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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