and adequate
responses to Plaintiff s Second Set of Interrogatories and Second Set of Request for Production
of Documents. By way of further answer, by letter dated May 13, 2005, counsel for Compass
forwarded a copy of the tapping screw section ofthe IFI handbook, which had been just received
by counsel, in furtherance of supplementing Compass' response to Plaintiff s discovery requests.
A true and correct copy of Compass' cOWlsel's May 13, 2005 letter is attached hereto as Exhibit
"C."
8. Denied. Compass is advised by counsel and therefore avers that the allegations
contained in paragraph 8 of Plaintiffs Motion to Compel state conclusions of law to which no
answer is required. By way of further answer, it is specifically denied that Compass provided
anything other that full, complete and adequate responst:s to Plaintiff s Second Set of
Interrogatories and Second Set of Request for Production of Documents. By way of further
answer, despite having supplemented its responses by letter dated May 13, 2005, for the benefit
of counsel for Plaintiff, Compass has prepared a proposed formal Supplemental Response to
Interrogatories 9 and 11, which will be served once verification has been received. A true and
correct copy of Compass' proposed formal Supplemental Response to Interrogatories 9 and 11 is
attached hereto as Exhibit "D."
9. Denied. Compass is advised by counsel and therefore avers that the allegations
contained in paragraph 9 of Plaintiffs Motion to Compel state conclusions of law to which no
answer is required. By way of further answer, it is specifically denied that Compass provided
anything other that full, complete and adequate responst:s to Plaintiffs Second Set of
Interrogatories and Second Set of Request for Production of Documents. By way of further
answer, in addition to providing the supplemental documents by way of letter dated May 13,
2005, for the benefit of counsel for Plaintiff, Compass has prepared a proposed formal
Supplemental Response to Request for Production of Documents I, which will be served when
verification has been received. A true and correct copy of Compass' proposed formal
Supplemental Response to Request for Production of Documents 1 is attached hereto as Exhibit
"E."
WHEREFORE, Defendant, Compass International, hlC., requests that this Honorable
Court enter an Order denying Plaintiffs Motion to Compel Discovery
CIRPIANI & WERNER
By:
&
Dennis J. Bone ,E
Attorney ID #34329
Mark R. Zogby, Esquire
Attorney ID #84032
1011 Mumma Road, Suite 201
Lemoyne, PA 17043
(717) 975-9600
Counsel for the Defendant,
Compass International, Inc.
Date 9(J!65
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CIVIL DIVISION
DANA G. GROSS, trading and doing
business as MID-STATE GUTTERPRO,
Plaintiff
v.
PEMFO PACKAGING CO., INC. and
COMPASS
INTERNATIONAL, INC.,
Defendants
CASE NUMBER: 04-3027
ISSUE NUMBER:
PLEADING:
Answers to Plaintiff's Second Set of
Interrogatories
CODE AND CLASSIFICATION:
FILED ON BEHALF OF:
Compass International, Inc., Defendants.
COUNSEL OF RECORD:
DENNIS J. BONETTI, ESQUIRE
Pa. ID# 34329
CIPRIANI & WERNER, P.C.
1017 Mumma Road
Lemoyne, PA 17043
(717) 975-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PE1';'NSYLV ANIA
CIVIL DIV1SION
DANA G. GROSS, trading and doing
business as MID-STATE GUTTERPRO,
Plaintiff
v.
PEMFO PACKAGING CO., INC. and
COMPASS
INTERNATIONAL, INe.,
Defendants
) CASE NO: 04-3027
)
)
)
)
)
)
)
)
)
)
) JURYTRIALDEMANDED
COMPASS INTERNATIONAL. INC.'S ANSWERS TO PLAINTIFF'S SECOND
SET OF INTERROGATORlES
1. Robert Wilkinson
Ronald Farrell
2. Yes
3. No markings on screws.
Packaging includes our name brand and purchase order number.
4. PEMFO has purchased screws from Compass. Please check with PEMFO
regarding their procedures.
Screw designed by manufacturer as a standard part.
Compass is not involved in the production of the screw.
Standard packaging and labeling.
No instructions included.
None.
5. No instructions included.
6. No instructions included.
7.
a.
b.
c.
d.
e.
f. Compass tests the performance and dimensions to tapping screw
standards.
8. Compass uses tapping screw standards from the IFI book.
9. Tapping screw standards from the IFI book.
10. See IFI standards for tapping screws.
I I. See answer to interrogatory 10.
12. Implemented in 1994. Implemented to ensure IFI standards.
13.
a.
b.
Yes
Yes
14.
a-e
Refer to the 1FT book for tapping screws.
15. Refer to the IFI book for tapping screws.
16. See answer to interrogatory 15.
17. Refer to Compass brochures.
18. Not applicable.
19. Not applicable.
20. Refer to the IFI standards for tapping screws.
21. Various Taiwan factories.
22. Compass has purchased Taiwan screws for many years from the various factories.
23. Refer to the IFI book, "Tapping Screws".
24. Various Compass and factory personnel.
Respectfully submitted,
C I WERNER, P.C.
BY:
IJ
IS . BONETTI, ESQUIRE
toruey for the Defendant
Compass International, Inc.
VERIFICATION
I hereby affirm that the following facts are correct:
COMP ASS INTERNATIONAL, INC, is a Defendant in the foregoing action. The
attached Answers to Second Set of Interrogatories is based upon information which I have
furnished to my counsel and information which has been gathered by my counsel in preparation
for this lawsuit. The language of the Answers to Second Set of Interrogatories is that of counsel
and not of me. I have read the Answers to Second Set of Interrogatories and to the extent that
the Answers to Second Set of Interrogatories is based upon information which I have given to
my counsel, it is true and correct to the best of my knowledge, information and belief. To the
extent that the content of the Answers to Second Set of Interrogatories is that of counsel, I have
relied upon counsel in making this verification. I hereby acknowledge that the facts set forth in
the aforesaid Answers to Second Set of Interrogatories is made subject to the penalties of 18
Pa.C.S. 4904 relating to unsworn falsification to authorities.
Dated:
<-II ~ 105;;
I I
~ ~ I)/J
... 11/ L1;~.,
Authorized Representative of Compass International, Inc.
CERTIFICATE OF SERVICE
That counsel for the Defendant, Compass International, Inc., hereby certifies that
a true and correct copy of its Answers to Plaintiff s Second Set of Interrogatories has
been served on all counsel of record, by first class maiJl postage pre-paid, according to
the Pennsylvania Rules of Civil Procedure, on the : I day of
',f rlo-j- ,2005.
Albert Peterlin
Gates, Halbruner & Hatch
1013 Mumma Road
Suite 100
Lemoyne, PA 17043
David A. Fitzsimons
Martson Deardorff Williams & Otto
Ten East High Street
Carlisle, P A 17013
Respectfully submitted,
BY:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION
DANA G. GROSS, trading and doing
business as MID-STATE GUTTERPRO,
Plaintiff
v.
PEMFO PACKAGING CO., INC. and
COMPASS
INTERNATIONAL, INe.,
Defendants
CASE NUMBER: 04-3027
ISSUE NUMBER:
PLEADING:
Responses to Plaintiffs Second Request
for Production of Documents
CODE AND CLASSIFICA nON:
FILED ON BEHALF OF:
Compass 1nternational, Inc., Defendants.
COUNSEL OF RECORD:
DENNIS J. BONETTI, ESQUIRE
Pa.ID# 34329
CIPRIANI & WERNER, P.e.
1017 Mumma Road
Lemoyne, PAl 7043
(717) 975-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION
DANA G. GROSS, trading and doing
business as MID-STATE GUTTERPRO,
Plaintiff
v.
PEMFO PACKAGING CO., INC. and
COMPASS
INTERNATIONAL,INC.,
Defendants
) CASE NO: 04-3027
)
)
)
)
)
)
)
)
)
)
) JURY TRIAL DEMANDED
COMPASS INTERNATIONAL, INC.'S RESPONSES TO PLAINTIFF'S SECOND
REOUEST FOR PRODUCTION OF DOCUMENTS
1. See Answers to Interrogatories.
2. See Answers to Interrogatories.
BY:
submitted,
WERNER, P.C.
D IS J. BONETTI, ESQUIRE
torney for the: Defendant
ompass International, Inc.
VERIFICA nON
I hereby atlirm that the following facts are correct:
COMPASS INTERNATIONAL, INC, is a Defendant III the foregoing action. The
attached Response to Second Request for Production of Documents is based upon information
which I have furnished to my counsel and information which has been gathered by my counsel in
preparation for this lawsuit. The language of the Response to Second Request for Production of
Documents is that of counsel and not of me. I have read the Response to Second Request for
Production of Documents and to the extent that the Response to Second Request for Production
of Documents is based upon information which I have given to my counsel, it is true and correct
to the best of my knowledge, information and belief. To the extent that the content of the
Response to Second Request for Production of Documents is that of counsel, I have relied upon
counsel in making this verification. I hereby acknowledge that the facts set forth in the aforesaid
Response to Second Request for Production of Documents is made subject to the penalties of 18
Pa.C.S. 4904 relating to unsworn falsification to authorities.
Dated:
'-I Iv !c5
f I
/)/ //J /J
~ '/~A~_ z-
Authorized Representative of Compass International, Inc.
"
CIPRIANI & WERNER
A PROFESSIONAL CORPORATlON
Dennis p, Cullen Jr. t
Dennis J. Bonetti "
Lewis L Wolfgang
Jason K. Bums ....
Mark R. Zogby
PauJA. Cacciamani '"'
ATTORNEYS AT LAW
Philadelphia Office:
Suite] 11
482 Norristown Road
Blue Bdl, PA \9422-2152
Telephone (6]0) 567-0700
1017 Mumma Road
Lemoyne, Pennsylvania 17043-1145
Telephone (717) 975-9600
Fax: (711)975-3846
Hal A. Kest!er
or Counsel
www.C-WLAW.com
Pittsburgh Office:
Suite] 100
Two Chatham Center
Pittsburgh. PA 152]9-3437
Telephone (412) 281-2500
'" AlsoadmittedinNJ
t Also admitted in D.C. & NJ
.. Board CertifIed Civil Trial Advocate
Scranton Office:
Suite 210
Oppenheim Building
409 Lackawanna Avenue
Scranton, PA l8S03-20S9
Telephone (570) 347-0600
Writer's E~maj]: DBonetti@c-wlaw.com
May 13, 2005
Albert Peterlin
Gates, Halbruner & Hatch
1013 Mumma Road
Suite 100
Lemoyne, PA 17043
RE: Dana G. Gross, tJd/b/a Mid-State Gutterpro v. Pemfo Packaging Co., Inc. and
Compass International, Inc.
Our File No.: 7243-14022H
Dear AI:
Thank you for your letter of May 13, 2005. I have only recently been able to obtain a
copy of the tapping screw section of the IFI book. A copy is enclosed to supplement your
outstanding discovery request.
Otherwise. my client has fully complied with your discovery request. I cannot stop you
from filing a Motion to Compel. However, I assure you that my client has adequately responded
to your discovery request.
Very truly yours.
Dennis J. Bonetti
DJB/peb
Enclosure
cc: David A. Fitzsimons, Martson Deardorff Williams & Oltn
C.. ;/.... ;~-\
,f \.) ,
"" '\ ~ \"'''., \
('\.,', ">...-. \.' \"-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DANA G. GROSS, trading and doing
business as MID-STATE GUTTERPRO,
Plaintiff
v.
PEMFO PACKAGING CO., INC. and
COMPASS
INTERNATIONAL, INC.,
Defendants
CIVIL DIVISION
CASE NUMBER: 04-3027
ISSUE NUMBER:
PLEADING:
Supplemental Response of Compass
International, Inc. to Plaintiffs
Interrogatories
CODE AND CLASSIFICATION:
FILED ON BEHALF OF:
Compass International, Inc., Defendants.
COUNSEL OF RECORD:
DENNIS J. BONETTI, ESQUIRE
Pa.ID# 34329
CIPRIANI & WERNER, P.C.
1011 Mumma Road
Lemoyne, P A 17043
(717) 975-9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DANA G. GROSS, trading and doing
business as MID-STATE GUTTERPRO,
Plaintiff
v.
PEMFO PACKAGING CO., INC. and
COMPASS
INTERNATIONAL, INC.,
Defendants
) CASE NO: 04-3027
)
)
)
)
)
)
)
)
)
)
) JURY TRIAL DEMANDED
SUPPLEMENTAL RESPONSE OF COMPASS INTERNATIONAL. INC. TO
PLAINTIFF'S INTERROGATORIES
9. Compass International generally performs a spot-check on shipments of screws to
determine if they meet IFI standards.
11. See answer to Interrogatory 9.
BY:
Respectfully submitted,
CIPRIANI & WERNER, P.C.
D , IS J. BONETTI, ESQUIRE
Att 'rney for the Defendant,
C mpass International, Inc.
CERTIFICATE OF SERVICE
That counsel for the Defendant, Compass International, Inc., hereby certifies that a true
and correct copy of its Supplemental Response to Plaintiffs Interrogatories has been served on
all counsel of record, by first class mail, postage pre-paid, according to the Pennsylvania Rules
of Civil Procedure, on the day of ,2005.
Albert Peterlin, Esquire
Gates, HalbfWler & Hatch
1013 Mumma Road
Suite 100
Lemoyne, PA 17043
David A. Fitzsimons, Esquire
Martson DeardorffWilliarns & Otto
Ten East High Street
Carlisle, PA 17013
Respectfully submitted,
BY:
.~.~ I &WERNER, P.C.
i~
D . IS J. BONETTI, ESQUIRE
Att rney for the Defendant
Compass International, Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
DANA G. GROSS, trading and doing
business as MID-STATE GUTTERPRO,
Plaintiff
v.
PEMFO PACKAGING CO., INC. and
COMPASS
INTERNATIONAL, INC.,
Defendants
CIVIL DIVISION
CASE NUMBER: 04-3027
ISSUE NUMBER:
PLEADING:
Supplemental Response of Compass
International, Inc" to Plaintiff s Second
Request for Production of Documents
CODE AND CLASS1FICATION:
FILED ON BEHALF OF:
Compass International, 1nc., Defendants.
COUNSEL OF RECORD:
DENNIS J. BONETTI, ESQUIRE
Pa.ID# 34329
CIPRIANI & WERNER, P.C.
1011 Mumma Road
Lemoyne, PA 17043
(717) 975.9600
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN!A
CIVIL DIVISION
DANA G. GROSS, trading and doing
business as MID-STATE GUTTERPRO,
Plaintiff
v.
PEMFO PACKAGING CO., INC. and
COMPASS
INTERNATIONAL, INC.,
Defendants
) CASE NO: 04-3027
)
)
)
)
)
)
)
)
)
)
) JURY TRIAL DEMANDED
SUPPLEMENTAL RESPONSE OF COMPASS INTERNATIONAL. INC.
TO PLAINTIFF'S SECOND REOUEST FOR PRODUCTION OF DOCUMENTS
1. By cover letter dated May 13, 2005, Plaintiff was supplied with a copy of the
tapping screw section of the IF! book. An additional copy of the cover letter and the tapping
screw section of the IF! book is attached hereto.
BY:
Respectfully submitted,
CERTIFICATE OF SERVICE
That counsel for the Defendant, Compass International, Inc., hereby certifies that a true
and correct copy of its Supplemental Response to Plaintiff's Second Request for Production of
Documents has been served on all counsel of record, by first class mail, postage pre-paid,
according to the Pennsylvania Rules of Civil Procedure, on the day of
,2005.
Albert Peterlin, Esquire
Gates, Halbruner & Hatch
1013 Mumma Road
Suite 100
Lemoyne, P A 17043
David A. Fitzsimons, Esquire
Martson Deardorff Williams & Otto
Ten East High Street
Carlisle, PAl 7013
Respectfully submitted,.
BY:
,
VERIFICATION
I hereby affirm that the following facts are correct:
I am counsel for Defendant, Compass International, Inc., in the foregoing action and I
am authorized to make this verification on behalf of Defendant. I have read Defendant's Response
to Plaintiff's Motion to Compel and veritY that the information contained therein is true and correct
to the best of my knowledge, information and belief. This verification is made by me instead of
Defendant, since the facts stated in the Defendant's Response 110 Motion to Plaintiff's Motion to
Compel are better known to me. I hereby acknowledge that the facts set forth in the aforesaid
Defendant's Response to Plaintiff's Motion to Compel are made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities.
Date: o,,! t/ A5
ir , Counsel for
s International, Inc.
CERTIFICATE OF SERVICE
That counsel for the Defendant, Compass International, Inc., hereby certifies that a true
and correct copy of its Response to Plaintiffs Motion to Compel has been served on all counsel
of record, by first class mail, postage p. e-pai , ace rding to th,~ Pennsylvania Rules of Civil
Procedure, on the /:t'- day of e, 2005.
Albert Peterlin, Esquire
Gates, Halbruner & Hatch
10 13 Mumma Road
Suite 100
Lemoyne, P A 17043
David A. Fitzsimons, Esquire
Martson Deardorff Williams & Otto
Ten East High Street
Carlisle, PA 17013
Respectfully submitted,
BY:
ENNIS J. BE, ESQUIRE
MARK R. ZOGBY, ESQUIRE
Counsel for the Defendant
Compass International, Inc.
r?
..r._
::.) C)
"'-'
;::::;:;.
\.:-:';
'.:.:,
$~
.'.
-(;
c-....
-.,
-rJ
.....
:r
(1-13
r:~
N
~.
I '.~'
\..t:-'