HomeMy WebLinkAbout01-04586
JSK LABORATORIES AND : IN THE COURT OF COMMON PLEAS OF
TECHNICAL SERVICES, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
G&R CONSTRUCTION COMPANY, INC.,
Defendant No. d) -,qqx etc; ?.
PRAECIPE TO ENTER APPEARANCE
AND TO ENTER DISTRICT JUSTICE JUDGMENT
TO THE PROTHONOTARY:
Please enter my appearance on behalf of plaintiff, JSK
Laboratories and Technical Services, in the above-captioned
matter.
Please enter a $5,678.50 judgment in favor of
plaintiff, JSK Laboratories and Technical Services, and against
defendant, G&R Construction Company, Inc., as authorized by the
attached District Justice judgment.
4radfo d Dorrance
I.D. No. 32147
KEEFER WOOD ALLEN & RAHAL, LLP
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8014
(Attorneys for Plaintiff)
III
A`COMMONWEALTH OF PENNSYLVANIA
rni INITv np:- CUMBERLAND
Mag. Dist. No.:
09-1-01
DJ Name: Han.
CHARLES A. CLEMENT, JR.
Address: 1106 "'CARLISLE ROAD
CAMP HILL, PA
Telephone: (717) 761-4940 17011
ATTORNEY FOR PLAINTIFF :
KEEPER WOOD ALLEN & RAHAL, LLP
P.O. BOX 11963
BRADFORD DORRANCE, ESQ.
HARRISBURG, PA 17108-1963
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASE
NAME and ADDRESS
FUSK LABORATORIES AND TECHNICAL SVC?
C/O 3705 TRINDLE ROAD
CAMP HILL, PA 17011
L J
VS.
DEFENDANT: NAME and ADDRESS
rG&R CONSTRUCTION COMPANY, INC.
P.O. BOX 133
DOVER, PA 17315
L J
DocketNo.: CV-0000205-01
Date Filed: 4/10/01
THIS IS TO NOTIFY YOU THAT:
Judgment:
Fx] Judgment was entered for: (Name) .TeTC T.AnnRAmnRTRg AND Ti r- TCAT.
® Judgment was entered against: (Name) G&R C[O7N4TRTTC'TT0N COMPANY, TNC_
in the amount of $ 5, 678 - 5n on: (Date of Judgment) S/i 1 /Di
Defendants are iointly and severally liable. (Date & Time)
? Damages will be assessed on _
? This case dismissed without prejudice.::
E] Amount of Judgment Subject to
Attachment/Act 5 of 1996 $-
1-1 Levy is stayed for days or ? generally stayed.
Amount of Judgment $ 5; 5!
Judgment Costs $ 1
Interest on Judgment $
Attorney Fees $
Total $ 5,6
'
Post Judgment Credits
Post Judgment Costs
Certified Judgment Total
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 JUDGMI [ ,`,Y FlLlfy/(x NOTICE
.s,
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, Ck `DIVISION: V, 04
1I , MUST INCLUDEA COPY OF THIS NOTICE OF JUDGME?NT/TRANSCR T FORM WITH Yok bTIC6'xbF APPEAL
41
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w'Vµ.t'llCxKl ??.f??'Y"4'iv?V ?"
/1t1?CsCa2 Date:
Dlstric?sfice
I certify that this is a true n a rect co y of L tl}g re or the p n ntamif the,lue gmiOnt,
'.
7/27/2001 Date co 'vpfstric Justice
My commission expires first Monday of January, 2002 SEAL .
AOPC 315-99
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IN THE COURT OF OCMMON PLEAS OF CIDOW LAND OOURrY, PFMEnVANZA
CIVIL DIVISION
JSK LABORATORIES AND TECHNICAL SERVICES File No. nL - 49P6 UtiI? yy,
Amount Due $5,678.50
V.
G&R CONSTRUCTION COMPANY, INC.
V.
PNC BANK
4242 Carlisle Pike, Camp Hill, PA 17011
TO THE PROTHONOTARY OF THE SAID COURT:
Interest
: Atty's Comm
: Costs $179.25
Garnishee
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.
PRABCIM FOR EXECUTION
Issue writ of execution in the above matter to the Sheriff of York
County, for debt, interest and costs upon the following described property of the
defendant(s) All personal property owned by defendant.
PRAECIPE FOR ATPACHMETU FXE7CLMON
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 of lengthy personalty list)
All bank accounts of defendant in the possession, custody, or control of
garnishee, PNG Bank.
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a 1is pendens against
real estate of the defendant(s) described in the attached exhibit.
DATE : /O
Signature:
Print Name: B adford Dorrance, Esquire
Address: 210 Walnut Street. P. 0. Box 11963
Harrisburg, PA 17108-1963
Attorney for: Plaintiff, JSK Laboratories
and Technical Services
Telephone: (717) 255-8014
Supreme Court ID No.: 32147
Notes: If real property, supply six copies of description including improvements and an
original and copy of affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2001-04586 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
JSK LABORATORIES AND TECH SERV
VS
G & R CONSTRUCTION COMPANY INC
And now BRIAN BARRICK Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according
to law, at 0015:12 Hours, on the 8th day of August , 2001, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
G & R CONSTRUCTION COMPANY INC
hands, possession, or control of the within named Garnishee
PNC BANK 4242 CARLISLE PIKE
CAMP HILL, PA 17011
Cumberland County, Pennsylvania, by handing to
, in the
ROB STOVER (ADULT IN CHARGE)
personally 3 true and attested copies of the within
JUDGMENT - DJ and made the contents thereof known to His
Sheriff's Costs: So answers:
Docketing .00
Service .00 ? Z
Affidavit .00
Surcharge .00 R. Thomas Kline
.00 Sheriff f Cumberland Coun
00
00/00/0000
f
By A,44 ,
Deputy Sheriff
Sworn and subscribed to before me
this day of
A. D.
r thonotary
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED. , AS PER ATTORNEY.
Sheriff's Costs:
Docketing $
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Garnishee
18.00
1.56
.50
1.00:
9.75
20.00
20.00
9.00
77781-
Sworn and Subscribed to before me
this / Ltday of A0,0 =
2001 A.D.
pro onotary
Advance Costs: $ 150.00
Sheriff's Costs: 79.81
--7U--f7
Refunded to Arty on 12/1401
So Answers;
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R. Thomas Kline, Sheriff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 01-4586 CIVIL 1P TER1
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY
To satisfy the debt, interest and costs due JSK Laboratories and Technical Services
------- ------------- - - - ----- -,-, -PLAINTIFF(S)
from G&R Construction Company, Inc., P.O.Box 133, Dover, PA 17315
-DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
_ _pnrr• R.?^-!?r-a?a2 Carlsile Pike, a= Hill PA 17011 -- All bank accounts of defendant in
the possession „ct or control of_garnishee, PNC Bank.
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued, (b) the garnishee(s) is/are 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) ifpropertyof thedefendant(s) not levied uponan subjectto attachment isfound inthepossessionof anyoneother
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 $9-fi7R.50 L.L.
Interest
$.50
Due Prothy
Atty's Comm
Any Paid $31.75
Plaintiff
Date: August 1, 2001
Curtis R. Long
Prothonotary, Civil Division
Deputy
REOUESTING PARTY:
Name _ Rradfon9 Dorrance Esa.
Address: 710 walnut Street, P.O.BOx 11963
Harrish,ung PA 17108-1963
Attorney for: plaintiff
Telephone: 717-755-8014
TRUE COPY OM R Q
in Testimony wtlervot, j rwe unto &eit my hand
,+;fd the of said C " at Wk*. Pa.
I'h13Y _
$1.00
Other Costs $ Sn na garnishee
PROTHON. - 4,
F S -
WRIT OF EXECUTION-(MONEY JUDGEMENTS)
RULES P.R.C.P. 3101 to 3149
JSK LABORATORIES AND TECHNICAL SERVICES,,,, Writ No........ 04,5$4 ..........................Term u-,2110.1
c/o 3705 Trindle Rd. ... No ............................................... Term 19.......
Camp Hill, PA 17011 5 678 50
.............................. Amount Due ................................ _ g....r......:._..
N,ti (plus attorneys' fees,
interest, and.costs)
G&R CONSTRUCTION COMPANY, INC.
................................................................
P.O. Box 133
Dover PA 17315
VS.
FIRST UNION NATIONAL BANK
604 E. High St.
Carlisle, PA 17013 WRIT OF EXECUTION
Garnishee
NOTICE
This paper is a Writ of Execution. It has been issued because there is a judgement against you. It may cause your property to be
held or taken to pay the judgement. You may have legal rights to prevent your property from being taken. A lawyer can advise you more
specifically of these rights. If you wish to exercise your rights, you must act promptly.
The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of 5300 00
There are other exemptions which may be applicable to you. Attached is a summary of some of the major exemptions. You may have other
exemptions or other fights.
If you have an exemption. you should do the following promptly f 11 Fill out the attached claim form and demand for a prompt hear-
mg.! 2) Deliver the form or mail it to the Sheriff's Office at the address noted.
You should come to court ready to explain your exemption. If you do not come to court and prove your exemption, you may lose some
of your property.
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 or (800) 990-9108
r 1 - IN THE COURT OF CCMNDN PLEAS OF C[1EMAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
JSK LABORATORIES AND TECHNICAL SERVICES File No. 2001-04586
V. Amount Due $5,678.50
G&R CONSTRUCTION COMPANY, INC. Interest
V. Atty's Comm
FIRST UNION NATIONAL BANK Costs (unliquidated)
604 E. High St., Carlisle, PA 17013
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 E)®CUTION
Issue writ of execution in the above matter to the Sheriff of ---
County, for debt, interest and costs upon the following described property of the
defendant(s) All a - - ftfC?Idalft
PRAECIPE FOR ATTACMENT 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 of lengthy personalty list)
All bank accounts and other property of defendant in the possession, custody, or
control of garnishee, First Union National Bank.
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a !is pendens against
real estate of the defendant(s) described in the attached exhibit.
DATE: ux Signature:
Print Name: Bradford Dorrance, Esquire
Address: 210 Walnut Street, P.O. Box 11963
Harrisburg, PA 17108-1963
Attorney for: Plaintiff, JSK Laboratories
and Technical Services
Telephone: (717) 255-8014
Supreme Court ID No.: 32147
Notes: If real property, supply six copies of description including improvements and an
original and copy of affidavit of ownership (PaR.C:P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2001-04586 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
JSK LABORATORIES AND TECH SERV
VS
G & R CONSTRUCTION COMPANY INC
And now DAWN KELL , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according
to law, at 0015:31 Hours, on the 14th day of December , 2001, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
G & R CONSTRUCTION COMPANY INC in the
hands, possession, or control of the within named Garnishee
FIRST UNION NATIONAL BANK 604 E. HIGH ST
CARISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JILL MARLEY (CUSTOMER RELATIONS MANAGER)
personally 3 true and attested copies of the within
JUDGMENT - DJ and made the contents thereof known to Her .
Sheriffs Costs: So answers:
Docketing
Service .00
.00
ilr
Affidavit .00
Surcharge .00 R. Thomas Kline
.00 Sheriff of Cumberland County
.00
12/18/2001
(? ? f
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Deputy Sheriff
Sworn and subscribed to before me
this ZF iv, day of rtx?
pu( A.D.
t4
Prothonotary
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
JSK LABORATIES AND
TECHNICAL SERVICES
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
VS.
G & R CONSTRUCTION COMPANY, INC.
and
NO. 01-4586
FIRST UNION NATIONAL BANK,
GARNISHEE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of First Union National Bank, Garnishee, in the
above-captioned matter.
Date: /J ?D p
Attorney for Garnishee
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SERLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
JSK LABORATIES AND
TECHNICAL SERVICES
VS.
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
G & R CONSTRUCTION COMPANY, INC.
and
FIRST UNION NATIONAL BANK
GARNISHEE
NO. 01-4586
TO: JSK LABORATIES AND TECHNICAL SERVICES, PLAINTIFF
1. No.
2. Yes, an account titled G & R Construction Inc. with a zero balance. This account has
been restricted pursuant to this writ.
1-6 No.
J C. SIRLIN
Attorney for Garnishee
Dated:_
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FON°
First Union National Bank
PA4418
Liens and Levies
5th and Market Streets
Philadelphia, PA 19106
verification
Kathleen Gormley, being duly sworn according to law, dep6ses and says that she is the
Writ of Execution Administrator of First Union National Bank, Garnishee herein, and
verifies that the statements made in the foregoing Answers to Interrogatories are true and
correct to the best of her knowledge. Said Garnishee understands that false statements
herein are made subject to penalties of IS Pa. C.S. Section 4904, relating to sworn
falsification to authorities.
6? ?"''?
Kathleen Gormley
Manager
Dated: f1-6-61
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SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
JSK LABORATIES AND TECHNICAL SERVICES : COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
vs.
G & R CONSTRUCTION COMPANY, INC. : NO. 01-4586
and
FIRST UNION NATIONAL BANK,
GARNISHEE
To: Bradford Dorrance, Esquire
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
X PRAECIPE FOR RULE OF NON PROS
_ JUDGMENT BY DEFAULT
_ MONEY JUDGMENT
JUDGMENT IN REPLEVIN
_ JUDGMENT FOR POSSESSION
_ JUDGMENT ON AWARD OF ARBITRATION
_ JUDGMENT ON VERDICT
JUDGMENT ON COURT FINDINGS
S
` SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
JSK LABORATIES AND TECHNICAL SERVICES : COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
VS.
G & R CONSTRUCTION COMPANY, INC. : NO. 01-4586
and
FIRST UNION NATIONAL BANK,
GARNISHEE
TO THE PROTHONOTARY:
Kindly enter a Rule upon Plaintiff to either seek judgment against Garnishee, First Union
National Bank under Rule 3143(g) or to place the issue between Plaintiff and Garnishee upon the list
for trial, or in the alternative, to suffer judgment of non pros against Plaintiff and in favor of
Garnishee, First Union National Bank.
Att(Ymey for Garnishee
Date:
{
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
JSK LABORATIES AND TECHNICAL SERVICES : COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
vs.
G & R CONSTRUCTION COMPANY, INC. : NO. 01-4586
and
FIRST UNION NATIONAL BANK,
GARNISHEE
TO THE PROTHONOTARY:
AND NOW, this "04 y of , 20QXa Rule is hereby granted upon Plaintiff
to seek judgment against Garnishee, First Union National Bank, under Rule 3143(g) or to place the
issue between Plaintiff, Defendant and Garnishee upon the list for trial within twenty (20) days after
the service hereof or to suffer Judgment of Non Pros against Plaintiff.
PROTHONOTARY
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JSK LABORATORIES AND
TECHNICAL SERVICES,
Plaintiff
V.
G&R CONSTRUCTION COMPANY, INC.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
No. 2001-04586
PRAECIPE TO DISCONTINUE GARNISHMENT
TO THE PROTHONOTARY:
Please discontinue the garnishment as to garnishee,
First Union National Bank.
r orrance
d f o
I.D. N 32147
KEEFER WOOD ALLEN & RAHAL, LLP
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8014
(Attorneys for Plaintiff)
CERTIFICATE OF SERVICE
I hereby certify that I have this day served a copy of
the foregoing document upon the person(s) and in the manner
indicated below:
First-Class Mail, Postage Prepaid
Addressed as Follows:
Marc Roberts, Esquire
149 E. Market Street
York PA 17403
(Attorney for Defendant)
Jon C. Sirlin, Esquire
1529 Walnut Street
Suite 600
Philadelphia, PA 19102
(Attorney for Garnishee, First Union)
Dated: 6
/ Bradford Dorrance
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 01-4586 CIVIL 14X TERM
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
l
TO THE SHERIFF OF ,_. __.-... Cumberland ---_---COUNTY:
To satisfy the debt, interest and costs due JSK Laboratories and Technical Services
PLAINTIFF(S)
from G&R Construction Carpa'y, Inc., P.O.Box 133, Dever, PA 17315
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to seft'
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
aC Bapk, 4242 Carlsile Pike, Ca= Hill, PA 7011 - All bank accounts of defendant in
the possessicin, custody. or, control of garnishee, PNC Bank.
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued, (b) the garnishee(s) is/are 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) It 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/he rthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due S5 67A.50
Interest
Atty's Comm %
L.L. $.50 ...
Due Prothy $1.00
Other Costs $ 50 dl le ga=iRree
Atty Paid $31.75
Plaintiff 0airt
Date: August 1, 2001
REOUESTING PARTY:
Name Ryw7 f= ra g?a=ce, Esa.
Address: 2.10 walnut Street. P.O.Box 11963
Har-rjsbjWg - PP.r 17108-1963
Attorney for: Pl A5 nt3 ff
Telephone: 7 L7-oSy_Rn J A.
Curtis R. Long
Prothonotary, Civil Division
Deputy
TRUE COPY FROM REOORD
in ??T((? y s m my ?wjt?ero said d, '., II twe tu?rt?o?-so fry bane
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',W.02M(?tw
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: Advance Costs: 150.00
Sheriff s Costs 73.81
Docketing 18.00 76.81
Poundage 1.44
Advertising
Law Library .50
Prothonotary 1.00
Mileage 3.25
Misc.
Surcharge 20.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage
Garnishee 9.00 J
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TOTAL So Answers,
73.19
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R. Thomas Kline, eriff
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