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HomeMy WebLinkAbout01-2014 FX - ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND 09-3-04 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS "I IpEDORKO r LARRY & MARY 246 INDIAN CREEK DR MECHANICSBURG, PA 17055 L .J Mag. Dist. No.: OJ Name: Hon. THOMAS A. PLACEY Add"":104S. SPORTING HILL RD. MECHANICSBURG, PA V5. T",phO'" (717) 761- 8230 17050 DEFENDANT: NAME aod ADDRE55 IsEALOVER HOMES, INC. 145 BIG OAK RD DILLSBURG, PA 17019 L Docket No.: CV-0000508-00 Date Filed: 12/11/00 CROSS COMPLAINT 001 "1 SEALOVER, ,. VERNON R 145 :I:lIG OAK RD DILLSaURG, PA 17019 .J ,~' 11 'd THIS IS TO NOTIFY YOU THAT: Judgment: FOR PLAINTIFF [i] Judgment was entered for: (Name) FRnmnrn, T.l!.RRV Ii Ml!.RV [i] Judgment was entered against: (Name) llRl!.T.nVRR HnMRll, TNC_ in the amount of $ 'iq 17 on: (Date of Judgment) ".\ 1011/01 . . o Defendants are jointly and severally liable. o Damages will be assessed on: (Date & Time) O Amount of JudgmenlSubject to AttachmenVAct 5 of 1996 $ Amount of Judgment $ 34.17 Judgment Costs $ 25.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 59.17 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ o This case dismissed without prejudice, o Levy is stayed for days or 0 generally stayed. o Objection to levy has been filed and hearing will be held: Date: Place: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE . "" 'wJ$.1$Itf1r~gll!( OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PL.~\p,JtILJ?J~~~lf?N. YOU MUST INCLUDE A COpy OF THIS N E OF JUDG T NS RIPT FORM '#t~oUlfNOTI~SSl''1APPEAL. z:; ~... , . >;,.. 2 .' .' ~ J .,'~ ...., 'Distri6t ;)U~\ice 0-8'-0 t- Date I certify that this is a true a Date ~'," " " ; ...,-:.' - ~ ' ,," .' . correct copy of the record of the p oceedings',cg.titaining the judgn:l'enl..' \ ':7 '. ,:.:,,:'~' . :',. . , " : '.' Di.~trict Justice , , My commission expires first Monday of January, AOPC 315-99 '. :'';';.f~",/,;;,,\''.'" . 2004 SEAL ','-,"-~*- ~~ ~_. .' - ;' NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE' . , , PLAINTIFF: NAME and ADDRESS I IsEALOVER, VERNON R 145 BIG OAK RD DILLSBURG, PA 17019 L , 'I"',,"~' .. COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No.: 09-3-04 DJName: Hen. THOMAS A. PLACEY Add",,, 104S. SPORTING HILL RD. MECHANICSB~G, PA VS. DEFENDANT: NAME and ADDRESS 'FEDORKO r LARRY, ET AL. 246 INDIAN CREEK DR MECHANICSBURGr PA 17055 L Docket No.: cv- 0000508 - 00 Date Filed: 11/29/00 T"'pho"" (717) 761-,8230 17050 AT':fORNEYFOR PLAINTIFF : RICHARD G. SNELBAKERr ESQ. 44W.MAIN ST. MEqHANICSBURGr PA 17055 ~ - tl l' ~ THIS IS T9 1II0TIFYXOU ,THAJ: , Judgment: [i] Judgment was entered for: (Name)' ll'Rnn~"ll'nr Ml\.~V R 'lFOR DRPRIIlD1\.lI1T [i] Judgment was entered against: (Name) llRl\.T.OVRRr VRRNON R in the amount of $ (Date of Judgment) 'I InR In1 . nn on: D Defendants are jointly and severally liable, D Damages will be assessed on: (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total D This case dismissed without prejudice. D Amount of Judgment Subject to Attachment! Act 5 of 1996 $ Post Judgment Credits Post Judgment Costs D Levy is stayed for days or D generally stayed. Certified Judgment Total $ D Objection to levy has been filed and hearing will be held: .J I .J ..~.- ~ $ $ $ $ $ .00 .00 .00 .00 .00 $ $ ------------ ------------ " -'" " '. .'-.-,.", , .. --'- ., '. .. . ~'.,- , .--.,.- .. '. --..._''" .. "--. Date: Place: . Time: . ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUD9JJ1~~~FILING A NOTICE OF APPEAL WITH THE PROTHONOT ARY/CLERK OF THE COURT OF COMMON PL><~~~;j~,Q,~. YOU MUST INCLUDE A COPY OF THIS NO E OF JUDG TI NS RIPT FORM ~~~OCiR N(j'1'IGi(,9l"~PPEAL. 4 ~ ,~ "'" " ;" ~ '^' ! ..' 'i. "~ ~ ~. :: ' .....'oistrici.J\'Jstice 0-' 1- '. ::_, . ; ::~:' 2 '~ ., . """, J ,. 1'," ". I certify that this is a true a correct copy of the record of the p ceedings1::oFltaining the judgmllnt. c' .:!,.. ':'" - ,", : " . . . . . .. .. I3lsi~ct JUstice v" \' . " !i! Date Date ;QlflHl,l," , My commission expires first Monday of January, AOPC 315.99 2004 SEAL ~>- , ~ ,,' ,.",,~ ~I I, , I 1 ~ ...."~" , -= ~ ~~ ._-"""~'- ~ ' - '.' ;C__><'" CaMMON~EAL TH OF PENNSYLVANIA COURT OF COMMON PLEAS of Cumberland County JUDICIAL DISTRICT NOTICE OF APPEf\l > FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No.01-2014 Civil Term NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. N...ME OF ...,.,.EI.L...NT M4G. DI5T. NO. OR "....ME OF D.J. SEALOVER HOMES, mc. 09-3-04 Placey "'ODRESS OP ...PPELL...NT CITY STATE ZIP CODe: March 8, 2001 IN THIt C...SE OFIPldm,dIJ ~L.~ Fedorko, Larry & Mary PA 145 Big Oak Road O"-TE OF JUDGMENT CV 190000508-00 LT 19. SIGNATURE Snelb By: ;' CLAIM NO. This block will be signed ONLY wh'en this notatio'rl is recl'uired unde R.C.P.J.P. No, 10088. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgmE:nt for possession in this case. If was Claima,lJt (see, Pa. R.C.P.J.P. No. 1001(6) in action before District Justice, he MUST FILE A COMPLAINT. within twenty (20) days after filing his NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appellant was DEFENDANT (see Pa. R,C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED. detach from copy of notice of appeal to'beserved upon appellee). PRAECIPE: To Prothonotary x Larry Fedorko and Mary Fedorko Enter rule upon Name oi appellee(s) (Common Pleas No. 01-2014 Civil Tem ,appellee(s), to file a complaint in this appeal RULE: Tb Larry Fedorko and Mary Fedorko ) within twenty (20) da<:l>>~~g~W~~;;y ~pwfll!,;,e'l'.7!.non pros. Bv,=Richard C. Snelbaker. . Signature of appellant'or his attorney or agent Name of appellee(s) , appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal. within twenty (201 days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time. a JUDGMENT OF NON PROS WI LL BE ENTERED AGAINST YOU. (3) The date of service of this tule if service was by mail is the date of mailing. Date: April 6. 2,<w.1~01 AOPC 312-90 COURT FILE TO BE FILED WITH PROTHONOTARY e"';W~~ .~"_.,.,..-!IIlT _ I ' ,~ ~'I~ "JIWifll'~_~~ r -~~.,." l~---'. " ,~; ~ ~..,~,,,....,.~~ ~"'"~~'-"- ~,=.~~~~~<<>J,""lm~""""""~"<!,,",';1!''-'-!I'1'''{;f,;;iffl~,,",~" ;l;jO/;'~%Y;:~iW'f~~~" ~~ r , WT .~ " r~~ ~j --, J.~ p c.:e. ~ J -t::-\ c.'. () ,~ ;:,=;;-; c. oi'I ~. -l:> <.> <:j. ,,' ~^ <-- \ -;;.:t:J ~1~, ~!:~; (~, :~::CI ~i:-" c: .,0,_ --:i _1,- en '!-.- '\ ..g -"--, ..- .-,'> ~_':l ,-- '.- ~~--,~-+ PROOF OF SERVICE .0F NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of s(jrvice M-UST BE FILED WITHIN FIVE (5) DA YS AFTER filing the notict' of' appeal. Check ,-lpplicdbfe boxes) COMMONWEAL Tel OF PENNSYlVANIA COUNTY OF ;'55 AFFIDAVIT: I h8[i..;by sw8cli' or affirm that I served '-, (j coPy o,f the NotIC,e"o{ADP'i;;:d, 'C.-,\JIll tn on PI~as N,o. -,-__.__"...__"~,,~,pon d' (datt' of service) ____ __ m' . ~_'_'_____, 1 9 _ _, [J: .bv pf.~rsona! ,~LTVi,(;i;~' i'eceipt attachE:d \~er ero, Jnd l~pon the <ippelice, {l7imJeL,____._ --"".___,,_"'..______________, 19 I)y personal SCI'ViCE: [J bV (cuit'f;(~cl) t: D'strict Justice dcsig'latf:c.llherein Oil b,,' icen:fied} (rqistu8rJ) rn;~:I; st-:wk: '" L_~; ________" on 'Jrt) ~)k!r ~\;ndcr's ,.(~celpt (~;:tached',hc'ret(). and furthe,! that I serv'ed thE' Hule to File B Complaint accornpeJnY:I~iq t'lt': abo"/t' NOT-ic', of Appe<-,j u))on 'the ,mpi.;lh;elsi to whorn the Rule was addressed on___ __________"_"~__'_"_, 19__ -'I by f!ersorl(JI 3cl.l.flce C".; by (.certrheclj (rl':~li;;h:retl) mad,,"sender,'s receipt attached he.l"etn. SWORN (AFFIRMED) i"ND SU88CRI8,Eo BEFORE ME nrIS_,,~DAY . 19_~, SlgT!alU(t' of Clf'fianr Signature of oflicla; be fori.' whom affidavit wvs mdd2 I . , ----------'------~---""'----- Title of official My commission lJxpires on_~,~_, 19__ ,..,...... "'Ilj'ij~ilIiWi- - f.lif~,~,~~;'<ljl~8','Wll"'ql1;"1JiI;"._~~.~1J(l:J1;,",!'"."c-i;,-'H.~"]i<:"""",,' ''';-'-''''''} "jj,,~';h '-, ,<",j;;'\l,-"1,{'01;if',fC) :-': - . {, "'!-'-",;!\~;:\""';1.'};'\;\'~:t'':,:1iI,il\i~if#~ GOMMONWE..<<1 TH Of "-PENNSYLVANIA COURT OF COMMON PLEAS of Cumberland County JUDICIAL DISTRICT NOTICE OF APPEAL FROM p, DISTRICT JUSTICE JUDGMENT COMMON PLEAS NoC)I-2014 Civil 'term NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court 6t Common Pleas an appeal from the judgment rendered by the District Justi,ce on the date and in the case ment(oned below. N"'ME OF ...P..El.l-...NT MAG. DIST. NO. OR N....ME;; OF D.J. SlW.OW1l. HOMES. INC. 09-3-04 Plaeey ",OORE;;SS OF .....PE;;l-l-...NT CITV ST"'TE ZIP CODE 145~1g Oak Road Marth 8. 2001 IN THE C...SE OFIP''',n/,1f1 ~ Fedorko. Larry & Mary VA O"'TE OF JUD~ME"'T W' llclmeS. lne~ Cl-...IM NO. cv 1~00508-o0 LT 19 This block will be s-igri~ed ONLY when this notation R.G.P.J.P. No,1008B. This Notice of Appeal, when received by the District Justice. a SUPERSEDEAS to the judgment for possession in this case. will operate as . If was Clqima1)t Isaa Pa. R.C.P.J.P. No. 1001(6) in action bafora District Justica, ha MUST FILE A COMPLAINT within twenty (20) days aftar filing his NOTICE of'APPEAL. Signature of Prothonotarv or Deputv PRAECIPE TO ENTER RULE TQ,EILE COMPLAINT AND RULE TO FILE IThis saction of form to ba usad ONL Y whan appallarit Was DEFENDANT IsaaPa. R.C.Pjp.'No, '100lll) in action bafora District Justica. IF NOT USED, datach from copy of notica of appaal to ba sarvad upon appallaa). " . PRAECIPE: To Prothonotary x Enter rule upon Larry Fedorko and Mary Fedorko Name of appellee(s) (Common Pleas No. 01-2014 civil 'tetift .' appellee(s), to file a comp,laint in ~his appeal RULE: --' ". ';,. ~:\~;;"-, "::<'- La.rry Fedorko and To ) within twenty (20) da~~~yg_~"itt.fLnon pros. "" , By !!'Rich....d c. s....thaker '---\ c '-...._,,),~--:\ Signatur.e,l?f..appeflallror his attorney or agent Mary ,F~!r~' , appellee(,) Name of appellee(s) (1) You are notified that a "rule is hereby entered upon you to file a complaint il} this ,;;!,ppea! yvithtw,twenty (2Ql days ,after__ the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service bf this ru'le if service was by mail is the date of m'ailing. Date: Avril' 6. 2MJ,-2QOl' , I( Deputy ;( AOPC 312~90 COURT FILE llIIl'h'j.Or,w.>$'<_ ~ - ! .[r'nT' '1"'<<:'.''1'"''" ..- .. l I ffrl [llr-i." .' ., ..~. - -'''''' . . .." ----"----'--'''~'-""'----"._"'---"-----''-----'-----,-,,--,-"-'''--'------~- -, -- " - --- ----.-- ,. PROOF OF SERVICE OFI\IOTICE OF APPEAL AND RULE TO FilE COMPLA'~JT (This/irao/tif s&ryicc MUST BE Fi'L'ED vvrtHIN FIVE" (5) DA Y,S AFTEP ffhn(J th~.- notice of dpjH3,'J/. Chc!:,( ..7Cplit:e,.h!e h:J.\"es) COMMONWEALTH OF,PENNSYlVANIA COUNTY OF_ CUMBERLAND "___~,~;S5 AFFIDAVIT: ! hereby swei;11 or affir:"n that! $01'vw1 ;jl' a copvof the Notice of Appeal, ComcDon Pieoas N,o.,Q..l:-2.Q14._", upon the [) )rt,ct Ju.)~:c',d(!~i9il,HJ;d th,,'Jri~;1) un (date of service)__,~-PJ;:.i.l~6.~QOl___,,,_ ," 1"9"-~____1 LJ by. ~1f;\ sona: s!,!,\j~~'c .i~i1 bV lei,1 t::fie:d) (r.l;qistloil:d i m~~:i,,, sentlpl '<, !"cceipt attachHl herew, and UpOIl :he ilppellef;, (name)__ JdlrI'y,__F?dp:r,:k:9_,__al:!S~ ~_1:'"y Fedorko _____ 011 ___"_,,..~P',,!!1-_,,_?_.!__,_1..~q~ ___; hy jYJrsondl SC+V,CI~ [~ bv \u:' !,it:u,i,1 :;1u;;di '"::,1', :J~'n(il;"') r"ceiD1 c:'t1:1dll:d hen:to:' ''':"x ar~dl~furthf-5r '{bat I ';{~iVUj the, Fhde to File cl Complain!. accompany")!} whom'the Ruie,'-/vas addles~,ed on,_____,_,._A:P.!"}J__~__2QQ1__, 19". ,. rt),~il, s~JJqe(s' rec~!)p.t. .a'Hact:frcl'.lh~ereto ~ .. ,,,. ",' I" . ' ,,' <,kJ ,," ' -,-~" ,,'. ' the jbO\'~' !\101 :(;1": i"\jJPi~:Ji Uj>Ofl 'till: 2ppel!ee(s' t(l SWORN {AFFIRMED! AND SUBSCRIBED ErEFORE'~'~E ..... '"6t'h ' ., " "'A' ril '. :).[101 TH IS,___.___ DAY OF._____P____._...._. ""-'__. . ~?P~4---~--~.-~~~- Siqna,tu:.,_,.~ ~'.f:G~Jj-befor"e ~h~m dtfi(1aV~ttJn7afe . ~ ' ", <. '1 ".. ~_,--,-..l__.___"~:,___~......<..,,,._':":'__..",,,..;-,-"":"',,,,_~,,-----,----- Title of officiof ~p('"r"d ,'1"1((' 'i)(; by !cen;h,di {""jlstr"",li ~ Siq;liftt~re. of afflam Q c:::' -~- I~g -"._,1 My commiSSion expires'on_~~____~" 19~. c;: NotarialSelll ........~. Member, ~ of f\IClmieS ,,--,,;. '-', ~~- .,' 0" ,~-~ " .-.', -';;' -'-- 2<: 9;; ."~, (:.'::) _'A \ , \f~' 1 .., ~,J "4%1JI,~"'I'C .e ,0.- 'T. , .::r ..Jl n.J ..Jl rr r:J r:J l,fJ Postmark Here .::r r:J r:J r:J "" r:J .::r m Name (R/liN.se Print Cleafly) ~ COfIJPleted by mailer} TnOmaS 11.' 1'Lacey ~ I~j~t~t;B~~~~W4':"""io4"'s':'"s;~~'~i;;~'"Hiil'" :;: 'C;;';"St't':ZlP;;'h"hh""hMe'i:1ia"i:iI'cs1:iurg;""'PAi70!8a"a""'" l.r1 rr n.J -" rr r:J r:J l.r1 Postage $ .3~ o o .::r In Postmark Here Certified Fee .::r o CJ Restricted Delive CJ (Endorsement R cr St;eet,-!lP.i~No.~.-or-P6 m____m___mmmnnm__nnnnn___.n rr 246 Indian e Drive o .ciiy:Stafe:zij5+4n-.-..-~.nn.n....nnn--n.-__.n.nn-__nnnn__..~.n.h"_.__.~. l'- Mechanicsburg, PA 17055 Ij' " ~, I I .r :~ -~- . ~~, ..... · Cbnlpl~feijems'1.2; "and' s~ item 4 if Restricted Delivery is,desired. '< · Print your name and address on the"feverse so that we can return the card,to,YOtl:-_,,; " · Attach this card to the back of the mailpiece, or on the front if space permits. 1, Article AddresSed to: ~nt X D,A(jdressee D. Is eliveryaddressdifferent'fromitem1? 0 Yes If YES, enter delivery address below: 0 No Larry Fedorko Mary Fedorko 246 Indian Creek Drive Meehanicsburg, PA 17055 3. SelVice Type lJ Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (OoPYl'Pm s"",k;e (abeQ 709~ 34~p 0004,5009 ;62915 PS Form 3811. July 1999 + Domestic Return R_pt f0259S.00-M-0952 mm ~.,..,."" ,,0,. f' ~~~~ .,..,....., ~ ~, '''"'~' r" ':,"!" u . - '!lI~~~~1W~e'!!-~~~~tJ'~'~:{i:' _'~1I!<~1~~1~~~'Ii~~ "n' . ~'''''' ""', '" - ", ., ". ~ LAW OFFICES SNE:LBAKER. BRE;NNEMAN & SPARE ,!,~,A~ _ . ~" !I VERNON R. SEALOVER and SEALOVER HOMES, INC" : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO: 01-2014 CIVIL TERM vs CIVIL ACTION - LAW LARRY FEDORKO and MARY E. FEDORKO, JURY TRIAL DEMANDED Defendants NOTICE 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 attomey and filing in writing with a 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 By Atto LAW OFFICES SNELBAKER. BRENNEMAN & SPARE ,,',\, ^ , ""';,)-~."' VERNON R. SEALOVER and SEALOVER HOMES, INC., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : NO: 01-2014 , CIVIL TERM vs CIVIL ACTION - LAW LARRY FEDORKO and MARY E, FEDORKO, JURY TRlAL DEMANDED Defendants COMPLAINT AND NOW, come Plaintiffs Vernon R. Sealover and Sealover Homes, Inc., by their attorneys, Snelbaker, Brenneman & Spare, P.C., and.aver the following causes of action: 1. Vernon R. Sealover, an adult individual, is a Plaintiff herein and resides at 145 Big Oak Road, Dillsburg, P A 17019 (hereinafter called "Individual Plaintiff'). 2. Sealover Homes, Inc., a Plaintiff herein, is a Pennsylvania business corporation, having its principal office at 145 Big Oak Road, Dillsburg, P A 17019 (hereinafter called "Corporate Plaintiff'). 3. Defendants herein are Larry Fedorko and Mary E. Fedorko, husband and wife, adult individuals, who reside at 246 Indian Creek Drive, Mechanicsburg (Hampden Township), Cumberland County, Pennsylvania 17050. 4. At all times relevant hereto, Individual Plaintiff was the owner of a single-family residence known and numbered as 5010 Apache Drive, -,-,,',';'. LAW OFFICES SNEL8AKER, BRENNEMAN & SPARE , !i Mechanicsburg, (Hampden Township), Cumberland County, Pennsylvania (hereinafter clllled "Rental Property"). 5. On or about June 2000, Defendants' residence aforesaid was damaged by fire to the extent that said house was uninhllbitllble. 6. Knowing ofIndividual Plaintiffs ownership of the Rental Property, Defendants sought to rent said Property during the time the fire damage was being repaired. 7. On or about June 27, 2000, the Individual Plaintiff and Defendants entered into a written lease for the Rental Property, a true and correct copy of said lease being attached hereto marked "Exhibit A" and incorporated herein by reference thereto (hereinafter called "Lease"), and Defendants paid to Individual Plaintifffour (4) months' rent ($4,800) and also paid a security deposit of $1,600 and pet deposit of $150, totaling $1,750 (hereinafter collectively called "Security Deposit"). 8. Defendants took possession of the Rental Property pursuant to said Lease on or about July 1, 2000. 9. On or about August 25, 2000, during their tenancy of the Rental Property and while their fire damaged residence was being repaired, Defendants solicited Corporate Plaintiff to build and construct a powder room (containing only a toilet commode and a lavatory) in a portion of the basement of the Defendants' residence. 2 ~ LAW OFFICES SNEL8AKER. BRENNEMAN & SPARE II 10. As the result of their discussion, the parties entered into a written agreement dated August 25, 2000, which outlined the prospective work for a powder room and fixed the price/consideration at $3,970.00. 11. Defendants paid Plaintiff the sum of $2,000.00 on or about September 18, 2000, on account of the construction project. 12. During the course of said construction project, Defendants requested the addition of a stall shower thereby converting the project from construction of a powder room to construction of a bathroom. 13. Corporate Plaintiff provided Defendants with catalogue materials for the shower facility and fixtures and estimated an additional cost of approximately $1,500 to $1,700. 14. On or about October 11, 2000, Defendants selected a desired shower and fixtures, and directed Corporate Plaintiff to order the shower materials and to enlarge the proposed construction to accommodate the shower as a bathroom, 15. Relying upon Defendants' directive to proceed with the enlarged construction project, Corporate Plaintiff purchased the shower materials and had them delivered to Defendants' residence on or about October 13, 2000, together with a toilet commode and lavatory with fittings and fixtures. 16. Corporate Plaintiff proceeded to construct the bathroom with shower. 17, Defendants vacated the Rental Property on or about October 31, 200, and resumed occupancy of their present residence. 3 "'. ,~" LAW OFFICES SNELBAKER, BRENNEMAN & SPARE II 18. Upon Defendants' vacation of the Rental Property, it was discovered on Individual Plaintiffs behalf: (a) that Defendants had caused damage to the structure as follows (1) Three interior doors were damaged by holes; (2) Walls behind doors were damaged by dents resulting from Defendants' unauthorized removal of door stops causing doors to strike drywall covered partitions; and (3) Exterior vinyl siding damaged by hole; for which the reasonable repair and restoration costs was: $180.00 (b) that the premises required general cleaning, the reasonable cost of which was: $120.00 (c) that payment for the following services owed by Defendants under the Lease had not been paid: (1) Pennsylvania American Water Co. (water service): $ 86.87 (2)Township of Hampden (sanitary sewer and trash removal services): $ 32,67 (3) C. W. Fritz. Co, (air conditioning service): $ 82.00 $501.34 TOTAL 19. On or about November 16, 2000, the parties met to discuss the progress of Corporate Plaintiffs construction and Defendants' payment therefor at which time Corporate Plaintiff provided Defendants with an up-to-date billing for the construction indicating a balance of $2,447.83. 4 ,"' ,,~,. ~ LAW OFFICES SNELBAKER, BRENNEMAN & SPARE II Ii ! 20. As an accommodation to Defendants, Individual Plaintiff assigned the Security Deposit ($1,750) to Corporate Plaintiff and the latter gave full credit therefor in the billing aforesaid, as previously discussed and agreed to by Defendants, 21. In the matter aforesaid, Defendants issued their check to Individual Plaintiff in the amount of $495.73 in payment of the then known unpaid items under the Lease for the Rental Property as more fully set forth in paragraph 18 hereinabove 22. On or about November 22, 2000, Defendants dishonored the check aforesaid by stopping payment thereof, as a result of which Individual Plaintiff incurred a banking charge at his deposit bank in the amount of $20.00. 23. On or about November 16, 2000, Defendants directed Corporate Plaintiff to terminate work on the bathroom construction, which directive was in breach of the parties' agreement and understanding. 24. At the time of the breach as averred in paragraph 23 aforesaid, Corporate Plaintiff had constructed the partitions in the bathroom, installed waste water pipes in the existing concrete floor, installed the stall shower, roughed-in electrical and water utilities and delivered shower stall door, toilet commode and various fittings, pipes and fixtures,(including certain PVC pipe not included in the original tabulation mentioned in paragraph 19 hereinabove having a value of $41.80) having a value of $1,241.83. 5 LAW OFFICES SNELBAKER. BRENNEMAN & SPARE II 25. At the time of the breach as averred in paragraph 23 aforesaid, Corporate Plaintiff had not yet delivered the vanity and lavatory and had not yet installed a door and jamb, floor covering, paint, ceiling, nor installed the shower door and toilet commode, all such work having a value of $1,088.00. 26. At the time of the breach as averred in paragraph 23 aforesaid, Defendants owed Corporate Plaintiff a balance of $3,831.80 and after allowing credit for unfinished work ($1,088.00) and the Security Deposit assigned as aforesaid April 20, 2001($1,750.00), a balance remains unpaid of $993.80. 27. Corporate Plaintiff has demanded payment of said sum, but Defendants have failed and refused to pay said amount, COUNT I Corporate Plaintiff v, Defendants (Breach of Contract) 28. The averments contained in paragraphs 1 through 27 hereinabove are incorporated herein by reference thereto. 29. Defendants' unilateral termination of Corporate Plaintiffs work and failure and refusal to pay said sum of $993,80 constitutes a breach of contract for which Defendants are liable to Corporate Plaintiff. 30, Said sum of $993.80 is the fair and reasonable cost of the work and materials performed and provided by Corporate Plaintiff and is the amount which Defendants agreed to pay. 6 LAW OFFICES SNELBAKER, BRENNEMAN Be SPARE ,,'If 11 I- I i: I WHEREFORE, Corporate Plaintiffrespectfully requests your Honorable Court to enter judgment in favor of said Plaintiff and against Defendants in the amount of $993.80 together with interest and the costs of this action. COUNT II Corporate Plaintiff v. Defendants (Quantum MeriutlUnjust in the Alternative to Count I) 31. The averments contained in paragraphs 1 through 30 hereinabove are incorporated herein by reference thereto. 32. Defendants have received work and materials having a value of $993.80 by which they have been unjustly enriched at Corporate Plaintiffs expense, WHEREFORE, Corporate Plaintiff respectfully requests your Honorable Court in the alternative to Count I above to enter judgment in favor of said Plaintiff and against Defendants in the amount of $993.80 together with interest and the costs of this action, COUNT III Individual Plaintiffv. Defendants 33. The averments of Paragraphs 1 through 22 hereinabove are incorporated herein by reference thereto. 34, Defendants are obligated to Individual Plaintiff in the amount of $521.34 under and by virtue of the Lease averred as aforesaid. 7 , '~'r I'"' I" ,)" _II -~ LAW OFFICES SNELBAKER. BRENNEMAN & SPARE '>'~, !1 35. Individual Plaintiff has demanded payment of said sum of $521.34, which Defendants have failed and refused to pay. WHEREFORE, Individual Plaintiff respectfully requests your Honorable Court to enter judgment in favor of said Plaintiff and against the Defendants in the amount of $521.34 together with interest and the costs of this action. SNELBAKER, BRENNEMAN & SPARE, P.C. By Richard C. Snelbaker, Esquire 44 West Main Street P.O, Box 318 Mechanicsburg, P A 17055-0318 (717) 697-8528 Attorneys for Plaintiffs 8 _. LAW OFFICES SNELBAKER. BRENNEMAN & SPARE II VERIFICATION I, VERNON R. SEALOVER, being the Individual Plaintiff in the foregoing Complaint and the President of the Corporate Plaintiff (and authorized by the latter to make this verification on its behalf), do verify that the facts contained in said Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements made in said Complaint are subject to the penalties of 18 Pa. C.S. ~ 4909 relating to unsworn falsification to authorities. ~~,-k~ VERNON R. SEALOVER Dated: April 23 , 2001. 0'.-'[ ~o. ., LAW OFFICES SNELBAKER. BRENNEMAN & SPARE II , . " VERNON R. SEALOVER and SEALOVER HOMES, INC., Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO: 01-2014 CIVIL TERM LARRY FEDORKO and MARY E. CIVIL ACTION - LAW FEDORKO, Defendants JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND SS ) RICHARD C. SNELBAKER, ESQUIRE, being duly sworn deposes and says, that he served two duly certified copies of the Complaint heretofore filed upon the Defendants, Larry Fedorko and Mary E. Fedorko, by sending the same by Certified Mail, Postage Paid, Return Receipt Requested on April 24, 2001, which was received by Defendants on April 25, 2001, the original receipts for mailing and delivery being attached hereto and being made a part hereof; and that the facts set forth herein are true and correct to the of his knowledge, information and belief. Sworn to and subscribed before me this Jbll day of 4n/ ,2001 Notarial Seal Sussn L.~. ~ P\IbIic ~ BOlo, CumbilrlandCounty My Explrea Nl>Y. 24, 2003 A<Isllcla!icAalNottuies 1 , LAW OFFICES SNELBAKER, BRENNEMAN & SPARE ,- 'j ~ I .~ l q!Yo!'>l'ifl ;:,.,. "~, ,-. ~ 1! I. m m ru JI n- O o a.t1 '" o C] Restricted Delivery Fee o (Endorsement Required) o o Total Postage & Fe~ '" ITI Name (pfeasf;J Print lesrt,1t ~ -~~;~{NOf~i~~~{~~'~k-'D~i~~nn::::::'mmu:u:::::::::::: ~ 'ti(y,-1iiiii;iip<4m'Meclian'CcsDurg';--'YK 17055 . Complete. ,'Z,an '. Alsocomptete item 4 If Restricted Delivery is desired. . Print your name and address on't~e reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. D. s der ery 8ddress different 1? If YES, enter delivery address below: 1. Article Addressed to: Larry Fedorko Mary E. Fedorko 246 Indian Greek Drive Mechanicsburg, PA 17055 3. Service Type iE Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2, Article Number (Copy from service/abeO 7099 3400 0004 5009 6233 PS Form 3811, July 1999 Domestic Return Receipt 102595-()()..M-0952 + "c.' ,~_ ,r--,""":,"'i'?'I"o1:",,~ """, y!. .~, - .",",~- 1"",1 1:'-",: ')~ :;~ e ,~" ~ " ~ <-- '-:"" "",T-,_ ~l ~. 1'< ".,'llI'lI'!!l!~_., I J ,h-~~. ~!J.l""~' ,~~, '''''F'<~'''-''''''''''"I''"j~ r ~..~- 0 c:~ Cl C " ;r;. - -,""- -nee ),:,J ffln ......(. z::::' ,-:t:1 z:; ~2: ~,~~ ~c; "0 )>0 -~ ,<' Zo ~ -,,-r..-::tT! )>c ~ ~ r:- ;e> ::Q. .'.llIinl} , $~ "'~ ~!?f~JI'W!~f~';'i'!r:mil~:4~W,jlWlflwqf~m~~11IWif;~'tij"\'I;fl!ljjJ:m~~1~,:O---"",~ .,;;y, LAW OFFICES SNELBAKER. BRENNEMAN & SPARE Q"'lW ,', - II ,- ., VERNON R. SEALOVER and SEALOVER HOMES, INC., . Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO: 01-2014 CIVIL TERM LARRY FEDORKO and MARY E, FEDORKO CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF JUDGMENT BY DEF AUL T TO: PROTHONOTARY OF CUMBERLAND COUNTY AND NOW, comes SEALOVER HOMES, INC., one of the Plaintiffs in the above- captioned action, by his attorneys, SNELBAKER, BRENNEMAN & SPARE, P.c., and requests and moves for judgment against LARRY FEDORKO and MARY E. FEDORKO, Defendants, in the amount of Nine Hundred Ninety-three and 801100 ($993.80) Dollars together with interest and the costs ofthis action for failure to plead to Plaintiffs Complaint (with Notice to Plead) and after Notice pursuant to Pa. R.C,P. 237,1, The undersigned certifies that a true and correct copy of the Notice required pursuant to Pa. R.C,P. 237,1 is attached hereto and that said Notice was mailed to Defendants on May 18, 2001, at their address indicated on said Notice by first-class mail postage paid. By de- Dated: August 3,2001 . chard C. Snelbaker, Esquire 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff Vernon R. Sealover - lAW OFFICES SNELBAKER, BRl::NNEMAN & SPARE }1'ffl~''i!l~,~ II VERNON R. SEALOVER and SEALOVER HOMES, INe., Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO: 01-2014 CIVIL TERM LARRY FEDORKO and MARY E. FEDORKO : CIVIL ACTION - LAW Defendants : JURY TRlAL DEMANDED TO: LARRY FEDORKO and MARY E. FEDORKO 246 Indian Creek Drive Mechanicsburg, P A 17055 DATE OF NOTICE: May 18,2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRlTING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITH A HEARING AND YOU MAY LOSE YOUR 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 By 'ch . Snelbaker, Esquire 44 West Main Street P.0.Box3l8 Mechanicsburg, P A 17055-0318 (717) 697-8528 Attorneys for Plaintiff ^, '~I' ,~" '~"""'l c "- - Il ~~ ~ rD ~ ~~ W'\ <..)J -., ~ :f ~ ~ i L '1 u-> I C> --. o c: 2' -ow f'I1fTl Z:D zr-- (j) ?; -<./-- ~C ?Zo --0 )>c: ~ <:) '".''''~,~ o " "" c:: G> I ,-,} -< .-\~; :~n ,... ~-~~5~, ~!~ t~ orn :;:;! :I;! ~ -u :::x: t::~ 'Jl (" 0,,_ . ~~-, ~~. , 4' ~"""',_~' , ~ ",J~l!t~J!II!~~ ~"..~, r, ~r~~"'''''l'>!%'''p~[:r-~::;-1!;~lC'*r''?';~i~f~'!W_~~c!!~~~~~~,..,~~~ ~" LAW OFFICES SNEL8AKER. BRENNEMAN & SPARE :,";;''':" ~-' - - -,\-,,",,-<,,.,-'~ II ! , VERNON R SEALOVER and SEALOVER HOMES, INC., Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO: 01-2014 CIVIL TERM LARRY FEDORKO and MARY E, FEDORKO CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT TO: PROTHONOTARY OF CUMBERLAND COUNTY AND NOW, comes VERNON R SEALOVER, one ofthe Plaintiffs in the above- captioned action, by his attomeys, SNELBAKER, BRENNEMAN & SPARE, P.C., and requests and moves for judgment against LARRY FEDORKO and MARY E. FEDORKO, Defendants, in the amount of Five Hundred Twenty-one and 34/100 ($521.34) Dollars together with interest and the costs of this action for failure to plead to Plaintiffs Complaint (with Notice to Plead) and after Notice pursuant to Pa. R.C.P. 237,1, The undersigned certifies that a true and correct copy of the Notice required pursuant to Pa. RC.P. 237.1 is attached hereto and that said Notice was mailed to Defendants on May 18, 2001, at their address indicated on said Notice by first-class mail postage paid, By - c . Snelbaker, Esquire 44 West Main Street P.O. Box 318 Mechanicsburg, P A 17055-0318 (717) 697-8528 Attorneys for Plaintiff Vernon R Sealover Dated: August :3 ,2001 LAW OFFICES S~~EL8AKER, B~ENNEMAN 8: SPARE 4G {~ " ''''',"",,,,,, ~ ~, "~ Ii T- , Ii VERNON R. SEALOVER and SEALOVER HOMES, INe., Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO: 01-2014 CIVIL TERM LARRY FEDORKO and MARY E. FEDORKO : CIVIL ACTION - LAW Defendants : JURY TRIAL DEMANDED TO: LARRY FEDORKO and MARY E, FEDORKO 246 Indian Creek Drive Mechanicsburg, P A 17055 DATE OF NOTICE: May 18,2001 IMPORT ANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITH A HEARING AND YOU MAY LOSE YOUR 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 By c , Snelbaker, Esquire 44 West Main Street P.O, Box 318 Mechanicsburg, P A 17055-0318 (717) 697-8528 Attorneys for Plaintiff _P-~. , "."~', < = , ". " , 0--- ~ iii ,. ," ~,"". ~,~ ~ ~ "1-"1', ~."..,,~,. ~~ ~ ~ -- -- (jJ '->J \...oJ .' "~' ,~"ct ,"' ' . . '~'O'_ ~'''".. ~'''''' ~"" '""~",' '" '"","'''''''' " _.~~ -~'liill'J"I[;j'[1' fD g Cl 0 " s: ~~ ,-, -om c_. -~'~lifd m(T'l G' ~ z;:c I ~uSt ZS:: ::,J-i...) ~J::' (..) ::~/~:} d: ,<c -0 -:, ~'-'-\ ~ -,., :>:: ;~() ~2 r~ i,-:.:..rn d -t Z Ul ~ ::;! ,r;- ~ J.. d. -. ~ n~~~$'~,,,"'ii"'j'/';O!'\ilim:pl"J<\'I'~;"!ll\I';"fu'JJim'~\\f!i~,"i~~:~~ifi.'lj~IlJ~~~ \ H f't ri " ti rr i': " ,,' ri, ~ ~ i" LAW OFFICES SNELBAKER. BRENNEMAN & SPARE IN THE COURTOF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION [1.] VERNON R. SEALOVER and [2.] SEALOVER HOMES, INC., Plaintiffs FILE NO: 01-2014 CIVIL TERM AMOUNT DUE: Plaintiff#l - $521.34 Plaintiff#2 - $993.80 total: $1,515.14 vs, LARRY FEDORKO and 'MARY E. FEDORKO, Defendants and COMMERCE BANKlHARRlSBURG, N.A. 4960 Carlisle Pike Mechanicsburg, P A 17050, Garnishee INTEREST: @ 6% from August 3, 2001 COSTS: 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, but 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, PRAECIPE FOR EXECUTION Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property ofthe defendant(s): any tangible personal property in possession of Defendants at 246 Indian Creek Road, Mechanicsburg (Hampden Township), Pennsylvania, and any monetary deposits, accounts or other property in possession or custody of Commerce Bank/Harrisburg, N,A., Garnishee. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland 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): any monetary deposits, accounts, credits and all other property of Defendants in the possession, custory or control of Commerce Bank/Harrisburg, N.A., as Garnishee, By: Date: September 12,2001 ichar . Snelbaker, Esquire 44 West Main Street P.O. Box 318 Mechanicsburg, P A 17055-0318 Attorneys for Plaintiffs (717) 697-8528 Supreme Court ID No: 06355 w ," 1!111, , =- I "'j' '"T"' .. ............' 1_"lblUiIlltI'lhllljl"'- 'i" E \: \ 0 c::), (:) c: "n s: U} -- ~ ri1 g;; '""I ~. Z~r, .." 6;S: l",.] , ..... ~z .... r:" ~'''! " '>' :<: ......- -"0 -<. " ~c :~:; \:, '" -0 i;;:j ;J>c: 2; 0 =< .j;:"^ ~ )0.. 1- J\~ i ~ $ .. _ ~ ~":"",,"__,,c~"',,,-~ " ",f\'i,~~~~,:;t-M~;t'lrn1;pii"!'n:ifll~~lIl~If~~~,__,_"",,:~,"U ~ ~ ~ :> t\ LAW OFFICES SNELBAKER. BRENNEMAN & SPARE VERNON R. SEALOVER and SEALOVER HOMES, INC., Plaintiffs vs. LARRY FEDORKO and MARY E. FEDORKO Defendants r : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 01-2014 CIVIL TERM : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO SATISFY JUDGMENT TO: PROTHONOTARY OF CUMBERLAND COlJNTY Please cause the judgment(s) entered in the within action to be marked satisfied. Date: September ~I ,2001 B ard C. Snelbaker, Esquire 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiffs --, ----~'~------~~"~._---~" .-- ~~~:~,~;~.~~')i.;j;.~:';~~~;~i.2;~;t:r;J::ts~z::€t~~ ""__h',:'~'I";' ~~':~~:;;!;;:;?;:j;:>11!;~'?~;~~li:~F:>~:\ft':::'+;~~I:~<~r" w' ~ ! A", ~ I ! I I !I :.1,'. :;1 ~ .m " ~, if.'avit:i 0 c" c C ? " I -otD cr., nlr';-~ 1" ;-:::::rj CJ "' r- Z C" ~, rT~ ~ii~: i-'--' ~" C) ~j() ~ :Ei < 1-' ~[~ : ::':;;:1] ~, ~.~C) r:-?' C)i'l Z "" --J tv J.--'" -.:; (X> :0 -< l!"$,~rl!!!fjJli'l~~~~'!1"~',:~; ,-r.' .-~ '_'''_ [.1 .W W of ([:umoe ~~~~ I'I<tqg R. THOMAS KLINE Sheriff RONNY R. ANDERSON Chief Deputy EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF PATRICIA A. SHATTO Real Estate Deputy One Courthouse Square Carlisle, Pennsylvania 17013 September 21, 2001 () C~:;; C ~;:; "1;) r:':~ C/') [lJ(~: r'1 .2::,1' "':J Zc" ."\,) en 1'" -"'::.,- '~~1 r'::/'::;: ::::: .....~ :::2 ~() ~,'". ..-( j Pc::: . , Z -;:'.,--" =< .:;::, <:0 Commerce BanklHarrisburg 4960 Carlisle Pike Mechanicsburg, P A 17055 Re: Vemon R. Sealover & Sealover Homes, Inc Vs Larry and Mary E. Fedorko No. 2001-2014 Civil Term Writ of Execution / Dear Sir, Pertaining to Attachments made on accounts in the name of Larry and Mary E. Fedorko, in the above entitled action, please be advised as of this date, September 21, 2001 all attachments have been lifted by authority of the Cumberland County Sheriffs Office. Thank-you. !,o, cc: Richard Snelbaker, Atty Larry Fedorko, Deft. Mary E. Fedorko, Deft. Commerce BanklHarrisburg, Garn. so~ ~ ~ ~;.C'ef~~ R. Thomas Kline, Sheriff ByCJ Qudk-lJ. f~l/ " "i~~ , ~ - . "" ~'T ,'- r"""'~" , ~ ~. ~ - !:i ~~' I==it=:~lt , Ib!b. 1Yb,: ~\ L?:;~u" '1\' ,. "'~""'~~ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing $ Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Garnishee Advance Costs: $ Sheriff s Costs: 150.00 . 136.60 13.40 18.00 30.30 .50 1.00 7.80 Refunded to Attyon 9/26/01- 30.00 40.00 9.00 136.60 ,.,,9"', o ~ ~ - -<: So Answers; 1!'~~" Sworn and Subscribed to before me' tljis 1M" day of(}~ 2001 A.D. ~ Q ~,~ pr thonotary R. Thomas Kline, Sheriff By Cla(lofJtLQ,~b~ ~', H I ',"I' '; I ~ II H:-J'd 'lI t"'j] /'\ 'I'..,,--it.l.:l fHr, \0. Hd SO E HI"a~s "",,(Hill,' ;" ,.' o,rHl:) ;J~~llJ3HS 3ill ~O 3:ltHO -, 'I ~,,,. I', fJd1lt ~ ~ ~ - L.s() UL 3,//31 !2u-- J J 7/.13 ~~_~~I~,~, ~ _~, ~f~iWl. I "~'. ,-- . ~ """ "' >~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANtA) COUNTY OF CUMBERLAND) NO. __ill=2014 CIVIL 1e{ TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cunberland COUNTY: To satisfy the debt, interest and costs due ( 1) Vernon R. Sealover and (2) Sealover Hanes, Inc. PLAINTIFF(S) from Larry Fedorko and Mary E. Fedorko 246 Indian Creek Road, Mechanicsburg, Pa. 17055 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Anv tanqible personal property in possession of Defendants at 246 Indian Creek Road, Mechanicsburq (Harm:;den Township) Penna. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Cmrnprr.p Rfmk/HflrriRhllrg. N. A. 4960 Carlisle Pike. Mechanicsburq, Pa.17050 (Hampden Township) GARNISHEE(S) as follows: Any monetary deoosits. accounts, credits and all other property of Defendants in possession Custo;r:y Dr control pf C~ce Bank/Harrisburq, N. A. as G<;lrn:ishee anolo nouT}' tne garmsnee(S}lhat: (a) anattabflmeht nas been Is'Sued; (b) fhe garmshee(s) is/are enjoined frompaying any debt to or for the account of the defendant(s) and trom delivering any property of the defendant(s) or otherwise disposing thereof; (3) "property of the defendant(s) not levied upon an subject to attachment is found in the pof;session of anyone other than a named garnishee, y.ou are directedto notny him/her that he/she has been added as a garnishee and is enjoined as above stated. Plaintiff III $521.34 ' #2 $993.80 Amount Due $1.515.14 LL 50.50 Interest (<16% fran Auqust 3, 2001 Due Prothy ;; 1 00 Atty's Comm % Other Costs Atty Paid Plaintiff Paid SR1.25 Date: SF'tppJIlbler 12. 2001 Curtis R. Long Prothonotary, Civil Division by: q'"'jI!A/ O.~ Deputy REQUESTING PAF,i1Y: & B an Sneluaker rennern Name Rir.hflrn. C. Sne.lbaker. Esq. Address: 44 West Main Street, P. O. Box 318 MpchanicRblrrg. Pa. 17055-0318___ Attorney for:.Pl fl i nt i ffR Telephone; (717) r,Q7 R'i7R Supreme Court ID No. 06355 tv -" ,~. .' W "'"'f" ',,",' ""~',?i''-''&l''M.l<IM",,,-'l'=,Il1~~IIM!~~$~jJllfiiWJ?l)ii!!~!!"i>H~~ltWl!lf~%llr~r! m, ~~, _ . "~,, ,~~A'l~\'1P!'!l!:"~~'~:!lPir,~~..J~"rm~H~*F"~"'IK'W"'-'''. 'm"~,,,' ~,;",.-