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TRACY SPRINGBR
) IN TilE COUR1' OF COMMON PLEAS OF
) CUMBERLAND COUNTY, PENNSYLVANIA
)
)
) CIVIL ACTION - LAW
)
)
) NO: 98-4483 CIVIL TERM
)
)
)
Plaintiff
VS.
ROBERT WESTOVER
Defendant
PRAECIPE TO ENTER DEFAULT JUDGMENT
Kindly enter judgment in the amount of $3,950.00, plus record
'"
costs in the amount of G4~ ~o, plus $740.00 for storage at $10.00
. nO 00-
per day since July 4, 1998, for a total of $4,~.gO plus interest
in favor of the Plaintiff Tracy springer and against the Defendant,
Robert Westover, Defendant has failed to file an Answer to
Plaintiff's Complaint within the required time pursuant to the
pennsyl vania Rules of civil Procedure. A Certificate of Service of
the Complaint is filed and is of record. An Important Notice of
Default, a copy of which is attached hereto as "Exhibit A", was
mailed to Defendant on August 27, 1998 at his address at 3800-C
Elrnerton Avenue, Harrisburg PA 17109.
Gregory . Katshir, Esquire
Attorney for Plaintiff
PA ID # 61967
900 Market street
Lemoyne PA 17043
(717) 763-8133
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VB.
) IN TH~ COURT OF COMMON PLEAS OF
) CUMB~RLAND COUNTY, PENNSYLVANIA
)
) CIVIL ACTION - LAW
)
) NO. 98-4483 CIVIL TERM
)
TRACY SPRINGER
plaintiff,
ROBERT WESTOVER,
Defendant.
IMPORTANT-HOTICE OF DEFAULT
TO: Robert Westover
3800 - C Elmerton Avenue
Harrisburg PA 17109
Date of Notice:
August 27, 1998
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED
OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT
A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
FOLLOWING OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Cumberland County Bar Association
Lawyer Referral Service
2 Liberty Avenue
Carlisle PA 17013
Telephone: (717) 249-3
By
Gregory atshir, Esquire
Attorney for Plaintiff
PA lOll 61967
900 Market Street
Lemoyne PA 17043
(717) 763-8133
cyU,i Ii-
TRACY E. SPRINGER
Plaintiff
I II Till'; COURT 01,' CO~lMON PLEl\S OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 9f-l/l/q] e"w:!
ROBERT WESTOVER
Defendant
CIVIL ACTION - LAW
I,.
~.
VS.
I I
TO: DEFENDANT
NOTICE TO DEFEND
You have been sued in Court. If you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this complaint and notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be
entered against you by the court without further notice for any
money claimed in the complaint or for any other claim or relief
requested by the plaintiff.
You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumber1and County Bar Association
Lawyer Referra1 Service
2 Liberty Aven.l1e
Car1is1e PA 17013
Telephone: (717) 249-3166
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TRACY K SPRINGER
Plaintiff
: IN Tl-IE COURT OF COMMON PLgAS OF
: CUMBERLAND COUNTY, pgNNSYLVANIA
: NO: 9 i _ 'I 'I S'_~ 6~:J "'0.<_
VS.
ROBERT WESTOVER
Defendant
: CIVIL ACTION - LAW
COMPLAINT
AND NOW, comes Plaintiff, Tracy E. Springer, by and through his attorney,
Gregory J. Katshir, Esquire, with the following Complaint and avers as follows:
1. Plaintiff, Tracy E. Springer, is an adult individual residing at 411 Hillside
Road, New Cumberland, Cumberland County, Pennsylvania.
2. Defendant, Robert Westover, is an adult individual residing at 3800-C
Elmerton Avenue, Dauphin County, Pennsylvania.
3, On or about July 1996, Plaintiff and Defendant entered into a verbal
pal'tnership agreement. The agreement provided for, inter alia, the formation
of Springer RacinglWestover Motorsports, whereby Plaintiff and Defendant
became co-owners, Springer RacinglW estover Motorsports was a car racing
team that participated in limited late model racing at Silver Springs Speedway,
Cumberland County, Pennsylvania from 1996 until the end of the 1997 racing
season.
4, On or about March 2, 1998, Plaintiff and Defendant entered into a contract that
provided that Defendant would purchase, from Plaintiff, any and all of
Plaintiffs intcrcHt in SprinJ.:cr HacinJ.:/WcHtovcr MotorHpol.ts (tH' thc Hum of
$8,000.00. PurHuant to thc contl'llct, PlaintiffwaH to rclinquish any lInd all
intcrcst in thc pllrtncrshipand racc tcam. Pursuant to thc contract, Dcfcndant
was to rctainall parts, componcnts and misccllancous tools, but for a fcw
specifically listcd items that would be retained by Plaintiff. A copy of thc
contract is attached hereto and identiJicd as "Exhibit A",
5, Defendant was to pay Plaintiff by way of an initial installment of $2,000.00 on
March 7, 1998 and six (6) subsequent monthly installments of $1,000,00,
However, in the event that Plaintiff had not yet repaid a personal loan to
Defendant by the time the sixth and final payment was due, the final payment
was to be $150.00.
6. Pursuant to the contract, the items were either delivered to Defendant by
Plaintiff, or obtained by Defendant,
7, A truck and trailer were items that were included as "all parts, components and
miscellaneous tools". Although not specifically mentioned in the contract, titles
to the truck and trailer were to be transferred from Plaintiffs name into
Defendant's name, Plaintiff attempted, on numerous occasions, to meet with
Defendant to transfer the titles, however, Defendant was never available to
effectuate the transfer,
8. PlII'l'luant to the contract, Dcfendllnt tendered t he first monthly installment
payment of $2,000.00 to Plllintiffon March 7, W!J8.
9. On or about, April 3, l!HJ8, Defendant delivered a letter to Plaintiff indicating
thut he "must regretfully rescind the previously written agreement". Said
letter is attached hereto ami identified 111'1 "Exhibit B". Additionally, Defendant
parked the truck ami trailer in a shopping center parking lot. Since the truck
was still titled to Plaintiff, Plaintiff had to retrieve the truck and trailer.
Defendant has, however, retained all other items ofpurts, components and
miscellaneous tools that wel'C sold to him.
10. Subsequent to April 3, 1998, Plaintiff sold the trailer, with the express
permission of Defendant, for $1,200.00.
11. Defendant has failed and refused after repeated requests to make the
remaining payments to Plaintiff as per the March 2, 1998 contract,
12, Defendant continues to utilize the items sold to him by Plaintiff in another
race car venture.
13.Since July 1998, Plaintiff has been forced to pay a daily storage charge of
$10.00 for the truck that was purchased and returned by Defendant,
14, Defendant has acknowledged to Plaintiff that he is responsible for the payment,
however he refuses to pay. Defendant indicted that he will pay Plaintiff after
the mntter has proceeded to Court beclIuse be wishes PlaintifT to spend his time
nnd to incur atto1'lley's fees.
15. Plaintiff sold the trailer for $1,200.00 IInd has an outstanding loan with
Defendant in the amount of $850.00.
COUNT I - BREACH OF CONTRACT
16. Paragraphs 1 through 14 arc incorporated herein by reference as if the
same were set forth in detail.
17. Defendant has willfully breached his contractual obligations pursuant to the
March 2, 1998 contract between Plaintiff and Defendant by failing and refusing
to pay the remaining balance due to Plaintiff of $6,000,00,
18,Additionally, due to Defendant's willful breach of the contract, Plaintiff has
been forced to incur storage fees for the truck purchased and retu1'lled by
Defendant. Said fee is continuing per diam,
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against
Defendant in an amount not to exceed $25,000,00, together with interest, costs of
suit and attorney's fees,
COUNT II - ATTORNEYS FEES
19. Paragraphs 1 through 18 are incorporated herein by reference as if the same
were set forth in detail.
20. Defendant's conduct in indicating to Plaintiff that he would pay Plaintiff what
April 3, 199B
Mr. Tracey E, Springer
411 Hillside Drive
New Cumberland, Pa.
Mr. Springer:
We have previously negotiated terms of agreement for
the sale of the assets of the joint partnership of Springer
Racing/Westover Motorsports to be conveyed to Robert M.
Westover Jr. for the sum of $8,000,00, To date, the terms of
the agreement have not been satisfied, Specifically, the
titles to the tow package (Step-van and trailer) have not
been conveyed to Westover Motorsports, nor have the points
of contacts been provided for the anticipated receivables
for the 1997 and 199B racing seasons, Despite numerous
attempts at satisfying the conditions of the agreement, the
terms remain unsatisfied. The terms of the agreement have
been breached. Therefore, I must regretfully rescind the
previously signed agreement, and dissolve the previous
partnership in the following manner:
Sale Price:
Less Step Van Value
Less Trailer Value
Less Previous Cash Payments:
Less Previous Unpaid Personal Loans:
Less Pizza Land receivables (1997)
Less Pet's Plus receivables (1997)
Less Prorated Batteries Plus receivables(1997):
Less Batteries Plus receivables (199B)
Total
$B,OOO,OO
-$1,000.00
-$3,500,00
-$2,000.00
-$850.00
-$300.00
-$400.00
-$250.00
-$500.00
-$850.00
The Step Van and trailer have been returned to ACME
Trailer Works, the keys for which you will find enclosed
herein. As you can see, the aforementioned schedule
satisfies all financial commitments as per the agreed upon
sale price, Moreover, a credit in the amount of $350.00 is
due Westover Motorsports for the 1997 racing season, and an
additional credit in the amount of $500.00 is due in the
amount of $500,00 for the 199B racing season. Please remit a
check in the amount of $850.00, payable to Westover
Motorsports.
Should you have any questions or desire additional
information, please contact me at your convenience,
Very Truly Yours,
~ 10/ /1M.
Robert M. Westover Jr.
imIIBIT B
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'"
<,
TRACY SPRINGER
) IN 'l'HE COURT OF COHHON PLEAS
) CUMBERLAND COUNTY, PENNSYLVANIA
)
) NO: 98-4483 CIVLI TERM
)
)
) CIVIL ACTION - LAW
)
)
)
Plaintiff,
VS.
ROBERT WESTOVER
Defendant.
;4n~w e 1"'5' -INTERROGATORIES IN AID OF EXECUTION /GARNISHMENT
TO: Robert Westover
3800-C Elmerton Avenue
Harrisburg PA 17109
AND NOW, comes Plaintiff, by and through his attorney,
Gregory J, ICatshir, Esquire, and propounds the fOllowing
interrogatories to the Defendant requesting that the Defendant
answer in accordance with the Pennsylvania Rules of civil
Procedure fully and completely under oath within thirty (30) days
from the date of service hereof. Failure to answer in a timely
manner may result in the issuance of a contempt citation.
1. Real Estate. State whether you have a legal or equitable
ownership interest in any real estate located anywhere in the
United States?
ANSWER:
YES
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tion of 5UC~ docum~nt of titl~, including volum~ and
pdg'1 numb~r;
ANSWER:
See I>xhibit ^
'1. T~'1 pr'1s'1nt valu'1 of your '1quity int'1r'1st in t~'1
,Prop'1rty;
Approximtely $20,000.00
ANSWER:
f. T~'1 dat'l and amount of any mortgag'1, t~'l stat'1 and
county of r'1cordation, t~'l montMly paym'lnts (s'ltting
foct~ pcincipal, int'lc'lst, as w'lll as c'1al '1stat'l
tax'1S and insucanc'1 '1scrows,) and t~'l balanc'l now
du~;
ANSWER:
The property is not encumbered.
3. Agc'l'lm'lnts. Stat'l w~'lt~'1r you' ac'l pC'ls'lntly a pacty to
any agc'1'1m'lnt involving t~'l pUcc~as'1 oc sal'1 of any r'1al prop'1rty:
ANSWER:
No
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d, T~~ d~t~ on ~~ic~ ~ac~ bond, 5~~C~, 5toc~ c~cti(i-
c~t~ oc ot~~c 5imil~c intQCQ5t ~~5 ~cqui'Qd by you;
ANSWER:
See Exhibit C
Q. Ho~ Qac~ bond, sMdr~, stoc~ c~'tificdt~ or otM~c
"
int~r~st ~as acquir~d by you (wh~t~~r by purchas~,
gift oc ot~qC mqans) ;
ANSWER:
Purchase
Eo
T~~ nam~ and pr~sqnt addc~ss of qach pqrSOn, firm or
corporation from whom ~ac~ bond, shar~, stoc~
cqrtificatq or othqr intqrqst was acquir~d,
rqgacdlqss of mod~ of acquisition;
ANSWER:
Unknown
g. Thq nam~, pc~s~nt addrqss and t~18phon~ numb~r of
any p~rson, firm or corporation wit~ whom you sharq,
undqr any form of joint ownqrship or community
intqrqst, any d~gr~~ of o~n~rsMip or control of
any of th~ abov~ s~cucitiqs;
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AlliiliER :
Pamela 11. Killli
GOD Jrd strcet Juniata
^l tOOllil, Pcnlla. 16GOl
h. whother you are presently are indebted to or owe any
money to any individual or business entities for the
purchase of securities and if so, state to whom and
the amount of the indebtedness.
ANSWER:
E-Trade holds the margin balance of $2,338.00
as of 10/15/96.
9. Accounts,
saving accounts or
for anyone else'?
state whether you maintain any checking or
any accounts which you are holding in trust
ANSWER:
Yes
10. If the answ~r to interrogatory No. 9 is yes, for each
account , state:
a. Where the account is located;
^NSWER:
Checking and savings account
Pennsylvania state Employees Credit Union
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b. Und~r w~at nam~ or nam~s qac~ account is ~~ld;
ANSWER:
Robert M. Westover Jr.
c. T~~ nam~ of t~~ bdn~ and branc~ ~olding ~ac~
account;
ANSWER:
Pennsylvania State Employees Credit Union
d.
T~~ id~ntification numb~r of ~ac~ account;
ANSWER:
0179483207
~.
T~~ balanc~ of ~ac~ account;
ANSWER:
Checking: $1,327.14 as of 10/15/98
Savings: $1,564.84 as of 10/15/98
tl.
Saf~ D~posi t BOl(.
Stat~ wl1~tl1~r you maintain or l1av~
acc~ss to any saf~ d~posit bOl( or ot~~r d~pository for s~curiti~s,
cas~ or ot~~r valuabl~s?
ANSWER:
No
l2. If t~~ answ~r to int~rrogatory No. II is y~s for
~ac~ d~pository, stat~:
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~. T~~ nam~ and pr~s~nt addr~ss of ~ac~ individual or
busin~ss ~ntity to ~~om t~~ d~pository is r~nt~d or
l~as~d;
ANSWER:
b. T~~ nam~ and pr~s~nt addr~ss of t~~ ban~ and branc~
~~~r~ t~~ d~pository is locat~d;
ANSWER:
c. T~~ id~ntification numb~r or ot~~r d~signation of
t~~ bOK or bOK~S;
ANSWER:
d. T~~ nam~ and pr~s~nt addr~ss of ~ac~ individual
~aving acc~ss to t~~ d~pository;
ANSWER:
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.. A d.scription of t~. prop.rty contain.d in th.
d.pository, incLuding t~. amount of cash;
ANSWER:
f. Th. dat. you Last .nt.r.d .ach d.pository.
ANSWER:
L3. Stat. wh.th.r any of th. cont.nts of .ach of th. aboll.-
m.ntion.d d.positori.s w.r. mOIl.d during th. past y.ar?
ANSWER:
L4. If th. answ.' to in t.rroga tory No. L3 is y.s, for .ach
it.m r.moll.d, stat.:
a. A d.scription of th. prop.rty r.moll.d;
ANSWER:
b. Th. .xact dat. of .ach r8mollal;
ANSWER:
c. Th8 r8ason for 8ach r8mollal;
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ANSWER:
d. T~~ nam~ and pr~s~nt addr~ss of ~ac~ p~rson w~o
r~mov~d ~ac~ it~m;
ANSWER:
~. T~~ nam~ and pr~s~nt addr~ss of ~ac~ p~rson, or
busin~ss ~ntity to w~om t~~ prop~rty was conv~y~d,
d~liv~r~d or transf~rr~d.
ANSWER:
LS. Lawsuits. Stat~ w~~t~~r you ar~ pr~s~ntly involv~d as a
party in any lawsuits (otf)~r t~an tl1~ instant action). Includ~ any
and all actions now in Court or in tl1~ proc~ss of pr~paration for
Court or in tl1~ n~90tiation stag~ and supply tl1~ nam~s and pr~s~nt
addr~ss of all parti~s, individuals or busin~ss ~ntiti~s involv~d
or to b~ involv~d; tl1~ facts and issu~s involv~d or to b~ involv~d;
tl1~ amount or amounts claim~d; tl1~ nam~ and pr~s~nt addr'O!ss of ~ac~
l~gal r~pr~s~ntativ'O! of ~ac~ party; tl1~ Court or Courts in wl1icl1
~acl1 action is p~nding or is to b~ fil~d.
ANSWER:
Two claims pending against Mr. Tracy Springer. See
Exhibit B.
Claims to befiled with the District Justice.
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16. Business Equipment. State whether you own any business
equipment, including a full description of office equipment, any
any other items of property used in conjunction with the
operation of the business with full description, value and
present location. state also whether there ar.e any encumbrances
on that property; and if so, state the name and present address
of the encumbrance or lien holder; the date of the encumbrance or
lien; the original amount of the encumbrance or lien; the present
balance of the encumbrance or lien; and the transaction which
gave rise to the encumbrance or lien.
1.NSWER:
Various pieces of equipment associated with racing operation
too numerous to mention are located Dover, Pa.
The estimated value of the racing equipment is $15,000.00
There are no encumberances on the equipment.
17. Motor Vehicle. state whether you own any motor vehicle.
Include a full description of each motor vehicle including color,
model, serial number, vehicle identification number and license
plate number. Also, state whether each motor vehicle is owned
jointly with another; the exact name or names and address in
Which each motor vehicle is registered; the present value of each
motor vehicle; and the present address of location and place of
regular storage or parking. For each motor vehicle, state
whether said motor vehicle is encumbered, and if so, the name and
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20.
Transf~rs.
List all r~al ~stat'?, p'?rsonal prop'?rty,
stoc~s, bonds, cas~ and any ot~'?r ass~t or it'?m of valu~ w~ic~ you
~av~ transf~rr~d by gift or sold for l~ss tl,an its fair mar~~t
"
valu~ at any tim~ during tl,~ last ~ig~t (8) y~ars. List suc~ ass~t
transf~rr~d, its pr~s~nt location (or last ~nown location),
d~scription, Its approximat~ valu~, to w~om transf~rr~d, t~~
latt~r's r~lations~ip to you, t~~ consid~ration or amount r~c~iv~d
for suc~ transf~r, t~~ fair mar~~t valu~ at tim~ of transf~r and
t~~ fair mar~~t valu~ today.
ANSWER:
None
2L. Cr~dit or Financ~ Stat~m~nts: Hav~ you at any tim~ during
t~~ past fiv~ (5) y~ars giv~n a financial stat~m~nt or cr~dit
application to any ban~, corporation or p~rson or p~rson? If so,
attac~ a copy of ~ac~ sucl, docum~nt; list t~~ nam~ and addr~ss of
t~~ ban~, corporation or p~rsons to w~om giv~n; and provid~ a
compl~t~ ~istory, including dat~s, of your d~alings tl,~r~wit~.
ANSWER:
None that I can recall
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~. R~ntal Incom~. Stat~ wM~tM~r any of tM~ r~al ~stat~ you
own or Mav~ a dir~ct or indir~ct l~gal or ~quitabl~ int~r~st is
l~as~d. If so, stat~:
a. TM~ nam~ and ~r~s~nt addr~ss of ~acM individual,
individuals or busin~ss ~ntity to wMom ~ac~ ~arc~l
of r~al ~stat~ is l~as~d.
b. TM~ fac~ valu~ or amount of tM~ l~as~.
c. WM~tM~r said l~as~ is ~aid montMly, y~arly or
otM~rwis~.
d. W~~eM~r tM~ ~aym~nt is mad~ dir~ctly to you, and if
noe, stat~ t~~ nam~ and ~r~s~nt addr~ss to wMom tM~
~aym~nt is mad~.
~. WM~tM~r you ~m~loy any individual or busin~ss
~ntity to manag~ said r~al ~stat~ and if so, stat~
t~~ nam~ and ~r~s~nt addr~ss of all sucM individuals
and busin~ss ~ntiti~s.
ANSWER: Pamela M. Rani, 608 3rd Street,Juniata, Altoona
Pays $350.00 monthly. She pays gas,electric.
Other utilities are paid out of the rent money.
Rent is paid monthly to me. No others employed.
-.-............ .....
28. Employm~nt. Stat~ th~ nam~ and pr~s~nt addr~ss of ~ach
of your ~mploy~rs, your monthly salary or wag~ for ~ach ~mploym~nt.
Kindly attach a copy of your f~d~ral and stat~ p~rsonal and
busin~ss incom~ tax r~turns to th~s~ int~rrogatori~s.
ANSWER: Leon E Wintermyer, 220 Yocumtown Road
Etters, Pa. 17319
$40,000.00 annually
US Naval Reserves - $2,500.00 annually.
My Federal and state taxes have not been filed.as
Mr. Springer currently holds in excess of $4,000.00
of receipts applicable to my racing operations for
the 1997 calendar year. Appropriate extensions were
filed.
29. Busin~ss Own'lrshi Or Int~r~st in Busin~ss Pro ~ri;'.
Stat~ wh~th~r or not you own or ~av~ any int~r~st in any busin~ss
or busin~ss~s loca t~d anywh~r~ in th~ Uni ted S tat~s? I f so, for
~ach such busin~ss state:
a. its (th~ir) location (s) ;
b. its (their) r~gister~d place of business;
c. th'l nam'l5 oE any partn~rs or joint owners, their
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MADE the .~ 2.- I~ day of )/;.' (<-<,
in the year nineteen hundred and ninety-five (1995). 7
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ROBERT M. WESTOVER, single, of IIarrisburg, Pennsylvania
A. WESTOVER, single, of IIarrisborg, Pennsylvania, Grantors,
party of the first part:
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ROBERT M. WESTOVER of Harrisburg, Pennsylvania, Grantee,
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of the second part, WITNESSETH, That said part ie'<lf the first part, for and in consideration of Ibe
sum of ONE
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Dollars, lawful money of the United States of America, well and truly paid by the said party of the
second part 10 the said part ies of the first part, at and before the scaling and delivery of these
presents, the receipt whereof is hereby acknowledged, have granted, bargained,
sold, aliened, enfeoffed, released, conveyed and confirmed, and hy these presents do grant, bargain,
sell, alien, enfeoff, release, convey and confirm unto the said party of the second part, his
heirs and assigns,
ALL
THAT CERTAIN piece or part of the lot of ground with the
buildings and improvements thereon situate, located in the City of
cribed as follows:
BEGINNING at a point on the northeast side of
Third Street, distant, southeasterly 90.3 feet from the intersection
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" of the southeilnt nide of Seventh Avenue with the nnrthe[Jot nitle of
Third Street nntl in il noutlwant direction, II tli.ntolrlcl.' of 29,7 reet to
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Ii the northwes t line of S i.x th Alley:
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thence along dud upon tj(jid side of
said alley and in a northeast direction, a dintnnce of 25 feet to a
point;
thence in a northwest direction and parallel with said Third
Street, a distance of 29.7 feet to a point on line of land of Robert
J. Schultz:
thence along said Schultz land and in a southwest
direction, a distance of 25 feet to a point on the northeant side of
Third Street, the point and place of beginning and HAVING THEREON
ERECTED a 2~ story frame dwelling known and designated as Premises
608 Third Street, Juniata, Altoona, Pennsylvania.
BEING the same premises title to which became vested
~n Robert M. Westover and Mitzi A. Westover, husband and wife, by
deed of Robert W. Mock and Josephine C. Mock, husband and wife, dated
November 22, 1985, of record in Blair Coonty Deed Book Volume 1121 at
Page 602.
Robert M. Westover and Mitzi A. Westover were divorced
by Decree of the Court of Common Pleas of
a"~rl.""
County,
Pennsylvania to No. '/3'/8 So (<i')/ on the
11
day of
:r<if1l.10\,.,
19,'lJ
Since the time of said divorce, neither Robert M. Westover
nor Mitzi A. Westover has married.
To the best knowledge, information and belief of the
grantors, no hazardous waste is presently being disposed or has ever
been disposed on these premises.
Gibboney and Gibboney are the scriveners of this
deed and have not examined the title to the within described _premises.
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TOGETIIER wilh all and sinuular the tenemeuls, hereditaments 'lI1d appurtenances to the same
belonging, or in anywise apperlaining. and the rcvcr."iion .HHI reversions, remainder and remainders.
rents, issues and prufits thereof; ^NI> ^LSO all the estate, righi, title, interest, property, claim
and demaud wlHltsoever, hot h in law and equity, of the said pari :Lea of the first part, of, in, to or out of
the said premises, and e\'ery pari a'HI parcel thereof.
TO II^ VI: ^N/J TO 1101.1> the said premises. with all and singular the appurtenances, unto the s:lid
pari Y of the second pari, h is heirs and assigns, to and for the only proper use and
behoof of said pari Y of the second pari. h ia heirs and assigns forever.
^ND the said particB of the first pnrt, thcir
heirs. executors, and administnltors. do by these presents, covenant, grant and agree to and with
Ihe said pany of the second pan. his heirs and assigns, that they the said
parties of the first part, their
heirs. all amJ singular the hereditaments iJ nd premises herein ahove dcseri hed and granted, or mentioned
and intended so to be, with the appurtenances unto the s,lid pari y of the second pari, his
heirs and assigns, against Ihe said pan ies oflhe first pan and their heirs. and against all and
every other person or persons, wholllsoeyer, lawCully claiming or to claim the s.lIne or .IIlY part thereof.
shall and will, by Ihese presents, W^RR^NT ^ND FOREVER DEFEND.
IN WITNESS WIIEREOF.lhesaid part ies of the firsl part ha ve hereunto set their
handS 'IUd seals . the day and year firSI wriucnabove.
'2;
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Mitz~Westover
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CERTIFlC^TE OF I~ESfl)ENCE
I. hereby certify thai the precise residence of Ihe graJ1lee herein is as follows
3800C Elmerton Avenue CLu.:-~_ <L- ,c::
Harrisburg PA 17109
QIUIIIIlU11&{Ul'nlfl/ uf ll'l'11115UlulIlli:1 }
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On this, the 2 l.- '- day of /71 "Y"
the undersigned officer, personally appeared It"OBERT
1995 . before me
M. WESTOVER, single,
known to me (or satisfactorily proven) to be the person whose name is subscribed to the
within instrument, and acknowledged that he executed same for the pur~,osC' therein contained.
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IN WITNESS WHEREOF. I have hereunto set my hand and notaJi1'M:t;'.;.., seal.
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My commriSSi?n Expires __-.-:-,_
NOTARIIII, $EN. :" '
MElDA N. McC/l,UC.il-W., tio'!:,y PtMi ,
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WESIOVEJ< MOIOHSPOI<TS. 1!1:I1
EXPENSES. BY VENDOfl
VENDOR
AMOUNT COMMENTS
PAYMENT
BHIDGE SmEET AUTO
BRIDGE STREET AUTO
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3.1/ CAR PARIS
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CASH
CASH
6 CARL BILLETT
10 CARL BILLETT
310.00 STEERING RACK
600.00 CARBURA TOR
910001
CK 095
CK /05
/ CREMO'S :lG 1481TOOLS, SHOP I VAN CK 097
CUTLER CAMERA 24.95IPHOTOS CASH
21 G & BRACE COMP 404.0/ CAR PARTS CK /00
22 G & BRACE COMP 199.08 CAR PARTS CK /02
G & BRACE COMP 180.15 CAR PARTS
/84.501
11 MIKE NELSON JR 1.000.00 MOTOR CK 700
20 MIKE NELSON JR 900.93 MOTOR CK 700
1.900.931
2 MMI 089.00 RACE BODY CK091
3 MMI 45.00 CHASIS SCHOOL CK 092
5 MMI 1,48848 CAR PARTS CK 094
9 MMI 4.310./8 CAR PARTS/BODY CK 701
MMI 90.10 CAR PARTS CASH
12 MMI 047.21 CAR PARTS CK 721
13 MMI 134.99 CAR PARTS CK 723
14 MMI 40.88 CAR PARTS CK 720
10 MMI 354.31 CAR PARTS CK 733
1/ MMI 310.53 CAR PARTS CK 735
18 MMI 1.055.93 CAR PARTS CK /53
19 MMI 414.15 CAR PARTS CK /57
MMI 12/.20 TRANSMISSION REPAIR CASH
9,714.501
1 NAPA 30.231sTEP VAN PAINT CK 090
4 SUNSET TEES L 45.001TEAM SHIRTS CK 093
Speedwny Gmphics I 3941AUTOGRAPH CARDS Credit Cmd
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ROB~RT M WESTOVER JR
3800e EtHERTON AVE
HARRISBURG PA 17109
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3800e ElMERTON AVE
HARRISBURG PA 17109
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Plaintiff
) IN THE COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY, PENNSYLVANIA
)
) NO: 98-4483 CIVIL TERM
)
) CIVIL ACTION - LAW
)
)
)
TRACY SPRINGER
VS.
ROBERT WESTOVER
Defendant
RULE TO SHOW CAUSE
AND NOW, to-wit this
day of
1998, upon consideration of Plaintiff's Motion, it is hereby
ORDERED that a Rule is issued upon Defendant to show cause why
Defendant should not be required to answer the Interrogatories in
Aid of Execution/Garnishment served upon him, why sanctions
should not be imposed for failure to answer said Interrogatories
and why Defendant should not be required to pay Plaintiff's
reasonable counsel fees.
This Rule is returnable within 20 days of service.
BY THE COURT:
J.
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TRACY SPRINGER
) IN THE COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY, PENNSYLVANIA
)
) NO: 98-4483 CIVIL TERM
)
) CIVIL ACTION - LAW
)
)
Plaintiff
VS,
ROBERT WESTOVER
Defendant
MOTION FOR SANCTIONS
AND NOW comes plaintiff, Tracy springer, by and through
his attorney, Gregory J. Katshir, Esquire with the following
Motion for Sanctions, and avers as follows:
1. Plaintiff filed a civil Complaint against Defendant on
August 4,1998 to recover amounts owed pursuant to a contract
between the parties.
2. On september 16, 1998, Judgment was entered against
Defendant in the amount of $4735.50, plus interest. Judgment was
entered due to a failure of Defendant to timely file an Answer to
Plaintiff's Complaint.
3. On September 21, 1998, Plaintiff served Interrogatories
in Aid of Execution/Garnishment upon the Defendant, pursuant to
the pennsylvania Rules of civil Procedure.
4. Defendant has not answered the Interrogatories served
upon him as is required under Rule 4006 of the pennsylvania Rules
of Civil Procedure.
5. Defendant's conduct exhibits bad faith and exposes him
to liability for sanctions under Rule 4019 of the Pennsylvania
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Rulen of civil Procedure.
6. Defendant is unrepresented by counsol and has failed
and refused to respond to any correspondence and pleadings in
this matter.
WHEREFORE, Plaintiff respectfully requests that this
Honorable Court enter an Order requiring Defendant to answer the
Interrogatories in Aid of Execution/Garnishment within ten (10)
days and to pay to Plaintiff's counsel reasonable counsel fees
incurred in the preparation and prosecution of this Motion, or in
the alternative, issue a Rule to Show Cause upon Defendant to
show cause why Defendant should not be required to answer the
Interrogatories in Aid of Execution/Garnishment and why sanctions
should not be imposed for Defendant's failure to answer said
Interrogatories.
itted,
tshir, Esquire
r Plaintiff
PA 10 #61967
900 Market street
Lemoyne PA 17043
(717) 763-8133
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~IFICATION BY CO~HSEL
I am the attorney of record for the plaintiff.
1 verify that the statements made in this pleading are
true and correct to the best of my knowledge, information and
belief based upon my conversations with the plaintiff and the
information provided to me by the plaintiff. I understand that
false statements herein are made subject to the penalties of 18 Pa.
C.S. section 4904, relating to unsworn falsification to
Date:
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authorities.
Gregory J. atshir, Esquire
Attorney or plaintiff