HomeMy WebLinkAbout06-6197FERRARO FOODS, INC.
Plaintiff
v
GIUSEPPE P. BASILE individually and trading as
PINO'S PIZZA & SUB SHOP and GIUSEPPE P.
BASILE, personal guarantor for PINO'S PIZZA &
SUB SHOP
Defendant :
NOTICE
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 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.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
Avlso
USTED HASIDO 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
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
FERRARO FOODS, INC. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v NO.
GIUSEPPE P. BASILE individually and trading as
PINO'S PIZZA & SUB SHOP and GIUSEPPE P. CIVIL ACTION - LAW
BASILE, personal guarantor for PINO'S PIZZA &
SUB SHOP
Defendant
COMPLAINT
The Plaintiff, FERRARO FOODS, INC., by its attorneys, KODAK & IMBLUM, P.C., brings this action of
Assumpsit against the Defendants to recover the sum of EIGHT THOUSAND NINE HUNDRED SEVENTY
DOLLARS AND EIGHT CENTS ($8,970.08), along with interest thereon at the statutory rate from August 31,
2006, upon a cause of action of which the following is a statement:
1. The Plaintiff, FERRARO FOODS, INC., is a corporation organized and existing under the laws of the State
of New Jersey, having its principal office and place of business at 287 South Randolphville Road,
Piscataway, New Jersey 08854.
2. The Defendant, GIUSEPPE P. BASILLE, individually and trading as PINO'S PIZZA & SUB SHOP, is an
adult individual with an address of 1 East Main Street, Newville, Cumberland County, Pennsylvania 17241.
3. The Defendant, GIUSEPPE P. BASILLE, personal guarantor for PINO'S PIZZA & SUB SHOP, is an adult
individual with an address of 1 East Main Street, Newville, Cumberland County, Pennsylvania 17241.
4. On or about November 9, 1991, Defendant submitted a Credit Application, together with a Personal
Guaranty, to Plaintiff and agreed to the terms and conditions of same. A true and correct copy of said
Credit Application and Personal Guaranty is attached hereto, marked Exhibit "A" and made a part hereof.
FAUSER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\FERRARO F00DS\FERRAR032685.wpd:030ct06
5. Plaintiff, at the special instance and oral request of the Defendants, sold and delivered goods, wares and
merchandise to the Defendant at Defendant's place of business to the amount of Three Thousand Two
Hundred Thirty Dollars and Ninety-Three Cents ($3,230.90) as set forth on true and correct copies of
Plaintiff's invoices attached hereto, collectively marked Exhibit "B" and made a part hereof.
6. 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 Defendants orally promised and agreed to pay to
Plaintiff.
7. Defendant become entitled to certain credits against the charges aforementioned, as more particularly
shown on Plaintiff's credit memo, attached hereto, marked as Exhibit "C" and made a part hereof, to the
total amount of Forty-Four Dollars and Fifty-Two Cents ($44.52).
8. Thereafter, Defendant issued two (2) checks to Plaintiff on earlier invoices owed to Plaintiff, which checks
were returned to Plaintiff by Defendant's bank due to non-sufficient funds in Defendant's bank account,
and claim is made therefor, together with Plaintiff's bank charges. True and correct copies of said checks
are attached hereto, collectively marked Exhibit "D" and made a part hereof.
9. The amount due and owing by Defendant to Plaintiff is the amount of Six Thousand Eight Hundred Forty-
Seven Dollars and Thirty-Nine Cents ($6,847.39) as shown on Plaintiff's Statement of Account hereto
attached, marked Exhibit "E" and made a part hereof.
10. Due to the default of Defendant and pursuant to the terms and conditions of the Credit Application and
Personal Guaranty executed by Defendant and attached hereto, interest in the amount of Four Hundred
Ten Dollars and Eighty-Four Cents ($410.84) has been added to said account.
F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\FERRARO FOODS\FERRAR032685.wpd:030ct06 3
11. Due to the default of Defendant and pursuant to the terms and conditions of the Credit Application and
Personal Guaranty executed by Defendant and attached hereto, attorney fees and collection fees in the
amount of One Thousand Seven Hundred Eleven Dollars and Eighty-Five Cents ($1,711.85) have been
added to said account.
12. Plaintiff frequently demanded payment from Defendant of said amount due and owing as aforesaid, but
Defendant refused and neglected and still refuses and neglects to pay said amount or any part thereof.
WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of EIGHT THOUSAND NINE
HUNDRED SEVENTY DOLLARS AND EIGHT CENTS ($8,970.08), along with interest thereon at the statutory
rate from August 31, 2006.
Respectfully submitted,
KODAK & l_M8t M, 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\FERRARO F00DS\FERRAR032685.wpd:030ct06 4
DA1'
SALESPERS N
?p 5
ACCOUNT #
FERRARO FOODS, INC.
knPOrters of MARINO Products
701 Hadley Road. So. Plainfield, NJ 07080
(908) 757-1600 • FAX: (908) 757-2163
CREDIT APPLICATION
TRADE, CORPORATION, OR OWNER'S NAME -77»USINESS PHO
(7 / )7?
SHIPPING ADDRESS
I
CITY STATE ZIP CODE
!L
BILLING ADDRESS (IF DIFFERENT FROM SHIPPING DRESS)
? PROPRIETORSHIP
(OWNER'S NAME)
zu5 i nzbb
? PARTNERSHIP
/T_TCT L'AP-v raw r?.n?.r..-.
? CORPORATION
NAL4E #1 TITLE HOME ADDRESS
C
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?7 II
Social Security No. Driver's License N Home Phone No.
/0 p -3 Z p 71 7 776- ??
NAME #2 TITLE HOME ADDRESS
Social Security No. Driver's License No. Home Phonc- No.
NAME #3 TITLE HOME ADDRESS
Social Security No. Driver's License No. Home Plwne No.
Xoa S A V?l'aLll 1CMp-MKMN[=H:ti
NAME ADDRESS
t<)rr-e1'f0JA)J-j & Ir-
HOW I ACCO LISTED? PHONE NUMBER ACCOUNT NUMBER
vMALIZ41ULLM .11Vir%jKpwx1V14
MM OF BUSINESS IS THIS PA= OF a CRAW? FR 1K'8ISX ? IF YES, GIVE NAIS EIS
CO-Omm ? ADDRESS OF P?1? CO.
HOW LONG N BUSINESS AT THE LOCATION DATE INCORPORATED DATE OPENED
PREVIOUS BUSINESS (TRADE N/ADa'
T£0/M(A
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WILL PAYS BE MADE -FROM . THIS LOCATION? YES[ NO?
If not, where? Phone No.(
BUILDING IS : OWNED-rJ' LEASED? LIQUOR LICENSE: YESIINO?
LIQUOR'LICENSE NO: NAME ON LICENSE:
HEALTH LICENSE NO:
OPERATION: SEASONAL? ALL YEAR? CONCESSION?
ARE YOU EXEMPT FOR SALES OR USE TAX? YES?
If yes, attach signed Tax Certificate. Note Tax Exempt status will be
effective on the date of the certificate being received.
I/WE CERTIFY THAT THE ABOVE INFORMATION IS TRUE AND IS FURNISHED FOR THE SOLE
PURPOSE OF SECURING CREDIT FROM FERRARO FOODS, INC. BY SIGNING THIS
APPLICATION, PERMISSION IS GRANTED TO FERRARO FOODS, INC. TO OBTAIN IN
FORMATION FROM ANY OF THE ORGANIZATIONS LISTED ON THIS APPLICATION, AS WELL AS
ALL CREDIT BUREAUS.
WE AGREE TO PAY A SERVICE CHARGE FOR ANY CHECKS RETURNED FROM OUR BANK UNPAID
FOR ANY REASON. ADDITIONALLY, WE UNDERSTAND THAT A SERVICE CHARGE MAY BE
ASSESSED ON ANY UNPAID BALANCE EQUAL TO THE MAXIMUM RATE ALLOWED BY LAW.
I/WE AGREE TO PAY REASONABLE COLLECTION FEES, ATTORNEY FEES AND COURT COSTS FOR
COLLECTING OR ATTEMPTING TO COLLECT OR SECURE ANY AND ALL DEBTS WHICH MAY IN
THE FUTURE BE OWED TO FERRARO FOODS, INC. FOR GOODS SOLD OR FOR SERVICES
RENDERED WHETHER A LAWSUIT IS FILED OR NOT. FERRARO FOODS, INC. IS HEREBY
AUTHORIZED TO DELIVER GOODS WITHOUT A SIGNATURE OR PERFORM SERVICES AT YOUR
REQUEST, AND TO CHARGE SAME TO YOUR ACCOUNT. THIS AGREEMENT SHALL CONTINUE
UNTIL WRITTEN NOTICE TO THE CONTRARY IS GIVEN AND ACCEPTED, WHICH ACCEPTANCE
SHALL BE EVIDENCED BY LETTER FROM FERRARO FOODS, INC.
THE UNDERSIGNED HEREBY AGREES THAT ANY ACTION OR PROCEEDING TO ENFORCE THE
WITHIN GUARANTY MAY BE BROUGHT IN ANY COURT OF COMPETENT JURISDICTION IN THE
STATE OF NEW JERSEY, AND THE UNDERSIGNED SUBMITS TO THE JURISDICTION OF ANY
SUCH COURT IN THE STATE OF NEW JERSEY FOR SUCH PURPOSE AND AGREES NOT TO
CONTEST SUCH JURISDICTION BASED ON FORUM NON CONVENIENS OR FOR ANY OTHER
REASON. •
A
FOR VALUE RECEIVED AND IN ORDER TO INDUCE
TO THE ABOVE NAMED ACCOUNT, I (WE) HEREBY
WHEN DUE OF ANY AND ALL-DEBTS TO FERRARO
ADVANCES BY FERRARO FOODS, INC. NOTICE OF
WAIVED. USE OF CORPORATE TITLES SHALL IN
OF THE SIGNATORY.
FERRARO FOODS, INC. TO EXTEND CREDIT
PERSONALLY GUARANTEE PROMPT PAYMENT
FOODS, INC. ARISING OUT OF SALES OR
ACCEPTANCE OF THIS GUARANTEE IS
NO WAY LIMIT THE PERSONAL LIABILITY
SIGNATURE:
SIGNATURE:
RINT NAME
PRINT NAME:
DATE : /y'#M' 4r oc WITNESSED BY :
MUST BE SIGNED BY CORPORATE OFFICERS, AUTHORIZED UNIT
OWNERS OR PARTNERS OF PARTNERSHIP.
INDIVIDUAL
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287 S. Randolphvifle Road Tel (732)424-3400
Piscataway, NJ 08854 Fax (732)4244027
www.fermrofoods.com
PINO'S PIZZA NEWVILLE
1 E. MAIN STREET
NEWVILLE PA
C.O.D.
17241
Date Tran No Zype Charge Credit
10262005 55639 1922.61
11092005 60751 NV 1308.32
11172005 64054 C/M 44.52-
11282005 6660452 PYM 20.00
12132005 6660465 PYM 20.00
12062005 7770452 PYM 2225.10
12222005 7770465 PYM 1395.88
CUSTOMER- PINONE TOTAL
PAGE 1 NEWVILLE PA
17241
PINONE 075 5/08/06
Balance Number T
1922.61 55639 INV
1308.32 60751 INV
1263.80 64054 C/M
20.00 6660452 PYM
20.00 6660465 PYM
2225.10 7770452 PYM
1395.88 7770465 PYM
6847.39
Current Past Due Amount Due
.00 6847.39 6847.39
1-1 11WXX a?anom 0Y8 FM COC1 M"3 "*OF M MILL Dr.== AWMWILL
KAMUnSLE u MM NOCL? urowTDo?aKAW WOMa?ra aoan IE
T£0/6T0 [n
Statement Date
5/08/2006
Customer #
PINONE
PINO PIZZA
sls # 1 EAST MAIN STREET
075
NEWVILLE PA
17241
PINO'S PIZZA NEWVILLE
1 E. MAIN STREET
Amount
1922.61
1308.32
44.52-
20.00
20.00
2225.10
1395.88
TOTAL- 6,847.39
Amount Enclosed
XV.3 LV:ET 9002/60/90
OCT-03-2006 10:13 KNUPP KODAK & IMBLUM
VERIFICATION
717 238 7158 P.06
(narne) (title)
of FERRARO FOODS, INC., verify that the statements made in the aforegoing 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.
FERRARO FOODS, INC.
By:
Title: A ti-e ?--
Dated: 161 0b
32685
??3Y
TOTAL P.06
L
j ti
s 10
FERRARO FOODS, INC.
V
GIUSEPPE P. BASILE individually and
trad ?g as PINO'S PIZZA & SUB SHOP and
GIUSEPPE P. BASILE, personal guarantor for
PINO'S PIZZA & SUB HOP
Defendanb
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PA
NO. 2006-6197 CIVIL TERM
: CIVIL ACTION -LAW
TO: PROTHONOTARY, COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PRAECIPE FOR DEFAULT NDGMENT
Enter judgment in favor of Plaintiff and against Defendant(s) GIUSEPPE P. BASILE
individually and trading as PINO'S PIZZA & SUB SHOP and GIUSEPPE P. BASILE,
personal guarantor for PINO'S PIZZA & SUB SHOP, 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 less payment $8,570.08
Interest from August 31, 2006 at the statutory rate of b% per annum $10.97
Total $8,720.05
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 & , P
By
Robert D. Kodak, Attorney for Plaintiff
DATED: I?.)ex_ !2i Q,e(o Judgment entered and damages assessed as above.
Prothonota
Robert D. Kodak
Gary j. bnblum
LAW OFFICES OF
KODAK & IMBLUM, P.C.
CAMERON MANSION
407 NORTH FRONT STREET
POST OFFICE BOX 11848
HARRISBURG, PA 17108-1848
kkLlawfverizon.net
website: kki-law.com
November 15, 2006
GIUSEPPE P BASILLE
1 EAST MAIN STREET
NEWVILLE PA 17241
FILE
Fa
717.238.7158
RE: Ferraro Foods, Inc.
Vs: Giuseppe P. Basile Individually and Trading as Pino's Pizza & Sub Shop and
Giuseppe P. Basile, Personal Guarantor for Pino's Pizza & Sub Shop
No. 2006-6197 Civil Term, Court of Common Pleas
Cumberland County, Commonwealth of Pennsylvania
Our File No. 32685
Dear Mr. Basille:
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, nor has any attorney 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: REGAL COLLECTIONS
POST OFFICE BOX 1038
FAIR LAWN NJ 07410-8038
#A51234/ PINONE
FIL F 7jp FERRARO FOODS, INC. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PA
v : NO. 2006-6197 CIVIL TERM
GIUSEPPE P. BASILE individually and
trading as PINO'S PIZZA & SUB SHOP and CIVIL ACTION - LAW
GIUSEPPE P. BASILE, personal guarantor
for PINO'S PIZZA & SUB SHOP
Defendant
IMPORTANT NOTICE
TO: GIUSEPPE P. BASILE, Defendant(s)
DATE OF NOTICE: NOVEMBER 15.2006
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 OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT 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
D
LAW OFFICES OF
KODAK & IMBLUM, P.C.
Robert D. Kodak CAMERON MANSION
Gary J. lmblum 407 NORTH FRONT STREET
POST OFFICE BOX 11848
HARRISBURG, PA 17108-1848
kki.law®verizon.net
website: kki-lawxom
November 15, 2006
PINOS PIZZA & SUB SHOP
1 EAST MAIN STREET
NEWVILLE PA 17241
RE: Ferraro Foods, Inc.
Vs: Giuseppe P. Basile Individually and Trading as Pino's Pizza & Sub Shop and
Giuseppe P. Basile, Personal Guarantor for Pino's Pizza & Sub Shop
No. 2006-6197 Civil Term, Court of Common Pleas
Cumberland County, Commonwealth of Pennsylvania
Our File No. 32685
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, nor has any attorney 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,
Robert D. Kodak
KODAK & IMBLUM, P.C.
F IL E C aPelone
717.238.7159
Facsimile
717.238.7158
RDK/kqb
enclosure
cc: REGAL COLLECTIONS
POST OFFICE BOX 1038
FAIR LAWN NJ 07410-8038
--k
#A51234/PINONE
FILE r"HY
FERRARO FOODS, INC. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PA
v NO. 2006-6197 CIVIL TERM
GIUSEPPE P. BASILE individually and
trading as PINO'S PIZZA & SUB SHOP and CIVIL ACTION - LAW
GIUSEPPE P. BASILE, personal guarantor
for PINO'S PIZZA & SUB SHOP
Defendant
IMPORTANT NOTICE
TO: PINO'S PIZZA & SUB SHOP, Defendant(s)
DATE OF NOTICE: NOVEMBER 15, 2006
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURTYOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTHAGAINST YOU.
UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT 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
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®verizon.net
website: kki-law.com
November 15, 2006
GIUSEPPE P BASILLE
PER GUAR FOR PINO'S PIZZA & SUB SHOP
1 EAST MAIN STREET
NEWVILLE PA 17241
FIL E - 59 .
a e
717.238.7158
RE: Ferraro Foods, Inc.
Vs: Giuseppe P. Basile Individually and Trading as Pino's Pizza & Sub Shop and
Giuseppe P. Basile, Personal Guarantor for Pino's Pizza & Sub Shop
No. 2006-6197 Civil Term, Court of Common Pleas
Cumberland County, Commonwealth of Pennsylvania
Our File No. 32685
Dear Mr. Basille:
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
tern and number, nor has any attorney 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: REGAL COLLECTIONS
POST OFFICE BOX 1038
FAIR LAWN NJ 07410-8038
#A51234/PINONE
1
F IL
FERRARO FOODS, INC. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PA
v NO. 2006-6197 CIVIL TERM
GIUSEPPE P. BASILE individually and
trading as PINO'S PIZZA & SUB SHOP and CIVIL ACTION - LAW
GIUSEPPE P. BASILE, personal guarantor
for PINO'S PIZZA & SUB SHOP
Defendant
IMPORTANT NOTICE
TO: GIUSEPPE P BASILE, PERSONAL GUARANTOR FOR PINO'S PIZZA & SUB SHOP,
Defendant(s)
DATE OF NOTICE: NOVEMBER 15, 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 OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT 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
7? ?
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-""`r
FERRARO FOODS, INC. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PA
V : NO. 2006-6197 CIVIL TERM
GIUSEPPE P. BASILE *individually. and
trading as PINO'S PIZZA & SUB SOP and : CIVIL ACTION - LAW
GIUSEPPE P. BASILE, personal guarantor
for PINO'S PIZZA & SUB SHOP
Defendants
TO: GIUSEPPE P. BASSILE, INDIVIDUALLY, Defendant(s)
You are hereby notified that on b£ L / 2 , 200khe following
(Judgment) has been entered against you in he above-captioned .
Tudement entered in the amount of $8,720.05.
DATE:_ 4124
oPro#ionota
I hereby certify that the name and address of the proper person(s) to receive this
notice is:
GIUSEPPE P BASILE - INDIV.
1 EAST MAIN STREET
NEWVILLE PA 17241
FERRARO FOODS, INC. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PA
V : NO. 2006-6197 CIVIL TERM
GIUSEPPE P. BASILE individuall MOP tradingg as PINO'S PIZZA & SUB SHOP and : CIVIL ACTION - LAW
GIUSEPPE P. BASILE, personal guarantor
for PINO'S PIZZA & HOP
Defendants
TO: PINUS PIZZA & SUB ,SHOP, Defendant(s)
You are hereby notified that on I) t' 2004the following
(Judgment) has been entered against you in e above-captioned case.
Judgment entered in the amount of $8,720.05.
DATE:
Pr onota
I hereby certify that the name and address of the proper Lon(S) to receive this
notice is:
PINOS PIZZA & SUB SHOP
1 EAST MAIN STREET
NEVWILLE PA 17241
. . .
FERRARO FOODS, INC. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PA
V No. 2006-6197 CIVIL TERM
GIUSEPPE P. BASILE individually and
tradingg as PINO'S PIZZA & SUB SHOP and : CIVIL ACTION - LAW
OIUSEPPE P. BASILE, personal guarantor
for PINO'S PIZZA & SUB SHOP
Defendants
TO: GIUSEPPE P. BASILE, PERSONAL G NTOR FOR PI--N(-YS PIZZA & SUB SHOP,
Defendan s)
You are hereby notified that on 20_.., the following
(Judgment) has been entered against you in the above-captioned case.
Lgment entered in the amount of $8,720,05.
DATE:
onota
I hereby certify that the name and address of the proper p Trson(s) to receive this
notice is:
GIUSEPPE P. BASILE, PERSONAL GUARANTOR FOR
PINOS PIZZA & SUB SHOP
1 EAST MAIN STREET
NEWVILLE PA 17241
SHERIFF'S RETURN - REGULAR
I'' -% CASE NO: 2006-06197 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FERRARO FOODS INC
VS
BASILE GUISEPPE P ET AL
MICHAEL BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
BASILE GUUSEPPE P the
DEFENDANT , at 1055:00 HOURS, on the 25th day of October , 2006
at 1 EAST MAIN STREET
NEWVILLE, PA 17241 by handing to
MARIO GONZALEZ, ADULT IN CHARGE
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: So Answers:
Docketing
Service 18.0
10.56 6
Postage .63
Surcharge 10.00
nn R. Thomas Kline
39.19 ?/ 10/27/2006
(?_ ' i 1 G ?4 KNUPP KODAK IMBLUM
Sworn and Subscibed to 1 By:
before me this day De uty Sheriff
of A. D.
SHERIFF'S RETURN - REGULAR
I" CASE NO: 2006-06197 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FERRARO FOODS INC
VS
BASILE GUISEPPE P ET AL
MICHAEL BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
BASILE GIUSEPPE P T/A PINO'S PIZZA & SUB SHOP the
DEFENDANT at 1055:00 HOURS, on the 25th day of October 2006
at 1 EAST MAIN STREET
NEWVILLE, PA 17241 by handing to
MARIO GONZALEZ, ADULT IN CHARGE
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: So Answers:
Docketing 6.00
Service .00
?%%?i•?-rr?L'?
Affidavit .00 l
Surcharge 10.00 R. Thomas Kline
.00
16.00/ 10/27/2006
C1 iI 1 (,, KNUPP KODAK IMBL
Sworn and Subscibed to By:
before me this day Deputy Sh riff
of A.D.
SHERIFF'S RETURN - REGULAR
1" -`+ CASE NO: 2006-06197 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FERRARO FOODS INC
VS
BASILE GUISEPPE P ET AL
MICHAEL BARRICK
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
BASILE GIUSEPPE P PERS GUARANT FOR PINO'S PIZZA & SUB SHOP the
DEFENDANT
, at 1055:00 HOURS, on the 25th day of October , 2006
at 1 EAST MAIN STREET
NEWVILLE, PA 17241 by handing to
MARIO GONZALEZ, ADULT IN CHARGE
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: So Answers:
Docketing 6.00 ?.
Service .00
Affidavit .00
Surcharge 10.00 R. Thomas Kline
16.00:/ 10/27/2006 ??-
n f f?Vq?6G KNUPP KODAK IMBLUM
Sworn and Subscibed to By:
before me this day th?fputy Sheriff
of A. D.
a
FERRARO FOODS, INC.
V
Plaintiff
GIUSEPPE P. BASILE i/a/t/a PINO'S PIZZA &
SUB SHOP and GIUSEPPE P. BASILE, personal
guarantor for PINO'S PIZZA & SUB SHOP
Defendant
V
COMMERCE BANK
Garnishee
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-6197
CIVIL DIVISION - LAW
INTERROGATORIES IN ATTACHMENT
TO: GARNISHMENT ADMINISTRATOR/LEGAL DEPT.
COMMERCE BANK
65 ASHLAND AVENUE
CARLISLE, PA 17013
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),
Giuseppe P. Basile and/or Pino's Pizza & Sub Shop, account no. 536218555, or any accounts under
defendant(s) name(s), any money or were you liable to 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, please describe.
ANSWER: Defendants had account 536218555 with a balance of $522.14 and account 536221351 with a balance of
$590.98 at time served. Account 536218555 is a business checking and account 536221351 is held
jointly.
32685
M
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: See answer to question 1.
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: See answer to question 1.
32685
r
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: No
5. At any time before or after you were served, did the Defendant(s) transfer or deliver any
property to you or to any person or place pursuant to your direction or consent and, if so, what was the
consideration therefor?
ANSWER: Defendants made deposits into the above referenced accounts in the ordinary course prior to service,
none of which were at the direction of Caamerce Bank,
32685
i
.w
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 direction or otherwise discharge any claim of the
Defendant(s) against you? If yes, please describe.
ANSWER: No
KODAK Brffg-B-LEL12P.C.
Robert D. Kodak, Esquire
Attorney for Plaintiff
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7152
Supreme Court ID No. 18041
32685
4.,t
VERIFICATION
I, Q YC n of COMMERCE BANK, 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 unsworn
falsification to authorities.
BY:
ADDRESS:
Dated: ? - /<-'/'
32685
5i
FERRARO FOODS, INC. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PA
v : NO. 2006-6197 CIVIL TERM
GIUSEPPE P. BASILE individually and
trading as PINO'S PIZZA & SUB SHOP CIVIL ACTION - LAW
and GIUSEPPE P. BASILE, personal
guarantor for PINO'S PIZZA & SUB SHOP
Defendants
v
COMMERCE BANK
Garnishee
PRAECIPE for ENTRY of JUDGMENT AGAINST GARNISHEE
TO THE PROTHONOTARY:
Please enter Judgment in favor of the Plaintiff(s) and against Commerce Bank, Garnishee,
in the amount of $522.14, which is less than the amount the Garnishee admits in the attached
Answers to Plaintiffs Interrogatories in Attachment, to be the property of Defendant in its,
possession, i.e. - the amount of FIVE HUNDRED TWENTY-TWO DOLLARS AND FOURTEEN
CENTS ($522.14).
TO CUMBERLAND COUNTY
Prothonotary
Dated: April 16, 2007
Robert D. Kodak, Attorney for Plaintiff
Attorney I.D. No. 18041
MAR-18-2001 23:27 COMMERCE WIRE-ACH 7177956128 P.02
FERRARO FOODS, INC.
v
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
GIUSEPPE P. BASILE i/a/t/a PINO'S PIZZA &
SUB SHOP and GIUSEPPE P. BASILE, personal
guarantor for PINO'S PIZZA & SUB SHOP
Defendant
V
COMMERCE BANK
Garnishee
NO. 2006-6197
CIVIL DIVISION - LAW
INTERROGATORIES IN ATTACHMENT
TO: GARNISHMENT ADMINISTRATOR/LEGAL DEPT.
COMMERCE BANK
65 ASHLAND AVENUE
CARLISLE, PA 17013
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);
Giuseppe P. Basile and/or Pino's Pizza & Sub Shop, account no. 536218555, or any accounts under
defendant(s) name(s), any money or were you liable to 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, please describe.
ANSWER: Defendants had account 536218555 with a balance of $522.14 and account 536221351 with s balance of
$590,98 at time served. count 5 is a busirss c and account 536221351 is held
jointly.
32685
MAR-19-2001 23:27 COMMERCE WIRE-ACH
7177956128 P.03
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: See rr to question 1.
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: See miner to question 1.
32685
4MAR-18-2001 23:27 COMMERCE WIRE-ACH 7177956128 P.04
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: No
5. At any time before or after you were served, did the Defendant(s) transfer or deliver any
property to you or to any person or place pursuant to your direction or consent and, if so, what was the
consideration therefor?
ANSWER: Defendants made deposits into the above referenced accounts in the ordinary course prior to service,
none of which were at the direction of Camnerce Bank.
32685
'MAR-18-2001 23:27 COMMERCE WIRE-ACH
7177956128 P.05
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 direction or otherwise discharge any claim of the
Defendant(s) against you? If yes, please describe.
ANSWER: No
KODAK BLU -P.C.
Robert D. Kodak, Esquire
Attorney for Plaintiff
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7152
Supreme Court ID No. 18041
32685
MAR-18-2001 23:27 COMMERCE WIRE-ACH 7177956128 P.06
VERIFICATION
I, ! a VC A.-It c of COMMERCE BANK, 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 unsworn
falsification to authorities.
I
By:
U U6
ADDRESS: 3?? l1G(/r /74?
Dated: / /'3 fir' r7
32685
TOTAL P.06
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FERRARO FOODS, INC.
v
: IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PA
GIUSEPPE P. BASILE individually and
trading as PINO'S PIZZA & SUB SHOP
and GIUSEPPE P. BASILE, personal
guarantor for PINO'S PIZZA & SUB SHOP
Defendants
v
COMMERCE BANK
Garnishee
To COMMERCE BANK, Garnishee(s)
: NO. 2006-6197 CIVIL TERM
CIVIL ACTION - LAW
You are hereby notified that on L l , 20021he following
(Judgment) has been entered against you i the above-captioned case.
Tudgment entered in the amount of $522.14.
DATE: i 7
All A
Pr thonota
I hereby certify that the name and address of the proper person(s) to receive this
notice is:
MARCY CRANDY
COMMERCE BANK - GARNISHEE
3801 PAXTON STREET
HARRISBURG PA 17111
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P. R. C. P. 3101 to 3149
FERRARO FOODS, INC.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs
GIUSEPPE P. BASILE i/a/t/a PINO'S PIZZA &
SUB SHOP and GIUSEPPE P. BASILE, personal
guarantor for PINO'S PIZZA & SUB SHOP
1 EAST MAIN STREET
NEWVILLE, PA 17241
Defendant(s)
Writ No. Term 20
No. 2006-6197 Term 2006
Amount due $ 8,320.05
Interest FROM DATE OF JUDG - 12/12/06
Atty's Comm. $ 416.00
Costs to be determined $
TO THEIPROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania
(2) against GIUSEPPE P. BASILE i/a/t/a PINO'S PIZZA & SUB SHOP and
GIUSEPPE P. BASILE, personal guarantor for PINO'S PIZZA & SUB SHOP
Defendant(s);
(3) and against COMMERCE BANK
Garnishee(s);
(4) and index this writ
(a) against GIUSEPPE P. BASILE i/a/t/a PINO'S PIZZA & SUB SHOP and
GIUSEPPE P. BASILE, personal guarantor for PINO'S PIZZA & SUB SHOP
Defendant(s) and
(b) against COMMERCE BANK
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 THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN
CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO CASH ON HAND, EQUIPMENT, FURNITURE, JEWELRY,
ELECTRONICS, VEHICLES, SUPPLIES, ETC. AND GARNISH COMMERCE BANK, 65 ASHLAND AVENUE, CARLISLE,
PA 17013, ACCOUNT NO. 536218555, OR ANY OTHER ACCOUNTS UNDER D S' NAME(S).
(5) Exemption has (not) been waived.
Robert D. Kodak, Esquire
PO Box 11848
Harrisburg, PA 17108
(717) 238-7159
Dated 3/27/07 Attorney For Plaintiff(s)
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6197 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FERRARO FOODS, INC., Plaintiff (s)
From GIUSEPPE P. BASILE I/A/T/A PINO'S PIZZA & SUB SHOP AND GIUSEPPE P.
BASILE, PERSONAL GUARANTOR FOR PINO'S PIZZA & SUB SHOP, 1 EAST MAIN
STREET, NEWVILLE, PA 17241
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE
ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO CASH ON
HAND, EQUIPMENT, FURNITURE, JEWELRY, ELECTRONICS, VEHICLES, SUPPLIES,
ETC..
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of GARNISH COMMERCE BANK, 65 ASHLAND AVENUE, CARISLE, PA 17013, ACCOUNT
NO. 536218555, OR ANY OTHER ACCOUNTS UNDER DEFENDANTS' NAME(S).
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 $8,320.05
Interest FROM DATE OF JUDG -12/12/06
Atty's Comm % $416.00
Atty Paid $162.69
Plaintiff Paid
Date: MARCH 28, 2007
L.L. $.50
Due Prothy $2.00
Other Costs
- A-, 11 4 ? ?,
Curtis . Long, P onotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
FERRARO FOODS, INC. IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v
GIUSEPPE P. BASILE individually and trading
as PINO'S PIZZA & SUB SHOP and GIUSEPPE
P. BASILE, personal guarantor for PINO'S
PIZZA & SUB SHOP
Defendant(s)
v
COMMERCE BANK
TO THE PROTHONOTARY:
NO. 2006-6197 CIVIL TERM
CIVIL ACTION - LAW
PRAECIPE
Please satisfy the judgment against the Garnishee, COMMERCE BANK, ONLY, in the above-
captioned matter.
TO: Cumberland County
Prothonotary
Dated: April 25, 2007
Garnishee
Robert D. Kodak, Esquire Attorney for Plaintiff
Attorney I.D. No. 18041
f
G
L.
r'y
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-06197 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
FERRARO FOODS INC
VS
BASILE GUUSEPPE P ET AL
And now STEVE BENDER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:40 Hours, on the 4th day of April , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
BASILE GIUSEPPE P
, in the
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND AVE
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
BECKY MOORE (ASST MANAGER)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to Her .
Sheriff's Costs: So %„?•?? '?.t
Docketing .00
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
00 ? Nliyw7,
04/17/2007
Sworn and Subscribed to
before me this day of By
De uty Sheriff
A.D
SHERIFF'S RETURN - GARNISHEE
.CASE NO: 2006-06197 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
FERRARO FOODS INC
VS
BASILE GUISEPPE P ET AL
And now STEVE BENDER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:40 Hours, on the 11th day of April , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
BASILE GIUSEPPE P T/A PINO'S PIZZA & SUB SHOP
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND AVE
CARLISLE. PA 17013
Cumberland County, Pennsylvania, by handing to
BECKY MOORE (ASST MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to Her
. in the
true
and made
Sheriff's Costs: So answers:
Docketing .00
Service .00
's+~C
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
00?q)10 z
04/17/2007
Sworn and Subscribed to
before me this day of By
puty Sheriff
A.D
SHERIFF'S RETURN - GARNISHEE
• SASE NO: 2006-06197 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
FERRARO FOODS INC
VS
BASILE GUISEPPE P ET AL
And now STEVE BENDER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:40 Hours, on the 11th day of April , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
BASILE GUUSEPPE P PERS GUARANT FOR PINO'S PIZZA & SUB SHOP
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND AVE
CARISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
BECKY MOORE (ASST MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to Her .
, in the
true
and made
Sheriff's Costs: So answers:
Docketing .00
Service .00
Affidavit .00 R. Thomas K i
Surcharge .00 Sheriff of Cumberland County
.00
00 Nj??Iv7 L
04/17/2007
Sworn and Subscribed to -/
before me this day of By
Deputy Sheriff
A.D
R. Thomas Kline, Sheriff, who being duly sworn according to law, states23
this writ is returned STAYED, DUE TO BANKRUPTCY.
Sheriff's Costs: Advance Costs: 150.00
Sheriff's Costs: 128.34
Docketing $ 18.00 21.66
Poundage 2.52
Advertising
Law Library .50
Prothonotary 2.00 Refunded to Atty on 07/10/07
Mileage 16.32
Surcharge 40.00
Levy 40.00
Post Pone Sale
Garnishee 9.00
Postage 1/17/t y
TOTAL $ 128.34 ? !'? So Answer
R. Thomas Kline, Sheriff
B 3 aLkj-1 - -16?
L -.1
4
z C:k 513Gi
;GS /? 2?
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-6197 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FERRARO FOODS, INC., Plaintiff (s)
From GIUSEPPE P. BASILE I/A/T/A PINO'S PIZZA & SUB SHOP AND GIUSEPPE P.
BASILE, PERSONAL GUARANTOR FOR PINO'S PIZZA & SUB SHOP, 1 EAST MAIN
STREET, NEWVILLE, PA 17241
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE
ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO CASH ON
HAND, EQUIPMENT, FURNITURE, JEWELRY, ELECTRONICS, VEHICLES, SUPPLIES,
ETC..
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of GARNISH COMMERCE BANK, 65 ASHLAND AVENUE, CARISLE, PA 17013, ACCOUNT
NO. 536218555, OR ANY OTHER ACCOUNTS UNDER DEFENDANTS' NAME(S).
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 $8,320.05
Interest FROM DATE OF JUDG - 12/12/06
Atty's Comm % $416.00
Atty Paid $162.69
Plaintiff Paid
Date: MARCH 28, 2007
L.L. $.50
Due Prothy $2.00
Other Costs
- ?_ If L ? ?2
Curtis.. Long, on tart'
(Seal)
By:
Deputy
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
FERRARO FOODS, INC. IN THE COURT OF COMMON PLEAS
Plaintiff Cumberland COUNTY, PENNSYLVANIA
v
GIUSEPPE P. BASILE ind & t/ a
PINO'S PIZZA & SUB SHOP and
GIUSEPPE P. BASILE, pers guar for
Pino's Pizza & Sub Shop
Defendant(s)
NO. 2006-6197
CIVIL ACTION - LAW
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-captioned Judgment as satisfied and the case discontinued.
TO: Cumberland County
Prothonotary
Dated: July 10, 2009
z4kL
Robert D. Kodak, Esquire
Attorney for Plaintiff
Attorney I.D. No. 18041
D
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TARy
14 Pi
v?th t.