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HomeMy WebLinkAbout00-01712 ~ff ....-~ -,. -..> R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instruction from the attorney. Sheriff's Costs: Docketing Poundage Law Library Prothonotary Service Garn_i-shee Surcharge Levy $18.00 1. 23 .50 1. 00 3.10 9.00 10.00 20.00 $62.83 Sworn and subscribed to before me This 3Ad.. day Of~, t:::. 2000, A.D;01'" d ;:',ij,.~.4~5 Prothonotary Advance Costs: $150.00 Sheriff's Costs: 62.83 $ 87.17 ;~~~ R. Thomas Kline, Sheriff By9VO~ !j~, D put Sheriff '- \.i., '_~'~.," 11 r:: t_~ ~"J...j '1'- :.. "-. '-' ~ ' '_' -'-"'" '"' - , J J~; ! '" I i I I ,., ... :: 11 A~H 3~f;i1.~i ;:~~ ~~ 'i~~~.~D \;;0 s-. r:::u=tJ ~ '=inl -l... = ~ (siJ t:n:n:i r ~ '2'13(,. v r&---- 9'1 <f ~f. WRIT OF EXECUTION and/or ATTACHMENT ... COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-1712 CIVIL Xl!: Term CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Sears, Roebuck and Company PLAINTIFF(S) from Christopher A. Bakota, 710 N. Middletown, Rd., Carlisle, PA 17013 and All:Eirst Bank - 812 1/2 High St., Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Allfirst Bank, 812 1/2 W. High St., Carlisle, PA 17013 - all accounts- - - -- including all savings, checking and other accol.mts, certificates ofc1eposits; notes receivables, oollateral, pledges, documents of title, securities, coupons and safe deposit boxes. . GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnlshee(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 propertyofthe defendant(s) not levied upon an subjectto attachment is found in the pol;session of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Atty's Comm Atty Paid Plaintiff Paid % LL Due Prothy Other Costs $.50 $1.00 Amount Due $2,719.50 Interest from 3/21/00 at 6% $32.25 Date: May 3. 2000 Curti:;: R. Long Prothonotary, Civil Division 4n--r "J P 7p/7?/U'IL-r- Deputy ~ REQUESTING PARTY: Name Daniel F. Wolfson, Esq. Address: 267 E. Market Street York. PA 17403 Attorney for; Plaintiff Telephone: 717-846-l?S?' Supreme Court 10 No. 20617 ... ,~ ",\~ of <!t Umber ~<;)~ J'Q>.q6 RONNY R. ANDERSDN Chief Deputy PATRICIA A. SHATTO Real Estate Deputy R. THOMAS KLINE Sheriff EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 July 31, 2000 Allfirst Bank 812 High St. Carlisle, P A 17013 Re: Sears, Roebuck & Co. VS Christopher A. Bakota No. 2000-1712 Civil Term Writ ofExecuticin iJ' Dear Sir, Pertaining to Attachments made on accounts in the name of Christopher A Bakata, in the above entitled action, please be advised as of this date, July 31, 2000 all attachments have been lifted by authority of the Cumberland County Sheriff s Office. Thank-you. cc: Daniel Wolfson, Atty for Pltff. Christopher A Bakota,Deft. Allfirst Bank,Gam. ?~~ R. Thomas Kline, Sheriff By ~~ dMLtk Depu Shenff 09-2-01 NO~E OF ~~~E~~~A~~;~. CIVIL CASE PLAINTlF;::: NAME: and ADDRESS 'sEARS ROEBUCK AND COMPANY -, 267 E MARKET STREET C/O WOLFSON & ASSOCIATES ~ORK, PA 17403 ~ ~-- .... . COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No,: DJ Name: Hon. PAULA P. CORREAL Add"" EAST WING - COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA T"'ph'" (717) 240-6564 17013-0000 VS. SEARS ROEBUCK AND COMPANY 267 E MARKET STREET C/O WOLFSON & ASSOCIATES YORK, PA 17403 DEFENDANT: NAME and ADDRESS fBAKOTA, CHRISTOPHER A 710 N MIDDLETOWN RD CARLISLE, PA 17013 L Docket No.: CV- 0000610 - 99 Date Filed: 11/23/99 -, ~ .'. ~ .'~. , . - THIS IS TO NOTIFY YOU THAT: 'd' -;_~_J_udgmeDt:_._ _. ... __ ,_..___ FOR PLAINTIFF 00 Judgment was entered for: (Name) ~R1IR~ R()R"'TTt"'K 111\Tn t"'()MP1INV 00 Judgment was entered against: (Name) "'11 KO'l'l'.. ~HRT~'l'OPHRR l'. in the amount of $ ? 71Q 'in on: (Date of Judgment) ?/n7/nn . . D Defendants are jointly and severally liable. D Damages wili be assessed on: D This case dismissed without prejudice. (Date & Time) O Amount of Judgment Subject to Attachment/Act 5 of 1996 $ -. - .. Amount of Judgment $ 2,653.50 Judgment Costs $ 66.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2,719.50 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ D D Levy is stayed for days or D generaliy stayed. Objection to levy has been filed and hearing will be held: Date: .-- . Pjaci': -- r , . -- Time: ANY PARTY HAS THE RIGHT TO APPE L WITHIN 30 DAYS AFTER THE ENTRY OF UDGMENT BY FILING A NOTICE 2-7-00 AS, CIVIL DIVISION. YOU TH YOUR NOTICE OF APPEAL. OF APPEAL WITH THE PR9T MUST INCLUDE A COpy THIS , District Justice, . ~ ') ~ -<1.;..~ ,~..,;_ .'" , I certify that this isa tiu 2"'7-00. 9 the judgment. , District .Justice My commission expires first Monday of January, Aope 315-99 2006 SEAL ~ - ~ ~ 1.:::-':2 ~c' re.::1 '\\fl ~ l~!\ i I... ,. , IIF-" '7 tEo'c ,I 'I!I '~''':' ': \; 'L""" =-~.._- 1.. I "11...__ " tlnl~'. FEB 1.1 2000 \\UJ\ III . l...... ; ;:.... W _~ ...,,-._. . , j ~ L _'."'___'_"'_~_ ---,~ -- G??p "1Q. -.. ..z:: ~ ~ ik , lU r' ~~ (/1\ Cl (") <'.'- (") 1:) c Cl -n -~ - =l "- ~ ~ ~ F -ow "". :J_3) mrn ::;0 ! n.- 7:J:J N ""'I:")rn ZI-' ~.i1y (1)1>- f"--- 1- -<2: Q,o ~~ GO -0 -" -'- :Il ~o ::!l: Q(~ (;) z ".-r 5>~ - (") .. ~ Z N I =< ~ y N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SEARS ROEBUCK AND COMPANY, Plaintiff VS. NO. 60 - 17/?-....- CHRISTOPHER A. BAKOTA, Defendant NOTICE OF ORDER, DECREE OR JUDGMENT TO: ( ) PLAINTIFF (X) DEFENDANT ( ) GARNISHEE ( ) ADDITIONAL DEFENDANT YOU ARE HEREBY NOTIFIED THAT THE FOLLOWING ORDER, DECREE OR JUDGMENT HAS BEEN ENTERED AGAINST YOU ON IN ACCORDANCE WITH THE PROVISIONS OF PA.R.C.P.236 ( ) DECREE NISI IN EQUITY ( ) FINAL DECREE IN EQUITY (X) JUDGMENT OF () CONFESSION (X) DEFAULT ( ) NON-PROS ( ) VERDICT ( ) NON-SUIT ( ) ARBITRATION AWARD () JUDGMENT IS IN THE AMOUNT OF $ PLUS COSTS. $ FOR A TOTAL OF $ (X) DISTRICT JUSTICE TRANSCRIPT OF JUDGMENT IN CIVIL ACTION IN THE AMOUNT OF $2,653.50 PLUS COSTS $66.00 FOR A TOTAL OF $2,719.50. ( ) IF NOT SATISFIED WITHIN SIXTY (60) DAYS, YOUR MOTOR VEHICLE OPERATOR'S LICENSE WILL BE SUSPENDED BY THE PENNSYLVANIA DEPARTMENT OF TRANSPDRTATION 'ROTHONOTARY~ ;] /~ [! 00 BY 1'1( G;d;-<, 12- IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: NAME OF (ATTORNEY/FILING PARTY): WOLFSON & ASSOCIATES, P.C. ADDRESS: 267 EAST MARKET STREET YORK, PENNSYLVANIA 17403 TELEPHONE NUMBER: (717) 846-1252 OR 800-321-8467 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SEARS, ROEBUCK AND COMPANY, Plaintiff NO. 00 - 17/?-- Clu ~LY~ vs. CHRISTOPHER A. BAKOTA, Defendant CIVIL ACTION- LAW ENTRY OF APPEARANCE Please enter the appearance of Daniel F. Wolfson, Esquire as the Attorney for the Plaintiff. Respectfully Submitted, Date: -;;?~~ Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.c. 267 E. Market Street York, Pennsylvania 1 7403 Telephone No. (717) 846-1252 Attorney I.D. # 20617 Attorney for Plaintiff -<-'. - . PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 Sears, Roebuck and Company, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. JUDGMENT NO. 00-1712 Christopher A. Bakota, Defendant PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against, Christopher A. Bakota- 710 N. Middletown Rd., Carlisle, PA 17013 Defendant(s); (3) and against, Allfirst Bank- 812 'h. W. High St., Carlisle, PA 17013 Garnishee(s); (4) and index this writ (a) against, Christopher A. Bakota, Defendant(s) and (b) against, Allfirst Bank, Garnishee(s), as a lis pendens against the real property of the Defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property)***GARNISH ONL Y*** You are directed to attach the property of the Defendant(s) not levied upon in the possession of Allfirst Bank 812 'h. W. High Sf. Carlisle, PA 17013 Garnishee(s) All accounts including all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount due $ 2,719.50 Interest from March 21,2000 At an interest rate of 6% per year To Be Determined Total $ 2.719.50 Plus costs & interest Dated 'Q)I )co ft?~~#~--- Daniel F. Wolfson:-Esquire Attorney 10 # 20617 267 E. Market Street York, PA 17403 (717)846-1252 -==~~.,~ , , -~ -=-~- . .. '" ...... ---v,-ro)rO 0 .:> . A ~ '" ~~-~ i '-- >- i'::: ~ ~~ ~ N ~ N ;;s cJ "- ~ 0 ;-5<( rli "- W:z: ~7 ~ --..< Qo :c 0<( ---< ~~ LJ-:r: a.. 6f-. (:J~ I . C' ~~ , 0'" ('") 9 Q ~ LUC.: I -'~:::z ~ E \ e ~ u.'~;d >- r.:cz V) 0 ",~jLD i=' """ [ntL C'6 == " t.; ~ r-r ....:. ~ L:.. 0 .':5 . 0 0 u -b;:. ..... co ~ "? ...,. ~ "'=- J SHERIFF'S RETURN - GARNISHEE ./ CASE NO: 2000-0l7l2 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND SEARS ROEBUCK AND COMPANY. VS BAKOTA CHRISTOPHER A ,Sheriff or Deputy Sheriff of And now CPL MICHAEL BARRICK Cumberland County of Pennsylvania, who being duly sworn according to law, at 1540:00 Hours, on the 5th day of May , 2000, attached as herein commanded all goods, chattels, rights, odehts, credLts., and moneys of the within named DEFENDANT BAKOTA CHRISTOPHER A in the hands, possession, or control of the within named Garnishee ALLFIRST BANK 812 1/2 E. HIGH ST. CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to KATHY ZERGERLE, BRANCH MAN~GER & ADULT IN CHARGE personally three copies of interogatories together with THREE true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So a?~/<~ R. Thomas Kline Sheriff of Cumberland County 00/00/0000 Sworn and. subscribed to before me this 1O'''=- day of ~ ~ o-tn) A.D. _. . $:h~"', f2 7vu tJO'_J ~. P t _onotary , . ~ ::t:f.;nJ6- 17 [-;)-CU';.d! PLAINTIFF'S INTERROt;ATORIES TO GARNISHEE DEFENDANT - CHRISTOPHER A. SAKOTA SS# 186-56-1321 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each account. If the Defendant(s) maintains any of these jointly with any other person, or persons, give their name and address. As of May 9, 2000, the defendant Christopher Bakota maintains account number 471-0979-7 jointly with Terri Leggore with Al1first Bank. The amount of $1098.89 is-being held in an escrow account pending further order of the court. 1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. N/A 2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. NO 3. PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not Defendant(s) owns any personal property that was in your possession andfor control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumberances or liens holders, the present balance of the encumberance. State where and when the encumberances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. As indicated in answer-one. :'.r ~ 4. OTHER ASSETS: m At the time you ..here served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset. NO 5. PROPERTY: At the time you were served or at any subsequent time, was there in your possession, custody, or control or in the joining possession, custody, or control of yourself and one or more other persons any property of any nature owned solely or in part by any Defendant(s)? If so, please describe for each Defendant each item of property including its value. As indicated in answer one. 6. REAL PROPERTY: At the time you were served or at any subsequent time, did you hold legal, or equitable title to any property of any nature owned solely or in part by the Defendant(s) or in which and Defendant(s) held or claimed any interest? If so, describe for each Defendant each item of property including its value and the interest held by the Defendant( s). NO ';"'" , , ~ ';--.,. 7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). NO 8. TRANSFER OF PROPERTY: At any time before or after you were served, did any Defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent If so, for each Defendant(s) describe the property transferred or delivered including the dates of delivery or transfer and state the consideration paid. NO ,.'... ~, '. - 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charged by you for the completion of this Answer. If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. . Al1first Bank charges debtor's account $150.00 bank service charge for processing this Writ of Execution. WOLFSON & ASSOCIATES, P.C. Dated: 5/' !()() 1i?~~ Daniel F. Wolfson, Esquire Attorney I.D. # 20617 267 East Market Street York, PA 17403 (717) 846-1252 c "G aJCo+"'-. , r- F~-~" ~ ~ ,.,---~- r -~ , '" ;;:~=- ~-- ~ ~'; F~~ < - k~ ..cc_ . ~ ~~ ~---~ ~:.~- ~:--~- .> ~ , . ....~ YERIFICATION I, Joan E. German, verify that I am a Legal Assistant for AIlfirst Bank a Maryland state-chartered commercial bank organized and doing business under the laws ofthe State of Maryland; that I make this verification on its behalf, being authorized to do so; that the statements made in the foregoing Answers to Plaintiffs Interrogatories to Garnishee are true and correct to my personal knowledge or information and belief. I understand that false statements made herein are made subject to penalties of 18 Pa.C.S. s4904 relating to unsworn falsification to authorities. DATE '5/J5/06 Cha~~~ Joan E. erman Legal Assistant Allfrrst Bank (410) 244-3803 , U allfirst ...__"0 ...-0" ~O~-850 AlIfirst Bank P.O. Box 1596 Baltimore, MD 21203 (410)244-3803 Fax (410)244-3817 May 25, 2000 Office of the Prothonotary Lancaster County Courthouse P.O. Box 43480 Lancaster, Pennsylvania 17603 RE: Sears Roebuck and Company Case No. 00-1712 To Whom It May Concern, Enclosed please find Garnishee's, Allfirst Bank Answers to Plaintiff's Interrogatories in Attachment for the matter referenced above. Very Truly Yours, ~1:1;4 Mq~e~ rfb Deputy General Counsel Allfirst Bank Enclosures cc: Wolfson & Associates Christopher Bakota Terri Leggore .".........../"';>. (") 0 ~<:) ~,-~_:~' C 0 ....;...lj ." :s.: - -- ""Dc::; ::;: ~::tl mrn --<; Z:Tj U:J ~s :z~ ~o (l5~ 0' ;:So --tQ --0 -r ., ,,:::: n=---n ~(") :x 00 2m :>@ ry <:) Z ~ ~ O"l -< " . ,../",,'1 '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Sears, Roebuck & Company Plaintiff, v. NO. 00-1712 Christopher A. Bakota Defendant, NOTICE OF FILING JUDGMENT v. Allfirst Bank Garnishee, ( x ) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $549.45 on .. ),.- .o....1s::' " :2 rY)"") . ( ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. 2 If you have any questions regarding this Notice, please contact the filing party. Daniel F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, PA 17403-2000 (717) 846-1252 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: Allfirst Bank Mail Code 101-850 25 South Charles Street Baltimore, MD 21201 Christopher A. Bakota 710 N. Middletown Rd. Carlisle, PA 17013 \~, ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Sears Roebuck and Company, Plaintiff, v. Christophe; A. Bakota, Defendant, v. Allfirst Bank, Garnishee, Garnishee: Allfirst Bank Mail Code 101"850 25 South Charles St. Baltimore, MD 21201 . NO. 00-1712 PRAECIPE FOR JUDGMENT UPON ADMISSION To the Prothonotary: Please enter judgment in favor of the Plaintiff and against the Garnishee, Allfirst Bank, in the amount of $549.45, as admitted in the answer to interrogatories to be in the Garnishee's possession. The amount of the judgment together with interest and cost of the Plaintiff against the Defendant is $2,719.50. Dated: 25 May 2000 ~?d/~ Daniel F. Wolfson, ~quire Attorney for Plaintiff I.D. No. 20617 WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, PA 17403-2000 Telephone: (717) 846-1252 4q. ~~ ~ 8 F~~~ ~ ~ -...()-l R1 G-7 ~ (") c: ;;:: -um rr1r-' z:b Z'-. ci5?i ~d ;,;::: ">>8 ?-;~ )>c ~ ~,"""" .... c:> <=> '- c: = (") ..." ::::1 -,- ::D ~)6;:; '.' I.:;J _, --< ~ :;c:=J:j S-;o om ~ ~ -< -0 ~ r:-? :n m SEARS, ROEBUCK & COMPANY, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CHRISTOPHER A. BAKOT A, Defendant, NO. 00-1712 v. ..----.---- ALLFIRST BANK, Garnishee, CIVIL ACTION-LAW \ PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, Allfirst Bank, discontinued, upon payment of your costs only. Respectfully submitted, WOLFSON & ASSOCIATES, P.c. By: Daniel F. Wolfson, Esquire Attorney for Plaintiff WOLFSON & ASSOCIATES, P.c. 267 East Market Street York, Pennsylvania 17403 Telephone No. (717)846-1252 Attorney I.D. No. 20617 Dated: 1 5 June 2000 ~~F >-:, '^' ~ ~~, ~ ~ <::::- 1'-' -...j .~, Q 0 0 C ~T! ,- .---1 $::: ~ -0 CD :.::~, rnj-;-. .~ ZOO] ';fY zc ,.0 cry ~_.. ".-.;C) -<.-:.:. ~~:B kc;::, :::s >- -"- ~-~C) Z'..-.' ~Orn -.-0 -S:? ::r>c: s! ~ w ~ 0-.