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HomeMy WebLinkAbout01-04720RAYMOND C. GIZANDON, JR., Plaintiff KENNETH HOY IN THE COURT OF CONIMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Defendant TO: Kenneth Hoy, Defendant ~~~~~~~~ You are hereby notified that on August ~, 2001, a Judgment in the amount of $3,261.50 has been entered against you in the above-captioned case. Date: ~) ~, ~~~.~. Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: Kenneth Hoy 175 Beacon Hill Drive New Cumberland, PA 17070 Kenneth Hoy, Defendido/a Por este medio se le esta notificando que el de August de12001, eUla siguient Fallo ha lido anotado en contra suya en el caso mencionado en el epigrafe. Fallo $3,261.50. Fecha: Protonotario Certifico que la siguiente direccione es la del defendido/a segue indicada en el certificado de residencia: Kenneth Hoy 175 Beacon Hill Drive New Cumberland, PA 17070 Thom s O. Williams Abogado del Demandante RAYMOND C. GRANDON, JR., Plaintiff KENNETH HOY v. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: CIVIL ACTION -LAW Pursuant to Pa.D.J.R.C.P. 402(D) and the attached certified judgment of the Honorable Charles A. Clement, Jr., please enter judgment against Kenneth Hoy and in favor of Plaintiff Raymond C. Crandon, Jr. in the amount of $3,261.50. Date: ~ ~~ Respectfully submitted, REAGER & ADLER, P.C. TH(SMAS O. WILLIAMS, ESQUIRE Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 (717)763-1383 Attorneys for Plaintiff COMMONWEALTH OF PENNSYLVANIA rnl INrv nF~ CUHIDSRLAND 09-1-01 DJ Name: Hon. CHARLS3 A. CLi~ffiVT, JR. Adtlrasa: 1106'CARLISLS ROAD CAMP HILL, PA Telephone: (717) 761-4940 17011 NOTICE OF 3UDGMENT/TRANSCRIPT RESIDENTIAL LEASE PLAINTIFF: NAME antl ADDRESS ~GRANDON JR, RAYMOND C 300 HOWL AVS LSMOYNS, PA 17043 L -I VS. DEFENDANT: NAME and ADDRESS ~RSNNSTH HOY/FAIRFISLD INN ~ 175 BEACON HILL BLVD LNSW COMBERLAND, PA 17070 J RAYMOND C. GRANDON JR 300 HUlvIl~lEL AVS DocketNo.: LT-0000331-01 LSMOYNS, PA 17043 Date Filed: 6/14/01 THIS IS TO NOTIFY YOU THAT: Judgment: FOR PLAINTIFF Judgment was eritered for: (Name) GRANDON SR, RAYMOND C Judgment was entered against RSNNETH HOY/FAIRFISLD INN in a 0 Landlord/Tenant action in the amount of $ 3, 261.50 on 6/25/01 (Date of Judgment) The amount of rent per month, as established by the District Justice, is $ 400.00, The total amount of the Security Deposit is $ . 00 Total Amount Establish d bb pJ Loess ~ Security Deposit Apit~~li d Rent in Arrears $ ~, 75.0 - $ •D~ - Physical Damages Leasehold Property $ 1,400.00 $ .00 barrages/Unjust Detention $ _ 00 - $ _ 00 - Less Amt Due Defendant from Cross Complaint - Interest(if provided by lease) UT Judgment Amount Attachment Prohibited/ Judgment Costs Victim of Abuse (Act 5, 1996) Attorney Fees This case dismissed without prejudice. ~X Possession granted. Possession granted if money judgment is no sa is ie y ^ Possession not granted. Levy is stayed for days or ~ generally stayed. Objection to Levy has been filed and hearing will be held: Total Judgment Past Judgment Credits Post Judgment Costs Certified Judgment Total Adjudicated $rr~ous0 $ 7 1,400.00 $ _00 $ _00 $ _nn $ 3 180_00 $ 81.50 $ _on $ 3,.261.50 Defendants are jointly and severally liable. IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEALOF THE MONEY JUDGMENT, IF ANY. IN ORDER TO OBTAIN A SUPERSEDERS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS 3D DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF - COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THE PARTY FILING AN APPEAL M1(~ T WC,,L~U/q~~~A C/~;Y NO .Jy_p//~M~ENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL. _ 6/25/2001 Date \~'~/~'u<xKl L1 X9ad: • _ .District Justice 8-7-O1 Date My commission expires first Moriday of January, 2002 Anar. aisA.ea District SEAL ~ ~~ ~ ~ ~ ~/ R.> n~CO 1 c ~ ~~ ~~~ m z a ~~~ ~ „~,y r <~ ~ ; ~ z~ A~% `; _ ,_ < '~ t)~f ~~ ~ "f f f7 ,`~i7 .t ~" - ~ ' ~ --- aw.-.~...,., _. ~. -. ~y n~a+z~;y-cos a3 run•'"'~"P3'R3~RMk~'% , PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENT) P.R.C.P.3101 TO 3149 RAYMOND C. GRANDON, JR. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Term 20 Writ No. nn No, n/- 'y~a.~ l'i~i~ Term 20 V Amount due $3.261.50 KENNETH HOY, Interest $ Defendant Atty's Comm. $ o.oo and Costs as of 8/8/01 8173.76 Total $3 , 435 , 26 TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Kannath Hoy of 17n Raarnn Hill Rnnlevard,flew Cumberland Pennsylvania 17070 Defendant(s); (3) and against Fairfield Inn at 175 Beacon Hill Boulevard,~ew Cumberland, PA 17070 (4) and index this writ (a) against (b) against Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff. Furnish 4 copies for real estate levy) (5) Exemption has (not) been waived. Date: ~U ~d 0 Garnishee(s); Defendant(s) and ` ~., Attorney for Plaintiff(s) ti `4 R.1 ~e ~ C ~ n C~ ^I :V -.~' ~4 ~~ ~~ ~ ^ -`~~A `' f rte- ~ C) 'c ~ rs ~t - Tp j ~ ~~ ~~ _ , _ , ~ ^~, lr ~ i, l T C !v y: fT . _. _ .. _ ,.. .. .. .. _ ~',m.~z. r .. sr ..^Y.npr,~~nii'1~; r~M1...y.~r':ar^a~eegav ~... „_ ~ VV~~IT'Q,P EXECUTION and/or ATTACHMEPf~ COMMONWEALTH OF PENNSYLVANIA) NO. Q1-4720 CIVIL ~ ?E~ COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due _ Raymond C. Crandon, Jr. __ PLAINTIFF(S) from_ Kenneth H~5 Beacon Hill Boulevard, New Cumberland, PA 17070 - (1) You are directed to levy upon the properly 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 Fairfield Inn at 175 Beacon Hill Boulevard, New Cumberland, PA 17070 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) If propertyoithedefendant(s)notlevieduponansubjecttoattachmentisioundinthepossessionofanyoneother than a named garnishee, you are directed tonotify him/herihat he/she has been added as a garnishee and is enjoined as above stated. Amount Due___ $3,261.50 Interest Atty's Comm Atty Paid Plaintiff F Date: ______ Aucrust 9. 2001 REQUESTING PARTY: Name Thanes O. Williams, Esq. Address: 2331 Market Street Camp Hill, PA 17011-4642 Attorney for: Plaintiff Telephone: 717-763-1383 L.L. $.50 Due Prothy- Other Costs Curtis R. bong ~~~~~ ~ Prothonotary, Civil Division Deputy TRUE COPY FROM RECORD in Testimony whereof, i bare unto set my hand and the se I of said Court at Carlisle, Pa. Thi day o-~'f-.- Qro honotar~ 67987 Supreme Court ID No '.; "' ~~~ _ ~ w -_ _ ., 9 ~,,~t,.,° l~~~t~~:9 v:. ~ ~ ~i'~~ t:C ~ ~ l ~t!4~ ~* ~„~~,~~,,x.=., ~~s~-~ ..:. , ,,,; a r.;,,. ~~ ,ss. t~ ~~~ _~~~. ~! ~* R. Thomas Kline, Sheriff, who being duly swc'~ccord~i~g' , ~ Y, states this writ is returned STAYED. ~~ ~ 67 I3y~ ~(~ Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Garnishee Sheriff's Costs: $ 7.8.00 .97 .50 1.00 20.00 9.00 ~- G J V Sworn and Subscribed to before me this ~ day of ,~Qe~°~ ~i"`~ 2001 A.D. ~ ~. ~ ~/ prothonotary f' E i { 'a `~l~eri°~s~t~sts: $ 154_ Refunded to Atty on 8/23/01 So Answers; ~? R. Thomas Kline, Sheriff By ~-e`x-l/ 1•~v C82.. 3~~G`f ~. .,, ,~ „_ ~ _ n s" 4VR{T OF EXECUTION andfor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 01-4720 CIVIL #~ TES COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF Ctsnberland COUNTY: To satisfy the debt, interest and costs due Raymond C. Crandon, Jr. from Kenneth Hoy, 175 Beacon Hill Boulevard, New Ctnnberland, PA 17070 (t) You are directed to levy upon the property of the defendant(s) and to DEFENDANT(S) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Fairfield Inn at 175 Beacon Hill Boulevard, New Cumberland, PA 17070 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) islare enjoined ftotn,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 propertyofthedefendant(s)notlevieduponansubjecttoattachmentis(oundinthepossessionofanyoneother than a named garnishee, you are directedto notify himlherthat helshe has been added as a garnishee and is enjoined as above stated. Amount Due $3, 261.50 Interest Atty's Comm Atty Paid Plaintiff Paid Date: m~~,st 9. 2001 REQUESTING PARTY: Name Address 2331 Market Street C~no Hill, PA 17011-4642 Attorney for: Plaintiff L.L. ~ $.50 Due Prothy Other Costs S173.76 Curtis R. Long Prothonotary, Civil Division Deputy Telephone: _717-763-1383 Supreme Court ID No.~ x6=7987 ~ . ~'~ !. Thanas 0. Williams, Esq. RAYMOND C. GRANDON, JR., Plaintiff ~. KENNETH HOY, FAIltFIELD INN, Defendant Garnishee TO: Fairfield Inn, Garnishee 175 Beacon Hill Boulevard New Cumberland, PA 17070 J~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW Pursuant to Rule 3144 of the Pennsylvania Rules of Civil Procedure, 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. 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 him any money or were liable to him for any reason? If your answer is yes, please state the amount you claim you owed the Defendant and describe what contract or transaction it relates to. C ] S ~ .~ 2. At the time you were served, or at any subsequent time, was 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? 2 S ( ) ~ t ~ 3. At the time you were served, did the Defendant maintain any savings, checking or any other type of account with-you or with regard to which the Defendant was a signatory? If your answer is yes, set forth separately for each such account the following: (a) The name or names in which the account is maintained; (b) The account number(s); (c) The balance of each account as of the date of service; (d) The date the account was first opened; and (e) The name and address of each signatory to the account(s). ANC~_ 3 .~ ? 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which Defendant had an interest? If your answer is yes, please specify the property. h~ 5. At any time after you were served, did you pay, transfer or deliver any money or property to any person or entity in which Defendant had an interest? ~' q At the time you were served or at any subsequent time, did you have or share any safe- deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, or collateral in which there was an interest claimed by defendant(s)? 6 ,,_ . ~„ ~` ,k Identify every account (not previously noted), titled in the name of defendant(s) or in which you, believe defendant(s) have an interest in whole or part, whether or not styled as a payroll account, individual retirement account, tax account, lottery account, partnership account, joint or tenants by entirety account, insurance account, trust or escrow account, attorney's account or otherwise. Include in yoiii' answer the amount or value of each account. 7 n 8. At the time you were served with these interrogatories, or at any subsequent time, did you employ Defendant Kenneth Hoy? If your answer to this interrogatory is yes state the following: a. The annual gross salary of Kenneth Hoy; b. The weekly or bi-weekly (as applicable) gross wage of Kenneth Hoy; c. The net weekly or bi-weekly (as applicable) wages of Kenneth Hoy after deductions for taxes, medicare, FICA and other government deductions and union dues; and d. How often you pay Kenneth Hoy. 8 ' , ,~ .~ 9. State in dollars what would be 10% of Kenneth Hoy's weekly wage. REAGER & Date: August 7, 2001 By: THOI4IAS O. WILLIAMS, ESQUIRE Attorney LD. No. 67987 2331 Market Street Camp Hill, PA 17011-4642 (717)763-1383 Attorneys for Plaintiff « .~ I, ,hereby verify that I am the of Fairfield Inn and, as such, I am authorized to verify the averments of the foregoing document are true and correct to my personal lrnowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: By: ~_. '., r RAYMOND C. GRANDON, JR., Plaintiff v. KENNETH HOY, FAIRFIELD INN, Defendant Garnishee TO: Fairfield Inn, Garnishee 175 Beacon Hill Boulevard New Cumberland, PA 17070 c IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTYn, PENNSYLVANIA CIVIL ACTION -LAW .' Pursuant to Rule 3144 of the Pennsylvania Rules of Civil Procedure, 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. 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 instniment, or did the Defendant claim that you owed him any money or were liable to him for any reason? If your answer is yes, please state the amount you claitn you owed the Defendant and describe what contract or transaction it relates to. At the time you were seraed, or at any subsequent time, was 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? ANSWER' . ~~ 3. At the time you were served, did the Defendant maintain any savings, checking or any other type of account with you or with regard to which the Defendant was a signatory? If your answer is yes, set forth separately for each such account the following: (a) The name or names in which the account is maintained; (b) The account number(s); (c) The balance of each account as of the date of service; (d) The date the account was first opened; and (e) The name and address of each signatory to the account(s). ANSWER: 3 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which Defendant had an interest? If your answer is yes, please specify the property. 5. At any time after you were served, did you pay, transferor deliver any money or property to any person or entity in which Defendant had an interest? 5 6. At the time you were served or at any subsequent time, did you have or share any safe- deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, or collateral in which there was an interest claimed by defendant(s)? ~~ Identify every account (not previously noted), titled in the name of defendant(s) or in which you believe defendant(s) have an interest in whole or part, whether or not styled as a payroll account, individual retirement account, tax account, lottery account, partnership account, joint or tenants by entirety account, insurance account, trust or escrow account, attorney's account or otherwise. Include in your answer the amount or value of each account. At the time you were served with these interrogatories, or at any subsequent time, did you employ Defendant Kenneth Hoy? If your answer to this interrogatory is yes state the following: a. The annual gross salary of Kenneth Hoy; The weekly or bi-weekly (as applicable) gross wage of Kenneth Hoy; a The net weekly or bi-weekly (as applicable) wages of Kenneth Hoy after deductions for taxes, medicare, FICA and other government deductions and union dues; and d. How often you pay Kenneth Hoy. 8 i~ ~ ~ ~ Y 9. State in dollars what would be 10% of Kenneth Hoy's weekly «age. Date: August 7, 2001 By: REAGER & APSL1~Iil. P.C. / /i THOMAS 0. WILLIAMS, ESQUIRE Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011-4642 (717)763-1383 Attorneys for Plaintiff 9 I, ,hereby verify that I am the of Fairfield Inn and, as such, I am authorized to verify the averments of the foregoing document are true and correct to my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: By: :~~ 1 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANtA WRIT NO. CIVIL TERM WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment.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 $300. 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 rights. If you have an exemption, you should do the following promptly: (1) Fill out the attached claim form and demand for a prompt hearing. (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 TOYOUR LAWYER AT ONCE. IFYOU 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 x :. MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain Insurance proceeds 8. Such other exemptions as may be provided by law B E " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WRIT NO. CIVIL TERM CLAIM FOR EXEMPTION a) I desire that my $300 statutory exemption be L7 (i) set aside in kind (specify property to be set aside in kind): ~ (ii) paid in cash following the sale of the property levied upon; or b) I claim the following exemption (specify property and basis of exemption): To the Sheriff: I, the above named defendant, claim exemption of property from levy, or attachment: 1. From my personal property in my possession which has been levied upon, 2. From my property which is in the possession of a third party, I claim the following exemptions: a. my $300 statutory exemption: ~ in cash: Q in kind (specify property}: b. Social Security benefits on deposit in the amount of $ r ; . . c) other (specify amount and basis of exemption: I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at Address Telephone Number I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S. § 4904 relating to unsworn falsification to authorities. Date THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6390 ORDER OF COURT AND NOW, of Civil Procedure 3123.1(b), a hearing is set for pursuant to Pa. Rule in Court Room No. Cumberland County Courthouse, Carlisle, Pennsylvania. The Sheriff of Cumberland County shall notify the parties of the time and place for the hearing. By the Court, J. ' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N0. 01-4720 CIVIL %f~ TERM COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF Q.unberland __COUNTY. To satisfy the debt, interest and costs due Raymond C. Crandon, Jr. LAINTIFF(S) from Kenneth Hoy, 175 Beacon Hill Boulevard, New Ctunberland, PA 17070 DEFENDANT(S) (t) 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 Fairfield Inn at 175 Beacon Hill Boulevard, New Cumberland, PA 17070 GARNISHEE(S) as follows: and to nof'rfy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) islare 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) Itpropertyofthedefendant(s)notlevieduponansubjectfoattachmentisfoundinthepossessionofanyoneother than a named garnishee, you are directed to notify him/herthat he/she has been added as agarnishee and is enjoined as above stated. Amount Due $3, 261.50 Interest Atty's Comm Atty Paid Plaintiff F Date. Angrst 9 2001 REQUESTING PARTY: Name Thanas O. Williams, Address: 2331 Market Street Camp Hill, PA 17011-4642 L.L. $•50 Due Prothy_ Other Costs Curtis R. Long ~,~~~ /////~ Prothonotary, Civil Division Deputy In Testlrtfony ~uttereot,l ttere t~nta set qty t~at~d ~t1d t91e_at;~l of said C¢2tt?'$„~i ~~i13yI~, ~8. Attorney for: Plaintiff screoc.3aY u+~. s °~-f{\,~ Telephone: 717-763-1383 ~ /If)~, o f../ ~n~"l Pro#h otary Supreme Court ID No. 67982 ; _ __ ~- '- - _-_ _ s ~_..._.._ .. _ __... ¢' RAYMOND C. GRANDON, JR., Plaintiff KENNETH HOY, FAIRFIELD INN, v. Defendant Garnishee TO: Fairfield Inn, Garnishee 175 Beacon Hill Boulevard New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P/n~ENNSYLcV_,A_N_IA No.: (~ 1- '4°7,20 l~tv ~ ~ 1~2b~ CIVIL ACTION -LAW Pursuant to Rule 3144 of the Pennsylvania Rules of Civil Procedure, 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. At the time you were sen ed, 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 instnmient, or did the Defendant claim that you owed him any money or were liable to him for any reason? If your answer is yes, please state the amount you claim you owed the Defendant and describe what contract or transaction it relates to. 2. At the time you were served, or at any subsequent time, was 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? ~, 3. At the time you were served, did the Defendant maintain any savings, checking or any other type of account with you or with regard to which the Defendant was a signatory? If your answer is yes, set forth separately for each such account the following: (a) The name or names in which the account is maintained; (b) The account mmtber(s); (c) The balance of each account as of the date of service; (d) The date the account was first opened; and (e) The name and address of each signatory to the account(s). A1~,13: 3 :.f, 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which Defendant had an interest? If your answer is yes, please specify the property. 4 5. At any time after you were served, did you pay, transfer or deliver any money or property to any person or entity in which Defendant had an interest? 6. At the time you were served or at any subsequent time, did you have or share any safe- deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, or collateral in which there was an interest claimed by defendant(s)? Identify every account (not previously noted), titled in the name of defendant(s) or in which you believe defendant(s) have an interest in whole or part, whether or not styled as a payroll account, individual retirement account, tax account, lottery account, partnership account, joint or tenants by entirety account, insurance account, mist or escrow account, attorney's account or otherwise. Include in your answer the amount or value of each account. 7 8. At the time you were served with these interrogatories, or at any subsequent time, did you employ Defendant Kenneth Hoy? If your answer to this interrogatory is yes state the following: a. The annual gross salary of Kenneth Hoy; b. The weekly or bi-weekly (as applicable) gross wage of Kenneth Hoy; c. The net weekly or bi-weekly (as applicable) wages of Kenneth Hoy after deductions for taxes, medicare, FICA and other government deductions and union dues; and d. How often you pay Kenneth Hoy. 8 t 9. State in dollars what would be 10% of Kenneth Hoy's weekly wade. REAGER & Date: August 7, 2001 By: THOMAS O. WILLIAMS, ESQUIRE Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 1701 I-4642 (717) 763-1383 Attorneys for Plaintiff I, hereby verify that I am the of Fairfield Inn and, as such, I am authorized to verify the averments of the foregoing document are true and correct to my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of I8 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: By: . ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WRIT NO. CIVIL TERM WRIT OF EXECUTION NOTICE This paper iS a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. 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 $300. 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 rights. If you have an exemption, you should do the following promptly: (1) Fill out the attached claim form and demand for a prompt hearing. (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 WHEREYOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 .. , MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain Insurance proceeds 8. Such other exemptions as may be provided by law ,. ,. IN THE COURT OF CQMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WRIT NO. CIVIL TERM CLAIM FOR EXEMPTION a) I desire that my $300 statutory exemption be O (i) set aside in kind (specify property to be set aside in kind): Q (ii) paid in cash following the sale of the property levied upon; or b) I claim the following exemption (specify property and basis of exemption): To the Sheriff: I, the above named defendant, claim exemption of property from levy, or attachment: 1. From my personal property in my possession which has been levied upon, 2, From my property which is in the possession of a third party, t claim the following exemptions: a. my $300 statutory exemption: O in cash: ~ in kind (specify property): b. Social Security benefits on deposit in the amount of $ ,~,r i ,. c) other (specify amount and basis of exemption: I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at Address Telephone Number I verify that the statements made in this Claim for Exemption are true and correct.) understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6390 .~M ORDER OF COURT AND NOW, of Civil Procedure 3123.1(b), a hearing is set for pursuant to Pa. Rule in Court Room No. Cumberland County Courthouse, Carlisle, Pennsylvania. The Sheriff of Cumberland County shall notify the parties of the time and place for the hearing. By the Court, J. WRIT QF EXECUTION and/or ATTACHMENT ' e r COMMONWEALTH OF PENNSYLVANIA) NO. 01-4720 CIVIL ~ TEt~1 COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF _ Ctunberland --COUNTY: To satisfy the debt, interest and costs due Raymond C. Crandon, Jr. PLAINTIFF(S) from Kenneth Hoy, 175 Beacon Hill Boulevard, New Cumberland, PA 17070 DEFENDANT(S) (t) You are directed to levy upon the property of the defendant(s) and to (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Fairfield Inn at 175 Beacon Hill Boulevard, New Ctmtberland, PA 17070 GARNISHEE(S) as follows: and to notrfy 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) IfpropeAyofthedefendant(s)notlevieduponansubjecttoattachmentisfoundinthepossessionofanyoneother than a named garnishee, you are directed tonotify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3, 261.50 IntP.rest Atty's Comm L.L. $•50 Due Prothy Other Costs Atty Paid Plaintiff Paid Date: Aurnrst 9. 2001 REQUESTING PARTY: Name Thcrnas O. Williams, Esq. Address: 2331 Market Street Camp Hill. PA 17011-4642 Attorney for: Plaintiff Telephone: 717-763-1383 _ Curtis R. Long _~~~~ ~ Prot`/h/~onot~ary~, C~iJvil Division ~L-?LCLM~ r /~~IZ/1~ Deputy TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Cour~.,at Carlisle, Pa. SuQrefne Cold ID No 67987: ,; s ~ r . ;;'~. ..~ s RAYMOND C. GRANDON, JR., Plaintiff KENNETH HOY, FAIRFIELD INN, v. Defendant Garnishee TO: Fairfield Itm, Garnishee 175 Beacon Hill Boulevard New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: O (- ~Z~O etUlC ~~~ CIVIL ACTION -LAW Pursuant to Rule 3144 of the Pennsylvania Rules of Civil Procedure, 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. 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 him any money or were liable to him for any reason? If your answer is yes, please state the amount you claim you owed the Defendant and describe what contract or transaction it relates to. ANSWER: At the time you were served, or at any subsequent time, was 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 natrire owned solely or in part by the Defendant? ANSWER: 2 "F.. 3. At the time you were served, did the Defendant maintain any savings, checking or any other type of account with you or with regard to which the Defendant was a signatory? If your answer is yes, set forth separately for each such account the following: (a) The name or names in which the account is maintained; (b) The account number(s); (c) The balance of each account as of the date of service; (d) The date the account was first opened; and (e) The name and address of each signatory to the account(s). 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which Defendant had an interest? If your answer is yes, please specify the property. Y ~ At any time after you were served, did you pay, transfer or deliver any money or property to any person or entity in which Defendant had an interest? ~. 6. At the time you were served or at any subsequent time, did you have or share any saf8- deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, or collateral in which there was an interest claimed by defendant(s)? L r Identify every account (not previously noted), titled in the name of defendant(s) or in which you believe defendant(s) have an interest in whole or part, whether or not styled as a payroll account, individual retirement account, tax account, lottery account, partnership account, joint or tenants by entirety account; insurance account, trust or escrow account, attorney's account or othern ise. Include in your answer the amount or value of each account. 8. At the time you were served with these interrogatories, or at any subsequent time, did you employ Defendant Kenneth Hoy? If your answer to this interrogatory is yes state the following: a. The annual gross salary of Kenneth Hoy; b. The weekly or bi-weekly (as applicable) gross wage of Kenneth Hoy; The net weekly or bi-weekly (as applicable) wages of Kenneth Hoy after deductions for taxes, medicare, FICA and other government deductions and union dues; and d. How often you pay Kenneth Hoy. .~ State in dollars what would be 10% of Kenneth Hoy's weekly wage. REAGER & Date: August 7, 2001 By: THOMAS O. WILLIAMS, ESQUIRE Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011-46A2 (717) 763-1383 Attorneys for Plaintiff I, ,hereby verify that I am the of Fairfield Inn and, as such, I am authorized to verify the averments of the foregoing document are true and correct to my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Date: By: Y ~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WRIT NO. CIVIL TERM WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. 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 $300. 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 rights. If you have an exemption, you should do the following promptly: (1) Fill out the attached claim form and demand for a prompt hearing. (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 TOYOUR LAWYER AT ONCE. IFYOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHEREYOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 r y. . ' ~ ~ , " MAJOR EXEMPTIONS UNDER " PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain Insurance proceeds 8. Such other exemptions as may be provided by law :~ ~„ IN THE COURT OF COMMON PLEAS OF y C CUMBERLAND COUNTY, PENNSYLVANIA WRIT NO. CIVILTERM CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy, or attachment: 1. From my personal property in my possession which has been levied upon, a) I desire that my $300 statutory exemption be 2. ~ (i) set aside in kind (specify property to be set aside in kind): Q (ii) paid in cash following the sale of the property levied upon; or b) I claim the following exemption (specify property and basis of exemption): From my property which is in the possession of a third party, I claim the following exemptions: a. my $300 statutory exemption: ~ in cash: L7 in kind (specify property): b. Social Security benefits on deposit in the amount of $ ~. y• n . . • ~ c) other (specify amount and basis of exemption: I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at Address Telephone Number I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6390 .-' •, r= . w ~~ ORDER OF COURT AND NOW, of Civil Procedure 3123.1(b), a hearing is set for pursuant to Pa. Rule in Court Room No. Cumberland County Courthouse, Carlisle, Pennsylvania. The Sheriff of Cumberland County shall notify the parties of the time and place for the hearing. By the Court, J.