HomeMy WebLinkAbout03-1091
GRIFFIE & ASSOCIATES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
TANYA VASQUEZ,
Defendant
: CIVIL ACTION - LA W.. L ~
: NO. 0;}-/091 e.t~l. tfA..nt
: CONFESSION OF JUDGMENT
CONFESSION OF JUDGMENT
I, Marylou Matas, Esquire, of Griffie & Associates, pursuant to the warrant
contained in the subject Note, a copy of which is attached hereto, hereby appear on behalf
of the above Plaintiff and confess judgment in favor of the Plaintiff and against the
named Defendant in accordance with the Complaint, in the amount of $750,00, together
with costs, interest, and fees as may be allowed in the Note,
DATE: 3/ W / 03
GRIFFIE & ASSOCIATES
BY ~~1L~
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
I
"II
GRIFFIE & ASSOCIATES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
TANYA VASQUEZ,
Defendant
: CIVIL ACTION - LAW
: NO.
: CONFESSION OF JUDGMENT
COMPLAINT IN CONFESSION OF JUDGMENT
Plaintiff, Griffie & Associates, hereby files the within Complaint, averring as
follows:
1. Plaintiff, Griffie & Associates, is a sole proprietorship law practice having its
principle office at 200 North Hanover Street, Carlisle, Pennsylvania.
2, Defendant, Tanya Vasquez, (hereinafter referred to as "Vasquez") is an adult
individual whose current address is 12 Elmwood Building, Middleton,
Cumberland County, Pennsylvania,
3, On or about December 27, 2002, Defendant executed and delivered to
Plaintiff a Note in the principal amount of $750.00. A true copy of the said
Note is attached hereto and incorporated herein as Exhibit "A",
4. The said Note has not been assigned by Plaintiff,
5. Judgment has not been heretofore entered on the Note in any jurisdiction.
6, By the terms of the said Note, Plaintiff is entitled to confess judgment on the
said Note upon default of the terms of the Note.
7. Under the terms of the Note, Defendant was to provide for the disbursement of
proceeds from her divorce proceedings through the Offices of Griffie &
Associates, Plaintiff, who were authorized to deduct any and all sums due for
services rendered in the said divorce proceedings,
8, The divorce proceedings have been concluded and at the time of disbursement
of the various assets, there are insufficient liquid assets to pay the fees due and
owing to Griffie & Associates pursuant to the terms of the Note.
9, As of the date of this Complaint, the principal balance of the Note is $750.00,
and this balance remains due.
WHEREFORE, Plaintiff hereby confesses judgment in the sum of $750.00 as
authorized in the warrant appearing in the attached Note, together with any costs, interest,
and fees as provided in the said Note,
Respectfully submitted,
GRIFFIE & ASSOCIATES
.,r"
7Vl~
M atas, Esquire
200 No Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
DATE: -3./C) / C3
'f1!~ (M 7f~{~"
MaryI .' tas, Esq ire
GRIFFIE & ASSOCIATES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
TANYA VASQUEZ,
Defendant
: CIVIL ACTION - LA W
: NO.
: CONFESSION OF JUDGMENT
CERTIFICATE OF RESIDENCE
I hereby certify that the residence of the within named Defendant, Tanya Vasquez,
is 12 Elmwood Building, Middleton, Pennsylvania, 17057.
1/
Maryl , Esquire
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
$750.00
DeGember1J, 2002
/'i C"r-fll'lk ,-'
NOTE
ldrpl/b-~ /I1N~ dv/JI/{\j
TANYA 9B~Kl'UN, of~~ County, Pennsylvania,
("Maker"), for value received, hereby promises to pay to the law fIrm of GRIFFIE &
ASSOCIATES of 200 North Hanover Street, Carlisle, Cumberland County,
Pennsylvania, ("Payee"), the sum of SEVEN HUNDRED FIFTY AND 00/100 ($750.00)
DOLLARS, payable by making monthly payments of no less than FIFTY AND XX/I00
($50.00) DOLLARS to be made by the 15th of each month, beginning on December 15,
2002, and continuing each successive month thereafter until the total balance due
hereinunder, as well as any additional costs for services rendered by the Payee, are paid in
full. This note is intended to serve as a lien against any assets or proceeds of the Maker.
This sum shall accrue interest at the rate of TWELVE (12%) PERCENT per annum for
any sums remaining due and owing for legal services rendered from the date of this Note
and forward. Maker shall have the right of prepayment of this Note, in whole or in part,
at any time and from time to time, without penalty. This Note is intended to compensate
Payee for legal services rendered and, as such, the principal amount due hereinunder is
not intended to exceed the balance due and owing to Payee on the last monthly billing
forWarded by Payee to Maker.
AND FURTHER, MAKER DOES HEREBY AUTHORIZE AND EMPOWER
ANY ATTORNEY-AT-LAW, CLERK OF COURT OR PROTHONOTARY OR ANY
COURT OF RECORDS OF PENNSYLVANIA, OR ELSEWHERE, UPON DEF AUL T,
TO APPEAR FOR MAKER IN ANY SUCH COURT AND TO CONFESS JUDGMENT
AGAINST MAKER IN FAVOR OF PAYEE, FOR ALL SUMS DUE OR TO BECOME
DUE BY MAKER TO PAYEE UNDER THIS NOTE, WITH COSTS OF SUIT AND
RELEASE OF ERRORS WITHOUT STAY OF EXECUTION, TOGETHER WITH
REASONABLE ATTORNEY FEES UP TO FIFTEEN (15) PERCENT OF ALL SUMS
DUE HEREIN, AND FURTHER WAIVES THE RIGHT OF INQUISITION ON ANY
REAL ESTATE THAT MAYBE LEVIED UPON UNDER SUCH JUDGMENT AND
HEREBY VOLUNTARILY CONDEMN THE SAME, AND FURTHER AUTHORIZE
THE PROTHONOTARY OR CLERK OF COURT TO ENTER UPON ANY WRIT OF
EXECUTION SAID CONDEMNATION, AND THEY FURTHER AGREE THAT
SAID REAL ESTATE MAYBE SOLD UPON A WRIT OF EXECUTION, AND THEY
HEREBY WAIVE AND RELEASE ALL RELIEF FROM ANY AND ALL
APPRAISEMENT, STAY OR EXCEPTION LAWS OF ANY STATE, NOW IN
FORCE OR HEREAFTER TO BE PASSED, AND FOR DOING SO THIS NOTE OR A
COpy VERIFIED BY AFFIDAVIT SHALL BE SUFFICIENT WARRANT, SUCH
AUTHORITY AND POWER SHALL NOT BE EXHAUSTED BY ANY EXERCISE
THEREOF, AND JUDGMENT MAYBE CONFESSED AS AFORESAID FROM TIME
TO TIME AS OFTEN AS THERE IS OCCASION THEREFOR.
THE REMEDIES OF THE PAYEE AS PROVIDED HEREIN SHALL BE
CUMULATIVE AND CONCURRENT AND MAY BE PURSUED SINGLY,
SUCCESSIVELY OR TOGETHER AGAINST MAKER AND/OR ANY PROPERTY
PLEDGED OR ASSIGNED - TO PAYEE AS SECURITY FOR THIS NOTE, AT THE
SOLE DISCRETION OF PAYEE, AND SUCH REMEDIES SHALL NOT BE
EXHAUSTED BY ANY EXERCISE THEREOF BUT MAYBE EXERCISED AS
OFTEN AS OCCASIONS THEREOF SHALL OCCUR.
Maker hereby waives and releases all errors, defects and imperfections in any
proceedings instituted by Payee under the terms of this note, as well as all benefit that
might accrue to Maker by virtue of any present or future laws exempting any of maker's
property, real or personal, or any part of the proceeds arising from any sale of such
property, from attachment, levy or sale under execution or providing for any stay of
execution, exemption from civil process or extension of time for payment, as well as the
right of inquisition on any real estate that may be levied upon under a judgment obtained
by virtue hereof, and Maker hereby voluntarily condemns the same and authorizes the
entry of such voluntary condemnation on any writ of execution issued thereon, and agrees
that such real estate may be sold upon any such writ in whole or in part in any order
desired by Payee.
Maker waives presentment for payment, demand, notice of nonpayment, notice of
protest and protest of this Note, and all other notices in connection with the delivery,
acceptance, performance, default or enforcement of the payment of this Note, and he
agrees that his liability shall be unconditional without regard to the liability of any other
party and shall not be in any manner affected by an indulgence, extension of time,
renewal, waiver or modification granted or consented to by Payee; and maker consents to
any and all extensions of time, renewal, waiver or modification granted or consented to
by Payee with respect to the payment or other provisions of this Note, and to the release
of any property now or hereafter securing this Note with or without substitution, and
agrees that additional makers, endorsers, guarantors or sureties may become parties hereto
without notice to him or affecting his liability hereunder.
Payee shall not by any act of omission or commission be deemed to have waived
any of its rights or remedies hereunder unless such waiver be in writing and signed by
Payee, and then only to the extent specifically set forth therein; a waiver on one (1) event
shall not be construed as continuing or as a bar to or waiver of such right or remedy on a
subsequent event.
If any provision hereof is found by a court of competent jurisdiction to be
prohibited or unenforceable, it shall be ineffective only to the extent of such prohibition
or unenforceability, and such prohibition or unenforceability shall not invalidate the
balance of such provision to the extent it is not prohibited or unenforceable, nor
invalidate the other provisions hereof, all of which shall be liberally construed in favor of
Payee in order to effect the provisions of this Note.
The words "Payee" and "Maker" whenever occurring herein shall be deemed and
construed to include the respective successors and assigns of Payee and Maker. This
instrument shall be construed according to and governed by the laws of the
Commonwealth of Pennsylvania.
THIS NOTE SETS FORTH A WARRANT OF AUTHORITY FOR AN
ATTORNEY TO CONFESS JUDGMENT AGAINST THE MAKER. IN GRANTING
THIS WARRANT OF ATTORNEY TO CONFESS JUDGMENT AGAINST THE
MAKER, THE MAKER HEREBY KNOWINGLY, INTENTIONALLY AND
VOLUNTARILY UNCONDITIONALLY WAIVES ANY AND ALL RIGHTS THE
MAKER HAS OR MA Y HAVE TO PRIOR NOTICE AND AN OPPORTUNITY FOR
HEARING UNDER THE RESPECTIVE CONSTITUTIONS AND LAWS OF THE
UNITED STATES AND THE COMMONWEALTH OF PENNSYL VANIA. THE
MAKER FURTHER REPRESENTS THAT THIS DEBT IS IN CONNECTION WITH A
BUSINESS TRANSACTION, AND THAT MAKER HAS HAD THE OPPORTUNITY
TO BE REPRESENTED BY LEGAL COUNSEL IN CONNECTION HEREWITH.
IN WITNESS WHEREOF, Maker has duly executed this Note as of the day and
year first above mentioned.
WITNESS:
~~~
Vl,71;C7-
DISCLOSURE FOR CONFESSION OF JUDGMENT
I AM EXECUTING, THIS .~ 7 r& DAY OF 1\1 ~W 'lLlu r/ , 2002, A PROMISSORY NOTE
FOR $750.00 OBLIGATING ME TO REPAY THAT AMOUNT,
A, I UNDERSTAND THAT THE NOTE CONTAINS A CONFESSION OF JUDGMENT PROVISION
THAT WOULD PERMIT PAYEE TO ENTER JUDGMENT AGAINST ME IN COURT, AFTER A
DEFAULT ON THE NOTE, WITHOUT ADVANCE NOTICE TO ME AND WITHOUT OFFERING
ME AN OPPORTUNITY TO DEFEND AGAINST THE ENTRY OF JUDGMENT, IN
EXECUTING THE NOTE, BEING FULLY A WARE OF MY RIGHTS TO ADVANCE NOTICE
AND TO A HEARING TO CONTEST THE VALIDITY OF ANY JUDGMENT OR OTHER
CLAIMS THAT PAYEE MAY ASSERT AGAINST ME UNDER THE NOTE, I AM KNOWINGLY,
INTELLIGENTLY, AND VOLUNTARILY WAIVING THESE RIGHTS, INCLUDING ANY
RIGHT TO ADVANCE NOTICE OF THE ENTRY OF JUDGMENT, AND I EXPRESSLY AGREE
AND CONSwAYEE'S ENTERING JUDGMENT AGAINST ME BY CONFESSION AS
PROVIDED F HE CONFESSION OF JUDGMENT PROVISION,
INITIALS:
B, I FURTHER UNDERSTAND T.f\IAT IN ADDITION TO GIVING PAYEE THE RIGHT TO ENTER
JUDGMENT AGAINST ME WITHOUT ADVANCE NOTICE OR A HEARING, THE
CONFESSION OF JUDGMENT PROVISION IN THE NOTE ALSO CONTAINS LANGUAGE
THAT WOULD PERMIT PAYEE, AFTER ENTRY OF JUDGMENT, TO EXECUTE ON THE
JUDGMENT BY FORECLOSING UPON, ATTACHING, LEVYING ON, TAKING POSSESSION
OF OR OTHERWISE SEIZING MY PROPERTY, IN FULL OR PARTIAL PAYMENT OF THE
JUDGMENT. HOWEVER, PAYEE MUST PROVIDE NOTICE TO ME UNDER APPLICABLE
LAW IN EXECUTING ANY CONFESSED JUDGMENT, IN EXECUTING THE NOTE, BEING
FULLY A WARE OF MY RIGHTS TO ADVANCE NOTICE AND A HEARING AFTER
JUDGMENT IS ENTERED AND BEFORE EXECUTION ON THE JUDGMENT, I AM
KNOWINGLY, INTELLIGENTLY AND VOLUNTARILY WAIVING THESE RIGHTS, AND I
EXPRESSLY AGREE AND CONSENT TO PAYEE'S EXECUTING ON THE JUDGMENT, IN
ANY MANNER PERMITTED BY APPLICABLE STATE AND FEDERAL LAW,
INITlALS:~
C. I WAS ~~~NTED BY MY OWN INDEPENDENT LEGAL COUNSEL IN
CONNECTION WITH THE NOTE OR CHOSE TO NOT HAVE INDEPENDENT LEGAL
ADVICE,
~
INITIALS:
AFFIANTS:
TA
(SEAL)
COMMONWEALTH OF PENNSYLVANIA :
SS
COUNTY OF CUMBERLAND :
~ N oi~if
On this, the;;.1 day of D~, 2002, before me, the undersigned officer,
~~
personally appeared TANYA 0 , known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that she
executed same for the purposes therein contained.
IN WI1NESS WHEREOF, I hereunto set my hand and official seal.
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NOTARY PUBLIC
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GRIFFIE & ASSOCIATES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: CIVIL ACTION - LAW
TANYA VASQUEZ,
Defendant
: NO. 03-1091
: JUDGMENT
CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
To satisfy the judgment, interest and costs against Defendant, Tanya Vasquez, 2900
Pineford Drive, Middletown, Dauphin County, directing them to levy upon the property of the
Defendant and to sell her interest therein, said property to include, any and all household
furnishings, furniture, appliances, tools, motor vehicles, and any and all other personal property
of any nature located at 2900 Pineford Drive, Middletown, Dauphin County, Pennsylvania.
Total amount due and to be collected is as follows:
Principal amount due: .........................................,.......... $750,00
Interest from: 11/27/02 to 11/27/04 (12%)..................... 180,00
Interest from 11/27/04 to date of sale to be added..,............ *
Attorney's fees.......,.....................,................................... 112,65
Cost for filing Praecipe for Write of Execution................. 26.00
Sheriff s Cost.".".................,.,.""".,......................,.,.".", 150.00
Cost of filing Judgments................,..........................,......., 19.50
TOTAL: ...................................,.................... $ 1,238,15*
* To be added
Respectfully submitted,
:J/lt/uS
Date .
.' )1;t CuU{.cw. )1J\ ~ ~
~litas, Esquire
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
Supreme Court ID # 84919
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N003-1091 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF DAUPffiN COUNTY:
To satisfy the debt, interest and costs due GRIFFIE & ASSOCIATES Plaintiff (s)
From TANYA VASQUEZ
(I) You are directed to levy upon the property of the defendant (s)and to sell Any and all household
furnishing, furniture, appliances, tools, motor vehicles, and any and all other personal property of
any nature located at 2900 Pineford Drive, Middletown, Dauphin County, Pennsylvania.
(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 gamishee(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 deliv,ering 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$750,OO
Interest 11/27202 to 11/27/04 (12%) $180.00
11/27/2004 to date of sale to be added
Arty's Comm$112.65
Arty Paid $52.00
Plaintiff Paid
Date: March 7, 2005
L.L.$0.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
ProthO~ d"
. By: H~, IfJ? ~ . o/j
Deputy
REQUESTING PARTY:
Narne Marylou Matas, Esq.
Address: Griffie & Associates
200 North Hanover Street
Carlisle P A 17013
Attorney for: Plaintiff
Telephone: 717-243-5551
Supreme Court ID No. 54919
, TRUE COpy FROM RECORD
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GRIFFIE & ASSOCIATES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: CIVIL ACTION - LAW
T ANY A VASQUEZ,
Defendant
: NO. 03-1091
: JUDGMENT
CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
To satisfy the judgment, interest and costs against Defendant, Tanya Vasquez, 2900
Pineford Drive, Middletown, Dauphin County, directing them to levy upon the property of the
Defendant and to sell her interest therein, said property to include, any and all household
furnishings, furniture, appliances, tools, motor vehicles, and any and all other personal property
of any nature located at 246 East North Street, Carlisle, Cumberland County, Pennsylvania,
Total amount due and to be collected is as follows:
Principal amount due: .................................................... $750.00
Interest from: 11/27/02 to 11/27/04 (12%).....................180.00
Interest from 11/27/04 to date of sale to be added"............. *
Attorney's fees.................................................."............. 112,65
Cost for filing Praecipe for Write of Execution................. 26.00
Sheriffs Cost........................................................,....,..,.. 150,00
Cost of filing Judgments......,..................,............."........... 19.50
TOTAL: ....................................,..,..........."... $ 1,238.15*
* To be added
Respectfully submitted,
3/4/ (i'5-
Date'
/(1/ {)J, G<< III ck
M atas, Esquire
Attorneylor Plaintiff
GRIFFIE & ASSOCIATES
Supreme Court ID # 84919
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N003-1091 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GRIFFIE & ASSOCIATES Plaintiff (s)
From TANYA VASQUEZ
(I) You are directed to levy upon the property of the defendant (s)and to sell Any and all household
furnishing, furniture, appliances, tools, motor vehicles, and any and all other personal property of
any nature located at 246 East North Street, Carlisle, Cumberland County, Pennsylvania.
(2) You are also directed to attach the property of the defendant(s) not Ilevied 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 0' for the account of the defendant (s) and from deli..,ring 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 hirnlber that helshe has been added as a
garnishee and is enj oined as above stated.
Amount Due$750,OO
Interest 11/27202 to 11/27/04 (12%) $180.00
11/27/2004 to date of sale to be added
Ally's Comm$112,65%
Ally Paid $52.00
Plaintiff Paid
Date: March 7, 2005
L.L.$0.50
Due Prothy $1.00
Other Costs
(Seal)
CURTIS R. LONG
:~~wa lf~'~!fJ
Deputy ,
REQUESTING PARTY:
Name Marylou Matas, Esq.
Address: Griffie & Associates
200 North Hanover Street
Carlisle P A 17013
Attorney for: Plaintiff
Telephone: 717-243-5551
Supreme Court ID No. 54919
This
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff s Costs:
Oocketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Surcharge
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage
TOTAL $
18.00
.88
.50
1.00
3.70
20.00
.74
44,82
Sworn and Subscribed to before me
This 1 day of C?p",.l
2005 A'O'f J.~./ ~L.-")'tJ _~-
Prothonotary <TT'"V
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Advance Costs:
Sheriffs Costs:
150.00
44.82
$ 105.18
Refunded to Atty on 03129/05
~~~
R. Thomas Kline, Sheriff
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\....... 0U1.~ ~t:lt
By Claudia A. Brewbaker
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N003-1091 Civil
CIVIL ACTION ~ LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GRIFFIE & ASSOCIATES Plaintiff(s)
From TANYA VASQUEZ
(1) You are directed to levy upon the property of the defendant (s)and to sell Any and all household
furnishing, furniture, appliances, tools, motor vehicles, and any and all other personal property of
any nature located at 246 East North Street, Carlisle, Cumberland County, Pennsylvania.
(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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or lor the account of the defendant (s) and frorn 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 narned garnishee, you are directed to notify him/her that helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due$750.00
Interest 11/27202 to 11/27/04 (12%) $180.00
11/27/2004 to date of sale to be added
Atty's Comm$112.65%
Atty Paid $52.00
Plaintiff Paid
Date: March 7, 2005
L.L.$0,50
Due Prothy $1.00
Other Costs
(Seal)
CURTIS R. LONG
Prothono~ ~ rrk. I, t Jt4
By: -/(j)'v"'hA 1f1 . M A :
Deputy .
REQUESTING PARTY:
Name Marylou Matas, Esq.
Address: Griffie & Associates
~
200 North Hanover Street
Carlisle P A 17013
Attorney for: Plaintiff
Telephone: 717-243-5551
Supreme Court lD No. 54919
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA - CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
vs.
: ( ) Confessed Judgment
: (X) Other
: File No. 03-1091 CIVIL TERM
: Amount Due $750.00
: Interest $251.75
: Atty's Comm $112.65
: Costs
GRIFFIE & ASSOCIATES,
Plaintiff
TANYA VASQUEZ,
Defendant
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail
installment sale, contract, or account based on a confession of judgment, bit if it does, it
is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County,
for debt, interest and costs, upon the following described property of the defendant:
Including. but not limited to. household furnishings. furniture. appliances. tools. motor
vehicles. recreational vehicles and any other personal property of any nature located at
101 Texaco Road. Mechanicsburg, Cumberland County. Pennsvlvania.
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for
debt, interest and costs, as above, directing attachment against the above-named
garnishee(s) for the following property (if real estate, supply six copies of the
description; supply four copies oflengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said
gamishee(s).
_ (Indicate) Index this writ against the garnishee(s) as a lis pendens against real
estate of the defendant(s) described in the attached exhibit.
DATE:
qUI/D>
,
e Es uire
anover Street
lisle. P A 17013
Attorney for: Plaintiff
Telephone: (717) 243-5551
Supreme Court ID No,: 34349
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-1091 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GRIFFIE & ASSOCIATES Plaintiff(s)
From TANYA VASQUEZ, 101 TEXACOROAD,MECHANICSBURG PA 17055.
(1) You are directed to levy upon the property of the defendant (s)and to sell INLCUDING BUT
NOT LIMITED TO HOUSEHOLD FURNISHINGS, FURNITURE, APPLIANCES,
TOOLS, MOTOR VEHICLES, RECREATIONAL VEHICLES AND ANY OTHER
PERSONAL PROPERTY OF ANY NATURE .
(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 frorn
paying any debt to or for the account ofthe 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 narned garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $750.00
Interest $251.75
1.1.
Atty's Comm
AtIy Paid $94.32
Plaintiff Paid
Date: SEPTEMBER 22,2005
% $112.65
Due Prothy $1,00
Other Costs
rJud!f(~
CURTlsu::iONG Y
Prothonotary
By:
(Seal)
Deputy
REQUESTING PARTY:
Name BRADLEY L. GRIFFIE ESQ,
Address: 200 N. HANOVER ST,
CARLISLE PA 17013
Attorney for: PLAINTIFF
Telephone: (717) 243-5551
Supreme Court ID No. 34349
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months,
Sheriffs Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Mise,
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
TOTAL
18.00
,97
1.00
8,80
20,00
.37
49.14 / cr {,J3l>/ o~
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Advance Costs: 150,00
Sheriffs Costs 49,14
100,86
Refunded to Atty on 06/29/06
So Answers;
~~Jrt:~/i
R. Thomas Kline, Sheriff
By CO I..lLlr.i'k-B:i'\oJJJbcJ- r
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WRIT OF EXECUTION and/or A TT ACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-1091 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GRIFFIE & ASSOCIATES Plaintiff(s)
From TANYA VASQUEZ, 101 TEXACO ROAD, MECHANICSBURG PA 17055.
(1) You are directed to levy upon the property of the defendant (s)and to sell INLCUDING BUT
NOT LIMITED TO HOUSEHOLD FURNISHINGS, FURNITURE, APPLIANCES,
TOOLS, MOTOR VEHICLES, RECREATIONAL VEHICLES AND ANY OTHER
PERSONAL PROPERTY OF ANY NATURE .
(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) Ifproperty 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 $750.00
Interest $251.75
Atty's Comm % $112.65
Atty Paid $94.32
Plaintiff Paid
L.L.
Due Prothy $1.00
Other Costs
Date: SEPTEMBER 22, 2005
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Prothonotary
By:
(Seal)
Deputy
REQUESTING PARTY:
Name BRADLEY L. GRIFFIE ESQ.
Address: 200 N. HANOVER ST.
CARLISLE PA 17013
Attorney for: PLAINTIFF
Telephone: (717) 243-5551
Supreme Court ID No. 34349