HomeMy WebLinkAbout06-2525SHERWIN WILLIAMS COMPANY
V.
IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
HOWARD R. RABER and ROBERT HUMMEL, each
individually and trading as RABER'S PAINTING
Defendant
NOTICE
NO. OL --c?SsZ
CIVIL DIVISION - LAW
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a
written appearance personally or by an attorney and filing in writing with the court your defenses or objections to
the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and
a judgment may be entered against you by the court without further notice for any money claimed in the complaint
or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important
to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOTAFFORDTO HIREA LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas qua se
presentan mas adelante an [as siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias
despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una
comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas
presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe
anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada an la
demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado an contra suya
por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para
usted.
LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO
TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE
INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA
OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES
SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
SHERWIN WILLIAMS COMPANY
V.
Plaintiff
HOWARD R. RABER and ROBERT HUMMEL, each
individually and trading as RABER'S PAINTING
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. OL- ?29XS ` iUt l? `Y?
CIVIL DIVISION - LAW
COMPLAINT
The Plaintiff, SHERWIN WILLIAMS COMPANY, by its attorneys, KNUPP, KODAK & IMBLUM, P.C.,
brings this action of Assumpsit against the Defendantsto recoverthe sum of EIGHTTHOUSAND ONE HUNDRED
THIRTY DOLLARS AND THIRTY-FIVE CENTS ($8,130.35), along with interest thereon at the statutory rate from
March 10, 2006, upon a cause of action of which the following is a statement:
1. The Plaintiff, SHERW IN WILLIAMS COMPANY, is a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 186 Center Street,
Clinton, NJ 08809.
2. The Defendant, HOWARD R. RABER, is an adult individual, trading and doing business as
RABER'S PAINTING, at 11 Hummel Avenue, Camp Hill, Cumberland County, Pennsylvania 17011.
3. The Defendant, ROBERT HUMMEL, is an adult individual, trading and doing business as RABER'S
PAINTING, at 11 Hummel Avenue, Camp Hill, Cumberland County, Pennsylvania 17011.
3. On or about April 7, 2004, Defendants completed and submitted a Commercial Credit Application
to Plaintiff, which credit was granted. A true and correct copy of the Commercial Credit Application is attached
hereto, marked Exhibit "A" and made a part hereof.
F:AUSER\R0B1MCCP&DJ CMPSVCCP COMPLAINTS\SHERWIN WILLIAMS.32160.wpd:02May06
4. Thereafter on various dates and for various amounts, Defendants charged supplies, goods, wares
and merchandise from Plaintiff to the total amount of Six Thousand Seven Hundred Seventy Five Dollars and
Thirty One Cents ($6,775.31) as set forth on Plaintiff's Statement of Account attached hereto, marked Exhibit "B"
and made a part hereof.
5. The prices charged for said goods, wares and merchandise were just and reasonable, were the
legal and market prices therefor and were the prices which the Defendant orally promised and agreed to pay to
Plaintiff
6. The balance due and owing by Defendants to Plaintiff is the sum of Six Thousand Seven Hundred
Seventy Five Dollars and Thirty One Cents ($6,775.31), as appears by Exhibit "B" attached hereto.
7. Due to the default of Defendants, and pursuant to the terms and conditions of the Credit
Application executed by Defendants attached as Exhibit "A", attorney's fees in the total amount of One Thousand
Three Hundred Fifty-Five Dollars and Four Cents ($1,355.04) have been added to said account.
8. Plaintiff's Invoices are not attached to this pleading due to the voluminous nature of same and have
previously been provided to Defendant*.
9. Plaintiff frequently demanded payment from Defendants of said amount due and owing as
aforesaid, but Defendants refused and neglected and still refuse and neglect to pay said amount or any part
thereof
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\SHERWIN WILLIAMS.32160.wpd:02May06 2
WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of EIGHT THOUSAND ONE
HUNDRED THIRTY DOLLARS AND THIRTY-FIVE CENTS ($8,130.35), along with interest thereon at the
statutory rate from March 10, 2006.
Respectfully submitted,
KNUPP, KODr & IMBLUM, P.C.
Robert D. Kodak, Esquire
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7151
Attorney ID No. 18041
Attorney for Plaintiff
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\SHERWIN WILLIAMS.32160.wpd:02May06 3
r FROM : STOFE)ES111(1940YIE FWC,NO. 7177370165 Rpl-. 07 2004 01:27PM P2
Commercial Credit Application
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(or Magd With) OPPlleetlon to quality.
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Pleass
[]PRomirroaxmia ARrimeat IP ?coNVORAT1om 'STATE
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Check One;
iNCORPORATKO 1N
For Proprietorship. Partnership or Corporation if Appdcebte
I.N.me of Owner f ' e Addraa: f U d--^
City: State: - p Code: Social Security Number, Zqj_,rlo?r_ 3r ,re
2. Name of er Home Address:
city: State: . Zip Cedw Social Security Number:
?-mDM-ATI(MIN THIS SECTION MAY 9E USEo TO OSTAI$d A PERSONAL CRFDrT REPORT FROM A
COt6[MIER REPOIMMIG AGENCY
C;WT REFERENCES fif trtdre spew it inswo 1, pimp use cock of E!pL)
NaaQ adbtt$ Is10NE NUWLEA ACCOUNT NUMBER
a
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It credit ar grunosd. Me vadsrsrand that rho terns, of the ask are eat 20e of Np Iwo eth /ell nine! narMUw, The Seerwln • Wlltlend
Compwry rSherwAn-Wiiliarns7 may charge Interest oa any pat dw balance at tie matdmum nn allowed by low with aid Interest being
Nirow" From the date of default.
In consideration of Sborwln-Wgt]ama extending etedt to the serve fouslneek 1(WP do hereby agree Jointly rod (ndltrd,aly. to pay for alt
goods were! and merchandise supplied an me or to any of us or the above busaflosk III the Ought that the account is placed with a third party
for cedeerian. I/We agree to pay all cam including reavatulmo attorney Mace, court coats and lJ/lan¢a emaryas.
ICWe gUdlDHte Sherwin-Wlliams to WjerLigate our audit history Coastal bodtess end peraanel), bent reforenres and any Inrora uloa
deemed tuxuboury to eaten Credit. MG agree to: (q immediately Polity Shorwm-woul oat in Writing. defivered in person or try certified roll]
return mbulpt raquedted, of any theta, in ovanershljL Corm of business, or Wreak or the tal,nfmuoo of a pareoa's outha ty to hour charges
ubdor the account an behefl of the oppilconC and (ii) Indomouy Snerwih.Wlfllams for may toss incurred thereby a a result N our lauure to
provide sold Written nodes. This egragment shelf remain In full force a null wrlttee Dodge f rdvatatlon Is mcelved by
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INTERN USE ONLY
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Page: 1 Document Name: untitled
SERRWIN-WILLIAMS STORES DIVISION 02/10/06
ACCOUNT LACKED OUT CONSOLIDATED ACCOUNT Su MtARY - AL L JOBS R8ARM00-
?cbST...... 6751-9269-4 RABERS PAINTING T/A: 1 PAINTER
DCM........ 00169
UNAPPLIED PAYMENTS/CREDITS.... -1,376.94 STORE...... 5511
1-30 PAST DUE ................. 1,263.56 18.6$ SIC........ 1724
31-60 PAST DUE ................ 1,964.41 28.9k TERMS CODE: 120
61-90 PAST DUE ................ 2,940.65 43.4E
OVER 90 PAST DUE .............. 606.69 8.95
TOTAL PAST DUE ................
CURRENT DUE ...................
TOTAL COLLECTIBLE .............
FUTURE DUE ....................
*** TOTAL CURRENT BALANCE ****
LAST STATEMENT BALANCE........
TOTAL CRD LIMIT FOR ACTIVE JOSS..
6,775.31
.00
6,775.31
.00
6,775.31
6,775.31
14,500
99.83' 100.0$
.0$
100.0k 100.03
.0$
100.0%
OUST: 6751-9269-4 JOE:
PF1 = DCO COMMENTS PF11 - MAIN MENU
DC903077 THIS CUSTOMER HAS MULTIPLE JOBS
Date: 2/10/2006 Time: 2:51:40 PM
PF12 - EXIT APPLICATION
VERIFICATION
I, ROBERT D. KODAK, state that I am not a party to the action but that, at the request of the
Plaintiff, SHERWIN WILLIAMS COMPANY, and based upon knowledge, information, records and
documents supplied to me by the Plaintiff, the averments set forth in Plaintiffs Complaint are true. A
Verification executed by the Plaintiff can be supplied at time of trial or upon request.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904
relating to unsworn falsification to authorities.
?L
Robert D. Kodak
Dated: -S 3 olo
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\SHERWIN WILLIAMS.32160.wpd:02May06
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SHERWIN WILLIAMS COMPANY : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 2006-02525 CIVIL
HOWARD R. RABER and ROBERT HUMMEL, each CIVIL DIVISION -LAW
individually and trading as RABER'S PAINTING
Defendant
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the above-captioned Complaint and direct same to Doris of the Cumberland County
Sheriffs office for the following:
One deputized service through the Dauphin County Sheriffs office on Defendant ROBERT HUMMEL,
individually and trading as RABER'S PAINTING, at the address of 599 Claster Blvd., Dauphin PA 17108 and a
Second service through the Cumberland county sheriff `s Office for service upon Defendant HOWARD R
RABER, individually and trading as RABER'S PAINTING at the address of 11 Hummel Avenue, Camp Hill,
PA 17011.
TO CUMBERLAND COUNTY:
Prothonotary
Dated:bgy 23.2006
Robert D. 9Tr_A.1!_t
Attorney for Plaintiff
Krupp, Kodak & Imblum, P.C.
P.O. Box 11848, Harrisburg PA 17108-1848
Attorney I.D. No. 18041
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SHERWIN WILLIAMS COMPANY
Plaintiff
VS.
HOWARD R. RABER and
ROBERT HUMMEL, each individually
and trading as RABER'S PAINTING
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
No. 2006 - 02525
Civil Division - Law
PRAECIPE TO ENTER APPEARANCE
TO: PROTHONOTARY OF CUMBERLAND COUNTY,
Please enter the appearances of RUPP AND MEIKLE and RICHARD C.
RUPP, ESQ. as Attorneys for Defendant ROBERT HUMMEL named above as
one of the Defendants in the above captioned Civil matter.
Respectfully submitted,
AND IKL
KOO,
lky: Richard C. Rul p, Es
Attorneys for Defendant Robert Hummel
RCR/clr
'0 - k.
CERTIFICATE OF SERVICE
I, Richard C. Rupp, Esq., do hereby certify that I am serving a true and
correct copy of the foregoing document upon the persons named below.
Robert D. Kodak, Esq.
407 N. Front Street
P.O. Box 11848
Harrisburg, PA 17108-1848
and
Shana M. Pugh, Esq.
The Law Offices of Patrick F. Lauer, JR., L.L.C.
2108 Market Street, Aztec Building
Camp Hill, PA 17011
Richard C. Rupp, Esquire
Attorney I.D. # 34832
355 North 21'" Street, Suite 201
Camp Hill, Pennsylvania 17011
(717) 761-3459
Date: !5/ rl?t7 6
RCR/clr
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v-,
- .{,
'? ?` .tom V
SHERWIN WILLIAMS COMPANY,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVNIA
NO. 2006-02525
HOWARD R. RABER AND ROBERT
HUMMEL, each individually and trading : CIVIL DIVISION
as RABER'S PAINTING,
Defendant
PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT
AND NOW, comes the Defendant, Howard R. Raber, individually and trading as Raber Painting,
by and through his attorneys, the Law Offices of Patrick F. Lauer, Jr., LLC, and files Preliminary
Objections to Plaintiff s Complaint and avers the following in support thereof:
A. PRELMINARY OBJECTION PURSUANT TO Pa.R.C.P. 1028 (a)(1) FOR
1. Pennsylvania Rule of Civil Procedure 1028(a)(1) authorizes a preliminary objection
based upon improper service of the complaint.
2. In the pending action, the Plaintiff filed the Complaint, attached hereto as Exhibit "A"
and incorporated herein, on May 4, 2006 and reinstated the Complaint on May 24, 2006.
3. On or about June 11, 2006, the Dauphin County Sheriff served Defendant Robert
Hummel with a copy of the Complaint at his residence located at 599 Claster Boulevard Dauphin,
Pennsylvania, 17018.
4. On or about June 11, 2006, the Dauphin County Sheriff also served Defendant Robert
Hummel with Defendant Howard R. Raber's copy of the Complaint. Service was made at Robert
Hummel's residence located at 599 Claster Boulevard Dauphin, Pennsylvania, 17018.
5. Defendant Howard R. Raber was not present when the Complaint was served.
6. Defendant Robert Hummel's residence is not a usual place of business or office for
Defendant Howard R. Raber nor is Robert Hummel an agent of Howard R. Raber
7. Service of the Complaint was not proper pursuant to Pa.R.C.P. 402(2)(iii).
WHEREFORE, Defendant Howard R. Raber, respectfully requests this Honorable Court sustain
the preliminary objection to service and dismiss the Complaint as to the Defendant, Howard R.
Raber, and as to Raber Painting.
Respectfully submitted,
(3A /7 I/d I I M
Shana M. Pugh, squ e
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street
Camp Hill, Pennsylvania 17011
Date ID# 200952 Tel. (717) 763-1800
SHERWIN WILLIAMS COMPANY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY PENNSYLVNIA
V. : NO. 2006-02525
HOWARD R. RABER AND ROBERT
HUMMEL, each individually and trading : CIVIL DIVISION
as RABER'S PAINTING
VERIFICATION
I verify that the statements made in this document are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom
falsification to authorities.
Date: V2-`-6(o Signature: 141441 ? gL
Howard R. Raber
c,141alT A
SHERWIN WILLIAMS COMPANY,:;;
V.
: IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
HOWARD R. RABER and ROBERT HUMMEL, each
individually and trading as RABER'S PAINTING
Defendant
NOTICE
NO. ZOO( - 6 a2-G
CIVIL DIVISION - LAW
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a
written appearance personally or by an attorney and filing in writing with the court your defenses or objections to
the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and
a judgment may be entered against you by the court without further notice for any money claimed in the complaint
or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important
to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IFYOU CANNOTAFFORDTO HIREA LAWYER, THIS OFFICE MAY BEABLETO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCgW COPY FROM RECORD
- TWO L-+BERTY AVENUE 5+Q yw1"eol• I two-unto sat my 4W
CARLISLE PA 17013 aw t i of %6d C4011 at L'arliew. Pa.
(717) 249-3166 rhig 0
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se
presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias
despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una
comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas
presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe
anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la
demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya
por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para
usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO
TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE
INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA
OFICINA LE PUEDA PROVEER INFORMACION SOBREAGENCIAS QUE OFREZCAN SERVICIOS LEGALES
SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
SHERWIN WILLIAMS COMPANY : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
HOWARD R. RABER and ROBERT HUMMEL, each
individually and trading as RABER'S PAINTING
Defendant
NO.
CIVIL DIVISION - LAW
COMPLAINT
The Plaintiff,) SHERWIN WILLIAMS COMPANYI by its attorneys, KNUPP, KODAK & IMBLUM, P.C.,
brings this action ofAssumpsit against the Defendants to recoverthe sum of EIGHTTHOUSAND ONE HUNDRED
THIRTY DOLLARS AND THIRTY-FIVE CENTS ($8,130.35), along with interest thereon at the statutory rate from
March 10, 2006, upon a cause of action of which the following is a statement:
1. The Plaintiff, SHERWIN WILLIAMS COMPANY, is a corporation organized and existing underthe
laws of the Commonwealth of Pennsylvania, having its principal office and place of business at 186 Center Street,
Clinton, NJ 08809.
2. The Defendant, HOWARD R. RABER, is an adult individual, trading and doing business as
RABER'S PAINTING, at 11 Hummel Avenue, Camp Hill, Cumberland County, Pennsylvania 17011.
3. The Defendant, ROBERT HUMMEL, is an adult individual, trading and doing-business as RABER'S
PAINTING, at 11 Hummel Avenue, Camp Hill, Cumberland County, Pennsylvania 17011.
3. On or about April 7, 2004, Defendants completed and submitted a Commercial Credit Application
to Plaintiff, which credit was granted. A true and correct copy of the Commercial Credit Application is attached
hereto, marked Exhibit "A" and made a part hereof.
4. Thereafter on various dates and for various amounts, Defendants charged supplies, goods, wares
and merchandise from Plaintiff to the total amount of Six Thousand Seven Hundred Seventy Five Dollars and
Thirty One Cents ($6,775.31) as setforth on Plaintiffs Statement of Account attached hereto, marked Exhibit "B"
and made a part hereof.
5. The prices charged for said goods, wares and merchandise were just and reasonable, were the
legal and market prices therefor and were the prices which the Defendant orally promised and agreed to pay to
Plaintiff.
6. The balance due and owing by Defendants to Plaintiff is the sum of Six Thousand Seven Hundred
Seventy Five Dollars and Thirty One Cents ($6,775.31), as appears by Exhibit "B" attached hereto.
7. Due to the default of Defendants, and pursuant to the terms and conditions of the Credit
Application executed by Defendants attached as Exhibit "A", attorney's fees in the total amount of One Thousand
Three Hundred Fifty-Five Dollars and Four Cents ($1,355.04) have been added to said account.
8. Plaintiffs Invoices are riot attached to this pleading due to the voluminous nature of same and have
previously been provided to Defendant'.
9. Plaintiff frequently demanded payment from Defendants of said amount due and owing as
aforesaid, but Defendants refused and neglected and still refuse and neglect to pay said amount or any part
thereof
WHEREFORE, Plaintiff brings this suit to recover from Defendants the sum of EIGHT THOUSAND ONE
HUNDRED THIRTY DOLLARS AND THIRTY-FIVE CENTS ($8,130.35), along with interest thereon at the
statutory rate from March 10, 2006
Respectfully submitted,
KNUPP, KOD & IMBLUM, P.C.
Robert D. Kodak, Esquire
I 407 North Front Street
Post Office Box 011848
Harrisburg, PA 17108-1848
(717) 238-7151
Attorney ID No. 18041
Attorney for Plaintiff
FROM : SDF20S55111Le10YhE FPX MD. : 7177310165 PPr. 07 2004 61:27M P2
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(or flood with) application to qualify. ?^ G
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Chalk ?CdIDORA710N LLC
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For Proprietorship. Pannetamp or Cor'porsUan if Applkabla -
1.N.me or Owners • a Addrac ' y=
City: State: - P 'Code! Social Security Number.
2.11ama of er Nome Address: 1W 42E?&
c)O: Stars: , Zip Cadx Social Sacurl[y Number:
INFOpNAT10N IN Ti)IS SECTION mAY of USED TO O6TAIN A PERSONAL CRlDIr REpoitT FRQN A
CONSJJDIEB REPORTIFIO ArANCV
CREDIT REFERENCES Of moms it doodad, please use back a E!geL)
HAa@ Anagm NIpNE NnA AC[OUNr AILING"
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B"Nmw . - Foam Account f
If credit Ice granted, ME undetsund mac the terms of are sate am net 200, of t)IO.rnenth lo4mahae oershave, The Sherwin-Williams
company (-Sherwin-Williams-) may ebarge Inceten on any past due balance at the MXJmum rate allowed by law Moth said Interact behng
eekalsted tram the data of default.
In consideration of Sborwbt-WdWma eatendfa0 cscAt to %M above business, UWE E-do hereby spratJointly and Individually. w pay for all
goads wares and merch"Ise supplied to ma or co any of us or the above businaaa. Iii the even: ttlat the account Is placed wlin a TAIrd party
for collection, UWo agree to pay all coati Including rucanaele attorney fees, mart torts and nntnca Charges.
IfWa Wthorlu Sho wIMWintams w Investigate our Credit history (bath busUmm and personal). Ionic nlefeftes and any mrofmadoo
dautad aaoossery to ckwd Credit. IIWe mine to: (Q Immediately aatny Sharwm-Wabams in writing. delivered in person or by cardned mall
roture receipt gquessad, of any change In ownersalF form of buttnesR or address, or the termination of a panoe's authority to orcw Charges
under the --, at on behalf of the applicant: and (l) Indecently Snerwln.Wlillatns for arty lots Incurred thereby as a result of our lagbre to
prordda sere written nottra. This agreement. shall remain In full force a .Until wrime, rual t ravocatloe Is recalved by
tor.
na[e [ee "A aaw. boo.
Prim Name Fiance PNeNoroNan c
'INTERN USE ONLY '
Stare r. Torrlwry Y: CAC Coda: . DCP: o P.S. Vaiume:
A.dalpated Cndk Ltmfct _ L67 ApdAYed Credit Llmle.
Aeeaunt Humber: Date: 4 A and By.
'
'Oeekrr N.qn Sflbaq
Sinm D.u tact
Cho. Sol. Tv mob Crater 8.1.""
Pea: out
mmern
EX BIT
Page: 1 Document Name: untitled
SHERWIN-WILLIAMS STORES DIVISION 02/10/06
ACCOUNT LOCKED OUT CONSOLIDATED ACCOUNT BUMMARY - A LL JOBS RBARMo0-
?GVST...... 6751-9269-4 RABERS PAINTING T/A: 1 PAINTER
DCM........ 00169
UNAPPLIED PAYMENTS/CREDITS.... -1,376.94 STORE...... 5511
1-30 PAST DUS ................. 1,263.56 18.62 SIC........ 1724
31-60 PAST DDB ................ 1,964.41 28.9% TERMS CODE: 120
61-90 PAST DUE ................ 2,940.65 43.4*
OVHR 90 PAST DUB .............. 606.69 8.9%
TOTAL PAST DUE ................ 6,775.31 99.8* 100.0*
CURRENT DUE... ............ .00 .Ot
TOTAL COLLECTIBLE ............. 6,775.31 100.01 100.01
FUTURE DUE.. ...... .00 .0%
*** TOTAL CURRENT BALANCE *+** 6,775.31 100.0%
LAST STATEMENT BALANCE .....I... 6,775.31
TOTAL CRD LIMIT FOR ACTIVE JOBS.. 14,500
COST: 6751-9269-4 JOB:
PP1 a DCO COMMENTS PF11 a MAIN MENU PY12 - SKIT APPLICATION
DC9C3077 THIS CUSTOMER BAS MULTIPLE JOBS
Date: 2/1012006 Time: 2:51:40 PM
EXHIBIT -
VERIFICATION
I, ROBERT D. KODAK, state that I am not a party to the action but that, at the request of the
Plaintiff, SHERWIN WILLIAMS COMPANY, and based upon knowledge, information, records and
documents supplied tome by the Plaintiff, the averments set forth in Plaintiffs Complaint are true. A
Verification executed by the Plaintiff can be supplied at time of trial or upon request.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904
relating to unsworn falsification to authorities.
Robert D. Kodak
Dated: 3 0(c
r? (-?
t-, ?l
.. .mil r J
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^,;`t
y
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cS
SHERWIN WILLIAMS COMPANY
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-02525
HOWARD R. RABER and ROBERT
HUMMEL, each individually and trading as CIVIL DIVISION -LAW
RABER'S PAINTING
Defendants
ACCEPTANCE OF SERVICE
I, SHANA M. PUGH, ESQUIRE, of the Law Offices of Patrick F. Lauer, Jr., hereby accept
service of the Complaint on behalf of the Defendant, HOWARD R. RABER, individually and
trading as RABER'S PAINTING, and certify that I am authorized to do so.
SHANA M. PUGH, 4$QISEE/
LAW OFFICES OF P\ATRICK F. LAUER, JR.
2108 MARKET STREET
CAMP HILL PA 17011
(717) 763-1800
Dated:
?'
?,
?? a
SHERWIN WILLIAMS COMPANY, : IN THE COU T OF COMMON PLEAS OF
Plaintiff : CUMBERLA D COUNTY PENNSYLVNIA
V. :NO. 2006-025 5
HOWARD R. RABER AND ROBERT
HUMMEL, each individually and trading CIVIL DIVISI N
as RABER'S PAINTING,
Defendant
AND NOW, comes the Defendant, Howard R. Raber, individually and trading as Raber Painting,
by and through his attorneys, the Law Offices of Patrick F. uer, Jr., LLC, and files an answer
to Plaintiff's Civil Complaint and avers the following in sup rt thereof:
1. Admitted.
2. Denied. The Defendant Howard Raber is tr-4ng and doing business as Raber's
Painting at 421 Garriston Road, York Haven, York County, :el sylvania, 17370,
3. Denied. It is denied that Defendant Ris trading and doing business
as Raber's Painting at 11 Hummel Avenue, Camp Hill, C berland County, Pennsylvania,
17011. It is denied that Defendant Robert Hummel is tradin and doing business as Raber
Painting.
4. Denied. Defendant Howard Raber denies tha he completed and signed the
Commercial Credit Application attached to Plaintiff s Com laint as Exhibit "A".
5. After reasonable investigation, the Defendant Howard Raber has insufficient
information as to the purchaser of such items and the Commercial Account Balance, therefore
proof thereof is demanded at the time of trial.
6. Admitted in part, denied in part. It is admitted
goods, wares, merchandise, and supplies were just and reasor
prices therefore. It is denied that Defendant Howard Raber or
Plaintiff.
7. After reasonable investigation, the Defendant
the Commercial Account Balance, therefore proof thereof is
8. Denied. It is denied that Defendant agreed to
Credit Application.
9. Admitted.
10. Denied. Defendant Howard Raber's counsel r
collection agency as well as Plaintiffs attorney to resolve an
been due and owing, attached hereto as Exhibits "A" and `S
herein.
11. After reasonable investigation, the Defe:
the Commercial Credit Account balance and attorney's
demanded at the time of trial.
Date-b4
Respectfully
the prices charged for said
, were the legal and market
promised and agreed to pay
s insufficient information as to
winded at the time of trial.
terms and conditions of the
ale contact with Plaintiff s
outstanding balance that may have
respectively, and incorporated
insufficient information as to
efore strict proof thereof is
bnana M. Pn rsquue `-?
Law Offices o Patrick . Lauer, Jr., LLC
2108 Market S et
Camp Hill, Pe ylvania 17011
IN 200952 el. (717) 763-1800
0 r? R
THE LAW OFFICES OF PATRICK F. LAE
2108 MARKET STREET, AZTEC BUILDER
CAMP HILL, PENNSYLVANIA 17011
Patrick F. Lauer, Jr., Esq.* (717) 763=1800 FAX (717) 763-4247
Marlin L. Markley, Esq.** Reply to Camp Hill Address
Shana M. Pugh, Esq. "
1-800-822-4-LAW May 1, 2006
A.G. Adjustments, Ltd.
1600 Old Country Road
P.O. Box 9109, Suite 100
Plainview, NY 11803-9109
Your File No.: 827807
Original Creditor: Sherwin Williams
Account No.: 675192694
Dear Mr. Fox:
Please be advised' that this office represents Howard Ral
referenced above. Please contact me at your earliest possible
account.
If you have any questions, please contact me.
VIA FACSIMILE AND
FIRST CLASS MAIL
SMP/
JR., L.L.C.
Satellite Office:
8 S. Hanover Street
Carlisle, PA 17013
aim a,.t_pas....+
M9 I R1
holder of the account
renience to discuss the
*(@>$oard Certified as a Criminal PIal Advocate by the National Board
• dblNember„ National Association of Criminal Defense Law
THE LAW OFFICES OF PATRICK F. LAU
2108 MARKET STREET, AZTEC RUILDIN
CAMP HILL, PENNSYLVANIA 17011
Patrick F. Lauer, Jr., Eaq.* (717) 763-1800 FAX (717) 763-4247
Marlin L. Markley, Esq.- Reply to Camp Hill Address
Shana M. Pugh, Esq.
1-800-822-4-LAW
May 3, 2006
Robert D. Kodak, Esquire
Knupp, Kodak, and Imblum, P.C.
407 N. Front St., Cameron Mansion
Harrisburg, PA 17108
RE: Creditor: Sherwin Williams
Debtors: Howard Raber and Robert
Your file No:: 32160
Dear Attorney Kodak:.
JR., L.L.C.
Satellite office.,
8 S. Hanover Street
Carlisle, PA 17013
• FILE Oi
R°
Please be advised that I represent Howard Raber in the action referenced above. I have
also advised A.G. Adjustments of my representation. It is my understanding from
speaking to Mr. Raber that contact has not been made with Robert Hummel. If you have
been unsuccessful in finding Mr. Hummel;* please advise as I am in possession of his
contact information.
Please contact me at your earliest possible convenience to discuss this debt.
yours,
SMP/
Cc: Howard Raber
Shana M. Pugh,
*4MBoard Cerhied as a Criminal 7Wal Advocate by the National Boar of Pia1 Advocacy.
I
SHERWIN WILLIAMS COMPANY, : IN THE
Plaintiff : CUMBI
V. : NO. 2(
HOWARD R. RABER AND ROBERT
HUMMEL, each individually and trading : CIVIL
as RABER'S PAINTING
OF COMMON PLEAS OF
COUNTY PENNSYLVNIA
VERIFICATION
I verify that the statements made in this Answer to PI 'tiff s Complaint are true and correct.
I understand that false statements herein are made subject t the penalties of'18 Pa. C.S. §4904,
relating to unworn falsification to authorities.
Date:
SHERWIN WILLIAMS COMPANY, : IN THE
Plaintiff : CUMBI
V. : NO.
HOWARD R. RABER AND ROBERT
HUMMEL, each individually and trading : CIVIL
as RABER'S PAINTING
I, Shana M. Pugh, Esquire hereby certify that I am this
DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT
indicated below, which service satisfies the requirements
Procedure, by depositing the same through first class mail,
Sherwin Williams Co.
c% Robert D. Kodak, Esq.
407 N. Front St.
Harrisburg, PA 17108
Date:
Respectfully
Shana M. Pik
Law Offices
2108 Market
Camp Hill, P
ID# 200952
OF COMMON PLEAS OF
COUNTY PENNSYLVNIA
serving a copy of the foregoing
the person, and in the manner,
Rules of Civil
addressed as follows:
hi& F. Lauer, Jr., LLC
t, Aztec Building
dvania 17011-4706
7) 763-1800
n O
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5 A
n
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G
J7
SHERIFF'S RETURN - NOT FOUND
I
CASE NO: 2006-02525 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SHERWIN WILLIAMS COMPANY
VS
RABER HOWARD R ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
RABER HOWARD R but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
the within named DEFENDANT
11 HUMMEL AVENUE
CAMP HILL, PA 17011
RABER HOWARD R
NOT FOUND , as to
DEFENDANT IS NOT LOCATED AT 11 HUMMEL AVENUE
Sheriff's Costs: So a
Docketing 18.00 .?1
Service 39.60
Not Found 5.00 R. Thomas Kline
Surcharge 10.00 eriff of Cumberland County
Postage 1.74
74.3 ? KNUPP KODAK IMBLUM
06/19/2006
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-02525 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SHERWIN WILLIAMS COMPANY
VS
RABER HOWARD R ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
HUMMEL ROBERT but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
NOT FOUND , as to
the within named DEFENDANT HUMMEL ROBERT
I
11 HUMMEL AVENUE
CAMP HILL, PA 17011
DEFENDANT IS NOT LOCATED AT 11 HUMMEL AVENUE
Sheriff's Costs:
Docketing 6.00
Service .00
Not Found 5.00
Surcharge 10.00
So an
Thomas Kline
ri f of Cumberland County
21 . 00 ,/ (KNUPP KODAK IMBLUM
a eG 06/19/2006
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-02525 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SHERWIN WILLIAMS COMPANY
VS
RADER HOWARD R ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
RABER HOWARD R T/A RABER'S PAINTING but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
NOT FOUND , as to
the within named DEFENDANT
RABER HOWARD R T/A RABER'S
PAINTING
11 HUMMEL AVENUE
CAMP HILL, PA 17011
DEFENDANT IS NOT LOCATED AT 11 HUMMEL AVENUE
Sheriff's Costs: So ans
Docketing 6.00
Service .00 _
NOt Found 5.00
Surcharge 10.00
.00
21.00?
17.07-OG
Sworn and Subscribed to before
me this day of
' Thomas Kline
ff of Cumberland. County
UPP KODAK IMBLUM
06/19/2006
A. D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2006-02525 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SHERWIN WILLIAMS COMPANY
VS
RABER HOWARD R ET AL
R. Thomas Kline
duly sworn according to law,
inquiry for the within named
HUMMEL ROBERT T/A RABER'S
unable to locate Him in his
COMPLAINT & NOTICE ,
,Sheriff or Deputy Sheriff, who being
says, that he made a diligent search and
DEFENDANT
PAINTING but was
bailiwick. He therefore returns the
NOT FOUND , as to
the within named DEFENDANT HUMMEL ROBERT T/A RABER'S
PAINTING
11 HUMMEL AVENUE
CAMP HILL, PA 17011
DEFENDANT IS NOT LOCATED AT 11 HUMMEL AVENUE
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
So a
6.00
.00
5.00 R. Thomas Kline
10.00 riff of Cumberland County
.00
21.00 KNUPP KODAK IMBLUM
06/19/2006
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2006-02525 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SHERWIN WILLIAMS COMPANY
VS
RABER HOWARD R ET AL
R. Thomas Kline
Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
HUMMEL ROBERT
but was unable to locate Him
deputized the sheriff of DAUPHIN
serve the within COMPLAINT & NOTICE
County, Pennsylvania, to
On June 19th , 2006 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs: So
Docketing 6.00
Out of County 9.00
Surcharge 10.00
Dep Dauphin County 73.00 S
.00
98.00
06/19/2006 ? Dlw?+
KNUPP KODAK IMBLUM
Sworn and subscribe to before me
this day of
A. D.
Tomas Kline
riff of Cumberland County
,.r
in his bailiwick. He therefore
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2006-02525 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SHERWIN WILLIAMS COMPANY
VS
RABER HOWARD R ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
HUMMEL ROBERT T/A RABER'S PAINTING
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On June 19th , 2006 , this office was in receipt of the
attached return from DAUPHIN .-----7
Sheriff's Costs:
Docketing 6.00
Out of County .00
Surcharge 10.00
.00
.00
16.00 ?
06/19/2006 Y?o7/4G
KNUPP KODAK IMBLUM
Sworn and subscribe to before me
this day of
iff of Cumberland County
A. D.
In The Court of Common Pleas of Cumberland County, Peninsylvariaa
Sherwin Williams Canpany
Howard R. Rabse--r et al
SERVE: Robert Hummel No. 06-2525 civil
Now, May 25, ,2006 I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Daupl" County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of.Service
Now,
within
20 , at o'clock M. served the
upon
at
by handing to
a
and made known to
Sworn and subscribed before
me this day of , 20,
copy of the original
So answers,
the contents thereof.
Sheriff of
COSTS
SERVICE
MILEAGE
AFFIDAVIT
County, PA
Z E :01 V 91 Nnr 9001
d ";'.? isllu jiii iacr?fi?i
AA183HS 3HI A 301330
(j)ffice of t4P f*hEriff
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania SHERWIN WILLIAS COMPANY
vs
County of Dauphin HUMMEL ROBERT
Sheriff's Return
No. 0922-T - - -2006
OTHER COUNTY NO. 2006 02525
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
AND NOW:June 12, 2006 at 9:57AM served the within
REINSTATED COMPLAINT upon
HUMMEL ROBERT by personally handing
to ROBERT HUMMEL DEFENDANT 1 true attested copy(ies)
of the original REINSTATED COMPLAINT and making known
to him/her the contents thereof at 599 CLASTER BLVD
DAUPHIN, PA 17108-0000
Sworn and subscribed to
before me this 13TH day of JUNE, 2006
11 Gel.[/
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept. 1, 2006
So Answers,
? le" A C -
Sheriff of Dauphin County, Pa.
r f1
By
Deputy Sherif
Sheriff's Costs:$73.00 PD 06/02/2006
RCPT NO 218326
GMILLER
s z :01 V 91 NA 9001
tt
JAW3N5 3Hi ]0 3313. 0
In The Curt of Common Pleas of Cumberland County, Pennsylvania
Sherwin Williams Company
Howard R. Rater et al
SERVE: Robert Hammel t/a Raber's Painting No. 06-2525 civil
Now, May 25 , 2006
hereby deputize the Sheriff of
I, SHERIFF OF CUMBERLAND COUNTY, PA, do
Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now, , 20 , at o'clock M. served the
within
upon
at
by handing to
a
and made known to
copy of the original
So answers,
Sheriff of
Sworn and subscribed before
me this day of , 20
COSTS
SERVICE $
MILEAGE
AFFIDAVIT
the contents thereof.
County, PA
z E -01 b 91 NRr 4001
E?.aUY"vi ij
JAMHs 3Hi A joi3??
(?f £ice Of t4E o$heriff
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania SHERWIN WILLIAS COMPANY
vs
County of Dauphin HUMMEL ROBERT
Sheriff's Return
No. 0922-T - - -2006
OTHER COUNTY NO. 2006 02525
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
AND NOW:June 12, 2006 at 9:57AM served the within
REINSTATED COMPLAINT upon
HUMMEL ROBERT by personally handing
TA RABERS PAINTING
to SERVED ROBERT HUMMEL DBA RABERS PAINTING 1 true attested copy(ies)
of the original REINSTATED COMPLAINT and making known
to him/her the contents thereof at 599 CLASTER BLVD
Sworn and subscribed to
before me this 13TH day of JUNE, 2006
1 A/
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept. 1, 2006
DAUPHIN, PA 17108-0000
So Answers,
Sheriff of Dauphin CQunty, Pa.
'4P
By
Deputy Sheriff
Sheriff's Costs:$73.00 PD 06/02/2006
RCPT NO 218326
GMILLER
8 Z :01 V 91 Nnr 90OZ
ti
?4 - k. '.0
SHERWIN WILLIAMS CO. IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v NO. 2006-02525
HOWARD R RABER and ROBERT HUMMEL,
each individually and trading as RABER'S CIVIL ACTION - LAW
PAINTING
Defendant
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Robert D. Kodak, Esquire, counsel for the plaintiffs in the above action, respectfully represents that:
1. The above-captioned action(s) isiare at issue.
2. The claim of plaintiff in the action is $8,310.35, plus interest from March 10, 2006.
The counterclaim of the defendant in the action is: N/A.
The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as
arbitrators: ROBERT D. KODAK, ESQUIRE (KODAK & IMBLUM, P.C.) and SHANA M. PUGH, ESQUIRE,
LAW OFFICES OF PATRICK F. LAUER, JR. and RICHARD C. RUPP, ESQUIRE, RUPP AND MEIKLE
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case
shall be submitted.
Respectfull u itt ,
Robert D. Kodak, Esquire
Kodak & Imblum, P.C.
PO BOX 11848
Harrisburg, PA 17108-1848
(717) 238-7151
ORDER OF COURT
AND NOW, , 2006, in consideration of the foregoing petition,
Esq., and Esq., and
Esq., are appointed arbitrators in the above captioned action (or
actions) as prayed for. BY THE COURT:
GEORGE E. HOFFER, P.J.
a .- i- •
CERTIFICATE OF SERVICE
1, ROBERT D. KODAK, ESQUIRE, hereby certify that I served a true and correct copy of the
PETITION FOR APPOINTMENT OF ARBITRATORS in the above-captioned matter upon the below
listed individual(s) by causing same to be deposited in the United States mail, first class postage prepaid
at Harrisburg, Dauphin County, Pennsylvania, addressed as follows:
SHANA M PUGH ESQUIRE
LAW OFFICES OF PATRICK F LAUER JR
2108 MARKET STREET
CAMP HILL PA 17011
KODAK 8 IMBLUM, P.C.
Robert D. Kodak, Esquire
407 North Front Street
Post Office Box 11848
Harrisburg, PA 17108-1848
(717) 238-7151
Attorney I.D. No. 18041
Attorney for Plaintiff
Dated: November 1, 2006
... . W
Vv ? ?t
N '' G
y ?.dt
SHERWIN WILLIAMS COMPANY
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-02525 Civil
HOWARD R. RABER and ROBERT
HUMMEL,each individually & trading CIVIL DIVISION -LAW
as RABER'S PAINTING
Defendants
TO: PROTHONOTARY, COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PRAECIPE FOR DEFAULT JUDGMENT
Enter judgment in favor of Plaintiff and against Defendant(s) ROBERT HUMMEL (only),
named for failure to file within the required time an Answer to the Complaint in the
above-captioned case and assess the Plaintiffs damages as follows:
Amount claimed in Plaintiffs Complaint $8,130.35
Interest from March 10, 2006 at the statutory rate of 6% per annum 284.55
Total $8,415.10
It is hereby certified that a written notice of intention to file this Praecipe was mailed to
the Defendant(s) and his attorney of record, after the default occurred and at least ten
(10) days prior to the date of the filing of this Praecipe. See Exhibits A & B attached.
KODAK &
By _
Robert D. Kodak, Attorney for Plaintiff
DATED: Judgment entered and damages assessed as above.
? 1_/m ?11
l
"OR066?__'
LAW OFFICES OF
KODAK & IMBLUM, P.C.
Robert D. Kodak CAMERON MANSION
Gary J. Imblum 407 NORTH FRONT STREET
POST OFFICE BOX 11848
HARRISBURG, PA 17108-1848
kki.law®verizomnet
website: kki-law.com
September 13, 2006
ROBERT HUMMEL
C/O RICHARD C RUPP ESQ
355 NORTH 21ST STREET STE 201
CAMP HILL PA 17011
tTj( 1
ILE 5
F
Facsiunillee
717.238.7158
RE: Sherwin Williams Company
VS: Howard R. Raber and Robert Hummel e/ i/ a/ t/ a Raber's Painting
No. 2006-02525 Civil, Court of Common Pleas
Cumberland County, Pennsylvania
Our File No. 32160
Greetings:
In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are enclosing
herewith a Notice of a Praecipe for Entry of Default Judgment According to the records as they are
found in the Office of the Prothonotary of Cumberland County, you have not filed responsive
pleadings to the Complaint filed against you to the above term and number, or an attorney has not
entered an appearance on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do
not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request
the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount
as set forth in said Complaint
Very truly yours,
KODAK & IMBLUM, P.C.
Robert D. Kodak
THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE
RDK/kqb
enclosure
cc: DINA FERRIS
AG ADJUSTMENTS
PO BOX 9109
PLAINVIEW NY 11803-9109
#827807
F 8C9
t yy T.
{f ?"Aa[ F'fl'6
SHERWIN WILLIAMS COMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2006-02525 Civil
HOWARD R. RABER and ROBERT HUMMEL, CIVIL DIVISION - LAW
each individually & trading as RABER'S
PAINTING
Defendants
IMPORTANT NOTICE
TO: ROBERT HUMMEL , Defendant(s)
DATE OF NOTICE: SEPTEMBER 13, 2006
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 OROBJECTIONS TOTHE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAYBE ENTERED AGAINST YOU W ITHOUT A HEARING, AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
--b-
SHERWIN WILLIAMS COMPANY
Plaintiff
V.
HOWARD R. RABER and ROBERT
HUMMEL, each individually & trading
as RABER'S PAINTING
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-02525 Civil
: CIVIL DIVISION -LAW
Defendants :
TO: ROBERT HUMMEL, Defendant(s)
You are hereby notified that on a) tT,,L, ) (° , 2W_? the following
(Judgment) has been entered against you in the above-captioned case.
Judgment entered in the amount of $5,415.10.
DATE: c r-P ,, I t, . a- ov 4
Pr onotary
I hereby certify that the name and address of the proper person(s) to receive this
notice is:
ROBERT HUMMEL
C/O RICHARD C RUPP ESQ
355 NORTH 21ST STREET STE 201
CAMP HILL PA 17011
ti
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W
SHERWIN WILLIAMS CO. IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v NO. 2006-02525
HOWARD R RABER and ROBERT HUMMEL,
each individually and trading as RABER'S CIVIL ACTION - LAW
PAINTING
Defendant
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Robert D. Kodak, Esquire, counsel for the plaintifffdielvi rdan! in the above action, respectfully represents that:
1. The above-captioned action(s) istm-e at issue.
2. The claim of plaintiff in the action is $8,310.35, plus interest from March 10, 2006.
The counterclaim of the defendant in the action is: N/A.
The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as
arbitrators: ROBERT D. KODAK, ESQUIRE (KODAK & IMBLUM, P.C.) and SHANA M. PUGH, ESQUIRE,
LAW OFFICES OF PATRICK F. LAUER, JR. and RICHARD C. RUPP, ESQUIRE, RUPP AND MEIKLE
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case
shall be submitted.
Respectfull u itt ,
Robert D. Kodak, Esquire
Kodak & Imblum, P.C.
PO BOX 11848
Harrisburg, PA 17108-1848
(717) 238-7151
ORDER OF COURT
AND NOW, , 2006, i consideration of the foregoing petition,
Esq., and Esq., and
Esq., are appoint trators in the above captioned action (or
actions) s prayed for. BY T OURT
N C", 19?
P.J.
I : 8I IVIV 8- AM HE
CERTIFICATE OF SERVICE
I, ROBERT D. KODAK, ESQUIRE, hereby certify that I served a true and correct copy of the
PETITION FOR APPOINTMENT OF ARBITRATORS in the above-captioned matter upon the below
listed individual(s) by causing same to be deposited in the United States mail, first class postage prepaid
at Harrisburg, Dauphin County, Pennsylvania, addressed as follows:
SHANA M PUGH ESQUIRE
LAW OFFICES OF PATRICK F LAUER JR
2108 MARKET STREET
CAMP HILL PA 17011
KODAK & IMBLUM, P.C.
Robert D. Kodak, Esquire
407 North Front Street
Post Office Box 11848
Harrisburg, PA 17108-1848
(717) 238-7151
Attorney I.D. No. 18041
Attorney for Plaintiff
Dated: November 1, 2006
4J
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SHERWIN WILLIAMS COMPANY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVNIA
V. : NO. 2006-02525
HOWARD R. RABER AND ROBERT
HUMMEL, each individually and trading : CIVIL DIVISION
as RABER' S PAINTING,
Defendant
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw the appearance of Shana M. Pugh, Esquire, in the above-captioned action
as the Defendant, Howard R. Raber is entering his appearance pro se.
Respectfully submitted,
, q'. 4A. P-"?;
Shana M. Pugh, Esquire
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
Date: - 9 - ID# 200952 Tel. (717) 763-1800
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of Howard R. Raber, Pro se, in the above-captioned action.
Respectfully submitted,
Howard R. Raber, Pro se
421 Garriston Road
York Haven, PA 17370
Date: 1 / (717) 938-8802
T""Z f'"lj
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?QrWC o 6,t
A "Jlaintiff
I a:57
Defendant
In The Court of Common Pleas of Cumberland
County, Pennsylvania No -oZOG - O ZSi?
Civil Action - Law.
Oath
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United
States and the Constitution of this Commonwealth and that we will discharge the duties of our office
with delignature
A r
Na e (Chairman)
Law Firm
Address
C-ar?o; ?i?<7a
city, zip
I /oil/
Signature
r •
ro 14 A 6L
Name
Signature
-Dd-
Name
Law Firm
30 ( Mu, l
Address
c?O43
LeM??
city, zip
Law Firm
Address
city, zip
?' ID?G 3
Award
4 11431
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Note: If damages for delay are awarded, they shall be separately stated.)
er , on 4 a ?vK o-F "? /3d.3 s? ??5 l ?e e.?-F ?rm c,•-,
. ze;el ?
-Lds2-R-*-
DateofHearing:
?
Date of Award: f7 -Zd -a
Notice of Entry cif .?,wzrd
(Chairman) ;
Now, the day of &Wnq&t- , 2061, , at _Za:,38 , P.M., the above award was
entered upon the docket and notice thereof given by mail to the parties or their attorneys.
corn-Densation In be paid anon appeal: SC2g6. 00
v
rothonotary
eAts. (IEser iraffiie if applicable.)
Deputy
t7- ?L
5 1,
41 CS
k.
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SHERWIN WILLIAMS COMPANY ; IN THE COURT OF COMMON
Plaintiff : CUMBERLAND COUNTY, PEr
V. ; NO. 2006-02525 Civil
HOWARD R. RABER and ROBERT CIVIL DIVISION -LAW
HUMMEL, each individually & trading as
RABER'S PAINTING
Defendants :
PRAECIPE
TO THE PROTHONOTARY:
Please enter Judgment in favor of the Plaintiff, SHERWIN WILLIAMS
and against the Defendant, HOWARD R. RABER, per the attached copy of
from Arbitrators and NOTICE OF ENTRY OF AWARD filed with this
on December 26, 2006. Please enter Judgment in the amount of 130.35
from March 10, 2006, plus costs per said Award.
TO: Cumberland County
Prothonotary
Dated: February 6, 2007
?s
VANIA
?MPANY,
AWARD
ble Court
is interest
Robert D. Kodak, Attorney for
Attorney I.D. No. 18041
70
",,Painti?ff
?Q?erS A .H? Defendant
In The Court of Common Pleas of Cumberland
County, Pennsylvania No.-20G - O ZS
Civil Action - Law.
Oath
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United
States and the Constitution of this Commonwealth and that we will discharge the duties of our office
with delignature
n r
Na e (Chairman)
A?reu-)?i ?
Law Firm
Address
C. I-k5 fe r 7a/
City, zip
1 /0111
r
Signature
&*1,4 A,
Name
C, /10
Signature
Name
/ .
Law Firm Law Firm
Address
city, zip
41 ?o?q 3
Award
30 Mu VI
Address
c?b?3
L&V'el?
City, zip
? I I ?-3 I
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Note: If damages for delay are awarded, they shall be separately stated.)
Date of Heaing: (t-2!0-4.
Date of Award: [2 -Zd _ tj? 6=,
Notice of Entry cif ????arcl
?_-i?.y.sJ.`,A-alors' Comlpens^tinn? to be paid ur)on aT)peal: S AL OD
_ rte. y
- rothonotary
Deputy
P8
Now, the nth day of &XnI&'t- , 20j0_(v_, at la;38 , p.M., the above award was
entered upor, the docket and notice thereof given by mail to the paf--ties or their attorneys.
IF,-'
SHERWIN WILLIAMS COMPANY IN THE COURT OF COMMON
Plaintiff CUMBERLAND COUNTY, PETS
V. NO. 2006-02525 Civil
HOWARD R. RABER and ROBERT CIVIL DIVISION -LAW
HUMMEL, each individually & trading as
RABER'S PAINTING
Defendants
VANIA
TO: HOWARD R. RABER, Defendant(s',,,,-,
You are hereby notified that on 2W a following
(Judgment) has been entered against you in the above-captioned case.
Judgment entered in the amount of 130.35 plus interest from Ma?rCIt 10, 2006,
plus costs. I
DATE:
I hereby certify that the name and address of the proper person(s) toeceive this
notice is:
Dated: February 6, 2007
HOWARD R RABER
421 GARRISON ROAD
YORK HAVEN PA 17370 ?
r S,
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R. C. P. 3101 to 3149
IN THE COURT OF COMMON PLEAS
SHERWIN WILLIAMS COMPANY CUMBERLAND COUNTY, PENNSYLVANIA
Wri t No.
Term 20
Plaintiff NO. 2006-02525 CIVIL TERM Term 2006
VS
Amount due
HOWARD R. RABER AND ROBERT
HUMMEL, EACH INDIVIDUALLY AND
TRADING AS RABER'S PAINTING
$ 8,415.10
Interest FROM DATE OF JGMET -10116106
Atty's Comm.
and Costs BE DETERMINED$
Defendant (s)
$ 420.76
TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of DAUPHIN County, Pennsylvania;
(2) against ROBERT HUMbML INDIVIDUALLY AND TRADING AS RAKER'S PAINTING (ONLY)
Defendant (s)
(3) and against Garnishee (s),
(4) and index this writ
(a) against ROBERT HUMMEL INDIVIDUALLY AND TRADING AS RABER'S PAINTING Defendant(s)
and
(b) against Garnishee(s),
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s)
as follows:
(Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for
real estate levy)
LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT (S) AT. THE ADDRESS OF 599 CLASTER BLVD.,
DAUPHIN PA 17108 (DAUPHIN COUNTY), INCLUDING BUT NOT LIMITED TO EQUIPMENT, ELECTRONICS,
INVENTORY, ETC.
(5) Exemption has (not) been waived. x'
Robert D. Kodak, Esquire
PO Box 11848
Harrisburg, PA 17108
(717) 238-7159
Dated 06/12/07 Attorney For Plaintiff(s)
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-2525 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF DAUPHIN COUNTY:
To satisfy the debt, interest and costs due SHERWIN WILLIAMS COMPANY, Plaintiff (s)
From HOWARD R. RABER AND ROBERT HUMMEL, EACH INDIVIDUALLY AND
TRADING AS RABER'S PAINTING, 599 CLASTER BLVD., DAUPHIN, PA 17108
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF ROBERT HUMMEL INDIVIDUALLY AND TRADING AS
RABER'S PAINTING, 599 CLASTER BLVD., DAUPHIN, PA 17108 (DAUPHIN COUNTY)
INCLUDING BUT NOT LIMITED TO EQUIPMENT, ELECTRONICS, INVENTORY, ETC.
(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 $8,415.10 L.L. $.50
Interest FROM DATE OF JUDGMENT - 10/16/06
Atty's Comm % $410.76
Atty Paid $390.84
Plaintiff Paid
Date: JUNE 14, 2007
(Seal)
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 18041
Due Prothy $2.00
Other Costs
iiepury
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P, R. C. P. 3101 to 3149
IN THE COURT OF COMMON PLEAS
SHERWIN WILLIAMS COMPANY CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS
HOWARD R. RABER AND ROBERT
HUMMEL, EACH INDIVIDUALLY AND
TRADING AS RABER'S PAINTING
Defendant (s)
Writ No. Term 20
NO. 2006-02525 CIVIL TERM Term 2006
Amount due $ 8,130.35
Interest FROM DATE OF 03110106
Atty's Comm.
$ 406.52
and CostsTO BE DETERMINED$
TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of YORK County, Pennsylvania;
(2) against HOWARD R. RABER INDIVIDUALLY AND TRADING AS RABER'S PAINTING
Defendant (s)
(3) and against MEMBER'S 134 FEDERAL CREDIT UNION Garnishee (s),
(4) and index this writ
(a) against HOWARD R. RABER INDIVIDUALLY AND TRADING AS RABER'S PAINTING Defendant(s)
and
(b) against MEMBER'S Vt. FEDERAL CREDIT UNION Garnishee(s),
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s)
as follows:
(Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for
real estate levy)
LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT (S) AT THE ADDRESS OF 421 GARRISON ROAD,
YORK HAVEN PA 17370 (YORK COUNTY), INCLUDING BUT NOT LIMITED TO EQUIPMENT, ELECTRONICS,
INVENTORY, ETC. AND GARNISH MEMBER'S 1'T FEDERAL CREDIT UNION, AT THE ADDRESS OF 1200 GREENSPRINGS
DRIVE, YORK PA 17402; ANY ACCOUNTS UNDER DEFENDANT'S HUMS AND/OR SOC. SEC. NO. $##-##-3984.
(5) Exemption has (not) been waived.
Robert D. Kodak, Esquire
PO Box 11848
Harrisburg, PA 17108
(717) 238-7159
Dated 06/12/07 Attorney For Plaintiff(s)
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-2525 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF YORK COUNTY:
To satisfy the debt, interest and costs due SHERWIN WILLIAMS COMPANY, Plaintiff (s)
From HOWARD R. RABER AND ROBERT HUMMEL, EACH INDIVIDUALLY AND
TRADING AS RABER'S PAINTING, 421 GARRISON ROAD, YORK HAVEN, PA 17370
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF HOWARD R. RABER INDIVIDUALLY AND TRADING AS
RABER'S PAINTING, 421 GARRISON ROAD, YORK HAVEN, PA 17370 (YORK
COUNTY), INCLUDING BUT NOT LIMITED TO EQUIPMENT, ELECTRONICS,
INVENTORY, ETC..
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of GARNISH MEMBER'S 1sT FEDERAL CREDIT UNION, AT THE ADDRESS OF 1200
GREENSPRINGS DRIVE, YORK, PA 17042 - ANY ACCOUNTS UNDER DEFENDANT'S
NAMES AND/OR SOC. SEC. NO. ###-##-3984
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 $8,130.35
L.L. $.50
Interest FROM DATE OF 3/10/06
Atty's Comm % $406.52
Atty Paid $390.84
Plaintiff Paid
Date: JUNE 14, 2007
Due Prothy $2.00
Other Costs
(Seal)
Deputy
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 18041
SHERWIN WILLIAMS COMPANY
Plaintiff
V.
HOWARD R. RABER and ROBERT,
HUMMEL each individually & trading as
RABER'S PAINTING
Defendants
V.
MEMBER'S 1ST FEDERAL CREDIT UNION :
Garnishee
• D
IN THE COURT OFCOMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-02525 CIVIL
CIVIL DIVISION - LAW
C- C'7
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HMENT TO GARNISHEE
cn '*?
?n
TO: GARNISHMENT ADMINISTRATOR/LEGAL DEPT, MEMBER'S 1ST FEDERAL
CREDIT UNION, GARNISHEE
YOU ARE REQUIRED TO FILE ANSWERS TO THE FOLLOWING
INTERROGATORIES WITHIN TWENTY (20) DAYS AFTER SERVICE UPON YOU.
FAILURE TO DO SO MAY RESULT IN JUDGMENT AGAINST YOU:
1. At the time you were served, or at any subsequent time, did you owe the
defendant (s), HOWARD R. RARER, individually and/or trading as RABER'S PAINTING,
(Social Security No. ###-46-3984) any money or were you liable to the defendant (s) on
any negotiable or other written instrument, or did the defendant claim that you owed the
defendant any money or were liable to the defendant for any reason? (If yes, pleat! 402,
describe.) o c + n
-cc n
ANSWER: I O ?? v, o
C") -a
urn =9 C5
N cy
tT
2. At the time you were served, or at any subsequent time was there in your
possession, custody or control, or in the joint possession, custody or control of yourself
and one (1) or more other persons and/or entities, any property of any nature owned solely
or in part by the defendant(s)?( If yes, please describe.)
ANSWER: 0
q ?
C
M
U1
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 or in which
defendant(s) held or claimed any interest? (If yes, please describe.)
ANSWER: yes- P?# g?yos- lt Ed vet
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 an interest?
ANSWER: AO
M
rv
' m
M
Cn
M
cJJ =n
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 or place pursuant to your direction or consent
and if so, what was the consideration therefor?
ANSWER: 1 "?
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 the defendant's direction
or otherwise discharge any claim of the defendant(s) aainst you? (If yes, please
describe.) ^\
ANSWER:
O
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CC' rn
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7. If you are a bank or other financial institution, at the time you were served or at
any subsequent time did the defendant have funds on deposit in an account in which
funds are deposited electronically on a recurring basis and which are identified as being
funds that upon deposit are exempt from execution, levy or attachment under
Pennsylvania or federal law? If so, identify each account and state the reason for the
exemption, the amount being withheld under each exemption and the entity
electronically depositing those funds on a recurring basis.
ANSWER:
8. If you are a bank or other financial institution, at the time you were served or at
any subsequent time did the defendant have funds on deposit in an account in which the
funds on deposit, not including any otherwise exempt funds, did not exceed the amount
of the general monetary exemption under 42 Pa.C.S. § 8123.,.. If so, identify each
account.
ANSWER: U?
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KODAK & IMUM, P.C.
Robert D. Kodak
Attorney for Plaintiff
407 North Front Street
Post Office Box 11848
Harrisburg,-PA 17108-1848
(717) 238-7159
Supreme Court ID No. 18041
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Garnishee herein, verify that the statements made in these Interrogatories in Attachment
are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities.
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York Haven PA 17370
¦ Complete Items 1, 2, and 3. Also complete
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421 Garrison Rd
York haven PA 17370
3. !E" o Express Mail
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WOE RETURN RECEIPT REQUESTED o Insured Meg 13 C.O.D.
4. Restricted Deuvetyt (Exha Fee)
2. Article Number
(17WOi9YfrDmservice hAW 7005 2570 0002 1300 8116
Pa Form 3811, February 2004 Domestic Return Receipt +02695-02-WI540
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' York Haven PA 17370
PS Form 3800. Junc 2002 'erse fo Instructions
¦ Complete Items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ Print-your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailplece,
or on the front If space permits.
1. Article Addressed to:
Raber Painting
421 Garrison Rd
York haven PA 17370
WOE RETURN RECEIPT REQUESTED
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2. Article Number
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EXP 9/12/07 10 ,
1OF2
COUNTY OF YORK
OFFICE OF THE SHERIFF SERVICE CALL
(717) 771-9601
45 N. GEORGE ST., YORK, PA 17401 Certif 6/29/0tU?L? CO
SHERIFF SERVICE
PROCESS RECEIPT and AFFIDAVIT OF RETURN
1 PLAINTIFF/S/
SHERWIN WILLIAMS COMPANY
INSTRUCTIONS 0 (D `-
PLEASE TYPE ONLY LNE 1 THRU 12
DO NOT DETACH ANY COPIES
3. DEFENDANTIS/
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2
4I fXPE OF WRIT OR COM
1? l - 0 .
HOWARD R. RARER , /I/A/T/A RARER S PAINTING J WRIT OF EXEC./GARNISHMENT 0=
SERVE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD
MEMBERS 1ST FEDERAL CREDIT UNION, GARNISHEE
6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO. CITY, BORO, TWP. STATE AND ZIP CODE)
AT 1200 GREENSPRINGS DRIVE, YORK PA 17042
7. INDICATE SERVICE O PERSONAL U PERSON IN CHARGE U DEPUTIZE U CERT MAIL U 1ST CLASS MAIL U POSTED U OTHER
'NOW , 20 I, SHERIFF OF YORK COUNTY, PA, do hereby deputize the sheriff of
COUNTY to execute this Writ and make return thereof-according
to law. This deputization being made at the request and risk of the plaintiff.
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SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE.
GARNISHBENT
SERVE GARNISHEE
Def address: 421 Garrison Rd
York Haven PA
17370
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same
without a watchman, in custody of whomever is found in possession, after notifying person of le without liability on the part of such deputy or the sheriff to any plaintiff
herern for any loss, destruction, or removal of any property before sheriffs sale thereof.
9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11 DATE FILED
ROBERT D. KODAK 717-238-7159 06A 4 /07
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be Completed if notice is to be marled)
ROBERT. D. KODAK
P O BOX 11848, HARRISBURG PA 17108-1848 MATTER y- 32160A
SPACE BELOW FOR USE OF THE SHERIFF - DO NOT WRM BELOW THS LIRE
13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date
or complaint as indicated above. LT H O R P E 6/27/07 9/12/07
16. HOW SERVED: PERSONAL ( ) RESIDENCE ( ) POSTED( ) POE SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW
A. O 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, oompany, etc named above. (See remarks below.)
18. NAME AND TITLE OF INOIVIDUA ED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19 ate of service 20 Time of Service
1. ATTEMP ale Time Miles Int. Date Time Miles Int. Date Time Mies Ire. Date Time Miles Int. Date Time Miles Int. Dale Time Miles Int.
22.
vf\\S??
As informed lony by Robert Kodak, Attorney for Plaintiff, Defendant and Plaintiff have come
I to a settlement. Further execution stayed.
23. Advance Costs 24 Service Costs 25 N/F 26. Milne 27 Posta a 28. Sub Total 29. Pound 130 Notary X40r Su ohg.TOt. Costs 33 97Qr Relund Check No.
350 50.00 114. 82.47 60.00 7.00 .00 1B9.47 160.53 18075
34. Foreign County Costs 35. Advance Costs 36 Service Costs 37 Notary Cert. 38 a9e/P0stageJN0t Found 39 Total Costs 40 Costs Oue or Refund
41. AFFIR D subscribed to bef a me thi
44. Signature of
IV"
4
5
42 day of T". Dep. Sheriff r /2 ?6 U/vC) 7
AR 46. Signature of York
NOTARIAL SEAL County Sherill 47 PATE
LISA L. BOVWMIAN, NOTARY PUBLIC 7/31/07
CITY OF YORK, YORK COUNTY
MY COMMISSION' EX?IRES AUG. 12, 2009 48 Co nnaturS?rt Foreign 49 DATE
50. 1 AC THE SHERIFF'S RETURN SIGNATURE 51 DATE RECEIVED
OF AUTHORIZED ISSUING AUTHORITY AND TITLE
1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Shenffs Office 4. BLUE - Sheriffs office
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EXP 9/12/07
COUNTY OF YORK
OFFICE OF THE SHERIFF
45 N. GEORGE ST,,YORK, PA 17401
20F2
SERVICE CALL,
(717) 771-9601
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SHERIFF SERVICE NSTMXTiOM
PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINE 1 TWU 12
DO NOT DETACH ANY COPIES
1 PLAINTIFF/S! 2 CM RT M MR
SHERWIN WILLIAMS COMPANY -
4. TYPE O WRIT OR COMPLAINT
3 DEFENDANT/S/
HOWARD R. RABER /I/A/T/A RABER'S PAINTING WRIT OF EXEC./PERS. PROPERTY
SERVE 5. NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC TO SERVE OR OESCRIPTION OF PROPERTY TO BE LEVIED. ATTACHED, OR SOLD
HOWARD R. RABER I/A/T/A RABER'S PAINTING
6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO, CITY, BORO, TWP, STATE AND ZIP ODE)
AT 421 GARRISON ROAD, YORK HAVEN PA 17370 GQrr?s r)
7. INDICATE SERVICE' U PERSONAL U PERSON IN CHARGE U DEPUTIZE L] CERT MAIL U 1ST CLASS MAIL U POSTED LI OTHER
J40W 20 I, SHERIFF OF YORK COUNTY, PA, do hereby deputize the sheriff of
COUNTY to execute this Writ and make return thereof-according
to law. This deputization being made at the request and risk of the plaintiff.
SHERIFF OF YORK COUNTY
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE
LEVY UPON PERSONAL PROPERTY OF DEFENDANTS, INCLUDING, BUT NOT LIMITED TO
FURNITURE, JEWELRY, EQUIPMENT, ELECTRONICS, SUPPLIES, ETC.
,SET SALE 25 DAYS FROM LEVY ALLOW EXEMPTIONS , FORMS ENCLOSED
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy she 0n upon or attaching any property under within writ may leave same
wdhoyt a watchman, in custody of whomever is found in possession, after notifying person of levy or atta nt, u hab yon the rt of such deputy or the sheriff to any plaintiff
herein for any loss, destruction, or removal of any property before sheriffs sale thereof.
9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11 DATE FILED
P0$E§FXD11 CMAKHARRISBURG PA 17108-1848 de?l 717-238-7159 06/14/07
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed d notice is to be marled)
508ESOXDIISAKHARRISBURG PA 17108-1848 MATTER # 32160A
m-muc sm, w V1/ rwn w= ur i rW. a1r=nWr - W MI WM1 t IMLUW f "M LNft
13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date
or complaint as indicated above. LTHOR P E 9/12/07
II& HOW SERVED: PERSONAL ( ) RESIDENCE ( ) POSTED( ) POE( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW
17. U 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc named above. (See remarks below.)
18. NAME AND TITLE OF. INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20 Time of Service
21. ATTEMPTS?7D?te I Time I Miles I ri t? I Daje I Time I Miles I At I Date I Time I Miles V"t?? Time Miles Int. Date Time Miles Int. Date Time Miles Int
22. REMARKS:
23. Advance Costs 24 Service Costs 25 N/F 26 Mileage 27. Postage 28 Sub Total 29. Pound 30 Notary 31. Surdg. 32. Ta. Costs 33 Cosfs Due or Rdund Check No
34. Foreign County Costs 35. Advance Costs 36 Service Costs 37 Notary Cert. 38. Mileage/PostageNot Found 39. Total Costs 40 Costs Due or Refund
41
AFFI
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fpdd subscribed to bef re me this SO ANSWERS
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42
of ?' ?' ` 2Oil //?? 4
da Signature of
u Signature 45 DATE
,
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L TH ' E Dep. Sheriff
T Y
COM ONWEA
46. Signature of York 47 GATE
P OTARIAL SEAL County Sheriff
7/31/07
LISA L. BOVV'0: ?', 1,.0TARY PUBLIC
CITY OF Y0,7, ?:, YORK COUNTY 48 Signature of Foreign 49 DATE
9xv Z: ^! rzxjp?PF?S G. 12, 2000 County Sheriff
50. 1 A DGE RECEIPT_QE.JHE. SIGNATURE 51 DATE RECEIVED
t. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Shenfrs office
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SHERIFF' S RETURN OF SERVICE
06/28/2007 11:40 AM - SERVED TWO TRUE AND ATTESTED COPIES OF THE WITHIN WRIT OF EXECUTION AND
INTERROGATORIES UPON PATTI-JO KETTERMAN, MEMBER SERVICE REPRESENTATIVE FOR
MEMBERS 1ST FEDERAL CREDIT UNION,THE WITHIN NAMED GARNISHEE, AT 1200 GREENSPRINGS
DRIVE, YORK, PENNSYLVANIA, AND ATTACHED AS DIRECTED.
06/29/2007 SENT BY CERTIFIED MAIL, ONE TRUE AND ATTESTED COPY OF THE WITHIN WRIT OF EXECUTION
AND CLAIM FOR EXEMPTION FORM TO HOWARD R RABER, THE WITHIN NAMED DEFENDANT, TO
421 GARRISON ROAD, YORK HAVEN, PENNSYLVANIA 17370.
06/29/2007 SENT BY CERTIFIED MAIL, ONE TRUE AND ATTESTED COPY OF THE WITHIN WRIT OF EXECUTION
AND CLAIM FOR EXEMPTION FORM TO RABER'S PAINTING, THE WITHIN NAMED DEFENDANT, TO
421 GARRISON ROAD, YORK HAVEN, PENNSYLVANIA 17370.
07/03/2007 RETURN RECEIPT FOR CERTIFIED MAIL TO HOWARD R. RABER, DATED 6/30/07, ATTACHED HERETO.
07/03/2007 RETURN RECEIPT FOR CERTIFIED MAIL TO RABER PAINTING, DATED 6/30/07, ATTACHED HERETO.
07/30/2007 AS INFORMED BY ROBERT KODAK, ATTORNEY FOR THE PLAINTIFF, DEFENDANT HAS PAID THIS
JUDGMENT IN A SETTLEMENT AMOUNT AGREED TO BY THE PLAINTIFF. FURTHER EXECUTION
STAYED.
SHERIFF COST: $189.47 (PAID) SO ANSWERS,
oor-*?wp-?
July 31, 2007 WILLIAM M HOSE, SHERIFF
Supreme Court ID No. 18041
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
07 -50
NO 06-2525 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF YORK COUNTY:
To satisfy the debt, interest and costs due SHERWIN WILLIAMS COMPANY, Plaintiff (s)
From HOWARD R. RABER AND ROBERT HUMMEL, EACH INDIVIDUALLY AND
TRADING AS RABER'S PAINTING, 421 GARRISON ROAD, YORK HAVEN, PA 17370
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF HOWARD R. RABER INDIVIDUALLY AND TRADING AS
RABER'S PAINTING, 421 GARRISON ROAD, YORK HAVEN, PA 17370 (YORK
ER
COUNTY), INCLUDING BUT NOT LIMITED TO EQUIPMENT, ELECTRONICS,
G?
INVENTORY, ETC..
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possess= N
of GARNISH MEMBER'S 1sT FEDERAL CREDIT UNION, AT THE ADDRESS OF 1200;
GREENSPRINGS DRIVE, YORK, PA 17042 - ANY ACCOUNTS UNDER DEFENDANT'SA :3
NAMES AND/OR SOC. SEC. NO. ###-##-3984
GARNISHEE(S) as follows: N
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.
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Amount Due $8,130.35 L.L. $.50 -.t
Interest FROM DATE OF 3/10/06 C-- ?
Atty's Comm % $406.52 Due Prothy $2.00 x n
Atty Paid $390.84 Other Costs C.7
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Plaintiff Paid
PLUS YORK COUNTY SHERIFF 1
COS $
Date: JUNE 14, 2007 AZ
cn
(nurth R. Long, Prothonotary
(Seal) / /
Deputy
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 11848
HARRISBURG, PA 17108 TRUE COPY FROM RECORD
Attorney for: PLAINTIFF In Testimony wh?-r-^?, ' h, r^ unto set my hand
Telephone: 717-238-7159 and the seal of sa, Carlisle, Pa.
This ....I'X'`:.`- da
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Robert D. Kodak, Esquire
Supreme Court I.D. 18041
KODAK & IMBLUM, P.C.
Post Office Box 11848
407 North Front Street
Harrisburg, PA 17108-1848
717-238-7152 Fax: 717-238-7158
email: robert.kodak@kodak-imblum.com
Attorney for Plaintiff
SHERWIN WILLIAMS CO
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
HOWARD R. RABER and ROBERT
HUMMEL each individually and trading
as RABER'S PAINTING
Defendants
NO. 2006-02525 CIVIL
CIVIL DIVISION - LAW
PRAECIPE
TO THE PROTHONOTARY:
Please file the attached Dauphin County Sheriffs Return of Service on the above Writ of
Execution to the terms and number.
TO Cumberland County
Prothonotary
Dated: April 29, 2009
Robert D. Kodak Attorney for Plaintiff
Attorney I.D. No. 18041
!'. a
Personal Property
FACE SHEET
File # Case Number Document Type Bankruptcy Case Number
2007-CV-6125 WRIT OF
EXECUTION
Received From: County
Date Received: 6/25/2007
Date Expires:
Name: RABER PAINTING
Address: 599 CLASTER BLVD DAUPHIN, PA 17018
Name: HUMMEL ROBERT
Address: 599 CLASTER BOULEVARD DAUPHIN, PA 17018
Name: RABER HOWARD R
Address: 599 CLASTER BLVD DAUPHIN, PA 17018
Name: SHERWIN WILLIAMS COMPANY
Attorney: ROBERT KODAK
Attorney Phone: 717-238-7159
Attorney Address: PO BOX 11884 HARRISBURG, PA 17108
Monies Levied: Date of Sale:
Date of Levy:
District Justice:
[CASE TYPE: WRIT OF EXECUTION]
{DATEDUMP RECORD}
[DATEOFACTI ON: 06/25/2007]
[TIMEOFACTION: 15:22:00]
[CODEACTION: RECEIVED FROM PROTHONOTARY - PP]
{DATEDUMP RECORD}
[DATEOFACTION: 06/26/2007]
[TIMEOFACTION: 13:16:00]
[COSTSPAID: 200.00]
[CODEACTION: PAYMENT RECEIVED]
[COMMENT: 231882]
{DATEDUMP RECORD)
[DATEOFACTION: 06/26/2007]
[TIMEOFACTION: 14:07:00]
[CODEACTION: INITIAL SERVICE]
{DATEDUMP RECORD}
[DATEOFACTI ON: 06/26/2007]
[TIMEOFACTION: 14:13:00]
[CODEACTION: INITIAL SERVICE]
{DATEDUMP RECORD}
[DATEOFACTION: 07/10/2007]
[TIMEOFACTION: 08:16:00]
[CODEACTION: PP - HOLD FILE]
[COMMENT: PER ATTORNEY, HOLD]
AND NOW 4/10/2008
RECIEVED LETTER FROM ATT TO POST FOR SALE; HOWEVER LEVY
WAS NEVER DONE
SPOKE TO ATT OFFICE TO NOTIFY LEVY WILL BE SENT OUT
GAVE WRIT TO AL TO SEND FOR LEVY
LEVY MADE AT 599 CLASTER BLVD, DAUPHIN PA. BY DEPUTY G.
MILLER ON 04-25-08 @ 09:OOHRS.
AND NOW 12/15/2008
SENT REFUND TO ATTORNEY
RETURNED WRIT TO PROTHY/EXPIRED(TJF)
f'fet' Aidc{ad
77
$200.00 6/26/2007 Deposit
($96.00) 12/10/2008 Sheriff Costs
($30.00) 12/10/2008 State Fee
($1.92) 12/10/2008 Poundage
($72.08) 12/15/2008 Refund to Atty/Pitf
Total Number of Rows: 5
Balance Due: $0.00
FILED-3::a HCE
OF THE PP`" ll -',- ,{OTARY
2003 MAY - I Pli IZ; 52
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SHERWIN WILLIAMS CO. IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,
PENNSYLVANIA
v
HOWARD R. RABER and ROBERT
HUMMEL each individually and
trading as RABER'S PAINTING,
Defendant(s)
NO. 2006-02525 CIVIL
CIVIL ACTION - LAW
PRAECIPE
TO THE PROTHONOTARY:
Satisfy Judgment and Discontinue Case and end.
TO: Cumberland County
Prothonotary
Dated: May 23, 2012
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iit Kodak, Esquire
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Attorney for Plaintiff
Attorney I.D. No. 18041