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Home My WebLink About06-1532 0'-." Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KARL DODSON dfb/a K.D. GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : Civil Action - Law COTTON TRADERS, INC., Defendant : NO. OC" - /53^ : JURY TRIAL DEMANDED C;ulL~~ NOTICE TO DEFEND AND CLAIM RIGHTS 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 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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENICIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LlBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KARL DODSON dlb/a K.D. GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : Civil Action - Law ~ NO. O~- 153~ ~L>l<- /0L"'l : JURY TRIAL DEMANDED COTTON TRADERS, INC., Defendant COMPLAINT 1. Plaintiff is Karl Dodson d/b/a K.D. Graphics with offices located at 464 Big Springs Road, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is Cotton Traders, Inc., a Pennsylvania Corporation with offices located at 257 North 24th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiffs business is screenprinting and embroidering t-shirts, sweatshirts, sweatpants and hats. 4. Defendant's business is the selling of clothing and apparel. 5. Plaintiff and Defendant have had a continuing business relationship since May, 2005. 6. Incident to said relationship, Defendant requested Plaintiff screenprint and embroider certain articles of clothing for Defendant to sell and/or distribute. 7. Plaintiff agreed to perform the screenprinting and embroidering on certain dates between May, 2005 through August, 2005, as required by Defendant. 8. The costs and charges Plaintiff incurred to perform the work to complete Defendant's requested screenprinting and embroidering from May, 2005 through August, 2005, were specifically as follows: a. May 6, 2005- $1,049.50 b. June 23, 2005- $1,291.80 c. June 23, 2005- $2,671.00 d. June 23, 2005- $2,243.00 e. July 30, 2005- $ 52.80 f. July 30, 2005- $ 92.40 g. July 30, 2005- $ 445.80 h. July 30, 2005- $ 352.80 1. July 30, 2005- $1,244.00 J. July 30, 2005- $ 523.60 k. July 30, 2005- $ 805.00 L July 30, 2005- $1,050.00 m. July 31, 2005- $ 381.60 n. August 1,2005- $1,098.75 o. August 18,2005- $9,372.00 p. August 18,2005- $ 876.00 q. August 18,2005- $3,738.00 r. August 18,2005- $ 417.60 TOT AL- $27,705.65 True and correct copies of the invoices for work performed are attached hereto as Exhibit "A." 2 9. After receipt of the invoices, Defendant made one partial payment ofTen Thousand Dollars and 00/100 ($10,000.00) on or about November 1,2005. 10. The balance due and owing to Plaintiff is Seventeen Thousand Seven Hundred Five Dollars and 65/100 ($17,705.65). 11. Despite demand by Plaintiff, Defendant has failed to make payment. 12. Arbitration will be required for the amount in controversy. COUNT I BREACH OF CONTRACT 13. Paragraphs 1 through 12 are incorporated herein by reference. 14. Plaintiff and Defendant entered into an oral contract for Plaintiff to perform certain screenprinting and embroidering at the request of Defendant. 15. Plaintiff performed all work required by Defendant in a proper and workmanlike manner and provided all goods requested by Defendant. 16. PlaintiITincurred costs and charges of Twenty-Seven Thousand Seven Hundred Five Dollars and 65/100 ($27,705.65) to complete the work for Defendant. 3 17. While partial payment ofTen Thousand Dollars ($10,000.00) was made by Defendant, Defendant continues to owe the sum of Seventeen Seven Hundred Five Dollars and 65/100 ($17,705.65) to Plaintiff after Plaintiff demanded payment on two separate occasions. 18. Plaintiff has now suffered loss in the amount of Seventeen Thousand Seven Hundred Five Dollars and 65/100 ($17,705.65) plus interest and cost of suit. WHEREFORE, the Plaintiff requests the Court enter an order requiring Defendant to pay Plaintiff Seventeen Thousand Seven Hundred Five Dollars and 65/1 00 ($17,705.65) in damages, plus costs of suit, counsel fees and interest. DATE: March.l.t-, 2006 / / / ; I \ ~ ~, '''------- Barbara Sump1e-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court LD. 32317 Attorney for Plaintiff 4 Exhibit A 'II KARL DODSl, 464 Big Springs ~ f New Cumberland, PA 7 7 Phone (717) 938-6132 Fax <h ) 932.9161 II NAME ADDRESS SOLD BY ioo , :5"'0 , , 1'00 , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , RECEIVED BY 18167 CUSTOME~rs ORDER N ,/l-,c\, {,"" NAME ADDRESS SOLD BY 'I RECEIVED BY 18605 , <;\..\<;''0 !I 1)- KARL DODSO 464 Big Springs ~. New Cumberland, PA 17 Phone (717) 938-6132 fax (~ 7 932.9161 ) PHONE \...c.cAu...c S-{f "3;:l... :10 , loF :00 , , , , , , , , , , , , , TAl! I ) i I KARL DODSO I 464 Big Springs R~. New Cumberland. PA 117 7 Phone (717) 938-6132 Fax (t1 ) 932-9161 ~v NAME J--c;)- ADDRESS SO\..D9'1 \5 I 1'1'1 / sG '") 15-'9", ! (IS- bo , RECEIVED BY 18607 r -a.lna <I .... 0 ....... 717.'38.6 32 NAME ADDR.ESS SOLO BY RECEIVED BY 18608 " I II KARL DODS1' ! 464 Big Springs R . New Cumberland, PA 7 7 Phone (717) 938-6132 Fax (rl~) 932-9161 , I I: 1 -0) :2/n I' ':J'f)'il I $:.d 'I I' j,1 i ,I 'I ~ ,I I' ,I I I I I I 'I ! I Ii i ! CJ9i I 39 'CUr , 7o~: OcJ , , , , , , , , , , , , , , , , , 1-.".". 0 ..1. ....1. 717.S3'.& 32 CUSTOMER'S ORDE:R NO /"-1(2""'. eve. I NAME I I ~, ADDRESS KARL DODS(:) 464 Big Springs Rtl. New Cumbertand. PA 17 Phone (717) 938.6132 Fax (1 7 932-9161 PHONE Q-c'S' c: ; ~'" 'r ,jGy;' If? RECEIVED BY 18686 i,lO' I ~:~ , , , , , J , , , , , , , , , , , , I , , , , , , , , , , , , , i! '-.II'n.o _.18 0 ...... 717.138.1 32 I KARL DODSmlr 464 Big Springs Rl!I. I New Cumberland, PA 1,7 7 Phone (717) 938-6132 Fax en ) 932-9161 CUSTOMER'S ORDER NO. ---0 -;{", NAME ADDRESS SOLD BY CHARGE ON ACCT. 18687 RECEIVED BY il'l I I I i I J -.lIln* 0 ..1* 0 ....1. 717~938.& 32 CUSTOMER'S ORDER NO. '. Ilk..\e II NAME ADDRESS SOLD 6V CA.SH C.O.D. I CHARGE ON ACCT. I RECEIVED BY 18689 KARL DODSO I 464 Big Springs Rd.f New Cumberland, PA 1707 Phone (717) 938-6132 Fax CI'1~) 932-9161 I -<'S- /.~Sill I 10,~, I I I I ! I I I :80 , , l(/{) , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , I KARL DODSok 464 Big Springs Rd.i New Cumberland, PA 1 ~O 0 Phone (717) 938-6132 Fax (7*7 932.9161 I 1 -I.h.. D ..rl ...... 717&'3a~ 132 cu MER'S orDER N , & <",-el\. S( h PHONE fl..... \. NAME cA~" ADDRESS $OLoey , :)..0 , , , , , , , , , , , , , , , , , , , , , , , , , , , ~ECE\\JED BY 18694 KARL DODSbk 464 Big Springs Ri1.~ New Cumberland. PA ~ 7 Phone (717) 938-6132 Fax (? 7 o~c) ADDRESS SOLOBV q;;;J I P.o , I ,?,g-- : 00' , !sS-:..P , RECENEO BY 18697 Tank You! I KARL DODSO 464 Big Springs Rd. New Cumberland. PA i 0 Phone (717) 938-6132 Fax 0 7 932-9161 ADDRESS SOLO BY C.O.D, CHARGE ON ACCT. RECEIVEO BY 18704 I DATE "J i- I o~C's )G'(~':: , , !(;A;.1 , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , I KARL DODSO~ 464 Big Springs Rd. I New Cumberland, PA 1707 Phone (717) 938-6132 Fax (7117) 932-9161 I I o--oy ADDRESS SOLD BY ;)CC' 18705 I I i RECEIVED BY I -.lIln. 0 ..1. 0 ....1. 717.'18.& 12 CUSTOMER'S ORDER NO llA^-C G ",vi-. NAME ADDRESS I! KARL DODSO 464 Big Springs R~. New Cumberland, PA 17 7 Phone (717) 938-6132 Fax <fIr> 932-9161 PHONE Co +-k. \' J'a-e{ ()r S ! I I I SOLD BY RECEIVED BY 18706 G7r-: tXJ , ;270 :c:c; 1(;),,5: 00 , , , , , , , , , , , 16S"O I ~.O'c.., hank You! , I . I KARL DODSON 464 Big Springs RlII.T New Cumberland, PA V~7 Phone (717) 938-6132 Fax (71j7) 932-9161 I () NAME ADDRESS SOLO BY C.O.D. CHARGE ~ S C1 1 .5 0: , :OCl , , , , , , , , , , , , , , , , , , , , , , , , , , <",c;;fi:~. RECEIVED BY 18715 I KARL DODsoi 464 Big Springs Rd. New Cumberland, PA 17 7 Phone (717) 938-6132 Fax (71 ) 932-9161 , I , I -..hI8 0 ...8 0 ....,. 717.513&.& 32 CUSTOMER'S ORDER NO /) I ' , V 'oful/' 1i1~16-1- NAME PHONE (c~",- \:'v-.d.c" ADDRESS SOLD BY C.O.D. CHARGE ON ACCT. RECEIVED BY :)0 , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , o q ~ :7S- 18729 ank You! ! , I I I I KARL DODSOJ 464 Big Springs R& I New Cumberland, PA 17q7 Phone (717) 938-6132 Fax (7;11) 32-9161 I CUSTOMER'S r\~ NO NAME 1'6-0). PHONE \ ,\,yc.,Jn~ s ADDRESS SOLD BY C.O.D. CHARGE RECEIVED BY 18808 I I J -alliin 0 ..Ia 0 ...... 717.'.8.& 32 CUSTOMER'S ORDER NO] NAME ADDRESS 141./ J \j 1./ 14'-1 c; b RECEIVED BY 18815 SOLD BY I . ! KARL DODSq~ 464 Big Springs Rd.~ New Cumberland, PA 117 7 Phone (717) 938-6132 Fax (n ) 932-9161 ! I I '6-0 $- !'-ta", ~ ";;'13 .~.3~1 ;2.3:51 .~ , I /O.~~I. i 1 /"':"""1 I :o:A I' 'I I, ,I , , 13~:<.{~ , :?3'? :C/-o , /<=7 :.;lcJ , ~'. I eI C/ ,"'0 Go :OCl I KARL OODSON 464 Big Springs Rd.1 New Cumberland, PA 1;r. 0 Phone (717) 938-6132 Fax (7 ( 932-9161 CUS10MER'S ORDER NO liS- NAME ADDRESS SOLO BY RECEIVED BY 18817 ! ' KARLDODSO~ 464 Big Springs Rd, I New Cumberland, PA 1707 Phone (717) 938-6132 Fax (7~7 932-9161 I I-abluao ..n 717.938.6 CUSTOMER'S ORDER NO I t--c'J NAME ",,,,cAe.- S ADDRESS SOLD BY :w 1 :.;w , , , , , , , , , , , RECEIVED BY TAX -'I II 1 TOT~!- tiJ7 . :~O ,I L . . 18896 hank You! Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : Civil Action - Law COTTON TRADERS, INC., Defendant : NO. : JURY TRIAL DEMANDED VERIFICATION I, Karl Dodson d/b/a K.D. Graphics, hereby certify that the facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: ;- 7 -(J 6 ~!J~ KARL DODSON d/b/a K.D. Graphics ~ (,g., ;d \ l/( 1:1- V'\ -J en - () ~ ..t: tv -J \' i.A ~ F r g --C., (') C:'. t"~.", c:) ,:~::; :>'- .,,,".;;a ?J 8 0'" () -n .-1 :z..on filF -~~)' _,e, ~. ?) 1., It...;' +." ,d ,I ::.-'~_S'?l l..; \ -n :; .r.;: ::;1 ,<., (-') m - .. o Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KARL DODSON d/b/a KD. GRAPHICS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, Civil Action - Law COTTON TRADERS, INe, Defendant NO. 06-1532 JURY TRIAL DEMANDED PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY Enter judgment in favor of the Plaintiff and against the Defendant above named for want of Answer as required. The Complaint was initially filed on March 16, 2006. A Ten (10) day Notice to Enter Judgment was given to the Defendant on April 13, 2006, (Attached as Exhibit "A") No Answer had been filed, Certain ascertainable damages were set forth in Plaintiff's Complaint These damages were Seventeen Thousand Seven Hundred Five Dollars and 65/100 ($17,705.65), WHEREFORE, Plaintiff requests that Judgment be entered in his favor and against Defendant in the amount of Seventeen Thousand Seven Hundred Five Dollars and 65/100 ($17,705.65), Respectfully submitted, ,./ Dated: April 28, 2006 Bar ara Sump1e-Sullivan, Esquire ( Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Attorney for Plaintiff 2 ~ Exhibit A , ~ - :y LA"'~ OFFICES BARBARA SUMPLE-SULLIVAN 549 BRIDGE STREET NEW CUMBERLA:r-."'D. PENNSYLVANIA 17070-1931 PaONE (717) 774~1445 F~(717)774-7059 April 13, 2006 Cotton Traders, Inc. 257 North 24th Street Camp Hill, P A 17011 Re: Karl Dodson d/b/a KD. Graphics v. Cotton Traders, Inc. Dear Sir/Madam: Enclosed constituting service on you is the Notice dated April 13, 2006. Please review this matter with your counsel. Barbara Sumple-Sullivan BSS/ab cc: Mr. Karl Dodson KD, Graphics (w/encl) U$ POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTI PROVIDE F C ~~1~1~~NATrONAL MAIL, DOES NOT Barbar~ Sumple-Sullivan, Esquire 549 Bndge Street New Cumberland, PA 17070-193 w '" 0: Ln7 C"1~ "'" C::)~ tR-~ '" 1 O~e piece of ordinary mail addressed 10' WTT/J (\J 't1zAnuLb I NG t.::;; ~-m+ a'+~ sr. . fA-- 17em , '" '" '" '" PS Form 3817, January 2001 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cmuberland, PA 17070 (717) 774-1445 KARL DODSON d/b/a K.D, GRAPIDCS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PEN'NSYL VANIA v. : Civil Action - Law COTTON TRADERS, INC, Defendant : NO. 06-1532 : JURY TRIAL DEMANDED NOTICE TO: Cotton Traders, Inc. 257 North 24th Street Camp HilI, PA 17011 DATE OF NOTICE: April 13, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THE ABOVE REFERENCED CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAIN'ST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGillS, YOU SHOULD TAKE TIllS 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: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY A VENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 9- 166 ~ arbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PAl 7070-1931 (717) 774-1445 Supreme Court 1,0, No, 32317 Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KARL DODSON d/b/a KD, GRAPHICS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, Civil Action - Law COTTON TRADERS, INC, Defendant NO. 06-1532 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE 1, BARBARA SUMPLE-SULLIV AN, ESQUIRE, do hereby certify that on this date, I served a copy of the foregoing PRAECIPE TO ENTER JUDGMENT OF DEFAULT, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Cotton Traders, Inc, 257 North 24tl' Street Camp Hill, PA 17011 DATED: April 28, 2006 l Barbara Sump1e-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court LD, No. 32317 Attorney for Plaintiff 3 t K ~ ~/ ~ ~ " --.... ~ '>.i q..; V'\ ~ ,., ~ \) ""0 "- ""- ~ \~ '~' '~ 'J ~ ..~- -.... ."..- .,., ~'"" "~~ I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: KARL OOOOON d/b/a K.D. ~CS vs. Q)n()N TRADERS, INC. 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 col'lfession 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 exacution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) any and all property located at 257 North 24th street. Camp Hill. Cumberland County, Pennsylvania 17011. 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). Date o (Indicate) Index this writ against the garnishee(s) as a lis pendens defendant(s) described in the attached ,exhibi,t. ,/ b/a/oh Signature: &::: I Barbara SUmple-Sullivan,Esquire Print Name: Address: 549 Bridge street New Cumberland, PA 17070 Plaintiff (717) 774-1445 32317 Attorney for: Te,lephone: Supreme Court 10 No.: (over) ~- ~ ~ ~ ;". - l~ :Ct- )J ~ ..c ~ ~ -I- -;- . ~ Irl ~ C "'c.~o c c c-CC\) \ ...:t \ \ \ C0 \" r-~ - ~-~ - ~ - ?- )..) ~ i- t t r . .txJ:b - ~ - ~ "'-1 f::- .-..t:- - , t ~ l . - " o ~ 9n S ~ .-\ ::?.t<' ~ ~~ ....- .~n\C9 \ ~$J\ L tJ1 ,-',{ ) ~~~~ -j~ 1 -0 ,:)~' l'i-i ~ fsc;A C: t'J -~\ -/ ~:---< _ ::z. __~ (;1i WRIT OF EXECUTION and/or ATTACHMENT .. .. COMMONWEAL TII OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1532 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due KARL DODSON D/B/A K.D, GRAPHICS, Plaintiff (s) From COTTON TRADERS, INC., 257 NORTH 24111 STREET, CAMP HILL, PA 17011 (I) You are directed to levy upon the property ofthe defendant (s)and to sell ANY AND ALL PROPERTY LOCATED AT 257 NORTH 24111 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 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 $17,705.65 Interest Arty's Comm % Arty Paid $82.00 Plaintiff Paid Date: JUNE 5, 2006 LL $.50 Due Prothy $1.00 Other Costs $320.50 ~ . ~/~ CUR~~7 (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name BARBARA SUMPLE-SULLIV AN, ESQUIRE Address: 549 BRIDGE STREET NEW CUMBERLAND, P A 17070 Attorney for: PLANTIFF Telephone: 717-774-1445 Supreme Court ill No. 32317 SHERIFF'S RETURN - REGULAR CASE NO: 2006-01532 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DODSON KARL AKA KD GRAPHICS VS COTTON TRADERS INC BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon COTTON TRADERS INC the DEFENDANT , at 1153:00 HOURS, on the 23rd day of March , 2006 at 257 NORTH 24TH STREET CAMP HILL, PA 17011 CHRIS SILVA, OWNER/PRESIDENT by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge 18,00 13 .20 .39 10,00 .00 41. 59 So Answers: f"'~~ R. Thomas Kline me this "" /.,~ day of 03/29/2006 BARBARA SUMPLE l,U UrrzLLII VVAN By: I{~f!. Deputy Sheriff Sworn and Subscribed to before ~ 2,,0(.. A.D. Prothonotary Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPIllCS, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. Civil Action - Law COTTON TRADERS, INC., Defendant : NO. 06-1532 : JURY TRIAL DEMANDED TO THE HONORABLE mDGES OF SAID COURT: MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND DOCUMENT PRODUCTION REQUESTS IN AID OF EXECUTION AND NOW, this lOth day of August, 2006, comes the Plaintiff, Karl Dodson d/b/a K.D. Graphics, and respectfully moves this Honorable Court to Compel Responses to Interrogatories and Document Production Requests in Aid of Execution. In support thereof he avers the following: 1. On or about April 28, 2006, Judgment was entered against Defendant in the above captioned matter in the amount of Seventeen Thousand Seven Hundred Five Dollars and 65/100 ($17,705.65). 2. Plaintiff filed a Praecipe for Writ of Execution on June 5, 2006. 3. Following the Sheriff's execution upon Defendant's property, the President of Cotton Traders, Inc., Mr. Christopher R. Silva, filed a Property Claim stating that some of the items levied upon by the Sheriff were his personal property and not subject to execution. 4. In order to assist in determining the property Cotton Traders, Inc., Interrogatories and Document Production Requests in Aid of Execution were initially served by Plaintiff's counsel directly on the President of Cotton Traders, Inc., Christopher R. Silva, on or about June 29, 2006. A true and correct copy of same is attached hereto as Exhibit A. 5. Responses were due within thirty (30) days in accordance with 42 Pa.R.C.P. 4006 and 4009.12. 6. No timely response was received to this discovery request. 7. Plaintiff requests Defendant shall be ordered to answer the discovery requests within fifteen (15) days from the date of this Motion. 8. Pa. R.C.P. 4019 provides as follows: 4019 (a)(I) The court may, on motion, make an appropriate order for sanctions if interrogatories under Rule 4005. 4019 (c) The court, when acting under subdivision (a) of this rule, may make (1) an order that the matters regarding which the questions were asked, or the character or description of the thing or land, or the contents of the paper, or any other designated fact shall be taken to be established for the purposes of the action in accordance with the claim of the party obtaining the order; (2) an order refusing to allow the disobedient party to support or oppose designated claims or defenses, or prohibiting such party from introducing in evidence designated documents, things or testimony, or from introducing evidence of physical or mental condition; (3) an order striking out pleadings or parts thereof, or staying further proceedings until the order is obeyed, or entering a judgment of non pros or by default against the disobedient party or party advising the disobedience; (4) an order imposing punishment for contempt, except that a party may not be punished for contempt for a refusal to submit to a physical or mental examination under Rule 4010; (5) such order with regard to the failure to make discovery as is just. WHEREFORE, it is respectfully requested that Defendant, Cotton Traders, Inc., be compelled to respond to the Interrogatories and Document Production Requests referred to in this Motion within fifteen (15) days of the orde arbara Sump Ie-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff Dated: August 10, 2006 . 'VlMtti7)..SNN3d AlNnOJ cr/\;l{;:/38Y'ma 8*1 :6 UV 0 I 9nv 900l NN10NOH10Ud 3HJ. :10 301:l:fc>-a311:J Exhibit A LAW OFFICES BARBARA SUMPLE-SULLIVAN U8 BRIDGE STREET NEW OUMBERLAND. PENNSYLVANIA 17070-1881 PHONE (717) 774.-1U5 FAX (717) 774.-7059 June 29, 2006 CottOn Traders, Inc. . Attn: President, Christopher R Silva. 257 North 24th Street Camp Hill, PA 17011 Re: Karl Dodson d/b/a K.D. Graphics v. Cotton Traders, Inc. Dear SirlMadam: Enclosed constituting service on you are Interrogatories in Aid of Execution and Document Production Requests in Aid of Execution. Please know that your responses are due to my office within thirty (30) days. Barbara Sumple-Sullivan BSS/ab cc: Mr. Karl Dodson K.D. Graphics (w/encl) Barbara Sumple-Su1livan. Esquire Supreme Court #32317 549 Bridge Street New Cumberland. PA 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPHICS, Plaintiff : IN 1HE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : Civil Action - Law COTTON TRADERS, lNC., Defendant : NO. 06-1532 : JURY TRIAL DEMANDED INTERROGATORIES IN AID OF EXECUTION TO: Cotton Traders, Inc. Attn: President, Christopher R. Silva 257 North' 24th Street Camp mil, P A 17011 AND NOW comes, Karl Dodson d/b/a K.D. Graphics by his attorney, Barbara Sumple-Sullivan, Esquire and files, in accordance with Pa. RC.P. 3117, the following Interrogatories in Aid of Execution of his judgment against the Defendant. You must answer these interrogatories within thirty (30) days of the date of service on you. 1. Identify all financial accounts of the business. For purposes of this Interrogatory, financial account shall be any account held by a bank, credit union, insurance company, brokerage house, or any other depository of monies. For each financial account, please identify the following: a. The name and address of the financial institution; b. The account number(s); and c. The sum in the account(s) on June 15,2005 and each month thereafterto the present. Answer: 2. Identify all entities (natural person or otherwise) who owes the business money either as salary, wage, or for repayment of a debt or accounts receivable. a. For eac~ person, identify the name and address of the individual or company; b. The amount of the monies owed. Answer: 3. Please identify the location of any safe, deposit box held in the business's name and the contents thereof as of June 15, 2005 through the present. Answer: 2 4. Please identify all items of personal property (including all assets, cash and accounts) held by the business presently, including, but not limited to items such as vehicles, in excess of One Hundred Dollars ($100.00). For each asset, please identify the following: a. Any encumbrance against said personal property; and b. The current whereabouts of said personal property. Answer: 5. Please identify all inventory held by the business. If at a location other than 257 North 24th Street, Camp Hill, PA 17011, identify each party's name, address and telephone number and provide a description of the items held. Answer: 3 6. Please identify all equipment, fixtures and furniture of the business and list the whereabouts of all such equipments, fixtures and furniture. Answer: Dated: June 29, 2006 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court J.D. No. 32317 4 Barbara Sumple-SuIlivan, Esquire Supreme Comt #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPIflCS, Plaintiff : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. . : Civil Action - Law COTTON TRADERS, INC., Defendant : NO. 06-1532 : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Barbara Sumple-Sulli~ Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing INTERROGATORIES IN AID OF EXECUTION, in the above-captioned matter upon the followingindividua1(s) by first class mail, postage prepaid, addressed as follows: Cotton Traders, Ine. Attn: President, Christopher R. Silva 257 North 24th Street Camp mil, P A 17011 DATED: June 29, 2006 ....../ // ./ 4 - Smnp:~SWli~ E~Wre 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 5 Barbara Sumple-SulIivan. Esquire Supreme Comt #32317 549 Bridge Street New CumberJand. P A 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPlDCS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : Civil Action - Law COTTON TRADERS, INC., Defendant : NO. 06-1532 : JURY TRIAL DEMANDED DOCUMENT PRODUCTION REQUESTS IN AID OF EXECUTION TO: Cotton Traders, IDe. Attn: President, Christopher R. Silva 257 North 24th Street Camp mil, PA 17011 AND NOW comes, Karl Dodson d/b/a K.D. Graphics by his attorney, Barbara Sumple-Sullivan, Esquire and files, in accordance with Pa. R.C.P. 3117, the following Document Production Requests in Aid of Execution of his judgment against the Defendant. You must answer these document production . requests within thirty (30) days of the date of service on you. 1. Please provide monthly statements from all financial accounts of the business for each financial account listed in your Answer to Interrogatory No. I from June 15,2005 to the present. 2. Please provide documents to support each Answer to Interrogatory No.2. 3. Please provide the business's 2005 Federal, State and Local Tax Returns and 2006 year to date profits and losses. 4. Please provide a1l2006 monthly ledgers of the business. Dated: June 29, 2006 . Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland. P A 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPmCS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : Civil Action - Law COTTON TRADERS, INC., Defendant : NO. 06-1532 : JURY TRIAL DEMANDED (.-, CERTIFICATE OF SERVICE I, Barbara Sumple-SuI1ivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing DOCUMENT PRODUCTION REQUESTS IN AID OF EXECUTION, in the above~captioned matter upon the following individual(s) by first class ma.iL postage prepaid, addressed as follows: Cotton Traders, IDe. Attn: Mr. Christog!ter R. Silva 257 North 24 Street Camp mil, PA 17011 DATED: June 29, 2006 :b ' umple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court LD. No. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. Civil Action - Law COTTON TRADERS, INC., Defendant : NO. 06-1532 : JURY TRIAL DEMANDED CERTIFICA TE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served the Motion to Compel Response to Interrogatories and Document Production Requests in Aid of Execution to this Honorable Court, in the above-captioned matter upon the following individual via United States Mail: Cotton Traders, Inc. Attn: Christopher R. Silva 257 North 24th Street Camp Hill, PA 17011 arbara umple-Sullivan, Esquire 49 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 Attorney For Plaintiff DATE: August 10,2006 (') ~ I~ ;:s~ s:C) li : ....., Si 6ft ~ :lIMo :;I ~ O~i: c:. =D6 :;:!-r ""--'1 ~~ ~ ~ KARL DODSON, d/b/a K.D. GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. COTTON TRADERS, INC., Defendant : 06-1532 CIVIL ORDER OF COURT AND NOW, this 15th day of August, 2006, upon consideration of the Plaintiff's Motion to Compel Responses to Interrogatories and Document Production Requests in Aid of Execution, IT IS HEREBY ORDERED AND DIRECTED that: 1. Pursuant to PaRC.P. No. 206.5, a rule is issued upon the defendant to show cause why the plaintiff is not entitled to the relief requested; 2. The defendant will file an answer to this petition on or before August 31, 2006; 3. A copy of said answer will be filed with this Court; 5. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Plaintiff shall be granted. If the Defendant files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled. By the Court, ~~~ M. L. Ebert, Jr., J.' Cotton Traders, Inc. Christopher R. Silva, President Defendant ~-/~-~ ~ ~ Jt:; Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff/Petitioner bas V,N\I^lJ.SNN3d AlNnOJ n~,.~;;f1Pj8V'lnD S I :11 WV 9 I ~nv 900Z A!3\110NOHIOiJd 3Hl j() 3:J1:J:IO{J31I:l Barbara Swnple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cwnberland, P A 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPHICS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. Civil Action - Law COTTON TRADERS, INC., Defendant : NO. 06-1532 : JURY TRIAL DEMANDED PETITION TO MAKE RULE ABSOLUTE 1. Petitioner is Karl Dodson d/b/a K.D. Graphics. 2. Respondent is Cotton Traders, Inc. 3. The above-captioned matter involves a Judgment which was entered on or about April 28, 2006 in the amoWlt of Seventeen Thousand Seven HWldred Five Dollars and 65/100 ($17,705.65) against Defendant. 4. Payment has not been received from Defendant in accordance with the Judgment. 5. The Cwnberland COWlty Sheriff attempted to execute upon Defendant's property in order to satisfy the judgment. 6. Interrogatories and Document Production Requests In Aid of Execution were served by Plaintiffs counsel on Defendant on or about June 29,2006 in order to determine what property was Defendant's. 7. Responses were due within thirty (30) days in accordance with 42 Pa.R.C.P. 4006 and 4009.12. 8. No timely response was received to this discovery request. 9. On August 10,2006, Plaintiff filed a Motion to Compel Defendant's Reponses to the Interrogatories and Document Production Requests in Aid of Execution. 10. On August 15,2006, Judge M.L. Ebert, Jr. issued a Rule returnable in Fifteen (15) days upon Defendant to show cause why the Motion to Compel should not be granted. The Rule also provided that if no answer was filed, the relief requested by Plaintiff shall be granted. 11. Said Rule was served upon Defendant by letter dated August 17,2006. A true and correct copy of same is attached hereto as Exhibit A. 12. No timely answer or other response was filed to said Rule by Defendant. 13. No contact has been made at all to Plaintiff or Plaintiff s counsel by Defendant or any counsel representing Defendant. 14. Plaintiffrequests that Defendant shall respond to Plaintiffs Interrogatories and Document Production Requests in Aid of Execution within fifteen (15) days of this Order. 15. Plaintiff requests entry of an Order for costs of Ihree Hundred Dollars and 00/100 ($300.00) pursuant to Pa. R.C.P. 3117(b), which provides: All reasonable expenses in connection with the discovery may be taxed against the Defendant as costs if it is ascertained by the discovery proceedings that the Defendant has property liable to execution. WHEREFORE, Petitioner requests the Rille be made absolute and Defendant respond to Plaintiffs Interrogatories and Document Production Requests in Aid of Execution within fifteen (15) days of this Order and be ordered to pay all costs in association with the discovery requests and this Motion. Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 DA IE: September 6, 2006 Exhibit A " " LAW OFFICES BARBARA SUMPLE-SULLIVAN 549 BRIDGE STREET NEW CUMBERLAND, PENNSYLVANIA 17070-1931 PHONE (717) 774-1445 FAX (717) 774-7059 August 17, 2006 CERTIFICATE OF MAILING Cotton Traders, Inc. Attn: President, Christopher R. Silva 257 North 24th Street Camp Hill, PA 17011 Re: Karl Dodson d/b/a K.D. Graphics v. Cotton Traders, Inc. Dear Sir/Madam: Enclosed constituting service on you is an Order of Court dated August 15, 2006. Please know that your answer is due on or before AUt:! / ,/ ,./ .Jfncer (/ Barbara Sumple-Sullivan ( , 2006. BSS/lh Enclosure cc: Mr. Karl Dodson K.D. Graphics (w/encl) z m :E: :D c:: 5 n . ~ _.5"'ll!" O-'Jil5:c 2;-J~l!Bc~ -f <>, en <=> :D -t en Z ::D C C'l . m ." :>> OCiz~rdi~;:i;~;ltO:-=-rI1C- 1 ~~ V\ -lrn .0" -s.d. oJ, C), r .s top/1e r ~Sl ~l:il :2.5 7 Nor+h ~,;tt.. _ sir ~.d- C4~ J./. ')1 'f+ 1101 PS Form 3817, Mar. 1989 KARL DODSON, d/b/a K,D. GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, COTTON TRADERS, INC., Defendant : 06-1532 CIVIL ORDER OF COURT AND NOW, this 15th day of August, 2006, upon consideration of the Plaintiff's Motion to Compel Responses to Interrogatories and Document Production Requests in Aid of Execution, IT IS HEREBY ORDERED AND DIRECTED that: 1. Pursuant to Pa,R.C.P. No. 206.5, a rule is issued upon the defendant to show cause why the plaintiff is not entitled to the relief requested; 2, The defendant will file an answer to this petition on or before August 31, 2006; 3, A copy of said answer will be filed with this Court; 5. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Plaintiff shall be granted. If the Defendant files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then b,e scheduled. By the Court, Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff/Petitioner M~b~r.~,r Cotton Traders, Inc. Christopher R. Silva, President Defendant ftIJe toP\' FFIOM, ReCORD ..... 1T ....., whet8of. I here.. ...... ... of" ',!l;>I<lGourt~c;..-' {~l ~.,~ bas Barbara Swnple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cwnberland, P A 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPHICS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. Civil Action - Law COTTON TRADERS, INC., Defendant : NO. 06-1532 : JURY TRIAL DEMANDED CERTIFICA TE OF SERVICE I, BARBARA SUMPLE-SULLIV AN, ESQUIRE, do hereby certify that on this date I served a true and correct copy of the Petition to Make Rule Absolute in the above-captioned matter upon the following individual(s) by United States first-class mail, postage prepaid, addressed as follows: Cotton Traders, Inc. Attn: President, Christopher R. Silva 257 North 24th Street Camp Hill, PA 17011 arbara ump e-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 DATE: September 6,2006 11 r-<' e.::~ C~ ,...~~ I C'" ~ --1 I-n illp fli 7 C~,1 ~'T\ --r"! (' --, ':,h" 'C:I :!-~ :.< -'0 _..~." _:Ai. r;:, w I)? SEP 0 7 2006~ Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KARL DODSON d/b/a K.D, GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : Civil Action - Law COTTON TRADERS, INC" Defendant : NO. 06-1532 : JUR. Y TRIAL DEMANDED ORDER " AND NOW, this \\ day of ~t..\l-t. ,2006, upon consideration of Plaintiffs Petition to Make Rule Absolute, said Petition is hereby GRANTED. It is further ORDERED and DECREED as follows: 1) Defendant shall respond to Plaintiffs Interrogatories and Document Production Requests in Aid of Execution within fifteen (15) days of this Order; and 2) Defendant shall pay to Plaintiff the sum of Three Hundred Dollars and 00/100 ($300.00) for reimbursement of costs and fees incurred relative to her failure to comply with discovery; and 3) Any other relief as the Court deems just and reasonable BY THE COURT: aV n; ~,,\ o '\ 't ~\ J. ! 0 :8 HlJ 2! It ~\\\\t~ of f!Utnbrrl ~v t'llt(} RONNY R ANDERSON Chief Deputy R. THOMAS KLINE Sheriff EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF JODY S. SMITH Real Estate Sergeant One Courthouse Square Carlisle, Pennsylvania 17013 July 7, 2006 / <<-" r."'! ( .. I .-! Karl Dodson D/B/A K.D. Graphics vs Cotton Traders,Inc. Writ No. 2006-1532 Civil Term Property Claim Determination l' .:- ( , Dear Sir, Reference is made to Property Claim dated June 28, 2006, entered by Christopher R. Silva, pertaining to Writ of Execution No. 2006-1532 Civil Karl Dodson, D/B/A K.D. Graphics -vs- Cotton Traders, Inc. R. Thomas Kline, Sheriff, has determined that the claimant, Christopher R. Silva, in the above mentioned property claim, is prima facie the owner of the property set forth therein. ~~e R. Thomas Kline, Sheriff By C'loLUifL ~~ Barbara Sumple Sullivan, Atty for PUff cc: Cotton Traders, Inc., Deft. Christopher R. Silva, Claimant PROPERTY CLAIM . In the Court of Common Pleas of Cumberland County, Pennsylvania .... _ 'r,,,,,, /(1Ja.~ va~cJ.-J "-'~ K,D, GRAPttU:5' Writ No. 2.bOt:. - IS 32 VS C!C7'7"vhJ -ri2>f-t}.,.~ "" IN Co. zS 7 AJ. '#-"/ r/f ~ CA-1A-1p H, L '- P A /-, () 11 TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied, upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE ~'(f 117TIr€-HcD IWVE'PI/)/a,y ~s: S6tJ. O() THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: By pvI?C~"H~ II.rIf"H PEQf:"nAuH. M.D"'/~~ By &1 F.,- '--r- Date " (/ /'/E State of Pennsylvania: " Countyof Cumberland CH~lS'TQPt'tEA- ~ S iL.vA above list in the property claim are correct and true. 2~/H 2.006 Claimant . b~~,IY swoma=: to~;;;:;:tilie Claunant Notary 9I?A\901A t' BREWBAKER NOTARY PUBLIC Ca!llsle Bore Cumberland County My (;Oil1lnISSIC; tXfmes April 4 ,2009 Personal Property Inventory w R.', /VV.vI iJER. 2 0 () (, - / S '31... Christopher R. and Amy L. Silva 257 North 24th Street Camp HIli, PA 17011 Vehicle: 1999 Chevrolet Suburban PA: Registration EGX 7880 Living Room Qty Description 1 Sofa 2 Chairs 2 Antique Tables 1 Rocking Chair 2 Pictu res 1 Mantle Mirror Family Room Qty Description 1 Sofa 1 Loveseat 1 Television 1 Pioneer Receiver 1 Mantle Clock 1 AntiqueCedar Chest Dining Room Room Qty Description 1 Table 4 Chairs 1 Silver Set (stainless) 6 Pictures 1 Hutch 1 AntiqueCedar Chest 1 Digital Camera 1 Nikon SLR Camera Kitchen Qty Description 1 Island Bar 4 Stools 1 Microwave 1 Utensils 1 Pots & Pans 1 Iron 1 Ironing Board 1 Refirgerator Value $12,500 $1,200.00 $2,500.00 $3,000.00 $250.00 $500.00 $100.00 $2,500.00 $500.00 $250.00 $125.00 $250.00 $750.00 $1,250.00 $400.00 $500.00 $600.00 $1,250.00 $750.00 $175.00 $250.00 $750.00 $400.00 $250.00 $350.00 $500.00 $35.00 $50.00 $2,500.00 1 Cooktop 1 Washer 1 Dryer 1 Mixer 1 Blender 1 Food Processor 1 Coffee Maker 1 Toaster $650.00 $400.00 $350.00 $250.00 $100.00 $125.00 $110.00 $90.00 Master Bedroom Qty Description 1 King Box Spring & Mattress 2 Dressers 1 Nightstand 1 Player 1 VHS DVD 1 Sony Computer Monitor 1 Epson Printer 1 2 Drawer File Cabinet $1,200.00 $1,500.00 $250.00 $125.00 $500.00 $50.00 $50.00 $50.00 2nd Bedroom Qty Description 1 Twin Bed 1 Chest of Drawers 1 Bookshelf $750.00 $350.00 $50.00 3rd Bedroom Qty Description 1 Twin Canopy Bed 1 Dresser 1 Desk $350.00 $200.00 $125.00 Garage Qty Description 1 Skis 2 Bikes 1 Desk 1 Push Lawnmower 1 Weedwacker 1 Tools / Gardening Items $125.00 $400.00 $125.00 $50.00 $50.00 $500.00 Basement Qty Description 1 27" Proscan TV 1 Panasonic DVD Player 1 Play Table 1 Chair & Ottoman 1 Twin Mattress $400.00 $100.00 $150.00 $200.00 $75.00 1 G.E. Refrigerator 1 Kids Toys $50.00 $500.00 Patio Qty Description 1 Patio Table 1 Umbrella 6 Patio Chairs $250.00 $75.00 $250.00 Front Porch Qty Description 2 Deacons Benches Total $200.00 $45,560 11 0 :8 '\I 8l Nnr qOOl Vd '"HIlIJ,) '",i.: i<.j~lm.jl (J .:ldIB3HS 3Hl .::10 3:JI.::lJO aP -{:..... ([ Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL $ 18.00 1.44 Advance Costs: 150.00 Sheriff s Costs: 73.26 $ 76.74 .50 1.00 12.32 20.00 20.00 Refunded to Atty on 08/07/06 73.26 ;-~1'<~ <> ~R. Thomas ~line, Sheriff / ; 'ClLt&.-b. 12M A ~- -l ' ~ y laudia A. Br~~~XL . I tt :01 '\! 8 - Nor qOOl ('-3- ~0 ~ ~ t:::=::::::, ~~ ~r:ol n'~, t'l 'lid 'J" ll~ II U ,) .j,.; \1 ; (j ~-: l:Hln;j .:l.:lIH3HS ::JfH .:!O 3JI.:L:lO ~ ~ -u:u = ~ ,'ffl l,~ rn.'; SDs~ 1 ~t.u.,. ) y ~ t I. 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due KARL DODSON D/B/A K.D. GRAPHICS, Plaintiff (s) From COTTON TRADERS, INC., 257 NORTH 24TH STREET, CAMP HILL, P A 17011 NO 06-1532 Civil CIVIL ACTION - LAW (1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL PROPERTY LOCATED AT 257 NORTH 24TH STREET, CAMP HILL, P A 17011 . (2) You are also directed to attach the property of the defendant(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 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 $17,705.65 L.L. $.50 Interest Atty's Comm % Atty Paid $82.00 Plaintiff Paid Date: JUNE 5, 2006 Due Prothy $1.00 Other Costs $320.50 (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name BARBARA SUMPLE-SULLlV AN, ESQUIRE Address: 549 BRIDGE STREET NEW CUMBERLAND, PA 17070 Attorney for: PLAN TIFF Telephone: 717-774-1445 Supreme Court ID No. 32317 Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : Civil Action - Law COTTON TRADERS, INC., Defendant : NO. 06-1532 : mRY TRIAL DEMANDED MOTION FOR SANCTIONS AND NOW, this day of ,2006, Karl Dodson d/b/a K.D. Graphics, Plaintiff, moves the court for a Sanction Order pursuant to Rule 4019 of the Pennsylvania Rules of Civil Procedure against Cotton Traders, Inc, Defendant. 1. On or about April 28, 2006, Judgment was entered against Defendant in the above captioned matter in the amount of Seventeen Thousand Seven Hundred Five Dollars and 65/100 ($17,705.65). 2. Plaintiff filed a Praecipe for Writ of Execution on June 5, 2006. 3. Following the Sheriffs execution upon Defendant's property, the President of Cotton Traders, Inc., Mr. Christopher R. Silva, filed a Property Claim stating that some of the items levied upon by the Sheriff were his personal property and not subject to execution. 4. In order to assist in determining the property of Cotton Traders, Inc., Interrogatories and Document Production Requests in Aid of Execution were initially served by Plaintiff s counsel directly on the President of Cotton Traders, Inc., Christopher R. Silva, on or about June 29, 2006. 5. Responses were due within thirty (30) days in accordance with 42 Pa.R.C.P. 4006 and 4009.12. 6. No timely response was received to this discovery request. 7. On or about August 10, 2006, Plaintiff filed a Motion to Compel the Discovery Responses. 8. An Order was entered by the Honorable Judge M.L. Ebert, Jr. on August 15,2006 issuing a rule requiring Defendant to file an Answer to the Motion to Compel on or before August 31, 2006. 9. Defendant failed to file an Answer to the Motion to Compel. 10. On or about September 6, 2006, Plaintiff filed a Petition to Make Rule Absolute. 2 11. An Order was entered by the Honorable Judge M.L. Ebert, Jr. on September 11, 2006 requiring Defendant to respond to the discovery requests within fifteen (15) days of the Order and pay to Plaintiff the sum of Three Hundred Dollars ($300.00) for reimbursement of costs and fees incurred relative to his failure to comply with discovery. A true and correct copy of the Order is attached hereto as Exhibit "A." 12. Plaintiff served the September 11, 2006 Order upon Defendant by Certificate of Mailing dated September 14,2006. A true and correct copy is attached hereto as Exhibit "B." 13. No response to the discovery requests were received from Defendant in accordance with the Order. 14. Pa. R.C.P. 4019 provides as follows: 4019 (a)(I) The court may, on motion, make an appropriate order for sanctions if: (i) a party fails to serve answers, sufficient answers or objections to written interrogatories under Rule 4005. 4019 (c) The court, when acting under subdivision (a) of this rule, may make (1) an order that the matters regarding which the questions were asked, or the character or description of the thing or land, or the contents of the paper, or any other designated fact shall be taken to be established for the purposes of the action in accordance with the claim of the party obtaining the order; 3 (2) an order refusing to allow the disobedient party to support or oppose designated claims or defenses, or prohibiting such party from introducing in evidence designated documents, things or testimony, or from introducing evidence of physical or mental condition; (3) an order striking out pleadings or parts thereof, or staying further proceedings until the order is obeyed, or entering a judgment of non pros or by default against the disobedient party or party advising the disobedience; (4) an order imposing punishment for contempt, except that a party may not be punished for contempt for a refusal to submit to a physical or mental examination under Rule 4010; (5) such order with regard to the failure to make discovery as is just. 15. Defendant requests that Plaintiff be ordered to pay sanctions in an amount of Seven Hundred Fifty Dollars ($750.00), in addition to the Three Hundred Dollars ($300.00) set forth in the September 11,2006 Order, for failure to respond to Plaintiff s Interrogatories and Document Production Requests in Aid of Execution. 16. Defendant Silva continues to operate his business. 17. Plaintiff requests that Defendant be ordered to fully and adequately answer the Interrogatories and Document Production Requests in Aid of Execution, within fifteen (15) days of the Order. WHEREFORE, it is respectfully requested that judgment be entered in favor of Plaintiff and Defendant be ordered to pay sanctions in an amount in excess of Seven 4 Hundred Fifty Dollars ($750.00) in addition to the Three Hundred Dollars ($300.00) set forth in the September 11,2006 Order, for failure to respond to Plaintiff's Interrogatories and Document Production Requests in Aid of Execution and also be ordered to fully and adequately respond to the Interrogatories and Document Production Requests in Aid of Execution within fifteen (15) days of the Order. Respectfully submitted, Dated: October 20, 2006 tiara umple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff 5 Exhibit A ---SEP 0 7 2000~. Barbara Smnple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : Civil Action - Law COTTON TRADERS, INC., Defendant : NO. 06-1532 : JURY TRIAL DEMANDED ORDER AND NOW, this Jliit day o.J\~^~. 2006, upon consideration of Plaintiff's Petition to Make Rule Absolute, saidL~herebY GRANTED. It is further ORDERED and DECREED as follows: 1) Defendant shall respond to Plaintiff's Interrogatories and Document Production Requests in Aid of Execution within fifteen (15) days of this Order; and 2) Defendant shall pay to Plaintiff the sum of Three Hundred Dollars and 00/100 ($300.00) for reimbursement of costs and fees incurred relative to her failure to comply with discovery; and 3) Any other relief as the Court deems just and reasonable BY THE COURT: .~. Exhibit B LAW OFFICES BARBARA SUMPLE-SULLIVAN 549 BRIDGE STREET NEW CtJMBBRLAND. PENNSYLVANIA 17070-1981 PHONE (717) 774-1445 FAX (717) 774-7059 September 14, 2006 Cotton Traders, Inc. Attn: President, Christopher R. Silva 257 North 24th Street Camp Hill, PA 17011 Re: Karl Dodson d/b/a K.D. Graphics v. Cotton Traders, Inc. Dear SirlMadam: Enclosed constituting service on you is an Order dated September 11, 2006 in the above captioned matter. Please know that your responses are due to my office within fifteen (15) days. Barbara Sump Ie-Sullivan BSS/lh Enclosure cc: Mr. Karl Dodson K.D.Grraphics(w/encl) AU:-- Zo__'" - . US POSTAL SERVICE CERTIFICATE OF MAILING M~,' BE usee rOR 90M&STICAND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE POSTMASTER 0:: 0.. w . _ ~ ~ rD .~- 0:: 0:: I:) ..... I t;; ...100 I-:- ~~ occx:r--.% '"'" ~ o..o:~~~El O~ .000E- E. ~I:) (/) ::l ~o:: .' "g"'T I:) . W Vi I:) ::l :x uJ % 11;~ ":0. ~~ i~ ..~ ~f I:) I:) I:) o Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 KARL DODSON d/b/a K.D. GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : Civil Action - Law COTTON TRADERS, INC., Defendant : NO. 06-1532 : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served the Motion For Sanctions to this Honorable Court, in the above-captioned matter upon the following individual via United States Mail: Cotton Traders, Inc Christopher R. Silva, President 257 North 24th Street Camp Hill, PA 17011 DATE: October 20, 2006 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney For Plaintiff o f~ ~ C? c:::> c::f' c:::> (~) --I f"v W -;;. ~ -0 ::::J: ~ ~-I :I:...,., rn:::==: :g2; .~ (':~ -i: :T.~ )~~ , ) ':-:i '? <.0 :< (~) CJ \..D -. KARL DODSON, d/b/a K.D, GRAPHICS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA v. COTTON TRADERS, INC" Defendant : 06-1532 CIVIL ORDER OF COURT AND NOW, this 30th day of October, 2006, upon consideration of the Plaintiff's Motion for Sanctions filed October 23, 2006, IT IS HEREBY ORDERED AND DIRECTED that a hearing shall be held on this matter on Monday, November 27,2006 at 1:30 p.m. in Courtroom NO.5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED AND DIRECTED that the Defendant, Cotton Traders, Inc., and its president Christopher Silva, shall appear at said hearing. If the Defendant has not answered Plaintiff's Interrogatories and Document Production Requests in Aid of Execution he shall be prepared to show cause why he should not be held in Contempt and/or subject to other sanctions pursuant to Pa.R.C. 4019. By the Court, ~ara Sumple-Sullivan, Esquire Attorney for Plaintiff J. bas 62 :2 Md IE lJO 900l ).."\'1""" "hI" '"'\\-11:10 ... \' lii";' r~" "-,,.; -' "..,' . ~,..t~ )..:_..../1."..;_ ...... 38\:bO-Q31Ij KARL DODSON, d/b/a K. D. GRAPHICS, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. COTTON TRADERS, INC., DEFENDANT 06-1532 CIVIL IN RE: PLAINTIFF'S MOTION FOR SANCTIONS ORDER OF COURT AND NOW, this 2ih day of November, 2006, this being the time and place for a hearing on the Plaintiff's Motion for Sanctions, and the Court noting that the Plaintiff has appeared and is ready to proceed, and that the Defendant and its President, Christopher Silva, have failed to appear in violation of this Court's Order of October 30, 2006, and have failed to answer Plaintiff's Interrogatories and Document Production Requests in Aid of Execution. Accordingly, IT IS HEREBY ORDERED AND DIRECTED that the Rule to Show Cause shall be made Absolute and a Bench Warrant shall issue for the Arrest of the Christopher Silva, President of Cotton Traders, Inc. It is specifically ordered that the Sheriff of Cumberland County shall only serve this warrant on a weekday between the hours of 8:30 a.m. and 3:00 p.m, and shall bring Christopher Silva immediately before the Court for the purposes of posting security and setting a final hearing on the issue of Sanctions. By the Court, ~"l ~ M. L. Ebert, Jr., J.' ~arbara Sumple-Sullivan, Esquire Attorney for Plaintiff ~ton Traders, Inc. Christopher Silva, President Defendant Cumberland County Sheriff - ~Wiv~ AAf- bas '.1 :1l1 t;k? \flNV^'ASNN3d AJJ\lflO:; ONiflH3811'4no eo :IIWV 9Z ^OH900l AtwlONOH10tJd 3H1 :10 38!;:!:iCKl311:J COMMONWEALTH OF PENNSYLVANIA ) SS: OCA: ) 1~-ltY1L. COUNTY OF CUMBERLAND ) TO: R. Thomas Kline, Sheriff, or any duly authorized law enforcement officer. RE: Christopher R. Silva 257 North 24th Street Camp Hill, PA 17011 DOCKET #: 06-1532 Civil OOB: 06/24/66 SEX: M HT: WT: 6'5" EYES: BRO OLN: 26002367 PA SID: RACE: WHITE HAIR: BRO FBI: SSN: WHEREAS, the above-named defendant failed to appear for a hearing held on November 27,2006 at 1 :30 p.m in Courtroom NO.5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. WHEREAS, this Court on November 27,2006, directed a Bench Warrant be issued for the apprehension of the Christopher Silva, President of Cotton Traders, Inc. This is therefore to command you to arrest the defendant above. It is specifically ordered that the Sheriff of Cumberland County shall only serve this warrant on a weekday between the hours of 8:30 a.m. and 3:00 p.m. and shall bring Defendant immediately before the Court for the purposes of posting security and setting a final hearing on the issue of Sanctions. WITNESS the undersigned Judge, at Carlisle, this 28th day of November, 2006. ~~ M. L. Ebert, Jr., J. ,/, h~ndaQ '~~a~ UOli ~ ~V/)1.L1J/-v~\J1f!J\8 JJT~a4S 'auTl~ SgW04~ .li 'S3aMSUg os 00.0$ :S~SO~ JJT~aqs .~~aq:3: a.6pn.r a~oJaq uaas PUg ~Ug~~gM s1q~ UO Plaq PUg P~gM .8 .~bS ~no hq ~Ug~~gM sTq~ paA~as SgM PUg asnoq~~no~ h~uno~ pugl~aqwn~ aq~ ~g ~~Dtld~ P1P ~oa~qns sTq~ 90/BZ/~~ uo ~gq~ ShgS MgI~^~hlnp .6u1aq JJ1~aqs h~ndaQ '~~a~ UO~ I I I t\1f10r) n~.fiflH~8Ifdno ~i $"\ - tI) () 1\J.J'i~. ,.,. "" n . 'IIAI~ ZES ~-990~1I wv sa AON 900Z gAl1S .~ .xaqdo~sT~q~ gUUad h~uno~ pugl~aq~ONOHlOcd 3H1:!O 381:1.'-0-0311:1 sgald uowwo~ JO ~~no~ aq~ UI SA VINVA'IXSNN:3:d dO H~'IVaMNOWWO~ KARL DODSON, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-1532 CIVIL DOCKET COTTON TRADERS, Defendant CIVIL ACTION - LAW IN RE: ARRAIGNMENT ORDER OF COURT AND NOW, this 28th day of November, 2006, the defendant having been apprehended on a bench warrant for failing to appear on November 27, 2006, in regard to the Plaintiff's Motion for Sanctions, to include contempt of court, IT IS HEREBY ORDERED AND DIRECTED that he shall appear for hearing on the . contempt on January 22, 2007, at 3:00 p.m. in Courtroom Number 5. Additionally, at that time the Court will hear the matter of the plaintiff's request for sanctions regarding the defendant's failure to answer the plaintiff's interrogatories and document production requests in aid of execution. By the Court, 't M. L. Ebert, .J2'6tton Traders 257 North 24th Street Camp Hill, Pa. 17011 Defendant ~ ~bara Sumple-Sullivan, Esquire For the Plaintiff :mtf \f\N\;fI\1)SNN3d '1 t .,\(1\\,",(\ (;t\\r\:l::\.~\\{lr\,t"\ i\JJ ,,\ ,_.",. """ ' \ IV 'l S ~m \-l~ O~ ~Qtl QUU1, }..tN10NOrU.odd 3rn. :YJ 3()B:\~ -- KARL DODSON, d/b/a K.D. GRAPHICS, THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, CIVIL ACTION - LA W v. NO. 06-1532 COTTON TRADERS, INC., JURY TRIAL DEMANDED Defendant. ENTRY OF APPEARANCE TO THE PROTHONOTARY: PLEASE enter the appearance of Ronald L. Finck, Esquire and the law firm of METTE, EVANS & WOODSIDE on behalf of Defendants, Cotton Traders, Inc., Christopher R. Silva and Amy L. Silva, in the above-referenced matter. Respectfully submitted, METTE, EVANS & WOODSIDE By: a~ 1, 4.JL Ronald L. Finck, Esquire Sup. Ct. I.D. #89985 3401 North Front Street P.O. Box 5950 Harrisburg, P A 17110-0950 Attorney for Defendants Cotton Traders, Inc., Christopher R. Silva and Amy Silva DATE: January 18, 2007 CERTIFICATE OF SERVICE I certify that I am this day serving a copy of the foregoing document upon the person( s) 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: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070-1931 METTE, EVANS & WOODSIDE By: 6?owLL ::1._~~: ~ Ronald L. Finck, Esquire Sup. Ct. J.D. #89985 3401 North Front Street P.O. Box 5950 Harrisburg, P A 17110-0950 Attorney for Defendants Cotton Traders, Inc., Christopher R. Silva and Amy L. Silva DATE: January 18, 2007 463838vl (") c: 5~ =2 "'" <= = .....J <- :;p. % f',,) W o -n ~-n nlp -0 fT~ ~:~{6 ~~~ Om ..-I ~ -< ~ -:u.. w K. D. DODSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V 06-1532 CIVIL TERM COTTON TRADERS, Defendant IN RE: CONTEMPT ORDER OF COURT AND NOW, this 22nd day of January, 2007, this being the time and place set for a hearing with regard to an allegation of contempt of court, sanctions for failure to comply with the request for interrogatories in aid of execution, and the defendant having appeared with counsel, and having provided a satisfactory explanation for his noncompliance of the past Order, the defendant will not be held in contempt. IT IS FURTHER ORDERED AND DIRECTED at the request of the plaintiff that the defendant shall submit himself to deposition by the plaintiff on or before the close of business on February 28, 2007. The defendant having previously failed to answer the required discovery and thereby causing the plaintiff additional damages, an additional award of $450.00 in counsel fees is awarded. By the Court, M.~1er~~ Barbara Sumple-Sullivan,Esquire For the Plaintiff Ronald Finck, Esquire For the Defendant ~,~ eJ_PI.07 ~ :mtf . f ~-, l Au'" "'-c,'/\;n8 ~S:6 !PJ 1- 81:J WOl ).,'1\" ..,., '.'.' 1 "'\'11::JO hdi,U' j"'" 'H"."<- "". ..... f..". 'ii\.,), "....-~"....u _t :IJ1:J :iO-{En~:l