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Home My WebLink About02-4566WILLIAM D. KEELEY, INC., Owner VS. WILLIAM D. KEELEY, INC., Contractor : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Term : STIPULATION AGAINST LIENS THIS AGREEMENT made and concluded this 20th day of September, 2002, by and between William D. Keeley, Inc, a Pennsylvania corporation having offices at 512 Partridge Court, Mechanicsburg, PA 17050 (hereinafter called"Owner"), and William D. Keeley, Inc., a Pennsylvania corporation having offices at 512 Partridge Court, Mechanicsburg, PA 17050 ("Contractor"). WHEREAS, the parties have by a duly executed agreement dated September 20, 2002, entered into a written agreement for the construction and completion of a home on the property referred to in the tax roles of Hampden Township as parcel 10-19-1604-428 located at 5907 Westover Drive, Mechanicsburg, PA 17050, Lot #25, Village of Westover (East). NOW THIS AGREEMENT WITNESSETH at the time of and immediately before the execution of the principal contract and before any authority has been given by the said Owners to the said Contractor to commence work on the construction of the home, or purchase materials for the same in consideration of the signing of said contract with Contractor, and Ten Dollars ($10.00) in hand paid by Owner to Contractor and other valuable consideration, receipt of which is hereby acknowledged, it is agreed that no lien shall be flied against the said home and the property upon which it is to be constructed by the Contractor, or any of its subcontractors, nor by any material men or workmen or any other person for any labor or materials purchased, or extra labor or materials purchased for the erection of said building on said property, the right to file such liens being expressly waived. IN WITNESS WHEREOF we above. hereunto set our hands and seals the first date written WI D. K~LEY, INC. By: ( ~~'/~ (SEAL) William D. KeeW'~Pres{dent, OWNER WI~/J~i"AM D.~ELEY, INC. (SEAL) William D. Kefflky, Pr~gident, CONTRACTOR PPL ELECTRIC UTILITIES CORP. COMPANY, Plaintiff VS CHAD SMITH Defendant FULTON BANK : Garnishee : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA No. 2002-4565 CIVIL ACTION - LAW Would you please enter judgment against Fulton Bank,, garnishee, in the amount ofV$1636.72 plus court costs of $359.01 plus interest in the amount of $73.00. Total, $2068.01. October 28 , 2002 Atto~ne~ for Plaintiff PPL ELECTRIC UTILITIES CORP. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PA Plaintiff : VS : DAUPHIN # 1062 CV 2002 : CUMBERLAND # 02-4565 : CHAD SMITH : Defendant : : CIVIL ACTION - LAW : FULTON BANK : Garnishee : Would you please enter judgment against FULTON BANK, garnishee, in the amount of $2061.72, the amount being due Plaintiff at time of garnishee's Answers to Interrogatories. Principal including interest to date, $1703.72, Court costs, $358.00 October 25, 2002 Attorney for Plaintiff PPL ELECTRIC UTILITIES CORP. Plaintiff CHAD SMITH Defendant FULTON BANK Garnishee : NO. : EX. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA 02-4565 : CIVIL ACTION - LAW To FULTON BANK You are hereby notified that on OCTOBER ~ 2002, the following judgment has been entered against you in the above captioned case. Judgment in the amount of $1636.72 plus court costs of $359.01 plus interest in the amount of $73.00. Total due:S2068.73 Date: OCTOBER ~% , 2002 Prothonotar I hereby certify that the name and address of the proper person/s to receive this notice is: CHAD SMITH 706 MOORES MTN. ROAD MECHANICSBURG, PA 17055 JAMES CLIPPINGER, ESQ. 3631 N. FRONT STREET HARRISBURG, PA 17110 PPL ELECTRIC UTILITIES CORP. Plaintiff VS. CHAD SMITH FULTON BANK Defendant : Garnishee : : COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PA : DAUPHIN # 1062 CV 2002 : CUMBERLAND #02-4565 CIVIL ACTION - LAW To FULTON BANK, Garnishee You are hereby notified that on OCTOBER ~ 2002, the following judgment has been entered against you in the above captioned case. Judgment in the amount of $2061.72, the amount being due Plaintiff at the time of garnishees answers to interrogatories. Principal including interest to date: $1703.72 plus court costs in the amount of $358.00. Date: OCTOBER ~ , 2002 Prothonotary ~~ ~f~ ~ / I hereby certify that the name and address of the proper person/s to receive this notice is: CHAD SMITH 706 MOORES MOUNTAIN ROAD MECHANICSBURG, PA 17055 JAMES CLIPPINGER CALDWELL & KEARNS 3631 NORTH FRONT STREET HARRISBURG, PA 17110 PPL ELECTRIC UTILITIES CORP. Plaintiff CHAD SMITH Defendant and FULTON BANK, Garnishee : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 1062-CV-2002-D! ~"f~,- qq : CIVIL ACTION - LAW ANSWERS AND OBJECTIONS OF GARNISHEE, FULTON BANK, WITH NEW MA'IIEI~ 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, CALDWELL & KEARNS Dated: 20-53/46361 By: 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorneys for Garnishee 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 ~mme of C~ad Sm/th, 3810 Walnut ~t, Harrisburg, PA 17109 or 706 Moores Mtn. l%oad, Mechanicsburg, PA 17055, which had a balance at the time of service of the Writ in express 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 otherthanesidentifiedinAns%~rtointerrogatoryNo. 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? N°meotherthanasidentifiedinAnswertoInterrogatoryNo. 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? Objectic~ is raised to this Interrogatory relative to any transfers or delivery prior to service of the Writ and sa.~ is, in such form unreasonable, lalrdens~e and without relevance in this proceeding. 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 a~l~inistrative and attorneys' fees in processing and responding to the Writ in the s%~ 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 true and correct upon my personal knowledge, information and belief. I understand that false averments herein arc made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. FULTON BANK: Robidderla y. Strauser Dated: OelcoE~ 10~ 2002 CERTIFICATE OF SERVICE AND NoW' this ~-~-day °f C~&~'~'~x ,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