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HomeMy WebLinkAbout06-6428, r b. In the Court of Common Pleas of Cumberland County, Pennsylvania INNOVATIVE REALTY CONCEPTS, LLC Plaintiff Civil Action - Law V. No. 2006- [s Ct,1 Civil Term GARY KOPPERMAN and THE RESTORATION CLINIC, INC. Defendants NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR 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 INFORMATIN ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMAITON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 comparecencia escrita y radicando en la Corte por escrito sus defenses 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 r 9 ft 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 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 USTED NO PUEDE PAGAR POR LOS SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. IF YOU DO NOT HAVE A LAWYER CONTACT: CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 r 0 t In the Court of Common Pleas of Cumberland County, Pennsylvania INNOVATIVE REALTY CONCEPTS, LLC Plaintiff Civil Action - Law V. GARY KOPPERMAN and THE RESTORATION CLINIC, INC. Defendants No. 2006- 4- y P Civil Term COMPLAINT AND NOW COMES the Plaintiff, Innovative Realty Concepts, LLC, by and through its undersigned attorneys, and states the following in support of its Complaint: 1. Innovative Realty Concepts, LLC ("IRC") is a Pennsylvania limited liability corripany with its principal place of business at 1006 North Second Street, Harrisburg, Dauphin County, Pennsylvania. 2. Gary Kopperman is an adult individual, residing at 17 N. 26th Street, Camp Hill, Cumberland County, Pennsylvania. 3. The Restoration Clinic, Inc. ("TRC") is a Pennsylvania corporation with its principal place of business at 827 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania. 4. On May 9, 2006, IRC, through its authorized agent, Innovative Business Concepts, Inc.,,entered into several related written contracts (the "Contracts") with Mr. Kopperman and TRC for the rehabilitation of three buildings in Harrisburg owned by IRC. (Contracts attached hereto as Exhibit "A"). 5. The three buildings owned by IRC, which were to be rehabilitated by Mr. Kopperman and TRC pursuant to the parties said Contracts, are known and numbered as 2150 Green Street, 2026 Green Street and 1827 Susquehanna Street, all in Harrisburg, PA. 6. Pursuant to the parties' said Contracts Mr. Kopperman and TRC promised to complete the specified rehabilitation "in a professional and workmanlike manner and in compliance with all applicable building codes." 7. Pursuant to the parties' said contracts, Mr. Kopperman and TRC promised that the buildings to be rehabilitated would be "occupancy ready upon completion" of the aforementioned rehabilitation. T • 2 8. The price to be paid by IRC for the work by Mr. Kopperman and TRC was $85,284.44, based upon initial agreement under and subsequent modification of the Contracts. 9. Mr. Kopperman and TRC held themselves out as experts with the necessary knowledge and ability required to complete the work they undertook "in a professional and workmanlike manner." 10. Part of the work to be completed under the parties' Contracts was the structural rehabilitation and leveling of the sagging second floor at 2150 Green Street. 11. Mr. Kopperman and TRC attempted to fortify the sagging floor at 2150 Green Street by attaching, with 8 penny nails, nominal two-by-six-inch framing lumber "sleepers" to the existing 2 3/-inch by 9 3/-inch floor joists. 12. The Harrisburg City building inspector and codes enforcement officer subsequently denied approval to the above-described attempted repair, deeming it inadequate and unsafe. 13. As a result, IRC was required to retain a structural engineer, who prescribed replacing the inadequate construction performed by Mr. Kopperman and TRC with doubled- and tripled two-by-ten-inch replacement joists, fastened by 3-inch #10 wood screws and secured to the supporting walls by "strong-tie" metal hangers. 14. In order to remedy Mr. Kopperman's and TRC's defective work, so that it would pass city inspections, IRC was required to hire another contractor to effect the necessary repairs, which also entailed the removal and replacement of electric wiring and plumbing lines and the partial demolition of second-story knee-walls installed and completed by Mr. Kopperman and TRC. 15. IRC paid the structural engineer $650 to inspect and analyze Mr. Kopperman's and TRC's defective work and to prescribe the above-described remedy. 16. IRC paid the replacement contractor $6,309.09, and incurred $208 of in-house labor costs to perform the necessary work to correct Mr. Kopperman's and TRC's defective work and to properly fortify and level the sagging second floor at 2150 Green Street. 17. In addition, Mr. Kopperman and TRC failed to complete other work at 2026 Green Street, for which they were paid by IRC, and which they were bound by the parties' Contracts to complete, including inter alia plumbing, kitchen-subfloor removal and stairway work, which cost IRC $9,964 to have completed. 18. In addition, Mr. Kopperman and TRC failed to complete other work at 1827 Susquehanna Street, for which they were paid by IRC, and which they were bound by the parties' Contracts to complete, including inter alia plumbing and electrical work, 2 . 1 which cost IRC $410 to have completed in order to obtain a City of Harrisburg occupancy permit. 19. As a direct and foreseeable consequence of the delayed completion of rehabilitation to 2150 Green Street, which Mr. Kopperman and TRC undertook to complete in a professional and workmanlike fashion, and which subsequently had to be replaced, re-done and/or completed by another contractor, TRC lost one month's rental income for two apartments, in the amount of $1,450. 20. IRC acknowledges retention of $6,764.95 in payments agreed to be paid under the parties' contracts for completion of the rehabilitation promised, but not performed, by Mr. Kopperman and TRC. 21. On June 22, 2006, after a portion of the work had been completed at 1827 Susquehanna Street, Mr. Kopperman directed Mary Lynn Fisher, principal owner of IRC, that payment, as provided by the parties' contract for a portion of completed work, should be tendered by check made payable to "Gary Kopperman," rather than to "TRC." 22. Accordingly, Ms. Fisher made the check, in the amount of $4,500, payable to Mr. Kopperman, as directed. (Copy of the check attached hereto as Exhibit "B"). WHEREFORE,,the Plaintiff prays this Court award damages for breach of contract, and restitution to prevent unjust enrichment, in the amount of $18,783.09, reduced by an offset of $6,764.95, for a net judgment against the Defendants, jointly and severally, in the amount of $12,226.14. Respectfully submitted, SAIDIS, FLOWER & LINDSAY BY ?UU? Mic el L. Solomo PA Sup. Ct. # 36031 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 3 VERIFICATION I, M. LYNN FISHER, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 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Q C D Z CL b ro g m N nh o O o r n3 CD Q is 'tt , m O a t,, o ro r O M. a O u,' 7p _ ° n? g 5 O w fD p =3 rn F- po ro _ D ro , 3 0 a. CL w O m 3 q CD r -0 0 w m ?O m N T N rn C m m o rn CL D N r m Z o n m m O T o 70 C ` CD CD rn o 0 x1 3 m a CD < a - n, o tp z 0 m m A G) u O. D CD O Z ° (D a { .Zi O .a W ? N ? ? O tf? N O As .p N ? p Ch m C) 4% -N p Q En Cl oo ° ° ° o ° ° o O ? t/ L? W o tom` ?' 'dam a ? f Hur- 10/ 10 oNi o C m w m? m cc rY CD N 0 O 2 C .? N G7/ 1L/ LCJ 60 G f . JD fl 1 LL11113i 11YItiuvf4 11vL L)uy L l?loo? w' r?? '/?^.. I }li .??lr? - .?laM!Y10?!'liama'°". y??'?,w.'a1iR t? INNOVATlvp, REAL,-Y CC)NCEPT!i X50 s0-IADDr913 1.005 DEVEt OPturEnrt•' ACCOUNT 2 .: 1 1 06 N. zND STREET ?L 1 . , WPIS9URG, PA 17101 tt ?? ATE r.--? P JAY 1C+1'k1lF ORDL+l OF t ? T OLL ? L! Jam"' s? Y6r+r Yje, lour lxtnF i.::.' vF. tI mqq DO P311' A:0 3 11113 9071: 1L Woo. 39 09/12/2006 07:56 b? r a. 71 jig rC µK10 =ry f-:. i 4 .? /A t?G mW JJ 1"" EL ZI 46 mP°33 o =A a+' ?,?% ??ow x m t3 ttl ° p`,i, • PI u t 11 1'1211135 c T r. i c e n m 1NNUVAI1Vt bU5 UNrIU i . •. r ,2,r- ....., 1..y.M 106 MIry? ii'1?'I I{ 14 + e k4 ?O PTfl o? .? m d ]'. tD -rI rr^? CO Ts C to M Nm t-marl uof uo v l C5 r? ?' ?7 C. ? 7? lei a f.? Ln COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INNOVATIVE REALTY CONCEPTS, LLC Plaintiff Civil Action - Law V. No. 2006-06428 Civil Term GARY KOPPERMAN and THE RESTORATION CLINIC, INC Defendants PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAULT To the Prothonotary: Please enter judgment of default in favor of plaintiff INNOVATIVE REALTY CONCEPTS, LLC and against defendants GARY KOPPERMAN and THE RESTORATION CLINIC, INC., for defendant's failure to plead to the complaint in this action within the required time. The complaint contains a notice to defend within 20 days from the date of service thereof. Defendant GARY KOPPERMAN was served with the complaint on November 14, 2006, and defendant's answer was due to be filed on December 4, 2006. Defendant THE RESTORATION CLINIC, INC., was served with the complaint on November 16, 2006, and the defendant's answer was due to be filed on December 6, 2006. Attached as Exhibit "A" is a copy of plaintiffs written Notice of Intention to File Praecipe for Entry of Default Judgment for GARY KOPPERMAN. Exhibit "C" is a copy of plaintiffs written Notice of Intention to File Praecipe for Entry of Default Judgment for THE RESTORATION CIINIC, INC. Exhibit "B" is the Postal Form 3817 which I certify was mailed by regular mail to the defendant, GARY KOPPERMAN, at his last known address of record on December 6, 2006, which is at least 10 days prior to the filing of this Praecipe. Exhibit "D" is the Postal Form 3817 which I certify was mailed by regular mail to the defendant, THE RESTORATION CLINIC, INC., at the last known address of record on December 11, 2006, which is at least 10 days prior to the filing of this Praecipe. The aforesaid notices were contained within separate envelopes bearing the addresses of the undersigned. The notices have not been returned to the undersigned as undeliverable or otherwise. Please assess damages in the amount of $ 12,226.14, being the amount demanded in the complaint. Judgment is entered pursuant to Pa. R.C.P. 1037(b) for failure to file a pleading to Plaintiffs Complaint which contained a notice to defend within twenty (20) days of service thereof and after 10-day Notice was sent. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Date: December 22, 2006 By: IL'a l > Mich el L. Solomon PA Sup. Ct. # 36031 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Exhibit "A" COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INNOVATIVE REALTY CONCEPTS, LLC Civil Action -Law Plaintiff v No. 2006-06428 : Civil Term GARY KOPPERMAN and THE RESTORATION CLINIC, INC. Defendants IMPORTANT TEN DAY NOTICE FILE ?ap? TO: Gary Kopperman, 17 N. 26th Street, Camp Hill, Cumberland County, Pennsylvania. DATE OF NOTICE: December 6, 2006 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HIRING A FORTH BELOW. THIS OFFICE HAVE A LAWYER, GO O IOR TELEPHONE THE NFORMATION OFFICE SET CAN PROVIDE YOU WITH IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO MAY OFFER LEGAL PROVIDE YOU WITH INFORMATION A ABOUT UCED FEE AGENCIES THAT R NO FEE. SERVICES TO ELIGIBLE PERSON CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE PA 17013 800-990-9108 Respectfully submitted, SAIDIS, FLOWER & LINDS Y By, Michae . Solomon, Esq. PA Sup. Ct. # 36031 Attorney for Plaintiff 2109 Market Street, Camp Hill, PA 17011 (717) 737-3405 R Exhibit "B U.S. POSTAL SERVICE CERTIFICATE OF MAILING o ; i 1 MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT M p b caul PROVIDE FORINSURANCE-POSTMASTER k? Received From: e Saidis, Flower & Lindsay 2i9 Market Street to One piece of ordinary mail addressed to: °_?J 3m DN `? OoJ 9 r. N Cmo2.-.? Gary Kopperman 17 North Camp Hill, PA 17011 m I PS Form 3817, January 2001 I ; ;; Exhibit «c" FILE COPY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INNOVATIVE REALTY CONCEPTS, LLC Civil Action -Law Plaintiff v ; No. 2006-06428 Civil Term GARY KOPPERMAN and THE RESTORATION CLINIC, INC. Defendants IMPORTANT TEN DAY NOTICE TO: The Restoration Clinic, 827 West Trindle Road, Cumberland County, Mechanicsburg, PA DATE OF NOTICE: December 11, 2006 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF A HEARING, AND THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU OR OTHER IMPORTANT RIGHTS. YOU MAY LOSE YOUR PROPERTY YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE AOFFICE SET RTH HIRING A LAWYER. BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO MAY OFFER LEGAL PROVIDE YOU WITH INFORMATION A REDUCED FEE AGENCIES NO FEE. SERVICES TO ELIGIBLE PERSONS CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE PA 17013 800-990-9108 Respectfully submitted, SAIDIS, FLOWER LIN S By: Michael L. Solomon, q. PA Sup. Ct. # 36031 Attorney for Plaintiff 2109 Market Street, Camp Hill, PA 17011 (717) 737-3405 Exhibit "D" U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER o 0 0 H69 Market St. 7 Received From: Ps I One piece of ordinary mail addressed to: c fn C xc?? N o i Cli id R ? o? n c pstorat iin Thp a ? ?' .ter- rn * T_r-i.p d-1-a Road otJ1 82? ? m M m w 9 Meek, PA -370-5-5 PS Form 3517, January 2001 Ar r? n lv Q -Q 0 d ?J C'l ¦ . SHERIFF'S RETURN - REGULAR CASE NO: 2006-06428 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INNOVATIVE REALTY CONCEPTS LLC VS KOPPERMAN GARY ET AL KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KOPPERMAN GARY the DEFENDANT , at 1655:00 HOURS, on the 14th day of November , 2006 at 17 N 26TH STREET CAMP HILL, PA by handing to GARY KOPPERMAN 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 18.00 Service 13.20 .osL ' Postage .39 Surcharge 10.00 R. Thomas Kline .00 41.59; 00/00/0000 Ito C)(, Sworn and Subscibed to By: before me this day of A.D. SHERIF'F'S RETURN - REGULAR CASE NO: 2006-06428 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND INNOVATIVE REALTY CONCEPTS LLC VS KOPPERMAN GARY ET AL KENNETH E GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RESTORATION CLINIC INC THE the DEFENDANT , at 1515:00 HOURS, on the 16th day of November , 2006 at 827 WEST TRINDLE ROAD MECHANICSBURG, PA by handing to MARSHA VANORMER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service 9.68 Affidavit .00 Surcharge 10.00 R. Thomas Kline nn 25.68 00/00/0000 t?iat? f a(? Sworn and Subscibed to By: before me this day De ut Sh r'ff of A.D. or t COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INNOVATIVE REALTY CONCEPTS, LLC Plaintiff Civil Action - Law V. No. 2006-06428 Civil Term GARY KOPPERMAN and THE RESTORATION CLINIC, INC. Defendants PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Issue writ of execution in the above matter, (1) directed to the sheriff of Cumberland County: (2) against Gary Kopperman, and The Restoration Clinic, Inc., the defendants; -,W ALL, "i!,xvs p&cfSQJy- (3) against M&T Bank, garnishee regarding Account # 191035 4- (4) Amount due $ 12,226.14 Interest from December 27, 2006, at $2.00 per day Costs to be added Respectfully submitted, SAIDIS, FLOWER & LINDSAY By. Michael L. Solomoh PA Sup. Ct. # 36031 2109 Market Street Camp Hill, Pa 17011 (717) 737-3405 f O 10 -'c Q it) ?o oc ?O ?V 0 W -4 CD <, . =C ti? v ? P o? i v c J ?' e k WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6428 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due INNOVATIVE REALTY CONCEPTS, LLC, Plaintiff (s) From GARY KOPPERMAN, 17 NORTH 26TH STREET, CAMP HILL, PA 17011 AND THE RESTORATION CLINIC, 827 WEST TRINDLE RD, MECHANICSBURG, PA (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL AND BUSINESS PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of M&T BANK, 3805 TRINDLE RD., CAMP HILL, PA 17011 - GARNISHEE REGARDING ACCOUNT # 191035 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 $12,226.14 Interest FROM 12/27/06 AT $2.00 PER DAY Atty's Comm % Atty Paid $149.27 Plaintiff Paid Date: JANUARY 10, 2007 (Seal) REQUESTING PARTY: Name MICHAEL L. SOLOMON, ESQUIRE Address: SAIDIS, FLOWER & LINDSAY 2109 MARKET STREET CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-737-3405 Supreme Court ID No. 36031 L.L. $.50 Due Prothy $1.00 Other Costs $.50 DUE GARNISHEE ? Jj.ty K w R COUNTY COURT OF COMMON PLEAS COMMONWEALTH OF PENNSYLVANIA Re: Writ of Garnishment on Garnishee received by Manufacturers and Traders Trust Company, Garnishee Realty Concepts vs Restoration Clinic & Agry Kopperman Case # 06-6428 Responses to Interrogatories MANUFACTURERS AND TRADERS TRUST COMPANY, pro se, for its answer to the Interrogatories states: (Questions and Answers Pursuant to 14 Pa C.S.A. Rule 3253] At the time you were served or at any subsequent time, did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed any money or were liable to defendant(s) for any reason? Answer: x YES- Holding account #9836495557 Balance in account $182.55 ? Denies knowledge or information sufficient to form a belief as to the answer to the question. At the time you were served or at any subsequent time, was there in you , custody or control or in the joint possession, custody or control of yourself or o or i#j ?t sons any property of any nature owned solely or in part by the defendant(s)? OLN r?rjs, ?Qe f/S'?OrO d Answer: 1:1 Yes ?On1`?Cj?/)S On Obd x No to Or 'dOS? ? Denies knowledge or information sufficient to form a belie fd?O4' answer to the question. 9tC`e OS At any time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the defendant(s) or in which defendant(s) held or claimed any interest? Answer: ? Yes x No ? Denies knowledge or information sufficient to form a belief as to the answer to the question. At any time you were served or at any subsequent time, did you hold as a fiduciary any property in which the defendant(s) had an interest? Answer: ? Yes x No ? Denies knowledge or information sufficient to form a belief as to the answer to the question. S y1 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: ? Yes. The consideration was X No ? Denies knowledge or information sufficient to form a belief as to the answer to the question. At the time you were served or at any subsequent time, did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the direction of defendant(s) against you? Answer: ? Yes X No ? Denies knowledge or information sufficient to form a belief as to the answer to the question. [Additional Questions and Answer (f any)] If any of the following reasons are checked, the account(s) in question are not subject to attachment because: ? Account(s) No(s). are escrow account(s) for real estate taxes and insurance. ? [Field 12] has a right of set off against the account(s) which it hereby elects to assert. ? Other: [Consult with Counsel's Office and type in reason] MANUFACTURERS AND TRADERS TRUST COMPMt C h l= Dated. _ By: c -- ,'?---- Name. .i i e M Glasgow Title: Le Document Analyst M&T Bank - Legal Document Processing PO Box 844 Buffalo New York 14240 Phone(716)635-7713 Fax (716) 635-7725 a (°? ° ---? ? ?-ti , ? ? ,.? r , ??, -? ??> ??.; , ? -?!' c.,? .1 (,.?= SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-06428 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND INNOVATIVE REALTY CONCEPTS LLC VS KOPPERMAN GARY ET AL And now STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:50 Hours, on the 30th day of January , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT RESTORATION CLINIC INC THE hands, possession, or control of the within named Garnishee M & T BANK 3805 TRINDLE ROAD CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to LOUISE SILVER (CUSTOMER REP) personally three copies of lnterogatories together with 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 s: Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 . 00 2140`1 02/07/2007 Sworn and Subscribed to before me this day of By L2.e? Deputy Sheriff A.D SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-06428 P • COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND INNOVATIVE REALTY CONCEPTS LLC VS KOPPERMAN GARY ET AL And now STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:50 Hours, on the 30th day of January , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT KOPPERMAN GARY hands, possession, or control of the within named Garnishee M & T BANK 3805 TRINDLE ROAD CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to LOUISE SILVER (CUSTOMER REP personally three copies of lnterogatories 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 answer Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 02/07/2007 Sworn and Subscribed to 3?41w? before me this day of By /Deputy Sheriff A.D R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, DUE TO BANKRUPTCY. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Post Pone Sale Garnishee Postage TOTAL $ 18.00 3.82 10.00 .50 1.00 25.76 50.00 60.00 15.00 9.00 1.56 194.64 ? Advance Costs: 225.00 Sheriff s Costs: 194.64 30.36 Refunded to Atty on 03/19/07 3/dF?07 So An er R. Thomas Kline, Sheriff By c ;? ":Z d Z I I''V ICiR J 'j, M7- c? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6428 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due INNOVATIVE REALTY CONCEPTS, LLC, Plaintiff (s) From GARY KOPPERMAN, 17 NORTH 26TH STREET, CAMP HILL, PA 17011 AND THE RESTORATION CLINIC, 827 WEST TRINDLE RD, MECHANICSBURG, PA (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL AND BUSINESS PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of M&T BANK, 3805 TRINDLE RD., CAMP HILL, PA 17011 - GARNISHEE REGARDING ACCOUNT # 191035 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 $12,226.14 Interest FROM 12/27/06 AT $2.00 PER DAY Atty's Comm % Arty Paid $149.27 Plaintiff Paid Date: JANUARY 10, 2007 (Seal) REQUESTING PARTY: Name MICHAEL L. SOLOMON, ESQUIRE Address: SAIDIS, FLOWER & LINDSAY 2109 MARKET STREET CAMP HILL, PA 17011 Attorney for: PLAINTIFF L.L. $.50 Due Prothy $1.00 Other Costs $.50 DUE GARNISHEE Deputy Telephone: 717-737-3405 Supreme Court ID No. 36031 v Michael L. Solomon, Esquire Saidis, Flower & Lindsay 2109 Market Street Camp Hill, PA 17070 (717)737-3405 msolomon@sfl-law.com COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INNOVATIVE REALTY CONCEPTS, LLC: Civil Action -Law Plaintiff V. No. 2006-06428 Civil Term GARY KOPPERMAN Defendant PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Issue Writ of Execution in the above matter, (1) directed to the Sheriff of Cumberland County: (2) against all personal property of Gary Kopperman, the Defendant; located at 17 North 26th Street, Camp Hill, PA, and 827 West Trindle Road, Mechanicsburg, PA, including, but not limited to the following automobiles: • 1998 Ford E250 Triton Van • 1995 Jeep Grand Cherokee • 1994 E420 Mercedes Benz Sedan • 1987Ford Iveko Cargo Van and; ,bile 38os 7?:p (k'1( PA calo (3) against M&T Bank, garnishee regarding Account # 191035 and any other accounts and; (4) against Commerce Bank, garnishee, regarding any accounts; \34UI 7rindle Rol ezuy 14w, PA (5) Amount due $ 12,226.14 Interest from December 27, 2006, at $2.00 per day (461 days) 922.00 Costs to be added $ - Respectfully submitted, SAIDIS, FLOWER & LINDSAY Date: April 2-, 2008 By: / " ` Lk Michael L. Solomo , Esquire PA Sup. Ct. # 36031 2109 Market Street Camp Hill, Pa 17011 (717) 737-3405 (J'j b c? r x/71, :o t IV v a (A 70 ? 7 ? o°oR?C*-mop it O O 1 C ° ? 4y 72 rn ? -C 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due INNOVATIVE REALTY CONCEPTS, LLC, Plaintiff (s) From GARY KOPPERMAN, 17 North 26`h Street, Camp Hill, PA and 827 West Trindle Road, Mechancisburg, PA (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property of Gary Kopperman, the defendant; located at 17 N. 26th Street, Camp Hill, PA and 827 W. Trindle Road, Mechanicsburg, PA, including, but not limited to the following automobiles: NO 06-6428 Civil CIVIL ACTION - LAW -1998 Ford E250 Van - 1995 Jeep Grand Cherokee - 1994 E420 Mercedes Benz Sedan - 1987 Ford Iveko Cargo Van (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: M&T BANK, 3805 Trindle Road, Camp Hill, PA 17011 account #191035 and any other accounts COMMERCE BANK, 3201 Trindle Road, Camp Hill, PA 17011 regarding any accounts 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 $12,226.14 L.L. $.50 Interest from 12/27/06 at $2.00 perday (461 days) -- $922.00 Atty's Comm % Due Prothy $2.00 Atty Paid $365.91 Other Costs Plaintiff Paid Date: 4/09/08 Curt R. Long,, P (Seal) By: REQUESTING PARTY: '? . Name MICHAEL L. SOLOMON, ESQUIRE Address: SAIDIS, FLOWER & LINDSAY 2109 MARKET STREET CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-737-3405 Supreme Court ID No. 36031 Michael L. Solomon, Esquire Saidis, Flower & Lindsay 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 msolomon@sfl-law.com COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INNOVATIVE REALTY CONCEPTS, LLC : Plaintiff Civil Action - Law V. No. 2006-06428 Civil Term GARY KOPPERMAN Defendant MOTION FOR CHARGING ORDER PURSUANT TO TITLE 15 Pa.C.S.A. SECTION 8345 Judgment creditor, Innovative Realty Concepts, LLC ("IRC"), by its undersigned counsel, hereby moves for a charging order against the partnership interest of judgment debtor, Gary Kopperman ("Kopperman"), in 827 W. Trindle Partners (a/k/a 827 West Trindle Partnership), stating as reasons therefore the following: 1. IRC, the judgment creditor, is a limited liability corporation organized and existing under the laws of the Commonwealth of Pennsylvania with a principal place of business located at 2109 Market Street, Camp Hill, PA 17011. 2. Kopperman, the judgment debtor, is an individual residing at 17 North 26th Street, Camp Hill, Cumberland County, PA. 3. 827 W. Trindle Partners is a Pennsylvania general partnership with its principal place of business at 827 West Trindle Road, Mechanicsburg, Cumberland County, PA. 4. On December 27, 2006, money judgment by default was entered in the Court of Common Pleas of Cumberland County, Case No. 2006-06428, in . . favor of Innovative Realty Concepts, LLC., against Kopperman in the amount of $12,226.14 plus interest and costs. 5. The judgment debtor, Kopperman, has not made payment on this debt to IRC and judgment entered thereon in Case No. 2006-06428. 6. Title 15, Pa.C.S.A. Section 8345 provides that upon due application to the Court, the Court may charge a debtor's interest in partnership pursuant to a charging order. 7. IRC seeks a charging order against the 50% partnership interest of Kopperman in 827 W. Trindle Partners to satisfy the judgment entered against him in favor of IRC. The charging order shall direct that any asset sale, payment or other form of monetary on non-monetary distribution by 827 W. Trindle Partners to Kopperman on account of Kopperman's partnership interest shall instead be paid to IRC; and that any failure of 827 W. Trindle Partners to abide by the charging order shall result in contempt of court. 8. Pursuant to Local Rule 208.3(a), no hearing on this Motion is requested and no discovery is necessary. 9. 1 hereby certify that no opposing counsel has entered an appearance in this case on behalf of Kopperman, and therefore I am unable to obtain concurrence or non-concurrence of counsel in accordance with Local Rule 208.2(d). WHEREFORE, Plaintiff, IRC, moves this Honorable Court for a charging order against the partnership interest of Gary Kopperman to satisfy the judgment in Case No. 2006-06428. Dated: April 2008 Respectfully submitted, SAIDIS, FLOWER && LI DSAY I'Mu'u By: (r„ Mich el L. Solomon PA Sup. Ct. # 36031 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 ' ? t? !C ) ??", "' ..,? ' "1 ?`i7{ '? r'S, C' ?' ?? ? .rr- APR 1 52008yI? COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INNOVATIVE REALTY CONCEPTS, LLC Plaintiff Civil Action - Law V. No. 2006-06428 GARY KOPPERMAN Civil Term Defendant CHARGING ORDER This matter coming before the Court upon the Motion of Innovative Realty Concepts, LLC ("IRC") for Charging Order Pursuant to Title 15 Pa.C.S.A. Section 8345 against the partnership interest of judgment debtor, Gary Kopperman ("Kopperman"), in 827 W. Trindle Partners (a/k/a 827 West Trindle Partnership), and.the Court being fully advised in the premises, IT IS HEREBY ORDERED THAT: 1) The Motion is granted. 2) Any asset sale resulting in payment or other form of monetary or non- monetary distribution by 827 W. Trindle Partners to Kopperman on account of Kopperman's partnership interest therein shall be paid to IRC until such time that IRC's money judgment by default in Case No. 2006-06428, entered in the Court of Common Pleas of Cumberland County, is satisfied in full. 3) Any failure of Kopperman or 827 W. Trindle Partners to abide by this Order shall result in contempt of Court. 4) Upon proper request of IRC, and payment by IRC of any relevant fee therefore, a certified copy of this Order shall be indexed upon the records of the Prothonotary and Recorder of Deeds in and for Cumberland County, PA as to both the Defendant and 827 W. Trindle Partners. BY THE COURT Dated: / i 2008 ,---/ G, 4 k- J. =! I1? ? 827 W. Trindle Partners c/o Mr. Gary Kopperman 827 West Trindle Road Mechanicsburg, PA 17055 ? Mr. Gary Kopperman 17 North 26t Street Camp Hill, PA 17011 Michael L. Solomon, Esquire Saidis, Flower & Lindsay 2109 Market Street Camp Hill, PA 17070 (717) 737-3405 msolomon@sfl-law.com coPr?s ?m.?(r? y/?afoa DISTRIBUTION LIST © M&TBank April 25, 2008 Prothonotary of Cumberland County Court of Common Pleas Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Legal Document Processing Phone # 716-635-7713 Fax # 716-635-7725 Re: Writ of Garnishment on Garnishee received by Manufacturers and Traders Trust Company, Garnishee Innovative Realty Concepts vs Gary Kopperman (Individually) Case # 06-6428 Dear Prothonotary: Enclosed for filing with your office are Manufacturer and Traders Trust Company's Responses to Interrogatories herein. Please date stamp and return the enclosed copy in the enclosed, pre- addressed, postage pre-paid envelope. Thank you. cerely, Jani M Glasgow Legal Document Analyst Legal Document Processing (716) 635-7713 Enclosures: Original Answer for filing Copy of Answer to Date Stamp and Return Pre-Addressed, Postage Pre-paid Return Envelope Manufacturers and Traders Trust Company PO Box #844 Buffalo NY 14240 COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland County Re: Writ of Garnishment on Garnishee received by Manufacturers and Traders Trust Company, Garnishee Innovative Realty Concepts vs Gary Kopperman (Individually) Case # 06-6428 Responses to Interrogatories MANUFACTURERS AND TRADERS TRUST COMPANY, pro se, for its answer to the Interrogatories states: [Questions and Answers Pursuant to 14 Pa C.S.A. Rule 3253] At the time you were served or at any subsequent time, did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed any money or were liable to defendant(s) for any reason? Answer: NO OPEN ACCOUNTS 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 or one or more other persons any property of any nature owned solely or in part by tliefendant s)? Answer: NO e/ate t?'i? t,'?r o,?S s Ch oe?,? 3. At any time you were served or at any subsequent time, did you h ?gproperty of any nature owned solely or in part by the defendant(s) or in which defe `14eld or claimed any interest? X04, Answer: NO 4. At any time you were served or at any subsequent time, did you hold as a 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: NO 6. At the time you were served or at any subsequent time, did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the direction of defendant(s) against you? Answer: If any of the following reasons are checked, the account(s) in question are not subject to attachment because: ? [Field 12] has a right of set off against the account(s) which it hereby elects to assert. ? Other: [Consult with Counsel's Office and type in reason] MANUFACTURERS AN4 DERS TRUST COMPANY ? Dated: By: v? Name: J ' M Glasgow Title: Lega ocument Analyst M&T Bank - Legal Document Processing PO Box 844 Buffalo, New York 14240 Phone(716)635-7713 Fax (716)635-7725 ni C) ?:? C?. +? .? °' ;? ? -? N _ `,`= . '- ` -ms's ? -- z: _ ?,?? r ? ".:?= .? w COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INNOVATIVE REALTY CONCEPTS, LLC: Plaintiff Civil Action - Law V. No. 2006-06428 Civil Term GARY KOPPERMAN Defendant COMMERCE BANK GARNISHEE ?j INTERROGATORIES TO GARNISHEE IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. B. The term "Defendant(s)" means the individual(s) (or entities) against whom the Writ of Execution issued. C. "You" means the main office and all branch offices of Members 1st Federal Credit Union. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which was then in your possession, custody or control was attached, including all property of the Defendant(s) which comes into your possession thereafter. INTERRAGATORIES IN ATTACHMENT 1. At the time you were served with these Interrogatories or any subsequent time, did you owe the Defendant(s) any money, were you liable to them on any negotiable or other written instrument, or did he (they) claim that you owed him (them) any money or were liable to them for any reason? N o I 16 2. At the time you were served with these Interrogatories 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 or more other persons any property of any nature owned solely or in part by the Defendant(s)? No 3. At the time you were served with these Interrogatories or at any subsequent time, did you hold legal title to any property of any nature owed solely or in part by the Defendant(s) or in which Defendant(s) held or claimed any interest? No 4. At the time you were served with these Interrogatories or at any subsequent time, did the Defendant(s) transfer or delivery any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefore? No 5. At the time you were served with these Interrogatories, did you pay, transfer or deliver any money or property to the Defendant(s), to any person or place pursuant to Defendant(s)' direction, or otherwise discharge any claim of the Defendant(s) against you? No 6. At the time you were served with these Interrogatories or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax, or other accounts or deposits in which Defendant(s) has (have) an interest? No 7. At the time you were served with these Interrogatories or at any subsequent time, did you hold as fiduciary any property in which the Defendant(s) has (have) any interest? No 8. At the time you were served with these Interrogatories or at any subsequent time, did you hold any Treasury Bill, repurchase Agreement or any other type of investment or commercial paper in which the Defendant(s) has (have) any interest? No 9. At the time you were served with these Interrogatories or at any subsequent time, did you have property of the Defendant(s) or property in which he (they) has (have) any interest on deposit or otherwise in your possession, custody or control other than that property indicated in your answers to the previous Interrogatories? No 10. Have you ever owed money to Defendant(s) or held any property belonging to Defendant(s)? If so, state when you either satisfied the debt or disposed of the property and in what manner, for what consideration, and to whom? No Respectfully submitted, SAIDIS, FLOWER & LINDSAY Date: By: Michael L. Solomon, Esquire Supreme Court ID # 36031 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Lauren Bowser (Name) Levy Specialist of Commerce Bank/Harrisburg N.A., garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) tii SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-06428 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND INNOVATIVE REALTY CONCEPTS LLC VS KOPPERMAN GARY ET AL ,Sheriff or Deputy Sheriff of And now MARK CONKLIN Cumberland County of Pennsylvania, who being duly sworn according of April 2008, attached to law, at 00 Hours, on the 17th day as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT in the KOPPERMAN GARY hands, possession, or control of the within named Garnishee M & T BANK 812 & 1/2 WEST HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to CARIE DERICK (BRANCH SALES ASSOCIATE) ' personally three copies of interogatories together with 3 true and made and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . So ans s' . Sheriff's Costs: Docketing .00 POP, ?? i or Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County 00 o t/os - op V -i- 05/20/2008 Sworn and Subscribed to before me this day of By ep eriff A.D -? SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-06428 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND INNOVATIVE REALTY CONCEPTS LLC VS KOPPERMAN GARY ET AL And now MARK CONKLIN ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according 2008, attached to law, at 0010:45 Hours, on the 17th day of April , as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , KOPPERMAN GARY hands, possession, or control of the within named Garnishee COMMERCE BANK 65 ASHLAND AVE , in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to JENNY BEAR (TELLER) personally three copies of interogatories together with 3 true and made and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . Sheriff's Costs: So answers- Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County s/?a/off n .0000 V, 05/20/20408 Sworn and Subscribed to before me this day of BY ep ty iff A.D Cohen Seglias Pallas Greenhall & Furman, PC Michael L. Solomon, PA I. D. # 36031 msolomon@cohenseglias.com 240 N. Third Street, 8 Floor Harrisburg, PA 17101 Attorneys for Plaintiff INNOVATIVE REALTY CONCEPTS, LLC Plaintiff V. GARY KOPPERMAN and THE RESTORATION CLINIC, INC Defendants To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 2006-06428 Civil Term : Civil Action -Law Praeciae Please dissolve the attachment against Commerce Bank, garnishee, entered in the above-captioned case. Respectfully submitted, Cohen Seglias Pallas Greenhall & Furman, PC Date: 1 M. , By: ,,;?.L , I!? C(t ?- Mich I L. Solomon, ID # 36031 240 North Third Street, 8th Floor Harrisburg, PA 17101 (717) 234-5530 Attorneys for Plaintiff t O - `; 00 A R. Thomas Kline, Sheriff, who being duly sworn according to law, states that a Sheriff s Sale of personal property was held on Thursday February 19, 2009 at which time the personal property of Gary Kopperman, at, 827 West Trindle Road, Mechanicsburg, PA 17055 and 17 North Twenty Sixth Street, Camp Hill, PA, 17011, to Innovative Realty Concepts, LLC, of, 1006 North Second Street, Harrisburg, PA 17108, for for the sum of $1.00, it being the highest bid and best price quoted for the same. Date and Time of Sale, Thursday February 19, 2009 at, 3:00 and 3:30 P.M.E.D.S.T., at, 827 West Trindle Road, Mechanicsburg, PA 17055 and 17 North Twenty Sixth Street, Camp Hill, PA, 17011. Sheriff's Costs: Docketing $ 18.00 Poundage 7.01 Advertising 30.00 Law Library .50 Prothonotary 2.00 Milage 101.90 Surcharge 70.00 Levy 80.00 Post Pone Sale 30.00 Garnishee 18.00 P ostage TOTAL $ 357.41 ? z????Gq c ; o N c? ti So Ans ers• R. Thomas Kline, Sheriff 0-0 Cp ;2'z t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6428 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due INNOVATIVE REALTY CONCEPTS, LLC, Plaintiff (s) From GARY KOPPERMAN, 17 North 26th Street, Camp Hill, PA and 827 West Trindle Road, Mechancisburg, PA (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property of Gary Kopperman, the defendant; located at 17 N. 26th Street, Camp Hill, PA and 827 W. Trindle Road, Mechanicsburg, PA, including, but not limited to the following automobiles: -1998 Ford E250 Van .,. -1995 Jeep Grand Cherokee N - 1994 E420 Mercedes Benz Sedan ' - 1987 Ford Iveko Cargo Van +0 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: M&T BANK, 3805 Trindle Road, Camp Hill, PA 17011 account #191035 and any other accounts COMMERCE BANK, 3201 Trindle Road, Cam HM, PA 17011 regarding any accounts 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 $12,226.14 L.L. $.50 Interest from 12/27/06 at $2.00 perday (461 days) -- $922.00 Atty's Comm %o Due Prothy $2.00 Atty Paid $365.91 Other Costs Plaintiff Paid Date: 4/09/08 Cu rdirk Lang, (Seal) By: eb rr SHERIFF'S SALE BY VIRTUE OF WRIT OF EXECUTION NO. 2006-6428 CIVIL TERM ISSUED OUT OF THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA, AND TO ME DIRECTED, I WILL EXPOSE TO PUBLIC SALE ON THURSDAY THE 19TH DAY OF FEBRUARY 2009 AT 3:00 P.M., THE PROPERTY OF GARY KOPPERMAN, AT, 827 WEST TRINDLE ROAD, MECHANICSBURG, AND 3:30 P.M., AT, 17 NORTH TWENTY SIXTH (26TH) STREET, CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA. THE FOLLOWING PROPERTY TO WIT: PROPERTY LOCATED AT: 827 WEST TRINDLE RD, MECHANICSBURG, PA 17055 1998 FORD E250 VAN REG. NO. YJP9522 VIN. NO. 1FTNE24L3WHA21148 1994 MERCEDES E240 REG. NO. EJZ3182 VIN. NO. WDBEA3YEORL01573 1995 JEEP GRAND CHEROKEE REG. NO. ENC5527 VIN. NO. 1J4G278YOSC748170 DELL DESKTOP COMPUTERS WITH MONITOR & KEYBOARD (2) S,`r DELL LAPTOP t ??- PRINTER (CANNON), r , PROPERTY LOCATED AT: 17 NORTH 26TH STREET, CAMP HILL, PA 17011 SOFAS (2)-,, COFFEt" END TABLES MISC. FURNITURE _ LE ISION IPIONEEB) ? (JE AIR CONDITIONERS (2) - UTENSILS IRON REFRIGERATOR FOOD PROCESSOR W_ COOLER 4 HANTS TOO_ _ -? c` i BICYCLES STEP LADDER= LOVESEAT MISC. LAMPS MISC. PICTURES DE(21 ROSENE HEATE POTS/P IRONING BOARD ELECTRIC STOVE COFFEE POT LAWNMOWER LS WHEELBARROW i (A) ALL CLAIMS TO PROPERTY MUST BE CERTIFIED AND FILED WITH THE SHERIFF BEFORE THE SALE, ALONG WITH THE PRESCRIBED FEE OF FIFTY-FIVE DOLLARS ($55.00) (B) ALL CLAIMS TO THE PROCEEDS MUST BE FILED WITH THE SHERIFF . BEFORE DISTRIBUTION. (C) THE SHERIFF'S SCHEDULE OF DISTRIBUTION WILL BE FILED IN HIS OFFICE ON THE 24TH DAY OF FEBRUARY 2009 NOT LATER THAN FIVE (5) DAYS AFTER THE SALE, AND DISTRIBUTION WILL BE MADE IN ACCORDANCE WITH THE SCHEDULE UNLESS EXCEPTIONS ARE FILED WITHIN THE TEN (10) DAYS THEREAFTER. TOGETHER WITH ALL THE BALANCE OF THE DEFENDANT'S PERSONAL PROPERTY SEIZED AND TAKEN IN EXECUTION AS PROPERTY OF GARY KOPPERMAN, AT, 827 WEST TRINDLE RD, MECHANICSBURG, AND, AT 17 NORTH 26TH STREET, CAMP HILL, CUMBERLAND COUNTY. AND TO BE SOLD BY: R. THOMASX.-LINE; SHERIFF CUMBERLAND. COUNTY SHERIFF'S OFFICE CARLISLA, PAS 17013 POSTED 1 6-Dq O l& kfS CUMBERLAND COUNTY SHERIFF'S OFFICE CARLISLE, PA 17013 R. Thomas Kline, Sheriff, who being duly sworn according to law, says that due and legal notice having been given according to law, he sold the personal property of, Gary Kopperman, of, 827 West Trindle Road, Mechanicsburg, PA 17055 and 17 North Twenty Sixth Street, Camp Hill, PA, 17011 for the sum of $1.00, it being the highest bid and price quoted for the same. Date and Time of sale, Thursday February 19, 2009 at, 3:00 and 3:30 P.M.E.D.S.T., at, 827 West Trindle Road, Mechanicsburg, PA 17055 and 17 North Twenty Sixth Street, Camp Hill, PA, 17011 Cumberland County Pennsylvania. So Answer R. Thomas Kline, Sheriff By,, Sworn and Subscribed to before me this day of 009 A.D. otary Public _ WTN UIL SS AL A. Codbb 80M. cwtaftw CO FMX Can "W 4,2000