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Home My WebLink About05-4734 KRAFT & KRAFT, P.C. BY: Robert E. Cherwony, Esquire Attorney No. 17623 1311 Spruce Street Philadelphia PA 19107 (215) 546-5100 Attorney for Plaintiff GENERAL ELECTRIC CO., - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION P. O. Box 640025 Pittsburgh, PA 15264-0025 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA v. CIVIL ACTION AT LAW THE BARRETT COMPANY 429A S. 18th Street Camp Hill, PA 17011 NO. DS -lJ1JL; C~..;J,.'TEfl.n.. PRAECIPE TO THE PROTHONOTARY: Kindly enter the judgment in the amount of $108,219.16 in Court of Common Pleas of CUMBERLAND COUNTY, PA in the above matter upon payment of your costs only. obert E. Cherwony, Esquire Attorney for Plaintiff BY: Dated: August 4, 2005 PROTHONOTARY, MONTGOMERY COUNTY, PA CASE INFORMATION DATE 08/31; GENERAL ELECTRIC CO VERSUS BARRETT CO CASE # 05-12154 DATE COMMENCED 04/27/05 CASETYPE COMPLAINT-CIVIL ACTION PARCEL # ::: JUDGE ALBRIGHT PLAINTIFF GENERAL ELECTRIC CO PO BOX 640025 PITTSBURGH ATTORNEY CHERWONY ROBERT PA 15264 PLAINTIFF GENERAL ELECTRIC CONS & IND DVSN ATTORNEY CHERWONY ROBERT PO BOX 640025 PITTSBURGH PA 15264 DEFENDANT BARRETT CO 429A S 18TH STREET CAMP HILL ATTORNEY *UNREPRESENTED* PA 17011 DOCKET INFORMATION 05/18/05 SERVED DEFT BARRETT CO ON 5/9/05 06/27/05 JUDGMENT ENTERED IN FAVOR OF PLTF & AGNST DEFT IN AMT OF $94,103.62 DAMAGES ASSESSED AT $108,219.16 CERT OF MAILING 06/27/05 CERTIFICATION OF ADDRESSES 06/27/05 236 NOTICE/JUDGT REQ DOC MAILED END OF DATA August 31, 2005 Judgment certified in the amount of $108,219.16, in favor of the Plaintiff, GENERAL ELECTRIC COMPANY, and against the Defendant, THE BARRETT COMPANY. ~TlfIED FROM THE RttQAOS OF :tHE PROTHONOTARY. eOUAl OF COMMON PLEAS. W>NTGOMERY CQlJffTY. PA. . M..LlAM 6. DONNElLY, PROTHONOTARY ~/!~A~ CURX (Page i of 2) 1'~ /b~ ~13. ~ IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA GENERAL ELECTRIC CO. . GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION P. O. Box 640025 Pittsburgh, PA 15264-0025 vs. THE BARRETT COMPANY 429A S. 18th Street Camp Hill, PA 17011 I 111M 1I1111I 1.III~M 11111111111111 ~D II II Imm 1111 11M 2005-12154-0002 ~ .llldgl:lllcnl Entered in Favor of Montgomcrv County Prothonotary William E DOlmdly Monday, .luBe 27. 2005 03:55"00 PM No. 05.12154 PRAECIPE FOR JUDGMENT To The Prothonotary: Enter judgment in favor of Plaintiff and against: THE BARRETT COMPANY for want of an answer. ( ) Assess Damages as Follows: Debt Interest Total $ 94,103.62 $ 14.115.54 $108,219.16 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or livered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and lea~;?11~s prior to the date of filing of this praecipe. A copy of the notice is ac . 'J.l ~ laintiff Robert E. Cherwony. Esquire. 17623 215-546-5100 Thisa1dayof -:S-UN~ ,.~()OS ,judgment is entered in favor of Plaintiff and against Defendant, .&()..(( e..++ c.. 0 . _ by default for want of an ~s,r and damages assessed at the sum of $ \()'1\, ll, \ q. I \g as per the above CertificatV~ # $;.. Prothonotary, Montgomery County ~ THE RECOA06 Of ~ CERTIF\EO FROM CO~lOF CQMI.~ON PLEAS. PRO'tHQMC'f N<<. MQMTGOtM;RY COOo~~~~r~'Pf\OTt!ON~Tft.I{Y WLLlAM &.."'"lI~ .-:- "\ / /.' r:e -r;;;- ~>- CLERK ,. L.J.<-.f' ~ - l"-' , I.~ 'Jo, { "/' R v (Page 2 of 2) Date of Notice: June 3, 2005 THE BARRETT COMPANY 1525 Cedar Cliff Drive Camp Hill, PA 17011 Caption: GENERAL ELECTRIC CO.-GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION v. THE BARRETT COMPANY COMMON PLEAS COURT OF MONTGOMERY COUNTY, PA CIVIL ACTION AT LAW No. 05-12154 IMPORTANT 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 (10) 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 Reference Service 100 West Airy Street Norristown PA 19401 (215) 279-9660 .:.; . ~_.'" 'l"'". Ro ert . C Esquire 1311 Spruce Street Phil'adelphia". .PA 19~07 (215) 54'6-5100 . , , YOU MAY SATISFY THIS MATTER BY PAYMENT BY RETURN MAIL IN THE ENCLOSED ,ENVELOPE. (Page 1 of 1) KRAFT & KRAFT, P.C. BY: Robert E. Cherwony, Esquire Attorney No. 17623 1311 Spruce Street Philadelphia P A 19107 (215) 546-5100 Attorney for Plaintiff GENERAL ELECTRIC CO. - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION P. O. Box 640025 Pittsburgh, P A 15264-0025 COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PA v. : CIVIL ACTION AT LAW THE BARRETT COWWANY 429A S. 18th Street CampHill,PA 17011 : NO. 05-12154 CERTIFICATION OF ADDRESSES I certify the address of the plaintiffis P. O. Box 640025, Pittsburgh, P A 15264-0025; and the address of defendant(s) is 429A S. 18th Street, Camp Hill, PA 17011. KRAFT & KRAFT, P.C. Date: June 17, 2005 bert E. Cherwony, Esquire Attorney for Plaintiff \ \,,~, \Il\\ ,ti~ 11\\\1\ \\ti\ \IDI \\11\ \~ \11 \1 II 11\ 1\\\ 1\1 2005-12154-0003 ~ C~rtitication of Addresses , Montgomery COl~nIY p~thonOlal) Wilham E Donnelly Mondav, June 27, 2005 03'.56-.00 PM \ \ I (Page ~ of 1) (RULE OF CIVIL PROCEDURE NO. 236) - REVISED IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GENERAL ELECTRIC CO. - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION P. O. Box 640025 Pittsburgh, P A 15264-0025 I 'UIII 111\ III 'I \1\ \11\1 111\ Illl\ '.'111 II '11\\ III 2005-12154-0004 '\cd~ Notice 236 I Judgt Req Doc Ma~ Montgomery County Prothono , Wilham E Donnelly Monmw. June 27.200503:56:00 P vs. THE BARRETT COMPANY 429A S. 18th Street Camp Hill, P A 17011 No. 05-12154 NOTICE IS GIVEN THAT A JUDGMENT IN T~E ~Pi'E CA~IO~~ MA TIER HAS BEEN ENTERED AGAINST YOU. V tfff.l..... I." //t---j- WILLIAM E. DONNELLY PROTHONOTARY If you have any questions concerning the above, please contact: Robert E. Cherwony. Esquire 13 I 1 Spruce Street Philadelphia. P A 19107 215-546-5100 KRAFT & KRAFT, P.C. BY: Robert E. Cherwony, Esquire Attorney No. 17623 1311 Spruce Street Philadelphia PA 19107 (215) 546-5100 Attorney for Plaintiff GENERAL ELECTRIC CO., - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION P. O. Box 640025 Pittsburgh, PA 15264-0025 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA v. CIVIL ACTION AT LAW THE BARRETT COMPANY 429A S. 18th Street Camp Hill, PA 17011 NO. CS - '113~ c'CJ~l~~ CERTIFICATION OF ADDRESSES I certify the address of the plaintiff is P.O. Box 640025, Pittsburgh, PA 15264-0025; and the address of defendant(s) is 429A S. 18th Street, Camp Hill, PA 17011. Date: August 4, 2005 KRAFT & KRAFT ~ PQC. .; ~{ . ". ? lr-- R bert E. Cherwony, Esquire Attorney for Plaintiff b ~ 0 ~ ~ U:. ~ ~ 8 ~ ~ g )~~~ ~ 12 K ~ F'-.' f.~-:"1 (-", -Tl c.r;,- :~ ~ [1"1 -;/ "-.) c.J (:-._;- . . (Rule of Civil Procedure No. 236) - Revised COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION AT LAW GENERAL ELECTRIC CO., - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION, Plaintiff vs. NO.~ C.;v:l/~ THE BARRETT COMPANY Defendant Notice is given that an Order to enter Judgment in the above-captioned matteL has been entered against you on , 2005. BY: If you have any questions concerning the above, please contact: KRAFT & KRAFT, P.C. 1311 Spruce Street Philadelphia PA 19107 (215) 546-5100 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL VANIA CIVIL DIVISION GENERAL ELECTRIC CO., - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION vs. THE BARRETT COMPANY Defendant, and PNC BANK 105 Noble Blvd., Carlisle, P A 17013 and CITIZENS BANK 665 N. East Street, Carlisle, PA 17013 and W ACHOVIA BANK 604 E. High Street, Carlisle, P A 17013 andCOMMERCE BANK 65 Ashland Avenue, Carlisle, P A 17013 ( ) Confessed Judgment ( ) Other NO. OS -1f73l./ C.. /'--- I 'Ul'~' €'JLn Amount Due $108,219.16 Interest 8/ /05 Atty's Comm Costs TO THE PROTHONOTARYOF THE SAID COURT: The undersigned hereby certifies that the below does not arise installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate opriginal proceeding filed pursuant toAct 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) To levy and sell any and all personal property at: THE BARRETT COMPANY 429A S. 18th Street Camp Hill. PA 17011 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland 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) Checking account, savings account, safe deposit box, or any other personalty or realty which may be in the possession of the garnishee belonging to the Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). () (Indicate) Index this writ against the garnishee(s) defendant(s) described in the attached exhibit> Date: September 7, 2005 Signature: Print Name: obert : C erwony, Esquire Address: 311 Spruce Street Philadelphia, P A 19107 215-546-5100 Attorney for Plaintiff Attorney ID NO. 17623 '1 Jl (:::1 2 , .9- -~ i!d .' -.. - 1 C') .. ... j ;.J..- ~~~ ... J <J ~ c".l --- ~ - 00 ~ -J ("'() ~- I \ -' ......9 - u- o ~ c C 'Q ~ ~ (~~; v, ~ l.I) <J () v, "tt \ viO~ .. ......... ~ . ........~ "tJ.. ~ CJ - -4- ~ 'bJ.. . d 3 b cn<!. :cr.p.. ~~ p..'t-' 5~ ~8 8~ b~ 't-'~ ~~ ~o uU ~ ~ ~ 5 .- t ~ ~ ~ u ~~ ~~ ~';;? 00 ,~ o~ ~ Q~ % ,J.. Q~ ~ _ ,J.. ZQ~ g~ 8~6 ~ ,J..~~ ~~~ ~~6 r.'" ~ Q.... 0 ~ QO ~ QO - Q.... u% ~~- ~.... ~~.... -~.... ~~- wo ~"'~ 7- -",- ~"'- Q ~ ~U ~~~ ,J..~~ ~~~ ~~~ ~1~ ?Q% ~d Z~~ Z~ " O~Q ~-Q ~~~ ~~~ ~1~ ~~~ g~~~~o~~ _U_ ~~~ Q _~~~~~_q~C ~~ ~~~~~~a~Z~B~U~Q~~$Q~Q~Q O~O'?'t-'~Ut<ip..- o 7. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4734 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GENERAL ELECTRIC CO., - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION, Plaintiff (s) From THE BARRETT COMPANY, 429A S. 18TH STREET, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell TO LEVY AND SELL ANY AND ALL PERSONAL PROPERTY AT THE BARRETT COMPANY 429A ST. 18TH STREET, CAMP HILL, PA 17011 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of CITIZENS BANK, 665 N. EAST ST., CARLISLE, P A 17013 - W ACHOVIA BANK, 604 E. HIGH STREET, CARLISLE, P A 17013 - COMMERCE BANK, 65 ASHLAND, AVENUE, CARLISLE, P A 17013 - CHECKING ACCOUNT, SAVINGS ACCOUNT, SAFE DEPOSIT BOX, OR ANY OTHER PERSONALTY OR REALTY WHICH MAY BE IN THE POSSESSION OF THE GARNISHEE BELONGING TO THE DEFENDANT. 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) 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $108,219.16 Interest 8/05 Atty's Comm % Atty Paid $38.00 Plaintiff Paid Date: SEPTEMBER 12, 2005 L.L. $.50 Due Pro thy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name ROBERT E. CHERWONY, ESQUIRE Address: 1311 SPRUCE STREET PHILADELPHIA, PA 19107 Attorney for: PLAINTIFF Telephone: 215-546-5100 Supreme Court ID No. 17623 GENERAL ELECTRIC CO., - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P A vs. CIVIL ACTION AT LA W THE BARRETT COMPANY and COMMERCE BANK Garnishee No. 05' - Lf131 tl \I~ I INTERROGATORIES IN ATTACHMENT TO: COMMERCE BANK, garnishee(s) Your are required to file answers to the following Interrogatories within twenty (20) days after service upe you. Failure to do so may result in judgment against you. 1. At the time you were served or at any subsequent time did you owe the defendant( s) any money or were yc liable to him, (her, them) or any negotiable or other written instrument, or did he (2h , they) claim that you owe h.iJ . (her, them) any money or were liable to him (her, them) for any reason? ~ 5/631 Cf1toL/ 3 Cki~ Q~53~73'-1j,qd\ WQJtt~41J77b-0rLI( - 4J f11/4.5C] ~9, 2. Mthe time you were served or at any subsequent time there' in your poss ssion custody or control or in 11 joint possession, custody or control for yourself and one or more persons any property of any nature owned sole or in part by the defendant(s)? If so, how muc~ 3. At th~ w~ su~sequen ti e did you hold legal title to any property of any natu owned solely or in part by the defendant(s) or in which defendant(s) held or claimed any interest? ~ ~'4-0 ~~ 1 4. At the tf~e you were served or at any subsequent tim~ou hold as fiduciary any property in which tI defendant(s) had any interest? I\fO 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you to an~.person place PursuWlt to YO\ll'. direc.!!~~ or consent and. what wati th~ ~9.nsidet:atiop ther~for? MO--~~~~~ Ut--tD~ ~~ ~<.!.L0Q~ L""~ I ~y'hI6~ari€ry~~A,~tlilil-~a~~~d~%1~0~~~J or to any person or place pursuant to his (her, their) direction or otherwise discharge any claim of the ::ellstYOU? ~~1~~ -t~f Robert E. Cherwony, Esquire Attorney for Plaintiff ,,> = 0 c-..:;;> 1;:") CJ"1 ." n-l U) ---t f""T'j :r: v nl :IJ N .. ::-g,m w g6 ;0.. =:: (?~ .,," 9 i'Srn ...,;-- ,-, :~ N ~ N -< KRAFT & KRAFT, P.C. BY: Robert E. Cherwony, Esquire Attorney No. 17623 1311 Spruce Street Philadelphia P A 19107 (215) 546-5100 Attorney for Plaintiff GENERAL ELECTRIC CO. - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA vs. CIVIL ACTION AT LAW THE BARRETT COMPANY, Defendant and COMMERCE BANK, Garnishee No. 05-4734 CIVIL TERM ORDER TO ENTER JUDGMENT AGAINST GARNISHEE TO THE CLERK OF THE SAID COURT: Kindly enter judgment against the garnishee, COMMERCE BANK, in the amount of $17,766.41, admitted in its Answers to Interrogatories to be in said garnishee's possession. Damages are to be assessed in the amount of $17,766.41. D~ (!I Date R ert E. Cherwony, Esquire Attorney for Plaintiff t~ -- ~ s- ~ ~ P \U ~ r -{,c:.. p ...() ~ () t;- ~J t, ~ VJ' ~ r ~ o r~ ~"" ;2~~>\ c),:' ~~: ~~":~- '2.-, ::< ,.., ~ cJ' (/l '" -0 N -l ~ -' :t',.....; f'nf::: ..,.,m :X?y' C't..";) :,::\J :2;"\ {":So ",:?':tn 9 '!;> -:0 .-<C -0 :;Ii;: ~ (J'\ o - GENERAL ELECTRIC CO., . GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA vs. CIVIL ACTION AT LAW THE BARRETT COMPANY and COMMERCE BANK Garnishee No. INTERROGATORIES IN ATTACHMENT TO: COMMERCE BANK, garnishee(s) Your 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. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to him, (her, them) or any negotiable or other written instrument, or did he2Sh ,they) claim that you owe him (her, them) any money or were liable to him (her, them) for any reason? ~ 5/531 cq foLj 3 c.kL~ Q~ 53~784/?qCJ\ bctlQJll.Q:l$ J7:U~'0, lJl - 1$/7, /14.5:1 ~~ 2. Mthe time you were served or at any subsequent time there in your pas ssion custody or control or in the joint possession, custody or control for yourself and one or more persons any property of any nature owned solely or in part by the defendant(s)? If so, how much? JU-.e-.- ~ C4c . 3. At the time you were served or at any subsequen ti did you hold legal title to any property of any nature owned solely or in part by the defendant(s) or in which defendant(s) held or claimed any interest? UY.- ~ '4-0 ~~ 1 4. At the l1~e you were served or at any subsequent tim~ou hold as fiduciary any property in which the defendant(s) had any interest? NO 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any. perspn place pursuant to yo~ directiqn or consent and what wa.~ th~ ':QJlside~ation ther,\:for? fY\.o...lli,.. Q - ~ ~-b)..-{:;tu, cuoeu..e.. 1~C!..<..0 G\..~ <:'/1\ ~ 0--" ' ~~ytB~~~\iilt~a~~d~%1d~Nf~~~1Jfug en ant s) or to any person or place pursuant to his (her, their) direction or otherwise discharge any claim of the efendant(s) ::""OU'15 N~5" ~. f ~ 1 'ore" E. Ch~ouy, &qu;re Attorney for Plaintiff GENERAL ELECTRIC CO., GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND vs. THE BARRETT COMPANY and : NO. 05-4734 WACHOVIA BANK, N.A. GARNTSHFF ATTORNEY LD.# \ 7 (9 d ~ ORORR TO mSCONTTNlTR A TT ACHMRNT RXRClTTTON TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, Wachovia Bank, N.A. discontinued, upon payment of your costs only. (~ R BERT E. CHERWONY Attorney for Plaintiff CLSD ~~ \.> ~ C> <- -S> ("- ..l1> - ~ '" v-, " ~ ( ~ ~ '"'" =, = "" o C'''') --i o -n ..... ~ ""c.. "'1'" rn'~'" r'~ ~"j n', ~,,~ :=:::1 -~C"- r.- " ~~, ;:!~:'~;~ -, 1.~ ~;J -< 0.0 ----- - General Electric Co., - General Electric Consumer & Industrial Division COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CNIL ACTION AT LAW vs. The Barrett Company and Commerce Bank Garnishee :}olf)-I..f.13'f No, SUPPLEMENTAL ANSWERS TO INTERROGATORIES IN A TT ACHMENT These answers are intended to supplement the answers served by the Garnishee in the above-captioned matter on or about August 4,2005. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to him, (her, them) or any negotiable or other written instrument, or did he (she, they) claim that you owe him (her, them) any money or were liable to him (her, them) for any reason? A: Yes. 2. At the time you were served or at any subsequent time there in your possession custody or control or in the joint possession, custody or control for yourself and one or more persons any property of any nature owned solely or in part by the defendant(s)? If so, how much? A: Yes. $ ~a. qYh, ~ f 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant(s) or in which defendant( s) held or claimed any interest? A: No. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant( s) had any interest? A: No. 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person place pursuant to your direction or consent and what was the consideration therefor? A: No. 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to this (her, their) direction or otherwise discharge any claim of the defendant(s) against you? A: No. VERIFICATION I, Paula Oman, employee of Commerce Bank/Harrisburg, N.A., have read the foregoing document and verify that the facts set forth herein are true and correct to the best of my knowledge, information and belief. To the extent that the foregoing document and/or its language is that of counsel, I have relied upon counsel in making this Verification. I understand that any false statements made herein are subject to the penalties of 18 Pa. C.S.A. 94904 relating to unsworn falsification to authorities. Th u.Y-D ~V\ ID - I ~ - DS DATED: Paula Oman CERTIFICATE OF SERVICE I hereby certify that I am serving a copy of the foregoing document upon the persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage, prepaid, as follows: Robert E. Cherwony, Esquire Kraft & Kraft, P.C. 1311 Spruce Street Philadelphia, PA 19107 Barrett Company, Inc. 429 South 18th Street Camp Hill, P A 17011 COMMERCE BANK/HARRISBURG, N.A. Garnishee By: ~L- 0 VVllLV\ Paula Oman Date: October Ia- , 2005 434788vl "', ~ 0 ;" ::~) .1 c..~-' C"). --I C-) ~.{ <-oj -.::! -- _. , .~( CO 5J .< SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-04734 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GENERAL ELECTRIC CO VS BARRETT COMPANY THE And now SHANNON SHERTZER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:35 Hours, on the 16th day of September, 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT BARRETT COMPANY THE , in the hands, possession, or control of the within named Garnishee CITIZENS BANK 665 NORTH EAST ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BONNIE DIVELBISS (BRANCH MANAGER) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 SO~_Il~~Le R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this ..1,,~ day of Q)~... ~:::7L~ By k, 09/19/2005 SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-04734 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GENERAL ELECTRIC CO VS BARRETT COMPANY THE And now SHANNON SHERTZER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:39 Hours, on the 16th day of September, 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT BARRETT COMPANY THE in the hands, possession, or control of the within named Garnishee WACHOVIA BANK 604 E. HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to JILL MANLEY (FINANCIAL MANAGER) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So answers: -;P'g;c:,^~~~ ~ R. Thomas Kline Sheriff of Cumberland County 09/19/2005 this o (J)- ;lo - day of ~ d"A:~. Pro honot " By ~kW Deputy Sheriff Sworn and subscribed to before me SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-04734 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GENERAL ELECTRIC CO VS BARRETT COMPANY THE And now SHANNON SHERTZER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:46 Hours, on the 16th day of September, 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT BARRETT COMPANY THE , in the hands, possession, or control of the within named Garnishee COMMERCE BANK 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to CONNIE DZEZSKI (AVP MANAGER) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So ans"'nY' // ~..-... '~-r ~<" R. Thomas Kline Sheriff of Cumberland County this ;Li)/f:... day of Ghr,-J,-" .1/Joi J.D. ~ proth6no~l By 9t,~v j lfk eputy Sh ri f 09/19/2005 Sworn and subscribed to before me KRAFT & KRAFT, P.C. BY: Robert E. Cherwony, Esquire Attorney No. 17623 1311 Spruce Street Philadelphia PA 19107 (215) 546-5100 Attorney for Plaintiff GENERAL ELECTRIC CO., - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA vs. CIVIL ACTION AT LAW THE BARRETT COMPANY, Defendant and COMMERCE BANK, Garnishee No. 05-4734 ORDER TO ENTER JUDGMENT AGAINST GARNISHEE TO THE CLERK OF THE SAID COURT: Kindly enter judgment against the garnishee, COMMERCE BANK, in the amount of $62,946.41, admitted in its Answers to Interrogatories to be in said garnishee's possession. Damages are to be assessed in the amount of $62,946.41. Date Robert E. Cherwony, Esquire Attorney for Plaintiff \1( - ~ ~ ~ \;J ~ ~ -- <y ~ - ....." ,~"l \..) ..Iq. y:::.. ....a \l \) o ~ ~ ~~ X \ ' ~ :.<' General Electric Co., - General Electric Consumer & Industrial Division COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CNILACTION AT LAW vs. The Barrett Company and Commerce Bank Garnishee No. SUPPLEMENTAL ANSWERS TO INTERROGATORIES IN ATTACHMENT These answers are intended to supplement the answers served by the Garnishee in the above-captioned matter on or about August 4, 2005. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to him, (her, them) or any negotiable or other written instrument, or did he (she, they) claim that you owe him (her, them) any money or were liable to him (her, them) for any reason? A: Yes. 2. At the time you were served or at any subsequent time there in your possession custody or control or in the joint possession, custody or control for yourself and one or more persons any property of any nature owned solely or in part by the defendant(s)? If so, how much? A: Yes. $ ~a. qYh, '-II 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant( s) or in which defendant( s) held or claimed any interest? A: No. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant( s) had any interest? A: No. 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person place pursuant to your direction or consent and what was the consideration therefor? A: No. 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to this (her, their) direction or otherwise discharge any claim of the defendant(s) against you? A: No. C ::tJ ~ ~ 4 ~ .~ R fi'--*- ~ ~ ~ P5! fG f: ~ ----<------ (Rule of Civil Procedure No. 236) - Revised COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION AT LAW GENERAL ELECTRIC CO., - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION vs. THE BARRETT COMPANY, Defendant and COMMERCE BANK, Garnishee NO. 05-4734 Notice is given that an Order to enter Judgment against Garnishee in the above-captioned nJatter has been entered against you on Dc_-/-. ,::)1../ ,2005. /71/h~~ P~~~~i&: 7 BY: If you have any questions concerning the above, please contact: KRAFT & KRAFT, P.C. 1311 Spruce Street PhiladelphiaPA 19107 (215) 546-5100 KRAFT & KRAFT, P.C. BY: Robert E. Cherwony, Esquire Attorney No. 17623 1311 Spruce Street philadelphia PA 19107 (215) 546-5100 GENERAL ELECTRIC CO., - GENERAL ELECTRIC CONSUMER & INDUSTRIAL DIVISION VS. THE BARRETT COMPANY and COMMERCE BANK, Garnishee Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION AT LAW No. 05-4734 ORDER TO SATISFY JUDGMENT AGAINST GARNISHEE TO THE CLERK OF THE SAID COURT: Kindly mark the judgment against the garnishee, COMMERCE BANK, in the above matter satisfied upon payment of your costs only. Dated: / ;/;t//&c;" KRAFT & KRAFT, P.C. m1!ff rZ Robert E. Cherwony, Esquire Attorney for Plaintiff ~ t- ~ t C\ "- o c: () -n 1',) f'C f". ~l U1 ----.. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL So Answers; 18.00 4.37 Advance Costs: 225.00 Sheriffs Costs 225.00 000.00 .50 1.00 14.13 Refunded to Atty on 5/12/06 80.00 80.00 27.00 225.00 (}- t,Jbf/OC. Sworn and Subscribed to before me ~~*~~~. ~ -~ : ~~ ~ ~/ R. Thomas Kline, Sheriff ~ ByCJ Culcll 0-0- {k-uJ'tx:tk/ this 2006 ~. /' Prothonotary i:J1,#,#@ '111 : i \ \1 S I cl3S SOuZ '.:.:\ , .' i if e:::; ; ifl U :, I', \ ,.;'0 tk.54 I aO ~ 11f?'(~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GENERAL ELECTRIC CO., - GENERAL NO 05-4734 Civil CIVIL ACTION - LAW ELECTRIC CONSUMER & INDUSTRIAL DIVISION, Plaintiff (s) From THE BARRETT COMPANY, 429A S. 18TH STREET, CAMP HILL, P A 17011 (I) You are directed to levy upon the property of the defendant (s)and to sell TO LEVY AND SELL ANY AND ALL PERSONAL PROPERTY AT THE BARRETT COMPANY 429A ST. 18TH STREET, CAMP HILL, PA 17011 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of CITIZENS BANK, 665 N. EAST ST., CARLISLE, PA 17013 - WACHOVIA BANK, 604 E. HIGH STREET, CARLISLE, PA 17013 - COMMERCE BANK, 65 ASHLAND, AVENUE, CARLISLE, P A 17013 - CHECKING ACCOUNT, SAVINGS ACCOUNT, SAFE DEPOSIT BOX, OR ANY OTHER PERSONALTY OR REALTY WHICH MAY BE IN THE POSSESSION OF THE GARNISHEE BELONGING TO THE DEFENDANT. 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) 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $108,219.16 Interest 8/05 Atty's Cornm % Atty Paid $38.00 Plaintiff Paid Date: SEPTEMBER 12, 2005 L.L. $.50 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name ROBERT E. CHERWONY, ESQUIRE Address: 1311 SPRUCE STREET PHILADELPHIA, PA 19107 Attorney for: PLAINTIFF Telephone: 215-546-5100 Supreme Court ID No. 17623