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HomeMy WebLinkAbout05-4622IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ LLC Plaintiff No: dS - .4/x,22` l IU?C vs. COMPLAINT IN CIVIL ACTION JONATHAN BOSSERMAN Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04457407 C A Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQ LLC Plaintiff vs. Civil Action No f7 j- 5/l. Z Z JONATHAN BOSSERMAN Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, NORTHSTAR CAPITAL ACQ LLC is a corporation with offices at 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 2. Defendant is adult individual(s) residing at the address listed below: JONATHAN BOSSERMAN 920 N FRONT ST 3 LEMOYNE, PA 17043 3. Defendant applied for and received a credit card bearing the account number 4146850002736143 4. Defendant made use of said credit card and has a current balance due of $1756.18 , as of August 26, 2005 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.000% per annum on the unpaid balance from August 26, 2005 . A copy of Plaintiffs Statement of Acco unt is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , JONATHAN BOSSERMAN , individually , in the amount of $1756.18 with continuing interest thereon at the rate of 6.000% per annum from August 26, 2005 plus costs. Jam C. Warmbrodt,42524 WE " WEINBERG & REIS CO., L.P.A. 43 eventh Avenue, Suite 2718 P t sburgh, PA 15219 41 ) 434-7955 412-338-7130 0 457407 C A Pit KMJ This law firm is a debt collector tempting to collect this debt for our client and any information obtained will be used for that purpose. North Star Capital Acquisitions, LLC Charge-Off Statement Please indicate Name, or address Telephone Changes Home ( ) Work ( ) ACCOUNT NUMBER PAYMENT DUE DATE PAST DUE AMOUNT MINIMUM PAYMENT NEW BALANCE AMOUNTOF PAYMENT ENCLOSED 4146 8500 0273 6143 09/02/2003 1410.38 560.60 1485.49 $ JONATHAN BOSSERMAN 920 N FRONT ST 3 WORMLEYSBURG PA 17043 220 JOHN GLENN DRIVE SUITE ONE AMHERST NY 14228 ACCOUNT NUMBER CREDIT LINE CREDIT AVAILABLE DAYS IN BILLING CYCLE BILL DATE PAYMENT DUE DATE MINIMUM PAYMENT DUE 4146 8500 0273 6143 1000.00 32 08/18/2003 09/0212003 560.60 DATE OF TRANS POST REFERENCE NUMBER DESCRIPTION OF TRANSACTI ONS AMOUNT 0818 0000 0818 0000 OVERLIMIT FEE LATE CHARGE - MIN PY MT NOT RECD BY DATE 29.00 35,00 FINANCE CHARGE CURRENT PURCHASE i i 11 FPREVIOUS BALANCE PAYMENTS CREDITS NF.W PURCHASES AND ADVANCES DEBIT ADJUSTMENTS FINANCE CHARGES OVERLINE AMOUNT NEW BALANCE 1410.38 .00 .00 .00 64.00 75.11 485.49 1485.49 AN AMOUNT FOLLOWED BY A MINUS SIGN(-) IS A CREDIT BALANCE UNLESS OTHERWISE INDICATED YOU MAY AVOID ADDITIONAL FINANCE CHARGES ON PURCHASES IF YOU PAY THIS AMOUNT BY THE DUE DATE TYPESOFCREDITTO WHICH RATES APPLY PURCHASES ADVANCES FINANCE CHARGE BALANCES 1410.38 DAILY PERIODIC RATE 02965'R 06299% NOMINALANNUAL PERCENTAGE RATES q00% 2299% ANNUAL PERCENTAGE RATES 9.00% %, $ QUESTIONS about account? Credit Card lost or stolen? Call Customer Service 24 hours a day 7 days a week, toll- free at 1-800.277-4431. Para Servicio at Cliente en espanol: 1-800-277-4431 EXHIBIT I VERIFICATION The undersigned does hereby veri fy subject to the penalties of 18 PA. C. S. §4904 relating to unworn falsifications to authorities, that he/she is Itya C /Ce r? 2 e n rip/? h (Name) eh r of ?? piy c? A" , plaintiff herein, that (Title) (Company) GLU he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signatur WWR# exly 5 7yo7 c") 6q ?? rrnn n i l i Iw_ C. T Crl `.J IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION LLC Plaintiff vs. Civil Action No. 05-4622-CIVIL JONATHAN BOSSERMAN Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on ?)OL 3Ut acaoS (xx) Assumpsit Judgment in the amount of $1778.40 plus costs. ( ) Trespass Judgment in the amount of$ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( } Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By? PROT NOTA JONATHAN BOSSERMAN 920 N FRONT ST 3 LEMOYNE,PA 17043 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`n Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION LLC Plaintiff vs. JONATHAN BOSSERMAN Defendant No. 05-4622-CIVIL PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.447437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR904457407 Judgment Amount $ 1778.40 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION LLC Plaintiff vs. JONATHAN BOSSERMAN Defendant TO THE PROTHONOTARY: Civil Action No. 05-4622-CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, JONATHAN BOSSERMAN above named, in the default of an Answer, in the amount of $1778.40 computed as follows: Amount claimed in Complaint $1756.18 Interest from AUGUST 26, 2005 to NOVEMBER 25,2005 at the legal interest rate of 6% per annum $22'22 TOTAL $1778.40 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. _ WELTMAN, WEINBERG & REIS CO., L.P.A. By: WILLIAM T. MOL ZAN SQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04457407 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: JONATHAN BOSSERMAN 920 N FRONT ST 3 LEMOYNE,PA 17043 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION LLC Plaintiff vs. JONATHAN BOSSERMAN Defendant TO: JONATHAN BOSSERMAN 920 N FRONT ST 3 LEMOYNE,PA 17043 Civil Action No. 05-4622-CIVIL IMPORTANT NOTICE Date of Notice YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG &REtSTO., L.P.A. By: L i r -N, Ir JAMES C. RMBRO PA I. D. #4 2 WELTM EINBERG & REIS CO., L.P.A. 2715 K per Building 436 S ent Avenue Pitts rg , PA 15219 (41 4 -7955 #04457407 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION LLC Plaintiff VS. JONATHAN BOSSERMAN Defendant Case no: 05-4622-CIVIL NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, JONATHAN BOSSERMAN is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, JONATHAN BOSSERMAN is not in the military service. Further Affiant sayeth naught. AFFIANT presence thi'day ? wC '' ObI CY My C'_In This law firm is a debt collector attempting to collect this debt for our chent and any information o ""ai ied will be used for that purpose. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members' Civil Relief Act Page 1 of 1 NOV-25-2005 06:39:14 '1; Last Name First/Middle Begin Date Active Duty Status Service/Agency BOSSERMAN Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the individual, per the Information provided, as to all branches of the Military. Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are most strongly encouraged to contact us by phone at (703-696-6762). We will then conduct further research. Your failure to re-contact DMDC may cause provisions of the SCRA to be invoked against you. This response reflects current active duty status only. For historical information, please contact the military services SCRA point of contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR.html. Report [D: BLKZHLDQWLO https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/25/2005 7j n Ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION, LLC Plaintiff No. 05-4622-CIVIL VS. PRAECIPE FOR WRIT OF EXECUTION JONATHAN BOSSERMAN (BANK ATTACHMENT ONLY) Defendant COMMERCE BANK, N.A.., Garnishee, FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04457407 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION, LLC Plaintiff VS. Civil Action No. 05-4622-CIVIL JONATHAN BOSSERMAN 9.2 .0 A-). 3',a.e. a r Lam, oyn, £? Pig 1704,3 Defendant COMMERCE BANK, N.A.., !mss AskLbc- .-'gort usi-rrler P?q ool'l Garnishee PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of Cumberland County: 2. against Jonathan Bosserman, Defendant 3. against Commerce Bank, N.A., Garnishee 4. Judgment Amount ,?p.rlO $ 1,778.40 Less payments of Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 400.00 $ 55.56 $ 105.30 $ 1,539.26 WELT/MA/N, WEINBERRG & REIS CO., L.P.A. By: William T. Molczan, Esquir PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04457407 i2l R u W t1 _ l c ?n o, 0 o c o o d W (S} tF WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4622 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NORTHSTAR CAPITAL ACQUISITION, LLC., Plaintiff (s) From JONATHAN BOSSERMAN, 920 N. FRONT ST. 3, LEMOYNE, PA 17043 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMERCE BANK, N.A., 65 ASHLAND AVENUE, CARLISLE, PA 17013 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $1378.40 Interest $55.56 Arty's Comm % Atty Paid $123.30 Plaintiff Paid Date: JUNE 16, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs $105.30 PURI LO G Prothonotary By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION, LLC Plaintiff No. 054622-CIVIL VS. A*150e j 40 INTERROGATORIES IN ATTACHMENT JONATHAN BOSSERMAN Defendant and COMMERCE BANK, N.A.. Garnishee FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04457407 i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION, LLC Plaintiff VS. Civil Action No.: 054622-CIVIL JONATHAN BOSSERMAN Defendant and COMMERCE BANK, N.A.. Garnishee TO: Commerce Bank, N.A. Suggested Reference No.: xxx-xx-2124, contact Kimberly 65 Ashland Avenue Coyne at 412.434.7955 for additional information Carlisle, PA 17013 IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? Defendant had account 536669716 with a balance of $252.54 at time served. The account is held individually. 2. If the answer to Interrogatory I is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. See answer to question 1. 3. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. See answer to question 1. 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 5. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? See answer to question 1. 6. If the answer to Interrogatory 5 is in the affirmative, describe the nature, fair market value, and present location of each of said properties. 7. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? No 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 9. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? Defendant made deposits into the above referenced account in the ordinary course prior to service, none of which were at the direction of Commerce Bank. 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 11. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? No 12. If the answer to Interrogatory I 1 is in the affirmative, describe the amount or nature, fair market value and present location of each of such payments and properties. Commerce Bank 3801 Paxton Street larrisbur¢. PA 17111 7 -6134 Date WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Esqu' PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04457407 r-' -i1 t?) s3 _4 . ? (.. ? L? ?'{1 ' ? t (?? ^.y .w. ._ C -' § '. r ? "i :y't f ?. a .t`i ?}Ilia -?t `?t`?'. ? ? ?'?,. s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION, LLC Plaintiff No. 05-4622-CIVIL VS. I M?SGJQIL_? INTERROGATORIES IN ATTACHMENT JONATHAN BOSSERMAN Defendant and COMMERCE BANK, N.A.. Garnishee FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molezan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04457407 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION, LLC Plaintiff VS. JONATHAN BOSSERMAN Defendant and COMMERCE BANK, N.A.. Garnishee TO: Commerce Bank, N.A. 65 Ashland Avenue Carlisle, PA 17013 Civil Action No.: 05-4622-CIVIL Suggested Reference No.: xxx-xx-2124, contact Kimberly Coyne at 412.434.7955 for additional information IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Gamishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? Defendant had account 536669716 with a balance of $252.54 at time served. The account is held individually. Defendant made a deposit of $100.00 July 26, 2006. The accounthas a balance of $352.54. 2. If the answer to Interrogatory I is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. See answer to question 1 3. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. See answer to question 1. 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 5. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? See answer to question 1. 6. If the answer to Interrogatory 5 is in the affirmative, describe the nature, fair market value, and present location of each of said properties. 7. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? No 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 9. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? Defendant made deposits into the above referenced account in the ordinary course prior to service, none of which were at the direction of Commerce Bank. 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 11. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? No 12. If the answer to Interrogatory 11 is in the affirmative, describe the amount or nature, fair market value and present location of each of such payments and properties. WELTMAN, WEINBERG & REIS CO., L.P.A. Commerce Bank 3801 Paxton Street Harrisbur , PA 17111 --"? 1 1 -6134 By. ' William T. Molczan, Esqu 047 PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04457407 t: 3 ? { l ' 44 O ..j W C..7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION, LLC Plaintiff vs. JONATHAN BOSSF.RMAN Defendant COMMERCE BANK, N.A. Garnishee No. 05-4622 Civil PRAECIPE FOR JUDGMENT AGAINST GARNISHEE FILED ON BEHALF OF Plaintiff COUNSEL OP RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA LD.#47437 Wellman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04457407 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION, LLC Plaintiff VS. JONATHAN BOSSFRMAN Defendant COMMERCE BANK, N.A. Garnishee Civil Action No. 05-4622 Civil PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, COMMERCE BANK, N.A., in the amount of $352.54, which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG & REIS CO., L.P.A. By: -A WILLIAM T. MOLC N, ESQUIRE PA L.D.447437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04457407 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: 3801 Paxton St, Harrisburg, PA 17111 { IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION, LLC Plaintiff VS. JONATHAN BOSSERMAN Defendant and COMMERCE BANK, N.A.. Garnishee No. 05-4622-CIVIL INTERROGATORIES IN ATTACHMENT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. 1!47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 ?? WWR904457407 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL ACQUISITION, LLC Plaintiff VS. Civil Action No.: 05-4622-CIVIL JONATHAN BOSSERMAN Defendant and COMMERCE BANK, N.A.. Garnishee TO: Commerce Bank, N.A. Suggested Reference No.: xxx-xx-2124, contact Kimberly 65 Ashland Avenue Coyne at 412.434.7955 for additional information Carlisle, PA 17013 IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. INTERROGATORIES IN ATTACHMENT I. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable.to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? Defendant had account 536669716 with a balance of $252.54 at time served. The account is held individually. Defendant made a deposit of $100.00 July 26, 2006. The accounthas_a balance of $352.54. 2. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. See answer to question 1. 3. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. See answer to question 1. 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 5. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? See answer to question 1. 6. If the answer to Interrogatory 5 is in the affirmative, describe the nature, fair market value, and present location of each of said properties. 7. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? No 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 9. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? Defendant made deposits into the above referenced account in the ordinary course prior to service, none of which were at the direction of Commerce Bank. 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 11. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his directign or otherwise discharge any claim of the defendant against you? No 12. If the answer to Interrogatory 11 is in the affirmative, describe the amount or nature, fair market value and present location of each of such payments and properties. Commerce Bank WELTMAN, WEINBERG & REIS CO., L.P.A. 3801 Paxton Street Harrisburg, PA 17111 .. -4 2-6134 , By: i)8?E 9 a(o William T. Molczan, Esqu' PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWM04457407 I JOW. N N- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPII'AL ACQUISITION, LLC Plaintiff VS. Civil Action No. 05-4622 Civil JONATHAN BOSSERMAN Defendant COMMERCE BANK, N.A. Garnishee NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff ( ) Defendant (xx) Garnishee You are hereby notified that the following Order or Judg nt was entered against you on aOOCP (xx) Assumpsit Judgment in the amount of $352.54 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: _ dac?L ROT TAR (OR DEPUTY) Commerce Bank 3801 Paxton Street Harrisburg, Pa 17111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NORTHSTAR CAPITAL, ACQUISITION, LLC Plaintiff vs. JONATHAN BOSSERMAN Defendant COMMEIR('I-' BANK Garnishee No. 05-4622-CIVIL PRAECI,PE FOR SATISFACTION OF JUDGMENT AS TO THE GARNISHEE COMMERCE BANK ONLY FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D 442524 William T. Molczan, Esquire PA. I.D.4474 37 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R No. 04457407 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL, DIVISION NORTHST'AR CAPI'T'AL ACQUISITION, LLC Plaintiff vs. JONATHAN BOSSti RMAN Defendant COMMERCE BANK Garnishee Civil Action No. 05-4622-CIVLI.., PRAECIPE FOR SATISFACTION OF JUDGMENT AS TO THE GARNISHEE, COMMERCE BANK, ONLY TO THE PROTHONOTARY: Please kindly Satisfy the Judgment of the above captioned matter upon the records of the Court and mark the cost paid as to Garnishee, Commerce Bank, only. Sworn to and subscribed Before me them Day of September, 006 NOY PUB .: C WELTMAN, WEI.JIBERG & REIS CO., L.P.A. By: U V I V,1 - James C. W rmbrodt PA i.D #i42, 24 William T /Molczan, Esquire PA. I.D.4?7437 WELTY(AN, WEINBERG & REIS CO., L.P.A. 2718,Koppers Building 436,"Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wayne A. Jones, Notary Public Criy Of Pittsburgh, Allegheny County My Commission Expires June 29, 2010 W W R No. 04457407 Member, Poort sylvartia Assodatinn of Notaries T l /V VI V ? ?'1 SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-04622 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND NORTHSTAR CAPITAL ACO LLC VS BOSSERMAN JONATHAN And now KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:00 Hours, on the 30th day of June , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , BOSSERMAN JONATHAN hands, possession, or control of the within named Garnishee COMMERCE BANK 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to in the AMY THOMAS (SENIOR CSR) , personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 nn Sworn and Subscribe to true and made So a R. Thomas Kline Sheriff of Cumberland County uu 07/05/2006 before me this day of By A.D Northstar Capital Acquisition LLC VS Jonathan Bosserman Writ of Execution Docket No. 2005-4622 Civil Term ?9r m OF Thy PROiHMMY 2009 SEP 30 AM 10: 18 PEWO" R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. Sheriff's Costs: Docketing $18.00 Surcharge 30.00 Garnishee 9.00 Levy 20.00 Mileage 4.40 Poundage 1.66 Prothonotary 1.00 Law Library .50 ? ?b?a x?ny $84.56 So Answers: R. Thomas Kline, Sheriff BYL1/1 Sergeant Cp Ck_ '7 a G 31a?z '0'. ?