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HomeMy WebLinkAbout01-03139COYNE & COYNE, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. O/- 3 / 39 CIVIL TERM JAMES E. PETTYJOHN, Defendant : CIVIL ACTION--LAW 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 Notice is served, by entering a written appearance personally or by an 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 Defendant. 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 Lawyer Referral Service 2 Liberty Ave. Carlisle, PA 17013 (717) 240-6200 COYNE & COYNE, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. o/- 3/ 39 CIVIL TERM JAMES E. PETTYJOHN, Defendant : CIVIL ACTION--LAW COMPLAINT AND NOW comes the Plaintiff, Coyne & Coyne, P.C., and files the within Complaint: 1. Coyne & Coyne, P.C. is a Professional Corporation, with offices located at 3901 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. James E. Pettyjohn is an adult individual residing at 629 N. Hanover Street, Carlisle, Cumberland County, Pennsylvania. 3. On or about August 8, 2000, Defendant engaged Plaintiff for legal services concerning various domestic relations issues to include custody, support, and divorce action and Defendant agreed to pay for Plaintiff's services pursuant to a written fee agreement, which the Defendant signed and acknowledged. (A True Copy of the written fee agreement is attached as Exhibit "A".) 4. Plaintiff performed legal services for Defendant and requested payment for services pursuant to the written fee agreement. (See Exhibit "B"). 5. Repeated demands for payment have been made to Defendant; however, Defendant has refused to pay outstanding invoice. 2 6. Defendant owes Plaintiff $2.052.24 as balance due and owing with an interest rate of 1.5% per month, annually 18%. WHEREFORE, Plaintiff, Coyne & Coyne, P.C., respectfully requests Judgment in the amount of $2,052.24, together with costs and fees and accruing interest from date of complaint filing. Respectfully submitted, COYNE & CCO/JYNE, P.C. Dated: - Z Z? I By: q :-K, Q - - ,Aisa Marie Co ne, Esquire 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 3 COYNE & COYNE, P.C. Attorneys at Law Henry F. Coyne Lisa Marie Coyne August 8, 2000 Mr. James E. Pettyjobn 629 North Hanover Street Carlisle, PA 17013 Re: Domestic Relations Dear James: 3901 Market Street Camp Hill, Pa. 17011-4227 Telephone (717) 737-0464 Facsimile (717) 737-5161 i l(? ? AUK ? s zo o rCr )? O It was a pleasure meeting with you recently. As we discussed, the following is a written fee agreement which I ask you to review and return to me at your convenience. As I explained to you, because of the nature of the matter, and because of the possibility of the occurrence of unpredictable and unforeseen circumstances, I am not in a position to quote you a final and specific fee for my professional services. However, I indicated to you that I would represent you on an hourly basis. My fee for professional services is One Hundred Fifty Dollars ($150.00) per hour, with fractions of hours computed in periods of not less than 15 minutes, which takes into account interruption of other work. Each such hour is based upon actual work regarding your particular case. I will provide you periodic invoices for services rendered. Payments on invoices are due upon receipt. After thirty (30) days, if an invoice remains unpaid, interest will be charged on the outstanding monthly balance at the rate of One and a half Percent (1.5%), annually Eighteen Percent (18%). This office reserves the right to modify the hourly rate and the rate of interest from time to time with advance notice to you should those changes be implemented. Any out-of-pocket expenses directly attributable to your case, including but not limited to postage, toll calls, court feestfiling fees, copy work, court reporter services, or travel expenses, will be. charged to you at cost in addition to the fee. Legal costs and expenses incurred are the obligation of and are to be paid by the client upon billing of same. I respectfully request you to remit to me the sum of One Thousand Dollars ($1,000.00) as a reduced retainer fee. This retainer is to be remitted by way of $500.00 upon the return of this executed fee agreement and then the balance of the retainer to be paid sixty (60) days later or upon the requirement of me to appear in court proceedings on your behalf, whichever occurs first It is impossible to predict a course that a domestic relations case will take. Therefore, it is important that you keep me informed of any and all changes in your life once my representation commences. e?Xff/1317'+4n. Mr. James Pettyjohn August 8, 2000 Page 2 Do not make changes or take, what may see, unimportant steps without consultation with me first. Do not hesitate to ask questions. However, bear in mind that while we attempt to promptly return all telephone calls, under certain circumstances, we might have some delay in returning your calls, particularly when preparing for or in trial on another case. I am pleased to represent you in.this matter, and I assure you that I will pursue your matter diligently and expeditiously. Please acknowledge receipt of this letter and your agreement to same by signing a copy and returning same in the enclosed envelope, postage prepaid. With best personal wishes to you, I remain-- Very truly yours, 4 LMC/crs Enclosure COYNE & COYNE, P.C. Lisa Marie Coyne I, JAMES E. PETTYJOHN, have read and fully understand the statements above written. I am acknowledging my agreement to the above by sign:-g belcle. Dated: o a jo'r '` _ V _ JAMES E. PETTYJOHN LAW OFFICES OF COYNE & COYNE, P.C. 3901 Market Street Camp Hill PA 17011-4227 Invoice submitted to: Mr. James Pettyjohn 629 N. Hanover Street Carlisle PA 17013 May 18, 2001 In Reference To:Domestic Relations Invoice #10093 Professional services 05/18/01 D/P: Review memo from Attorney Jones; draft memo to client. For professional services rendered Additional charges: 01/12/01- Long distance charges Total costs Interest on overdue balance Total amount of this bill Previous balance Balance due Hours Amount 0.50 75.00 0.50 $75.00 0.35 $0.35 $17.10 $92.45 $1,959.79 $2,052.24 ,z i VEBIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unswom falsification to authorities under 18 Pa. C.S.A. §4904. Coyne & Coyne, P.C Dated: 5-7-z-01 Henry F. Coy e, Pres. `1 r 9 ? o s ,c U c SHERIFF'S RETURN - REGULAR CASE NO: 2001-03139 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE & COYNE P C VS JOHN JAMES E KATHY J. CLARKE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PETTYJOHN JAMES E DEFENDANT the , at 1857:00 HOURS, on the 30th day of May , 2001 at 629 N HANOVER STREET APT 4 CARLISLE. PA 17013 JAMES PETTYJOHN by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof Sheriff's Costs: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 10.00 .00 31.10 Sworn and Subscribed to before me this " rl. day of .Z66 I ?A .. D . atA? `?L ?° -rT Prothonotary So Answers: R. Thomas Kline 05/31/2001 LISA MARIE COYNE By : I C. j Dep t Sheriff 4 V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA COYNE & COYNE, P.C., Plaintiffs, No. 2001-03139 CIVIL TERM : Civil Action-In Assumpsit JAMES E. PETTYJOHN, Defendant. TO: Mr. James E. Pettyjohn 629 N. Hanover Street, Apt. 4 Carlisle PA 17013 DATE OF NOTICE: July 5, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT 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 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Lawyer Referral System 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 COYNE & COYNE, P.C. Date: July 5, 2001 ?/ By: ? l/G? -?J A MARIE DYNE, Esquire 3901 Market treet Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of TEN DAY NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT was served this date upon the below- referenced individuals at the below listed address by way of first class mail, postage pre-paid: Mr. James E. Pettyjohn 629 N. Hanover Street, Apt. 4 Carlisle PA 17013 COYNE & COYNE, P.C. Dated: a Marie Coyne, Es ire 901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 cS, klT N A i? l Cl PJ - v COYNE & COYNE, P.C., Plaintiff V. JAMES E. PETTYJOHN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-03139 CIVIL TERM CIVIL ACTION - LAW STATEMENT OF INTENTION TO PROCEED TO THE COURT: The Plaintiff intends to proceed with the above-captioned matter and has, concurrently with this Statement of Intention to Proceed, filed a Praecipe for Entry of Default Judgment against the Defendant. Date_ Respectfully submitted: COYNE & COYNE, P.C. By: ?L_ q__- /Lj4a Marie Coyne, quire a. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing STATEMENT OF INTENTION TO PROCEED was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre- paid and facsimile: Mr. James E. Pettyjohn 629 Hanover Street, Apt. 4 Carlisle, PA 17013 Dated: Gtf? d isa Marie Coy e c`> ? o F 7r -ri 0In Co - j U r COYNE & COYNE, P.C., Plaintiff V. JAMES E. PETTYJOHN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-03139 CIVIL TERM CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter judgment of default in favor of plaintiff, COYNE & COYNE, P.C., and against defendant, JAMES E. PETTYJOHN, for failure to plead to the complaint in this action within the required time. The complaint contains a notice to defend within 20 days from the date of service thereof. Defendant was served with the complaint on May 30, 2001, and defendant's answer was due to be filed on June 20, 2001. Attached as Exhibit "A" is a copy of plaintiffs written Notice of Intention to File Praecipe for Entry of Default Judgment, which I certify was mailed by regular mail to the defendant at his last known address on July 5, 2001, which is at least 10 days prior to the filing of this Praecipe. Please enter judgment in favor of Plaintiff and assess damages in the amount of $1,330.17 and accruing interest at the rate of 18% APY and court costs, being the balance of the amount demanded in the complaint. Date '?-1z1-09" COYNE & COYNE, P.C. By: Pvi isa Marie Ce, Esquire Pa. Supreme t. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney for Plaintiff COYNE & COYNE, P.C., : IN THE COURT OF COMMON PLEAS Plaintiffs, : CUMBERLAND COUNTY, PENNSYLVANIA V. No. 2001-03139 CIVIL TERM JAMES E. PETTYJOHN, ?` - Defendant. Civil Action-In Assumpsit ".'r _ to - TO: Mr. James E. Pettyjohn 629 N. Hanover Street, Apt. 4 a` c Carlisle PA 17013 .3 DATE OF NOTICE: July 5, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT 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 3GAINST YOU. 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 FvIPORTANT 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 Lawyer Referral System 2 Liberty Avenue Carlisle. PA 17013 1-800-990-9108 COYNE & COYNE, P.C. Date: July 5, 2001 By: A MARIE OYNE, Esquire 3901 Market treet Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff •j P/ i CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of TEN DAY NOTICE OF INTENT TO ENTER DEFAULT JUDGMENT was served this date upon the below- referenced individuals at the below listed address by way of first class mail, postage pre-paid: Mr. James E. Pettyjohn 629 N. Hanover Street, Apt. 4 Carlisle PA 17013 COYNE & COYNE, P.C. Dated- GGG P/?/ a Marie Coyne, Esquire 901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT was served this date upon the below- referenced individuals at the below listed address by way of first class mail, postage pre-paid and facsimile: Mr. James E. Pettyjobn 629 Hanover Street, Apt. 4 Carlisle, PA 17013 Dated: Li Marie Coyne w C, Nt ? y z z :fi COYNE & COYNE, P.C. Lisa Marie Coyne, Esquire Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL, DIVISION COYNE & COYNE, P.C., File No.2001-03139 Civil Term Plaintiff, Amount Due: 1$,330.17 V. Interest: From Sept. 14, 2004 Atty's Commission: JAMES E. PETTYJOHN, Costs: All May, Costs and Sheriff Costs and Defendant. Associated Costs for this Execution TO THE PROTHONOTARY OF THE SAID COUNTY: 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 WRIT OF EXECUTION . 50W LOOJW, 'brive, N4&c4, PA (10W Issue WRIT OF EXECUTION in the /epposits, matter to the Sheriff of CUMBERLAND COUNTY, for debt, interest and costs uporr the folldescribed property of the defendant: levy All banking, savings, checking accounts, certificates of and monies located at any and all branches of MEMBERS 1sT FEDERAL CREDIT UNION and levy on all furniture, electronic equipment, jewelry, tools, supplies, furnishings, and property located at Defendant's residence of 629 NORTH HANOVER STREET, CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, 17013. COYNE & COYNE, P.C. Date: to 2 O By: ?-- S MARIE CO , ESQUIRE P .. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney for the Plaintiff ?,? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3139 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COYNE & COYNE, P.C., Plaintiff (s) From JAMES E. PETTYJOHN, 629 North Hanover Street, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell all furniture, electronic equipment, jewelry, tools, supplies, furnishings, and property located at Defendant's residence. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FEDERAL CREDIT UNION, 5000 Louise Drive, Mechanicsburg, PA 17055 All banking, savings, checking accounts, certificates of deposits, and monies located at any and all branches. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $1,330.17 Interest from 9/14/04 Atty's Comm % Atty Paid $117.60 Plaintiff Paid Date: 10/23/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs - R"r-0-4# C s R. Long o 0 By: Deputy REQUESTING PARTY: Name LISA MARIE COYNE, ESQUIRE Address: COYNE & COYNE, P.C. 3901 MARKET STREET CAMP HILL, PA 170114227 Attorney for: PLAINTIFF Telephone: 717-737-0464 Supreme Court ID No. 53788 COYNE & COYNE, P.C. Lisa Marie Coyne, Esquire Supreme Ct. No, 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 COYNE & COYNE, P.C., Plaintiff V. JAMES E. PETTYJOHN, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-03139 CIVIL TERM CIVIL ACTION - LAW Interro atories to Garnishee Members 1St Federal Credii Union To: Members 1St Federal Credit Union, Garnishee 5000 Louise Drive Mechanicsburg, PA 17055 IMPORTANT NOTICES TO Members 1St Federal Credit Union, GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. B. The term "Defendant" means the individual against whom the Writ of Execution issued. C. "You" means the main office and all branch offices of Members 1St Federal Credit Union. D. By service of the Writ of Execution upon you, all property of the Defendant subject to attachment which was then in your possession, custody or control was attached, including all property of the Defendant which comes into your possession thereafter. COYNE & COYNE, P.C. Dated: o b 00o By: ILis e Coyne, squire Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. Supreme Ct. No. 53788 INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? If so, identify in detail. (I, 2. At the time you were served or at any subsequent time were there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? If so, identify in detail. ((v 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? If so, identify in detail. r b 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? If so, identify in detail. (IC> 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefore? 6 n 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? If so, identify in detail. n c,, 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify in detail each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 120 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. 8123. If so, identify each account in detail and the amount deposited or held in the account and how the account is titled. 12c, MEMBERS 1 ST FEDERAL CREDIT UNION. Dated: 01,31100 By: &,, (SEAL) (Name) (Title) (? ?f^i(; VERNIC 17ION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unswom falsification to authorities under 18 Pa. C.S.A. 94904. Dated:10131 og ? `? ^,., } 3 .? :°. :'°i T?f ?ti?a. SHERIFF'S RETURN - GARNISHEE CASE N0: 2001-03139 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND COYNE & COYNE P C VS PETTYJOHN JAMES E And now KENNETH GOSSERT ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:35 Hours, on the 30th day of October , 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT PETTYJOHN JAMES E hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to LOTTIE LOE (HEAD TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge in the true and made So answ .00 .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 ? ?o5?b P ?, . 00 11/04/2008 19 /7 Sworn and Subscribed to before me this day of By A.D COYNE & COYNE, P.C. Lisa Marie Coyne, Esquire Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney for Plaintiff COYNE & COYNE, P.C., Plaintiff V. JAMES E. PETTYJOHN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-03139 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark this Judgment as Paid and Satisfied. Date 1c) 0 COYNE & COYNE, P.C. By: ?? Li A Marie Coyne, Esquire Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 170114227 (717) 737-0464 Attorney for Plaintiff C7 +? ?' ? ? ? l ^ "'^+ s ?^- ?i . ?+ ? J ?' j?„1 j ??' i r„ .? --'? r R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Docketing 18.00 Poundage 2.41 Law Library .50 Prothonotary 2.00 Mileage 10.00 Surcharge 40.00 Levy 40.00 Postage .88 Garnishee 9.00 122.79 ? 4 f ox?o 4 ?, Advance Costs: 150.00 Sheriff's Costs: 122.79 27.21 Refunded on 05/27/09 So Answers, R. fornas Kline, Sloe Sharon R. Lantz h U:fl'V 8Z1?08001 c "Id 'A 1?rt1?? LL-n- 3Hi C' C) r a c? co } FI 0 w 4 /nta `?" C C snk WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3139 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COYNE & COYNE, P.C., Plaintiff (s) From JAMES E. PETTYJOHN, 629 North Hanover Street, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell all furniture, electronic equipment, jewelry, tools, supplies, furnishings, and property located at Defendant's residence. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FEDERAL CREDIT UNION, 5000 Louise Drive, Mechanicsburg, PA 17055 All banking, savings, checking accounts, certificates of deposits, and monies located at any and all branches. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $1,330.17 Interest from 9/14/04 Atty's Comm % Atty Paid $117.60 Plaintiff Paid Date: 10/23/08 L.L. $.50 Due Prothy $2.00 Other Costs C s R. Lon ono (Seal) By: Deputy REQUESTING PARTY: Name LISA MARIE COYNE, ESQUIRE Address: COYNE & COYNE, P.C. 3901 MARKET STREET CAMP HILL, PA 170114227 Attorney for: PLAINTIFF Telephone: 717-737-0464 Supreme Court ID No. 53788