HomeMy WebLinkAbout02-4565 WRIT OF EXECUTION (MONEY JUDGMENTS)
P.R.C.P. 3101 TO 3149
COMMONWEALTH OF PENNSYLVANIA, COUNTY OF DAUPHIN
CIVIL ACTION - LAW
PPL Electric Utilities Corp.
VS.
Chad Smith
706 Moores Mtn. Road
Meohaniesburg, Pa 17055
VS.
Fulton Bank - Garnishee
~FO THE SHERIFF OF CUMBERLANi~:
Writ No. 1062-CV-2002-DJ
Amount Duc $1,636.72
COSTS
Plaintiff Paid: $14.25
Interest from: 5/20/2002 ~ 6%
Attorney: $3.00
This Writ: $23.75
Prior Writ: $23.75
To satisfy the debt, interest and costs against CHAD SMITH, Defendant(s).
(1) You are directed to levy upon the property of the defendant(s) and to sell his, her (or their) interest
therein.
(2) You are also directed to attach the property of the defendant not levied upon in the possession of
FULTON BANK: 6520 Carlisle Pike, #600~ Mechanicsburg~ PA 17050 as Garnishee(s) as follows:
Levy on defendants household goods and personal property
and to notify the Garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined fi.om
paying any debt to or for the account of the defendant(s) and fi.om 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 fotmd in the possession of
anyone other than a named garnishee, you are directed to notify him or her that he or she has been added as
a garnishee and is enjoined as above stated.
WITNESS, the Honorable Joseph H. Klcinfelter, President Judge of the Court of Common Pleas of Dauphin
County at the City of Harrisburg, September 11, 2002.
Stephen E. Farina, Prothonotary
Requesting Party:
Arthur M Feld Esquire
1309 Bridge Street
New Cumberland, PA 17070
717-770~0292
AND NOW
Writ re-issued
Stephen E. Farina, Prothonotary
PPL ELECTRIC UTILITIES CORP.
Plaintiff
V.
CHAD SMITH
Defendant
and
FULTON BANK,
Garnishee
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: No. 1062-CV-2002-DJ
02-
.
.
:
:
: CIVIL ACTION - LAW
ANSWERS AND OBJECTIONS OF GARNISHEE, FULTON BANK,
WITH NEW MATTER, TO INTERROGATORIES TO GARNISHEE
TO:
PPL Electric Utilities Corp.
c/o Arthur M. Feld, Esquire
1309 Bridge Street
New Cumberland, PA 17070
ATTACHED, please find Garnishee, Fulton Bank's, Answers and Objections, with New
Matter, to Interrogatories to Garnishee.
Respectfully submitted,
By:
CALDWELL & KEARNS
~ta~ ! 'iC.~.P~o. ~'1~uire
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
Attorneys for Garnishee
Dated:
20-53/46361
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? If so,
specify how much. No.
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?
If so, specify how much. Yes, Account No. 3621-99992 in the name of Chad
Smith, 3810 Walnut S~t, Hax~isburg, PA 17109 or 706 Moores Mtn. ~d,
Mechanicsburg, PA 17055, which bad a balance at the time of service of the
Writ in excess of $1,900.00.
3. At the time you were served or at any subsequent time did you
hold legal title to any p~operty of any nature owned solely or in
part by the defendant or in which defendant held or claimed any
interest ? None other than as identified in Answer to Interrogatory No. 2.
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? None otherthanasidentifiedinAnsw~rtoInterrogatoryNo. 2.
5. At any time before or after you were served did the defendant
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? Objection is raised to this Interrogatory relative
to any transfers or delivery ~rior to service of the Writ and same is, in such
form unre~_-~on~hle, burd?nsume and without relevance in this procccding. With
regard to transfers or deliveries subsequent to the Writ, the response is no.
6. At any time after you were served did you pay, transfer, or
deliver any money or property to the defendant or to any person or
place pursuant to his direction or otherwise discharge any claim
of the defendant against you? No.
7. Garnishee Fulton Bank asserts against said account balance the claim for
administrative and attorneys' fees in ~rocessing and responding to the Writ
in the s%~n of $200.00.
VERIFICATION
I, Robinderla Y. Strauser, Representative of Fulton Bank, who, having authority to
execute this Verification on its behalf, verify that the statements and averments contained in the
foregoing Answers and Objections to Interrogatories In Attachment are tree and correct upon my
personal knowledge, information and belief. I understand that false averments herein are made
subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities.
FULTON BANK:
Robin~er~a Y. Strauser
Dated: October 10~ 2002
CERTIFICATE OF SERVICE
AND NOW, this ~__~ day of ~--~&~;'~ , 2002, I hereby certify that I have
served a copy of the within document on the following by depositing a true and correct copy of
the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to:
Arthur M. Feld, Esquire
1309 Bridge Street
New Cumberland, PA 17070
Chad Smith
3810 Walnut Street
Harrisburg, PA 17109
Chad Smith
706 Moores Mtn. Rd.
Mechanicsburg, PA 17055
CALDWEI~ & KEARNS
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2002-0063~ T
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLA/qD
OCT 3 0
PPL ELECTRIC UTILITIES CORP
VS
SMITH CHAD
And now JASON VIORAL
Cumberland County of
to law, at 0009:21 Hours, on the 25th day of September
as herein commanded all goods, chattels, rights, debts
moneys of the within named DEFENDANT ,
SMITH CHAD
hands, possession, or control of the within named Garnishee
FULTON BA_NK 6520 CARLISLE PIKE
,Sheriff or Deputy Sheriff of
Pennsylvania, who being duly sworn according
2002, attached
credits, and
, in the
# 60O
MECHANICSBURG, PA 17055
Cumberland County, Pennsylvania, by handing to
BRENDA SMITH (ASSISTANT MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
t rue
and made
the contents there of known to Her
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
S~rcharge .00
.00
.00
Sworn and subscribed to before me
this ~ day of ~
~3~ A.D.
~tary - '
R. Thomas Klin~
Sheriff of Cumberland County
oo/oo/oooo
d--
By ~y Sheriff
PPL ELECTRIC UTILITIES CORP.
Plaintiff
VS
CHAD SMITH
Defendant
FULTON BANK
Garnishee
IN THE COURT OF COMMON PLEAS OF
CUMBERI~ND COUNTY, PA
No. 02- 4565
CIVIL ACTION - LAW
PRAECIPE TO SATISFY TME JUDGMENT
Would you please satisfy the judgment against Garnishee, Fulton Bank
in the above captioned matter. Thank you.
To
Prothonotary
November 27, 2002
Attorney for Plaintiff
Arthur M. Feld
ID #07172
R..Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff's Costs:
Docketing $ 18.00
Poundage 41.23
Advertising
La~v Library
Prothonotm-y 265, ~
Mileage 6.9 0
Misc.
Surcharge 20.00
Levy 20.00
Post Pone Sale
Garnishee 9.00
Advance Costs: 150. O0
Sheriff's Costs: 156, t~$
Refunded to Att5, on 12/3/02
Sworn and Subscribed to before me
This L['~: dayof
2002 A.D.
R. Thomas Kline, Sheriff .
WRIT OF EXECUTION (MONEY JUDGMENTS)
P.R.C.P. 3101 TO 3149
COMMONWEALTH OF PENNSYLVANIA, COUNTY OF DAUPHIN
CIVIL ACTION - LAW
PPL Electric Utilities Corp.
VS.
Chad Smith
706 Moores Mtn. Road
Mechanicsburg, Pa 17055
VS.
Fulton Bank - Garnishee
Writ No. 1062-CV-2002-DJ
Amount Due $1,636.72
COSTS
Plaintiff Paid: $14.25
Interest from: 5/20/2002 ~ 6%
Attorney: $3.00
This Writ: $23.75
Prior Writ: $23.75
po SPOOF OF CtnVm LX -
To satisfy the debt, interest and costs against CHAD SMITH, Defendant(s).
(1) You are directed to levy upon the property of the defendant(s) and to sell his, her (or their) interest
of
therein. · as follows:
(2) You are also directed to attach the property of the defendant not levied upon in the possession
FULTON BANK: 6520 Carlisle Pike #600 Mechamcsbur PA 17050 as Garmshee(s)
Levy on defendants household goods and personal property
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 the possession of
anyone other than a named garnishee, you are directed to notify him or her that he or she has been added as
a garnishee and is enjoined as above stated.
WITNESS, the Honorable Joseph H. Kleinfelter, President Judge of the Court of Common Pleas of Dauphin
County at the City of Harrisburg, September 11, 2002.
Stephen E. Farina, Prothonotary
Requesting Party: .
Arthur M Feld Esqmre
1309 Bridge Street
New Cumberland, PA 17070
717-770-0292
AND NOW
Writ re-issued
Stephen E. Farina, Prothonotary