HomeMy WebLinkAbout02-5897LEGACY BANK OF HARRISBURG,
Plaintiff
THE FRASER GROUP, INC.,
~ iMAGE AK-i'S, ETC: and
A. EDWARD FRASER,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
:
: NO. 0~ ~'-~7 ~6~ .
:
: CI\'II~ .\CTI()N - I.,\\V
PRAECIPE
TO THEPROTHONOTARY:
Please enter judgment in favor of the Plaintiff, Legacy Bank ~1' T lmTisbu~'~. :md :~,_':ti,~t
the Defendants, The Fraser Group, Inc. t/a Image Arts. Etc. and A. Edward Fraser. individual N.
based on m~ Exemplified Record of the Judgment fi'om Dauphin Cot,htr. in the amou,nt (~f { )tic
Hundred Seventy-Four Thousand Eight l Imxdrcd Thirty-Six and 15~ iu0 ~$174.,%0.15) Dollar:,,
together with interest at the rate of Thirty-One m~d 01/100 ($31.01) Dollars per diem, and court
costs, accruing from October 29, 2002, in the above-captioned case.
NICHOLAS & F~.C.
Attorney 1D #21193
4409 North Front Street
Harrisburg, PA 17110-1709
(717) 236-9391
Attorneys for Plaintiff
In The Court of Common Pleas of Dauphin County, Pennsylvania
Legacy Bank ofHarrisburg
VS.
Fraser Group Inc., A Edward Fraser
No. 2793-NT-2002
CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT
I, the undersigned Prothonotary of the Court of common Pleas of Dauphin County, Pennsylvania,
do hereby certify that the attached is a full, true and correct copy of the docket entries in the above
captioned case.
I further certify that judgment was entered in favor of Legacy Bank of Harrisburg, Plaintiff and
against Fraser Group In, A Edward Fraser, Defendant on October 29, 2002 in said case in the amount
of $148,855.25
· n ~;eztimont, ]~9Oereo[, I have hereunto set my hand and affixed the seal of the Court, on Friday,
December 06, 2002.
Prothonotary
JUDGMENT $148,855.25
Attorney Due $3.00
Plaintiff Paid $24.75
Prothy. Due $7.75
This record $15.75
Date: 12/6/2002
Time: 09:27'AM
Page 1 of 1
Dauphin County
ROA Report
Case: 2793-NT-2002-
Current Judge: No Judge
Legacy Bank of Harrisburg vs. Fraser Group Inc, A Edward Fraser
Notes
User:'KGRECO
Date
Judge
10/29/2002
11/1/2002
11/5/2002
New Civil Case Filed This Date.
Filing: Complaint with Confession of Judgment Paid by: Hicholas &
Foreman Receipt number: 0022689 Dated: 10/29/2002 Amount: $24.75
(Check)
On Complaint filed Judgment in
favor of Plaintiff and against Defendant in the sum of One Hundred
Forty-Eight thousand Eight Hundred Fifty-five and 25/100 Dollars
($148,855.25
by virtue of authority contained in the Warrant of Attorney
filed dated 4:22 p.m.
payable installments with interest, costs,
etc. - for colt'n. ~
Inquisition and Exemption Waived.
Entered At 4:23 p.m.
Stephen E. Farina, Prothonotary
Served Complaint in Confession of Judgment/Notice upon Defendant(s)
Edward A. Fraser. So Answers, J.R. Lotwick, Sheriff. Paid $74.75.
Served Complaint in Confession of Judgment/Notice upon Defendant(s)
The Fraser Group, Inc. T/A Image Arts (Cumberland County). So Answers,
J.R. Lotwick, Sheriff.
No Judge
No Judge
No Judge
No Judge
No Judge
LEGACY BANK OF HARRISBURG,
Plaintiff
Vo
THE FRASER GROUP, INC.,
t/a IMAGE ARTS, ETC. and
A. EDWARD FRASER,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
..
_.
: NO.
:
:
:
: CIVIL ACTION- LAW
The Fraser Group, Inc. t/a Image Arts, Etc.
1200 West Market Street
Lemoyne, PA 17043
You are hereby notified that on the __ dav of ,200
judgment, based on an exemplified record of thc judgment from Dauphin County, in thc amount
of One Hundred Seventy-Four Thousand Eight I hmdrcd Thirty-Six and 15/100 ($174,8_,6.
Dollars, together with interest at the rate of Thirty-One and 01/100 ($31.0 I) Dollars per diem,
and court costs, accruing from October 29, 2002, in the above-captioned case.
Date:
Prothonotary
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ON(-'}!. IF YO[? D()
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO ()R 'l'El.l.il'll()'xt-i Il ll.
OFFICE SET FORTH BELOW TO FIND ()[ JT WHERE Y()U CAN GET LI~( ~..\1 ill.il t'
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166
(800)990-9108
I hereby certify that the following is the address of the Defendant stated in tine certificate
of residence:
The Fraser Group, Inc. t/a hnage Arts, Etc.
1200 West Market Street
Lemoync, PA 1
rney f'6r P~ai[tiff(s)
LEGACY BANK OF HARRISBURG,
Plaintiff
THE FRASER GROUP, INC.,
t/a IMAGE ARTS, ETC. and
A. EDWARD FRASER,
Defendants
: IN THE COURT OF COMMON I'1~1,~:\~ ()~:
: CUMBERLAND COUNTY,
: PENNSYLVANIA
_.
: NO.
:
:
..
: CIVIl, ACTION - I~/\W
The Fraser Group, Inc. t/a Image Arts, Etc.
1200 West Market Street
Lemoyne, PA 17043
Por este medio sea avisado queen el dia __ de 200.
admision fue registrado contra usted por la cantidad de $174,836. l 5 del caso ames
Fecha:
Protonotario
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI N() qlli~41!
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SFRVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166
(800)990-9108
Por este medio certifico que lo siguiente es la direccion del demandado dicho c~ cl
certificado de residencia:
The Fraser Group, Inc. t/a lma,ge Arts. Etc.
1200 West Market Street
A/bo~affo (fi) xci~e D~mandante(s) ~
LEGACY BANK OF HARRISBURG,
Plaintiff
THE FRASER GROUP, INC.,
t/a IMAGE ARTS, ETC. and
A. EDWARD FRASER,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
..
: NO.
:
:
..
: CIVIL ACTION - LAW
A. Edward Fraser
4422 Carrington Court
Harrisburg, PA 17112
You are hereby notified that on the day o I' ,
judgment, based on an exemplified record of the judgment from Dauphin Counly. in the am{~l~t
of One Hundred Seventy-Four Thousand Eight l fundred Thirty-Six and
Dollars, together with interest at the rate of Thirty-One and 01/100 ($31.01) Dollars per diem.
and court costs, accruing from October 29, 2002, in the above-captioned case.
Date:
Prothonotary
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO '1'O
OFFICE SET FORTH BELOW TO FIND OUT WItEI>d5, YOU CAN (
Cumberland County Bar Associatim~
2 LiberW Avenue
Carlisle, PA 17013
(717)249-3166
(800)990-9108
I hereby certify that the following is the address of the Defendant stated in thc cc~-lific',t~,
of residence:
A. Edward Fraser
4422 Carrington Court
A~torney for ~!~ain[ff(s)
LEGACY BANK OF HARRISBURG,
Plaintiff
THE FRASER GROUP, INC.,
t/a IMAGE ARTS, ETC. and
A. EDWARD FRASER,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.
CIVIL ACTION- LAW
A. Edward Fraser
4422 Carrington Court
Harrisburg, PA 17112
Por este medio sea avisado queen el dia __ de 200__, un t'alh~
admision fue registrado contra usted por la cantidad de $174,836.15 del caso antes escrito.
Fecha:
Protonotario
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE..ql NO TII~NF,
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAI, ~I.iR\,'I(:I{).
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA I)1141.1( ~t'l( >'4' ~1.
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PI JEDF~ CONS I!(it :Il,'
ASISTENCIA LEGAL.
Cumberland County Ilar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166
(800)990-9108
Por este medio certifico que lo siguiente es la direccion del demm~dado dicho en el
certificado de residencia:
A. Edward Fraser
4422 Carrington Court
[Iarrisbu_[rg, PA 17112
A15oga~) de~dan~e(s)
LEGACY BANK OF HARRISBURG,
Plaintiff
THE FRASER GROUP, INC.,
t/a IMAGE ARTS, ETC. and
A. EDWARD FRASER,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
..
_.
: NO.
:
_.
:
: CIVIL ACTION - LAW
I hereby certify that the following is the address of the Plaintiff:
2600 Commerce Drive
~{ttorney'fo~ Plai~s)
~ ROTHON . 25
PRAECIPE FOR WRIT OF EXECUTION - {MONEY JUDGMENTSI
P.LC.P. 3101 to 3149
~L~GACY BANK OF HARRISBURG,
Plaintiff
THE FRASER GROUP, INC., t/a
IMAGE ARTS, ETC., AND
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
~[/tit No. --
02-5897 Civil
No.
Amount due __$174,836- 15 · -$
$31.01 per diem from 10/29/2002
Interest
,$
Atty's Comm.
and Costs_
TO THE PROTHONOTARY OF SAID COURT: iSSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
CUMBERLAND . County, Pennsyivania;
(1) Directed to the Sheriff of
THE FRASER GROUP, INC.., t/a IMAGE ARTS, ETC., and A. EDWARD FRASER
(2) against
. Defendant(s);
(3) sad against
(4) and index this writ
Ca) against
__ .Garnishee(s);
THE FRASER G~ROUPr,.INC. t/a IMAGE A~TS, ETC., aDx~ A. EDWARD FRASER
__Defendant(s) and
(b) against.
_ Gsmishee(s),
(5) Exemption has (not) been waived.
D.ted_ 'c~/'~ I{)°~,
ns s ifs pendens against the .esl property of the ~ic.d~,s[(s) in the name of the Garnishee(s)es follows:
(Specifically describe property and note any specific direction co Sheriff) Furnish 4 copies for real estate levy)
AT,T, PROPERTY, INVENTORY, SUPPLIES AND GOODS OF THE FRASER GROUP, INC., t/a
IMAGE ARTS, ETC., AND OF A. EDWARD FRASER, INDMDU~T.T.Y, LOCAT~ AT
1200 WEST ~'£ STRRRT, I.RMOYNE, CUMBERLAND COUNTY, p~I~NSYLVANIA 17043
AT THE IMAGE ARTS, ETC. STORE.
Bruce D. Foreman, Esq.
Atty ID ~21193
4409 N Front St, Harrisburg, PA 17~
(717 ) 236-9391
NOTE
Under p~uragraph fl) when Ihe'~q'it is directed to the sheriff of another county ss authorized by Rule 3103(b). the county ~hould he
indicated. ,
Under Rule 3103(c)a writ issued on a transferred judgemen! may be directed only to ~flr sheriff *t I'he county in which issued.
Pal'agtaph (3) (above should be completed only if a named garnishee is to be included in the writ.
Paragraph (4) (a) should be completed only if tndexlng of the executions in the county of issuance, is desbred as ~uthorized by Rule 3104(a).
When the writ issues to another county indexing ia required as of course in that county by the prothonotary. See Rule 3104 (b).
Paragraph (4) (b) should be completed only it' real property in the name of a garnishee is attached and indexing as a lis pendens is des/red.
See rule 3104(c).
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-5897 Civil
cOUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LEGACY BANK OF HARRISBURG, Plaintiff (s)
From THE FRASER GROUP, INC., T/A/IMAGE ARTS, ETC., ANDA. EDWARD FRASER,
1200 WEST MARKET STREET, LEMOYNE, PA 17043
(1) You are directed to levy upon the property of the defendant (s)and to sell ALL PROPERTY
INVENTORY, SUPPLIES AND GOODS OF THE FRASER GROUP, INC T/A IMAGE ARTS,
ETC., AND OF A. EDWARD FRASER, INDIVIDUALLY, LOCATE AT 1200 WEST MARKET
STREET, LEMOYNE, CUMBERLAND COUNTY, PENNSYLVANIA 17043 AT THE IMAGE
ARTS, ETC. STORE ·
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $174,836.15
Interest $31.01 PER DIEM FROM 10/29/02
Atty's Comm %
Atty Paid $73.00
Plaintiff Paid
Date: DECEMBER 18, 2002
(Seal)
L.L. $.50
DueProthy $1.00
Other Costs
CURTIS R. LONG
Prothonot_~ _
Deputy
REQUESTING PARTY:
Name BRUCE D. FOREMAN, ESQUIRE
Address: 4409 N. FRONT ST.
HARRISBURG, PA 17110
Attorney for: PLAINTIFF
Telephone: 717-236-9391
Supreme Court ID No. 21193
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2002-05897 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
LEGACY BANK OF HARRISBURG
VS
FP_ASER GROUP THE INC
And now GERALD WORTHINGTON , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according
to law, at 0012:30 Hours, on the 6th day of January , 2003, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
FRASER GROUP INC T/A IMAGE ARTS ETC , in the
hands, possession, or control of the within named Garnishee
DOUGLAS L. MARTIN (LANDLORD) 1200 WEST MARKET ST
SUITE 360
LEMOYNE, PA 17043
Cumberland County, Pennsylvania, by handing to
DOUGLAS L. MARTIN (LANDLORD)
personally 1 true and attested copies of the within
WRIT OF EXECUTION and made the contents thereof known to His
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
00
00
00
00
00
00
Sworn and subscribed to before me
this /3 ~ day of
.20~D A.D. ! /
Pr6t6onotary
So answers:
R. Thomas Kline
Sheriff of Cumberland County
00/00/0000 ,~
Deputy ~riff
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2002-05897 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
LEGACY BANK OF HARRISBURG
VS
FRASER GROUP THE INC
And now GERALD WORTHINGTON ,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0012:30 Hours, on the 6th day of January , 2003, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
FRASER A EDWARD , in the
hands, possession, or control of the within named Garnishee
DOUGLAS L. MARTIN LANDLORD) 1200 WEST MARKET ST
SUITE 360
LEMOYNE, PA 17043
Cumberland County, Pennsylvania, by handing to
DOUGLAS L. MARTIN LANDLORD) ,
personally three copies of interogatories together with 1
and attested copies of the within WRIT OF EXECUTION
the contents there of known to His
true
and made
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
.00
So answ~rs~F ~W/./~,
R. Thomas Kline
Sheriff of Cumberland County
oo/oo/oooo
Sworn and subscribed to before me
day of
this
~L~ A.D.
P~o~honot ary '
Deputy ~eriff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-5897 Civil
CIVIL ACTION - LAW
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LEGACY BANK OF HARRISBURG, Plaintiff (s)
From THE FRASER GROUP, INC., T/A/IMAGE ARTS, ETC., ANDA. EDWARD FRASER,
1200 WEST MARKET STREET, LEMOYNE, PA 17043
(1) You are directed to levy upon the property of the defendant (s)and to sell ALL PROPERTY
INVENTORY, SUPPLIES AND GOODS OF THE FRASER GROUP, INC T/A IMAGE ARTS,
ETC., AND OF A. EDWARD FRASER, INDIVIDUALLY, LOCATE AT 1200 WEST MARKET
STREET, LEMOYNE, CUMBERLAND COUNTY, PENNSYLVANIA 17043 AT THE IMAGE
ARTS, ETC. STORE ·
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $174,836.15
Interest $31.01 PER DIEM FROM 10/29/02
Atty's Corem %
Arty Paid $73.00
plaintiff Paid
Date: DECEMBER 18, 2002
(Seal)
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Pr°th°n°~)~Y ~t27~--~
fi-). £-"
Deputy
REQUESTING PARTY:
Name BRUCE D. FOREMAN, ESQUIRE
Address: 4409 N. FRONT ST.
HARRISBURG, PA 17110
Attorney for: PLAINTIFF
Telephone: 717-236-9391
Supreme Court ID No.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that a
Sheriff's Sale of personal property was held on March 10, 2003, at which time the
personal property of The Fraser Group, Inc., T/A Image Arts, Etc. and Edward Fraser
was sold to Legacy Bank by handing to JeffMyers, being the representative for Legac
Bank, of 2600 Commerce Drive,.Harrisburg, Pennsylvania 17106, for the sum of $1 .i?0,
it being the highest bid and best price quoted for the same. Date and Time of Sale,
Monday March 10, 2003 at 11:00 A.M.E.D.S.T. at The Storage Depot, 350 South
Seventh Street, Lemoyne, Pennsylvania, 17043. This Writ is returned STAYED as per
Attorney Bruce Foreman.
Sheriff's Costs:
Docketing $ 18.00
Poundage 4.01
Advertising 10.00
Law Library .50
Prothonotary 1.00
Milage 20.70
Cert. Mail 6.52
Surcharge 30.00
Levy 40.00
Post Pone Sale 15.00
Garnishee 9.00
TOTAL $154.73
Pd by Defendant
Sworn and Subscribed to before me
This. 7~-- dayof
2003 A.D.
P oth~n°tary
So Answers;
· Thomas Klino~,, .c~