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Home My WebLink About94-02222 J , ~ 1 , I ~ 1 I I f I \ ! \ ~,. r / ~ l"'l () C'( . ~ \)'0 W1UT OF ElGn1I'ION and/or ATI'ACUIENI' 94-2222 Civil Turm No. CIVIL 19 CIVIL ACTION - LAW- CCMoOf'MEAL'1l1 OF PENNSYLVANIA) C'OlJI'1J'Y OF ClMIlERLAND ) ro THE SHERIFF OF aJUNI'Y : DEFENDANl'(S) (1) You are directed to levy upon the property of the defendant(s) and to sell All cash on hand or in possessino of defendants. accounts receivables. furniture, turnishings, equipnent, inventory, tools, electronic equipnent, vehicles, and & all other personal property. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Firs t Bank and Trus t, Market & Locus t Sts., Mechanicsburg PA 17055. GI\RNISHEE as follows: All property including, without limitation, all savings & checking accounts, certificates of deposit, money market accounts, deposits and all debts & other property and/or obligations owing from garnishee to defendants, including but not (CNER) and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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 and subject to attachment is found in~he possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added ao a garnishee and is enjoined as above stated. CUMBERLAND To satisfy the debt, interest and costs due Donne11ey directory, a div. of of the Reuben H. Connelley ~rp. PLAINl'IFF(S) from James Heffelbower, individually and trading as Spahr Farm Supply Co.. 10 W. Windng Hill Road. Mechanicsburg PA 17055. Amount Due $2,205.57 Interest $22.48 Atty's Comn % Atty Paid $33.00 Plaintiff Paid L.L. Due Prothy Other Costs $.50 $1.00 DATE: July 6, 1994 Lawrence E. Welker by: Deputy REQUESTING PARrY: Name Ronald 'Amato, Esquire 100 Brodhead Rd., Ste. 150 Bethlehem PA 18017-8930 Plaintiff Attorney for: Telephone: (215) 866-0400 Supreme Court 10 No. 32323 "-, So a~ .. 1::":' .7',..",.,?; "Irt~~ R. Thomas Klin~~ff By giiv,,~ J4it Deputy Sher~ff R. Thomas Kline, Sheriff who being duly sworn according to law, says this writ is returned ABANDONDED. Sheriff's Costs: Docketing Advertising Postpone sale Law Library Prothonotary Sen'ice Levy Surcharge Garnishee Poundage Advance costs Sheriff's Costs $ 100.00 81.46 18.54 $ 14.00 9.00 7.00 .50 1.00 17.36 20.00 4.00 7.00 1. 60 81.46 refund to atty 4-15-96 Garnishee continued: limited to account "~, and any account owned solely or in part by defendants, which are in the possession, custody and/or control of said garnishee. ,. Sworn and Subscribed To Before Me This /1} 'E. Day of ~ 1996, A.D,CI,....o- (), /i"JPLJ LW:: ~ I ,-r J Prothonotary '" \.1.(, <> r:1 ,.,., r;) .... \' tJz.. 1.l1' 7 .2.,...376'/ ....."'. c~. -<: '" " " \- LA.W Of'f'ICE:.S N'AUHAN. Sl'IIT... SUlliI.LIIlR .. HALL 200 NOR'TH T...IRb STREET p, 0, 60M e40 HARRISBURG, PI:NHSYLVANIA 17106-0840 DONNELLEY DIRECTORY, A DIV. OF THE REUBEN H. DONNELLEY CORP., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 94-2222 JAMES HEFFELBOWER, individually CIVIL ACTION - LAW and trading as SPAHR FARM : SUPPLY CO., Defendant FIRST BANK & TRUST Garnishee PN~ 'B;l "'~- :VUE. 1- )3/, ~ 7 GARNISHEE'S BILL OF COSTS - PNC Bank, N.A., Garnishee, submits at this time a bill for costs chargeable pursuant to 42 Pa.C.S.A. 52503(3). The filing hereof has been withheld to the present time upon representation of a representative of counsel for the Garnishor that charges for attorney's fees of $150 and administrative costs of PNC in the amount of $50 would be paid voluntarily. That agreement was unilaterly withdrawn by telephone this date and the following bill is submitted as a consequence: NAUMAN, SMITH, SHISSLER & HALL FEES 07/20/94 Telephone Call to PNC Bank; .3 x $125.00 $ 37.50 receipt and review of writ of attachment and interrog. 07/29/94 Preparation of answers to .5 x $125.00 $ 62.50 interrogatories; tIc with PNC Bank 10/20/94 T/C with PNC Bank . 3 x $125.00 $ 37.50 10/25/95 Review of notice of entry .3 x $ 50.00 $ 15.00 of judgment and accompanying documents; letter to PNC 11/01/94 Review of file for status; . 3 x $50.00 $ 15.00 letter to R. Amato 11/02/94 T/C to R. Amato's office . 2 x $50.00 $ 10.00 .' , 11/04/94 T/C from J. Havssy; preparation of bill of costs .3 x $125.00 DISBURSEMENTS: 08/03/94 08/04/94 08/08/94 10/26/94 Telefax charge Postage charge Messenger service Postage charge TOTAL FEES , DISBURSEMENTS '. ,. $ 37.50 $ 8.00 $ 4.60 $ 3.48 $ .29 $231.37 WHEREFORE, PNC Bank, N.A., moves for entry of judgment for amount of $231.37. costs for reasonable attorney's fees and disbursements in the NAUMAN, SMITH, SHISSLER ~ HALL by, I a,V f f (- Davidk Eat~n, Esquire Supreme Court ID# 07169 200 North Third street, PO Box 840 Harrisburg, PA 17108 Telephone: 717/236-3010 Counsel for PNC Bank, N.A. Date: November 4, 1994 - 2 - VERIFICATION I, David C. Eaton, Esquire, verify that I am attorney for PNC Bank, N.A., that as such I am authorized to make this verification on its behalf, and that the statements made in the foregoing Bill of Costs as to charges assessed by Nauman, Smith, Shissler & Hall and PNC Bank, N. A. are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904 relating to unsworn falsification to authorities. / e) ,i (/1 ( / )~t, Davi~ Eaton, Esquire Witness: r,,' CERTIFICATE OF SERVICE I hereby certify that I have this 7th day of November 1994 served a true and correct copy of the within Garnishee's Bill of Costs upon all parties by placing same in the United states mail, addressed as follows: Ronald Amato, Esquire 100 Brodhead Road., ste. 150 Bethlehem, PA 18017-8930 Mr. James Heffe1bower 34 West Main street Meohaniosburg, PA 17055-6249 &Wf' M' Am~(1I1hO)'1- . Sherry L Amspache Paralegal to David C. Eaton Dated: November 7, 1994 "::7- C7') ~ .or ,." ~>-- "'rJ:: h-.., :.r. ~ ... ..:.):.: '.';'--C'_ .7- Cl (,,;';i ::Jff@ '-1- ;~:t~ I...~ o ~ "- ") en ".. <:> ::.:: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNELLEY DIRECTORY, A DIV. OF THE REUBEN H. DONNELLEY CORP. Plaintiff No. 94-2222 vs. JAMES HEFFELBOWER individually and trading as SPAHR FARM SUPPLY CO. CIVIL ACTION Defendant First Bank & Trust Garnishee NOTICE OF JUDGMENT AGAINST GARNISHEE (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE NAM~ GARNISHEE IN THE AMOUNT OF $ 1- 4J 51' ON(J)t'tI-RUL- /0 ' 1994. l{l. ) A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY COUNTY Per: AMATO By: , p.e. Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105-1111 AMATO By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105-1111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNELLEY DIRECTORY, A DIV. OF THE REUBEN H. DONNELLEY CORP. Plaintiff No. 94-2222 vs. JAMES HEFFELBOWER individually and trading as SPAHR FARM SUPPLY CO. CIVIL ACTION Defendant First Bank & Trust Garnishee PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment in favor of the Plaintiff and against the above-named Garnishee, in the amount of $643.58, admitted in the answer to interrogatories to be in the garnishee's possession, together with statutory interest and costs. The amount of the judgment of the Plaintiff against the Defendant is $2,205.57. Dated: October 5, 1994 911020 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNELLEY DIRECTORY, A DIV. OF THE REUBEN H. DONNELLEY CORP. Plaintiff No. 94-2222 vs. JAMES HEFFELBOWER individually and trading as SPAHR FARM SUPPLY CO. CIVIL ACTION Defendant First Bank & Trust Garnishee CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: 455 South Gulph Road KING OF PRUSSIA PA 19406 I do certify that the precise last known address of the within named defendant is: 10 West Winding Hill Road Mechanicsburg, PA 17055 I do certify that the precise last known address of the within named garnishee is: Market and Locust Streets Mechanicsburg, PA 17055 AMATO By: I p.e. Ronal A ato Attorney I.D. No. 32323 Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105-1111 JAMES HEFFELBOWER, individually : and trading as SPAHR FARM SUPPLY CO., Defendant CIVIL ACTION - LAW DONNELLEY DIRECTORY, A DIV. OF THE REUBEN H. DONNELLEY CORP., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . . . . v. : No. 94-2222 : . . : . . : FIRST BANK & TRUST Garnishee : NOTICE TO PLEAD ..J TO: DONNELLEY DIRECTORY - and - RONALD AMATO, ESQUIRE You are hereby notified to plead to the enclosed New Matter within twenty (20) days from the service hereof or a default judgment may be entered against you. NAUMAN, SMITH, SHISSLER , HALL J.1~ /) ('-~ By: V. (~~ ) Dav~ . C. Eaton, ESqu re Supreme Court ID I 07257 200 North Third Street 18th Floor Post Office Harrisburg, Telephone: Counsel for Box 840 PA 17108 (717) 236-3010 PNC Bank, N.A. DONNELLEY DIRECTORY, A DIV. OF THE REUBEN H. DONNELLEY CORP., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. . . No. 94-2222 . . JAMES HEFFELBOWER, individually : and trading as SPAHR FARM SUPPLY CO., Defendant CIVIL ACTION - LAW . . : FIRST BANK , TRUST Garnishee . . ANSWERS OF PNC BANK. N.A.. GARNISHEE TO INT~RROGATORIES OF PLAINTIFF Now comes PNC Bank, National Association, successor by merger to First Bank & Trust (collectively hereinafter referred to as "PNC") by its attorneys, Nauman, Smith, Shissler and Hall, and makes answer to the interrogatories of Plaintiff to garnishee as follows: 1. At the time you were served, or at any subsequent time, did you owe the Defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? Fnswer:l At the time of service PNC maintained Checking account # 5070105652 in the name of James Heffelbower which reflected a credit balance of $643.58. 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 or more other persons any property of any nature owned solely or in part by the Defendant? ;:t.Jt :: Answer: None except as interrogatory # 1. identified in to answer 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 held or claimed any interest? Answer: No. 4. At the time you were served, or at any subsequent time, did you hold, as fiduciary, any property in which the Defendant had an interest? Answer: No. 5. At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person, entity or place pursuant to your direction or consent and, if so, what was the consideration therefor? Answer: No. 6. At any time after you were served, did you pay, transfer or deliver any money or property to the Defendant or any person, entity or place pursuant to his direction or otherwise discharge any claim of the Defendant against you? Answer: No. 7. At any time before or after you were served, did defendant, either solely or in part, have any account (savings, checking, certificate of deposit, money market, deposits, and any other debt and/or property) with your office? Answer: See answer to interrogatory # 1. -2- 8. If your answer to interrogatory #7 is in the affirmative, state: A) the account number of each account; B) the amount of money in each account. Answer: See answer to interrogatory # 1. NEW MATTER 9. PNC, as Garnishee, is entitled to a reasonable counsel fee as a part of the taxable cost of the matter pursuant to the provisions of 42 Pa. C.S.A. Sec. 2503(3). NAUMAN, SMITH, SHISSLER AND HALL by: Davi ~Eat Supreme Court ID#07169 200 N. Third st., 18th Floor Harrisburg, PA 17108 Telephone: 717/236-3010 Counsel for PNC Bank, N.A., Garnishee Date: August 2, 1994 -3- ........v.,.... ........... w,.. ....,.. ..."...... i6UUU" uuo ,'oJoJ.a V!lRII'IC~'l'IOH t verify that I am a Legal Process, Bank Operations Officer of PNI: Ba~, N.A., that as such I am aUthorized to make this verifioation on its behDlf, and that the statements made in the foregoing answers to interrogatories with new matter ara true and correot to the be.t of my knowledge, information and belief. I understand that talse statements herein are made sUbject to the penalti.s ot 18 Pa. C.B.A. seotion 4904 relating to unsworn falsification to authorit:ies. ~a~~h~uu J n M. Gochenauer Dated: r-2-9y Witness: ~. ~~I\~ -4- CERTIFICATE OF SERVICE I hereby certify that I have this ~~ay of August 1994 served a true and correct copy of the within answers of garnishee with new matter to plaintiff's interrogatories upon all parties by placing same in the United states mail, addressed as follows: BV Reqular Mail Ronald Amato, Esquire 100 Brodhead Road., Ste. 150 Bethlehem, PA 18017-8930 BV certified Mail Hr. James Heffelbower 34 West Main street Mechanicsburg, PA 17055-6249 AhLw). qf. R!tm~hPA/ Sherry V. Amspache Secretary to David C. Eaton Dated: August ..3 , 1994 -5- ~ ""-. J '\' ,:) ~ '-... ..) ~" , ~ ~j ~ 'J .:.., --.) ,-....., -::r en = c. -, .;.J ':'..1 ,- <~ , = <\~ -- rsll.'lIIrsu. - KIt.. ADCCU:';::Jl:lJ"ll'nr e>>tN,(U C):)A'WM'I '"'"" ',:: f'- ~c-:;, \:)..;1'- '--> '- .~ ~ \ ~ ~~ ~~..) ~ \) \0 ~ ~ AW OFFICES L ASSOCIATES AMATO AND FleE CENTER NEWPOINTE OF 0 SUITE l~O l"O RC.A. , 100 BR?OH, p~ 18017.8930 BETHLEHEM. ~ ,,~~ ~'I' :g :s L~ 8- m g "~2 ~i 1l~~~~1!," ~ 0 ~ 9:i -N z 1!!00w ~_ ~ · ~ 5 ili 1i~ .... ~ ~~;:j u. ! z i~ ;. LAW Of'"F"ICES NAl111IAN. Hl'IITU. t::iIIlHHLIUI 200 NORTH Tkum STREET p 0 BOl( 840 ,.,~"~RIS>BURQ. P~NNSYCV"NI" ,'.7106 - 064~"I;'; ,.."_.....u~~.~,,-"'''~,,..,'=''~,."'-'''' - ''j'- ll: IIALL DONNELLEY DIRECTORY, A DIV. OF THE REUBEN H. DONNELLEY CORP., plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . . v. . . No. 94-2222 JAMES HEFFELBOWER, individually : and trading as SPAHR FARM SUPPLY CO., Defendant CIVIL ACTION - LAW . . . . . . FIRST BANK & TRUST Garnishee . . NOTICE TO PLEAD TO: DONNELLEY DIRECTORY - and - RONALD AMATO, ESQUIRE You are hereby notified to plead to the enclosed New Matter within twenty (20) days from the service hereof or a default judgment may be entered against you. NAUMAN, SMITH, SHISSLER , HALL BY' o.vUf.-g It Supreme Court ID I 07257 200 North Third street 18th Floor Post Office Harrisburg, Telephone: Counsel for Box 840 PA 17108 (717) 236-3010 PNC Bank, N.A. JAMES HEFFELBOWER, individually : and trading as SPAHR FARM SUPPLY CO., Defendant CIVIL ACTION - LAW DONNELLEY DIRECTORY, A DIV. OF THE REUBEN H. DONNELLEY CORP., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . . v. . . No. 94-2222 . . . . . . FIRST BANK & TRUST Garnishee ANSWERS OF PNC BANK. N.A.. GARNISHEE TO INTERROGATORIES OF PLAINTIFF Now comes PNC Bank, National Association, successor by merger to First Bank & Trust (collectively hereinafter referred to as npNC") by its attorneys, Nauman, Smith, Shissler and Hall, and makes answer to the interrogatories of Plaintiff to garnishee as follows: 1. At the time you were served, or at any subsequent time, did you owe the Defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? Answer: At the time of service PNC maintained checking account I 5070105652 in the name of James Heffelbower which reflected a credit balance of $643.58. 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 or more other persons any property of any nature owned solely or in part by the Defendant? Answer: None except as interrogatory I 1. identified in to answer 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 held or claimed any interest? Answer: No. 4. At the time you were served, or at any subsequent time, did you hold, as fiduciary, any property in which the Defendant had an interest? Answer: No. 5. At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person, entity or place pursuant to your direction or consent and, if so, what was the consideration therefor? Answer: No. 6. At any time after you were served, did you pay, transfer or deliver any money or property to the Defendant or any person, entity or place pursuant to his direction or otherwise discharge any claim of the Defendant against you? Answer: No. 7. At any time before or after you were served, did defendant, either solely or in part, have any account (savings, checking, certificate of deposit, money market, deposits, and any other debt and/or property) with your office? Answer: See answer to interrogatory # 1. -2- ,..,""..n..'...... 8. If your answer to interrogatory 17 is in the affirmative, state: A) the account number of each account; B) the amount of money in each account. Answer I See answer to interrogatory # 1. NEW MATTER 9. PNC, as Garnishee, is entitled to a reasonable counsel fee as a part of the taxable cost of the matter pursuant to the provisions of 42 Pat C.S.A. Sec. 2503(3). NAUMAN, SMITH, SHISSLER AND BALL bY'~ti ?'~ Supreme Court ID#07169 200 N. Third st., 18th Floor Harrisburg, PA 17108 Telephone: 717/236-3010 Counsel for PNC Bank, N.A., Garnishee Date: August 2, 1994 -3- ~OOj.008 08/02/0~ 1~:23 !t717 2H 1023 SSS&H V!lRtJ'ICA'l'IOH t verify that I am a Legal Process, Bank Operations Officer of PNC Ba~, N.A., that a. such I alii authorized to make this verification on it. behalf, and that the statements made in the foregoing answers to interrogatories with new matter are true and correot to the be.t of my knowledge, information and belief. I understand that fal.. stat.ments herein are made subject to the penalti.s of 18 Pa. C.S.A. seotion 4904 relating to unsworn falsification to authorities. -ifnM<~ ~h~1/ J n M. Goch nauer Dated: 1'-2-91 witn...: .\'). 9-, ,?I'\~ -4- ~ , ~, CERTIFICATE OF SERVICE I hereby certify that I have this ~~day of August 1994 served a true and correct copy of the within answers of garnishee with new matter to plaintiff'S interrogatories upon all parties by placing same in the United states mail, addressed as follows: Bv Recrular Mail Ronald Amato, Esquire 100 Brodhead Road., Stet 150 Bethlehem, PA 18017-8930 Bv Certified Mail Hr. James Heffelbower 34 West Main Street Mechanicsburg, PA 17055-6249 Arww;, qf. k~mJL/ Sherry V. Amspache Secretary to David C. Eaton Dated: August ..3 , 1994 -5- ...../ --------- ~ ... .., C'.J .",.. g ..,. ~ - >- .c~ --t'- I<IJ ~'. .,",,: ., ~;c,~::.:: l...OU:-. ~~;~_;i . ...- .~- -I'll " .' . ~": .~.:, I~I /. .:[;.. '" ~,,--, "..~ ""'.-"". ~ t IN THB COURT OF COMMON PLEAS OF CUMBBRLAND COUNTY, PBNNSYLVANIA CIVIL ACTION - LAW VDONNBLLEY DIRECTORY, A DIV. OF . . THB REUBBN H. DONNBLLEY CORP. . CIVIL ACTION NO. 94-2222 . Plaintiff . . V vs. : Amount Due $ 2,205.57 VJAMES HBFFBLBO~R individually . Interest $ 22.48 . and trading as SPAHR FARM : SUPPLY CO. : Costs $ 130.38 /0 IN W/t\tt""a illt RJ.. 0 Defendant (s) . . /vkdV"1\/< ~ Iu ~ (ft t7 cJ 5J . . VFirs~ Bank Trust . Total $ 2.358.55 . /J-url6{ I Lccusl sk Garnishee : MtL~ltdu.""(J P/l 1705) . . To ~he Pro~honotary - Cumberland County: ISSUE A WRIT OF EXECUTION AND ATTACHMENT IN THB ABOVE MATTER. PRAECIPE WRIT OF EXBCUTION Issue a writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) All cash on hand or in the possession of the defendantCsl. accounts receivables. furniture. furnishinqs. equioment. inventorv. tools. electronic equioment. vehicles. anv and all other personal orooertv belonqinq to the above-named defendantCsl. .- ~. . .0 \ PRAECIPE FOR WRIT OF ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above named garnishee (s) for the following property: All orODertv of the above-named defendantCsl. includinq. without limitation. all savinqs and checkinq accounts. certificates of deoosit. monev market accounts. deoosits and all debts and other oroDertv and/or obliqations owinq from the above-named qarnishee to the above named defendantCsl. includinq but not limited to account IDWNA. and anv account owned solelv or in Dart bv the above-named defendantCsl. which are in the oossession. custodv and/or control of said qarnisheeCsl. Attorney File': 911020 AMATO AND ASSOCI~ P.C. By: &-C-1' . Jl()nald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff . . .-. IN THB COURT OF COMMON PLBAS OF CUMBBRLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOHHBLLBY DIRECTORY, A DIV. OF THB REUBBN H. DOHHBLLBY CORP. Plaintiff . . . . No. 94-2222 : vs. . . : JAMES HBFFBLBOHER individually . . and trading a8 SPAHR FARM . CIVIL ACTION . SUPPLY CO. . . . . Defendant(s) . . . . Firat Bank & Tru8t . . Garnishee : INTBRROGATORIBS TO THB AHOVE NAMED GARNISHBB To: First Bank & Trust, Garnishee Market and Locust Streets, Mechanicsburg, PA 17055 You are required to file an answer to the following interrogatories within twenty (20) days after service upon you. Failure to do so may re8ult in judgment against you. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? 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 or more other persons any property of any nature owned solely or in part by the defendant? 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 held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person, entity or place pursuant to your direction or consent and if so, what was the consideration therefor? . ... . . 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or any person, entity or place pursuant to his direction or otherwise discharge any claim of the defendant against you? 7. At any time before or after you were served, did defendant, either solely or in part, have any account (savings, checking, certificate of deposit, money market, deposits, and any other debt and/or property) with your office? 8. If your answer to interrogatory '7 is in the affirmative, state: A) the account number of each account; B) the amount of money in each account. AMATO AND AS OCIZT , P. C. By: ~ onald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Attorney File': 911020 , . . 1M THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PBNNSYLVANIA CIVIL ACTION - LAW DORRELLEY DIRECTORY, A DIV. OF THE REUBEN H. DORRELLEY CORP. Plaintiff . . . . . . No. 94-2222 . . VS. . . . . JAMES HEPPELBOHBR individually and trading as SPAHR PARM SUPPLY CO. . . . . CIVIL ACTION : . . Defendant (s) : WAIVER OF WATCHMAN To the Sheriff: Any deputy sheriff levying upon or attaching any property under the within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before the sheriff's sale thereof. Dated:June 29. 1994 AMATO AND ASSOC ATES, P.C. By: '4,(~ Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Attorney File': 911020 ~ ;:J '~ ..... .r, ~j - I "..r, 'i i /"' ,:;', <)'-.. --- ........ .. i,. e{ ,'.... ~~ :;.. -J :::r ") f'> ...j Q ~ "-........J '- ~ ~ ~ 'l: f'\) NJ i"= ~ 1.:...\ \ ') ~~'~ I\(; ) . ~ r\ r\ ~ U> or!! 1il ~ ~~lll ~ - l1:).... II) ::l g ~i 8;;; ~ ~ ~~; ~~ l'i 0 ~~": I ill;;; ~ ~ l!!i:li5 ;;;;;; ~ ~ ~ ~~ &~ ,. ~..~ < z ~m -..-:: \j- ~ ....10.."". .~>'101 II. ,allOl"'.fQ ,,,,,, l"'''''fIlI OJl'l,U('ll,,"OIlJI.l"'" ., lAW OFFices AMATO AND ASSOCIATES NEWPOltlTE OFfiCE CENl[R 10Q ~flOOHE"'D ROAO. SUITE l~O BETHLEHEM. PA. 18017.8930 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CONNELLEY DIRECTORY, A DIVISION OF THE REUBEN H. DONNELLEY CORPORATION Plaintiff No. t!Y-J.lJ...1 ~ T~ vs. JAMES HEFFELBOWER individually and trading as SPAHR FARM SUPPLY CO. CIVIL ACTION Defendant NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s) IN THE AMOUNT OF $ ON 1994. ( ) A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY - CUMBERLAND COUNTY Per: If you have any questions concerning the above, please contact the undersigned. By: Ro ld Amato Attorney I.D. No. 32323 Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105 (215) 866-0400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNELLEY DIRECTORY, A DIVISION OF THE REUBEN H. DONNELLEY CORPORATION Plaintiff No. vs. JAMES HEFFELBOWER individually and trading as SPAHR FARM SUPPLY CO. Defendant CIVIL ACTION PRAECIPE FOR TRANSFER OF JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment in favor of Plaintiff and against the above-named defendant(s), pursuant to Pa.R.C.P.D.J. No.402(D), for failure of defendant(s) to appeal, within 30 days, a judgement entered November 23, 1992 against the above-named defendant(s) before Philadelphia Municipal Court, as set forth in the transcript of judgment, which is attached hereto. Assess damages as follows: Judgment Amount Post Judgment Interest (from November 23, 1992 to March 12, 1994 at 6% per annum) Court Costs Total Dated: March 12, 1994 2,043.61 161.96 $2,205.57 :~~TT'NSTE~~ Rona1tl. Amato Attorney I.D. No. 32323 Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105-1111 911020 , '. ~... - . ~._,..~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNELLEY DIRECTORY, A DIVISION OF THE REUBEN H. DONNELLEY CORPORATION plaintiff No. vs. JAMES HEFFELBOWER individually and trading as SPAHR FARM SUPPLY CO. CIVIL ACTION Defendant CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: 455 South Gu1ph Road KING OF PRUSSIA PA 19406 I do certify that the precise last known address of the within named defendant is: 10 West winding Hill Road Mechanicsburg, PA 17055 SCHATTENSTEIN By: onald AIDa 0 Attorney I.D. No. 32323 Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105-1111 ~ STA TEMEtfl" OF CLAIM - COMMONWEALTH OF PENNSYLVANIA THE PHiLADELPHIA MUNICIPAL COURT 34 SOUTH 11TH STREET ? 'J PHILADELPHIA, PA 19107 dcr ALAN K. SILBERSTEIN. PRESIDENT J E Al'PROVED /;;- Donnelley Directory, A D~vision of the Reuben H. Donnelley ,torporation '435 South Gulph Road . King of Prussia, PA 19406 co:~ COURT C08T8 $ .5.3, 5D JAMES HEFFELBOWER individually and trading as SPAHR FARM SUPPLY CO. 10 West Winding Hill Road Mechanicsburg, PA 17055 Claim Se- DBY r'l ,8 -~) C'J8Q7 . Plaintiff , [J CONSTABLE SERVICE De"""*-' . Certified & Regular First Class Mail TO THE DEFENDANT: The above named plaintiff(.) ask judgment in Ihla CoUll egBll18t you lor ~ 2 , 0 1 0 . 1 1 plus coUll COII8 upon the IolIowIng dam: At the special instance and request of Defendant, Plaintiff provided advertising in its publication known as the "Donnelley Directory". After applying all proper credits, there remains a principal balance due of $1,262.50, as set forth in the attached statement of account. A~ provided in the attached advertisement contract, Plaintiff is also entitled to interest on the above amount from 5/30/91 to 9/28/92 at the agreed rate of 18% per annum totalling $303.21 and its attorneys fees in the amount of $444.40, for a total of $2,010.11, which, despite demand by Plaintiff, remains due. Defendant was required to forward all payments to Plaintiff in Philadelphia establishing a proper basis for venue in this county. Lucas Enterprises, Inc. vs. Paul C. Harmon, Inc., 417 A.2d 72V (1980). XX~ NOnCE TO DEFEND FILEO SERVICE ADDRESS (INFORIIA TION) II other than .bov. MOTOR VEHICLE CASE - OeIendanl Uooll88lnlannation 0f'IM~. DATIi c# IRfM IDUINCWIT)' OHR. NO. DATI. OF NXIOIHT CWM. DA15 0# IIRTM ClClI.IeB. Fat ~m.lD. NO~ NMIIA ADONiiII Ronald Amato, ID03232T~ COMMONWEALn' 'JF PENNSYLVANIA COUNlY OF PHILADELPHIA sa: I, Ronald Amato depose and say that 11\" facI8 88t forth In 11115 complaint am !rUe cormct and ecknowledge that I am subjBCIlll ~. 4llO4 relaling to unsworn 10 . Slgnotln -""-.y IJCIiIriM ftATI fI). 0WHiII . QIIIft. NO. Atty File II 911020 Prind~Amorl, 262.50 InlD_1 al ! 0 from :J/~UI';Jl. $ :;i.lU.l.;l! AIIomey'. Fee: $ $444.40 OIher: $ TOTAl $ 'llo ~2,010.11 PLUS COURT COSTS 'lOA (215) SUMMONS to 1I1e defendant: You 8/8 hereby ordellld 111 appear aI a hearing scheciJled 88 lollow8: CIT ACiON . AI Oemandado: Por la pn;lenlD, uslBd ..Ia cirijlda a plll88n_ a Ia Blgulanta viola en: DATI ,.. LOOA11OH _ CoU/1lOOm 4- A Foul1h Floor, 34-40 South 11111 S~eel NOV 23 -- 1992 l2:30pm IMPORTANT NOTICE TO THE DEFENDANT You have been .ued In Court. If you with 111 defend egBll18tlhe claim. 1181 forth, you m..t appear a1the dalD, time and place as .00Wn. You 8/8 warned 1haI" you IaIIlll appear, 1I1e C8IB may pIllClI8d w1lhout you and a judgment may bit enlDllld egall18l you by the Court without further nob lor I1'rf money dBlmed In 11\" complBlnt or lor any o1I1er dam or reUe! requeoled by the plaintiff. You may Ioae money or propeny or other rights Important III you. 3C).71 (Rov. MIll NOTA IMPORTANTE PARA EL ACUSADO UIIBd he .Ido c1emandado en corta. 51 usled a delenderll8 contra 188 quejas que aparecen en conlra suya debit u.18d apolar eI dia. Is horsy 8Itio que 88 senalo. UIIBd..1a aa,.ertido que Bl no oompareoe, eIca80 pueda continuer IIln .u preaencia y una querela puede _ pueaIa an contra suya par Is COI1B.1n n1nguna nolificaclon, por dInero reclamado, 0 par alguns ocra queja reqularda par el demandanta. U.1ed puede perder dnalll, po opIedad u olro8 deredlloa Importanllll para ull8d. . . 1 0 ;..'0 '- " COURT RECORD - ENTER DISPOSITION ON PART 2 II. ] ( ~ n ~ '1.1 \. ~ lill:'. \I [] CONSTABLE SERVICE 0eIrmdItn . D~ i e d & !{ e ~ \I 4 r r i r AlIIIXXlNI'1IIUEDlml 30-78 (Rev.llIIll) n...A. _ J COMMONWEALTH OF PENNSYLVANIA THE PHILADELPHIA MUNICIPAL COURT :J.4 SOUTH 11TH STREET PHILADELPHIA. PA .IDl07 ALAN K. SILBERSTEIN, PRESIDENT JUDGE Donnelley Directory. A Division of the Reuben H. Donnelley ,':orporation '455 South Gulph Roa~ ~ing of ~russlo. PA 19406 Plain/iff . :1 PI.AlNT1FF o AA-ed O~llIdby: (_ . Ally. No.) o DId NoI Appeor o Not Repr-*'<I o AppeInd O~llIdby: (_. Ally. No., CASE MUST SE TRIED o AA-ed o Repl888IlIDd by: (_ . Ally. No.) o DId Not Appelli' o NotRe~ o Appeated o Rllpf808nllld by: (_. Ally. No.) I. . . . . -- - -- ..... O. 0'607" 92 \Q -8 Claim No. Se- ::;:nev TlD ~ J'1) JAMeS ~CFFELBOUER individually and tradinc a8 SPAHR FARll SUPPLY CO. 10 Vest Uindinu nill Road hechanicsburn. PA 17055 ~ o DId Not AppeIr ONot~1lId DATE ROOM JUDGE o DId NoI AppeIr o Not~1lId DATE ROOM mlAL DlSP08IT1ON JUDGE >>71~."".1'Igo2 COURT RECORD DISPOSITION .. .......-.--. '" ...."""'1""...... ._Nl.uun mUM W.... . .......,""--~t" .~...f.-nen........ aN not In axoe. 0' 11,DOD. In'" -.... · OOl......tIo.n or UII!noorPoratacl uaoolallon 11III)' be ~~_"'Jh_ nl8llon 01 auoh 81811la. For Iut1llar Inlonnallon,..... . 711701'7NI. " \~", 'lQw1<iI y'lll",.\! .... ~ "11 (!UV{ -atrr ..38(; PLAINTIFF o DId Not Appear 060 0 ND Servlc&- D1aml8aed WITHOUT Pl8Judloe 061 ~JudglT1!'.tft lor PlalnUII by Dslautt ~ LJ plus Interest lrom plus /1_ - TlmeolJ~~n~ .r::~:-- 062 0 JudgmentlorPlalntltl.- plus Intelllstlrom plus .... ...... A.M. COSTS Tlme 01 Judgment P.M. AnY. NO. 070 0 Judgmenllor Dslendanl 071 0 Judgn\ent lor Dslendant as AMOt.M' Plalntlllln Counterclaim 072 0 Judgment lor Plalntlll as a AMOt.M' Delendant on Counterclaim RBMRlC8 DAlC I JUDGE o Appelnd DEFENDANT [1DidNoI Appear. AnY. NO. 080 0 Judgment by Agreement-(SH ff1marlcs) 081 0 Judgment lor Delendant by Delautt 082 0 Wbhdrawn lrom Court Ust wbhoul Pl8Judloe (will be 1lI11sled upon recelp1 ollettsr lrom ebher party) 083 0 Withdrawn wtth PIlIJudlce 084 o Case Settled, DlsconUnued, and Ended Case translerred to COURT NO. Convnon Pleas Court 085 0 0860 S.C., Case 10 be consolidated wbh . .. '-' '-' /1 '" 1 !( ~ 'A '" PERSONAL SERVICE I DEFENDANT -IMPORTANT SEE OTHER SIDE 1.1!~~",)l~~ . . . . . . . . . . . . . . . . . . . . . , . .. Judgment certified in the anomt of $2,043.61 cost in:luded. J HN J. Pr:TTIT. J Prolh MV0N MCVl 92-10-08-08070 SC 122 DISPOSED ISSUE AMT. FEE INCIDENT 2010.11 33 *****.*. PLAINTIFF INFORMATION .*_...- DONNELLEY DIREC TORY 455 S GULPH RD KNG OF PR PA 19406 SC TYPE OTHER M.V. ---- NEXT HEARING ----- IVDF Y ._._._._ DEFENDANT INFORMATION HEFFELBOUER JAMES 10 W WINDING HILL RD MECHANICS PA 17055 llllll**** ATTY 032323 AMATO I I I I I RONALD I C 0 U R T ACT I V I T Y J~: ~54 SILBERSTEIN DISP JUDG FOR PL 2043.61 61-JUDG FOR PL DEFLT HEARING ~01 11/23/92 4A FINE+COST 2043.61 *.. PRESS ENTER FOR PAGE 1 INFORMATION MV0N MCVl 92-10-08-08071 SC 122 DISPOSED ISSUE AMT. FEE INCIDENT 2010.11 :~3 ...****. PLAINTIFF INFORMATION ..*.-.. DONNELLEY DIREC TORY 455 S GULPH RD KNG OF PR PA 19406 Pll SC TYPE OTHER M.V. ---- NEXT HEARING ----- A/DF Y _._._... DEFENDANT INFORMATION SPAHR FARM SUPP LY CO 10 W WINDING HILL RD MECHANICS PA 17055 *ll***** I I I I I RONALD I C 0 U R T ACT 1 V 1 T Y HEARING 101 11/23/92 4A JUDG 254 SILDERS1EIN DISP FINE+COST 2043.61 JUD~ FOR PL 204J.61 ATTY 032323 AMATO 61-JUDG FOR PL DEFLT ._. PRESS ENTER FOR PAGE I INFORMATION P/\ ~o Ul ffi~i ~ ~~, ~ z_~ ~ g w~_ 8;;; Ul U"o w ~ci:? ~' 0 Ul 9:8 iL Ul ii:~oe: :8~ ~ .. ~~n. 0 0 00 . ..~ z ~." -- ;t WW ~N .. -- .. Zx", t:!~ ... 0 oOUJ !< to'" ~ " wi~ .. Z 8 _m .~ 00 ~ ~ (Y) ~ ~o(-! ('{ ~ .~ '';:::$ t - -=r ~ N) .".. ~ ~ ~~ q:... - . ~ :l .., '\"' <> @) <:) (.:1 ,.;:) ~ 0 '::::' \J Q ls) l~ ~ rn - - <--..I n:;; ~ ~ ~ .:' ,", ~'.', ~ 'Ill..". ,II Ii"." .'.'.,'\ '.')1' hu~ ,.... LAW OFFICES .....TO 'NO .SSOCIATES N[WPOINT[ OHICE CENTER 100 f1ROO~4EAD ROAD SUITE I~O BETHLEHEM, PA 18017.8930 AMATO AND ASSOCIATES, P.C. By: nald Amato Attorney ID #32323 Attorneys for Plaintiff P.O. Box 1111 Allentown, PA 18105-1111 (215) 866-0400 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNELLEY DIRECTORY. A DIV. OF THE REUBEN H. DONNELLEY CORP. Plaintiff No. 94-2222 vs. JAMES HEFFELBOWER Individually and trading as SPAHR FARM SUPPLY CO. CIVIL ACTION Defendant(s) First Bank & Trust Garnishee PRAECIPE TO DISCONTINUE AGAINST GARNISHEE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please discontinue the above-captioned matter against ,First Bank & Trust, Garnishee, ONLY, without prejudice. '- ~ c.. "l ~ ~~ -;,- '" o <> '^ s ,. '" " ! ~ =- ~ ~ '-- ..... ...... "'" ~ u-, - <-> ~ , . I 'I II ! j , i I , ,