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Home My WebLink About99-028441 21? I y I f i •w lI e W I V ? V ? f.l r i JI. PATRICK F. LAUER, JR., IN THE COURT OF CONMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 99 - ' g24 .'. JOHN M. SALAPA, CIVIL ACTION Defendant 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 the Complaint and Notice are served, by entering a written appearance 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. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 PATRICK F. LAUER, JR., Plaintiff Va. JOHN M. SALAPA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - a 84' CIVIL ACTION COMPLAINT IN ACTION FOR BREACH OF CONTRACT AND NOW, comes the Plaintiff, Patrick F. Lauer, Jr., Esquire representing himself and respectfully avers the following: 1. The Plaintiff, Patrick F. Lauer, Jr., is an adult individual, who currently conducts business at his primary place of business which is 2108 Market Street, Cumberland County, Camp Hill, PA 17011. 2. The Defendant, John M. Salapa, is an adult individual whose last known address was 239 Walton Street, Lemoyne, Cumberland County, PA 17043. 3. On October 1, 1998, the Defendant requested Plaintiff's Law Office represent him and provide professional legal services. 4. Defendant signed a Retainer & Fee Agreement on October 1, 1998, which stated fees required for License Suspension Appeal Hearing, Arraignment and Trial. See Exhibit "A". 5. On October 16, 1998, Defendant signed another Retainer 6 Fee Agreement in regard to legal fees required for Arraignment and Trial. See Exhibit "B". 6. The Plaintiff provided legal services at the Defendant's request and performed the following services: A. The Plaintiff drafted and filed Defendant's Appeal From Suspension of Operator's Privilege. See Exhibit "C". B. The Plaintiff requested discovery from Mary Jo Mullen, ADA, Cumberland County District Attorney's Office. C. The Plaintiff drafted and filed Omnibus Pre-Trial Motion, November 7, 1998. D. The Plaintiff's associate appeared on behalf of Defendant at License Suspension Hearing November 23, 1998 at 1:30 PM. See Exhibit "D". E. The Plaintiff appeared with Defendant at Suppression Hearing January 5, 1999 in Judge Guido's Courtroom, and attended the Pre-trial conference that same day in Cumberland County Court. F. Plaintiff was prepared and ready to try this case when scheduled for Tuesday, January 19, 1999. However, the case was continued to the next term of Court. G. Defendant was again represented of the Pre-trial Conference February 23, 1999. See Exhibit "E". H. Plaintiff represented this Defendant at Trial during the March 8, 1999 trial term. See Exhibit "F". 1. Plaintiff represented Defendant at Sentencing Tuesday, April 27, 1999 at 1:30 PM in Judge Bayley's Courtroom. 7. The Plaintiff was sent a letter on March 19, 1999 stating the outstanding and over-due balance for legal services was $3,300.00 in regard to his case and payment plan was presented. See Exhibit "G". 8. Defendant has refused to compensate Plaintiff even though various fee agreements were signed by this Defendant and reminder letters were sent as represented in above exhibits offered. 9. Plaintiff provided Defendant services from October 1, 1998 until April 27, 1999. 10. The total outstanding balance remaining which is owed to the Plaintiff from the Defendant for Professional Attorney services rendered is $3,300.00. WHEREFORE, the Plaintiff requests Your Honorable Court award compensatory damages in the amount of $3,300.00, plus costs, and reasonable attorney fees to Plaintiff, with any other relief which the Court may deem appropriate. 6.1 Date: Respectfully Submitted: atrick F. ad-404LLauer, Jr., Esquire 2108 Market Street Camp Hill, PA 17011 (717) 763-1800 Supreme Ct. ID# 46430 VERIFICATION I, Patrick F. Lauer, Jr., state that I am the Plaintiff in the above-captioned case and that the facts set forth in the above COMPLAINT are true and correct to the best of my knowledge, information and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa C.S. 4904. P t ck F. Lauer, Jr J, Esquire DATED: Y',?7^f PATRICK F. LAUER, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 99 - JOHN M. SALAPA, CIVIL ACTION Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Complaint upon the person, and in the manner, indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Camp Hill, Pennsylvania, through first class mail, prepaid and addressed as follows: John Salapa 239 Walton Street Lemoyne, PA 17043 or, by HAND DELIVERY TO: John Salapa Cumberland County Prison 1101 Claremont Road Carlisle, PA 17013 Date • -? 7-(i trick F. Lauer, Jr., $squire 2Y08 Market Street, Aztec Building Camp Hill, Pennsylvania 17011 ID# 46430 Telephone (717) 763-1800 EXHIBIT A Y 1' TEMMWO orPAT8ZaRL4MMi 2lOB1IA1iX OMM AZWB CUM MIA P'ZTHlde0ANA 17011 PA 17018 (717) 701800 PAX 1717) MAW MI) 20*n 100.898?LAW • 48e.lobbs@lcset ; Yak PA 1M MV 801790 988 N 8eomd OWed I&Mhow J. MaW&MM Beq. 418 X. High Skut Saasb?asp, PA 17108 deemd B Wgbek zmq Duaosa=?PA UM 1717) 2MM47 Ck* to Camp H01 Ad&)W 1717) 8864®68 " RIS'FAI? 4 P7? AGRffie? The undersigned does hereby retain the Law Offices of Patrick F. Lauer, Jr., for representation on the following . charge(s): ?J _ cnrr ng o or about the ?`day County, Pennsyly nia. 192E, in _ he undersigned agrees to pay a retainer in the amount of S 670 , which is non-refundable, which sum is due immediately, which eh 11 be a li to the fallowing e schedule: 1. The sum of S •is for T4esentation at the '!a_04q ?a` Preliminary Hearing; 1.• Wn 2. The sum of/ S 3M -0 is to niYgotiate arraignment, and sentencing; o7721c? rep-ial motions are inc uded; -f-.3a?p?? = (oorT?• a? ja 7'a-? . 3. The sum of S. 3s if the case is litigated, i.e., pre-trial motions, arraignment, discovery, jury or npn- Jury; Fee is the-'same even if case results in a plea; W/ • r 4. Other , A_? LS 9a•JD) In addition thereto, the undersigned agrees to pay all costs associated with this action, including fees paid to expert witnesses,: photographers, investigators and for postage, copying and long distance calls. , I agree to pay and additional fee of addition representation regarding for '• r I understand that the Law Offices of Patrick F. Lauer, Jr. will begin work on any case when this amount has been paid and that no portion of this retainer fee is refundable to me. I further understand that if applicable, the additional fees must be paid not no later than fifteen (15) days prior to the date sat for any court appearance. If I do not pay the fees or cost as agreed, I understand the Law Offices of Patrick F. Lauer, Jr. will be relieved of any further obligation to represent me or to appear in court on my behalf and, in that event, I authorize him to'withdraw from my case. I have been advised. that my retainer is non-refundable. My fees subeequent to the retainer may be kefunded, lose any attorney time, paralegal time, and expenses at an hourly rate of $250.00 per hour. Hy fee schedule quoted 46'rein is only for those services listed. I specifically authorize the Law Offices Of Patrick F. Lauer, Jr. to take any action on my behalf, including the waiving of my right to a opeody trial or to a jury trial, if, in his opinion, my interests would be best served thereby. I further'understand that a 1.0% per month late charge will the due imposed on -ortion of hed above, 16anbalance d-I will fbehresponsible for any costs and reasonable attorney's fees incurred should collection procedures be necessary. I have read. and fully understand this contract and have discussed any questions I have with the Law Offices of Patrick F. Lauer, Jr. and I agree to its terms. I have received a copy of this contract. ? /) Dated this _ day of ,?/' J?x?^-----r l9 wit e s Tent Jam. M . EXHIBIT B 'F A , 8SUMMa 24son TM LAWUMMO PATRM?®-LUM® AL 20 . 49 S Dsi?s C YC%PASWU cm) solw9 AXWCWe Cased 4W N ?t 8t:eed 8oetkh?, PA 1 vd y?tbew J- F ?4 Dunmim%PAS Jamsb B. Wl?ehr, Fsq. cm) SEM47 M* to Cwp HM The undersigned does hereby retain the Law Offices of Patrick F. Lauer, Jr., for representation on the following charge(s): 0 cu ring o or about the ? day of ?? 19? . in - i?m? ?a County, Pennsylvania. The undersigned agrees to pay a retainer in the amount of g aw, 0) , which is non-refundablied hichhe following fee imanediately, and•which shall be app schedule: 1. The sum of $ _ is £or {Fopresentation `a?t tee ?%?/fd? Preliminary Hearing;. C /a'? 2. The sum of $ is o negotiate a plea, arraignment, and sentencing; No pre-trial motions are included; / 000. 3s if the case is litigated, 3. The sum of $? ent, discovery, jury or uon- i.o., pre-trial erotica:, arraignn? jury; Fee is the•same even if case results in a pleat • ? ? ? ?? q/ PIJO /?D ? 1?is ?.? /?4. ?/J 4 . Other . ?? r h?/n aia? 3 ?of???? _ In addition thereto, the undersigned agrees to pay all costs • associated with this action, including fees paid to exeercopying witnesses, photographers, investigators and for postaq , and long distance calls. for I agree to pay and additional fe of $ addition representation regarding . r I understand that the Law Offices of Patrick to Lauer, Jr. will begin work on my case when thin amount has been paid and that no portion of this retainer fee is refundable to me. I further understand that if applicable, the additional fees must be paid not no later than fifteen (15) days prior to the date set for any court appearance. If I do not pay the fees or cost as agreed, I understand the Law Offices of Patrick F. Lauer, Jr. Will be relieved of any further obligation to represent me or to appear in court on my behalf and, in that event, I authorize him to'withdraw from my case. I have been advised-that my retainer is non-refundable. Any fees subaegaant to the retainer may be 'refunded, less any attorney time, paralegal time, and expenses at an hourly rate of $250.00 per hour. listed fee schedule quoted 4erein is only for those services I specifically authorize the Law Offices of Patrick P. Lauer, Jr. to take any action on my behalf, including the waiving of my right to a speedy trial or to a jury trial, if, in his opinion, my interests would be best served thereby. I further.'understand that a 1.0% per month late charge will be imposed on any.portion of the balance of the fees not paid on the due date established above, and•I will be responsible for any costs and reasonable attorney's fees incurred should collection procedures be necessary. I have read and fully understand this contract and have discussed any questions I have with the Law Offices of Patrick P. Lauer, Jr, and I agree to its terms. I have received a copy of this contract. Dated this ?J day of ess lien BUMYT ll. u WMY MI. Pm Exhibit C umll THE LAW OFFICES OF PATRICK F. LAUER, JR. 2108 MARKET STREET, AZTEC BUILDING CAMP HILL, PENNSYLVANIA 17011 (717) 765.1800 FAX (717) 707.4247 1.800.822-4-LAW 892 N. Second Street Harrisburg, PA 17102 (717) 232-7747 Associate Counsel Matthew J. Eshelman, Esq. (Reply to Camp EM Address) 8 S. Hanover Street Carlisle, PA 17015 (717) 249.6971 November 18, 1998 John M. Salapa 239 Walton Street Lemoyne, PA 17043 Re: License Suspension Appeal Hearing 6 Balances Due for Representation Dear John: Please be advised your license suspension hearing is scheduled for Monday, November 23, 1998 at 2:00 PM in the Cumberland County Courthouse with Judge Guido. The fee for representation in this issue is $800.00, $500.00 of which has been paid leaving a balance due of $300.00 prior to the hearing. Additionally, you were to have paid $3000.00 at the time of your arraignment on October 20, 1998, $1,200.00 was paid on October 16, 1998 leaving a balance of $1,800.00 to be paid within 30 days. I will not file the pre-trial Motions until this balance is paid. At present you owe the firm $500.00 for the license suspension hearing, and an $1800.00 balance from the arraignment to negotiate this case. Should you decide to go to trial as noted on your fee agreement the cost is an additional $3000.00. I must have the balance due for the license suspension hearing prior to Monday 23, 1998. Please contact me immediately. Very truly you/rs:, ?a ?tcL t a r?,- Patrick F. Lauer, Jr., Esq. PFL/jak :?rf i e -- UNUT"6 sum, o, w W4 Exhibit D am,, THE LAW OFFICES OF PATRICK F. LAUE% JR. 2108 MARKET STREET, AT= BUILDING CAMP HII.L, PENNSYLVANIA 17011 (717) 764-1800 FAR (717) 7051247 1-800.822-4-LAW 832 N. Second Street Associate Couawl Harrisburg, PA 17102 Matthew J. Eshelman Esq. 8 S. Hanover Street (717) 232-7747 (Reply to Camp Hill Address) CarE* PA 17013 (717) 240.0071 November 19, 1998 John M. Salapa 239 Walton Street Lemoyne, PA 17043 Re: Comm. v. John Salapa Balances Due for Representation Dear John: I understand you will have the $300.00 balance due for the license suspension hearing on Monday, November 23, 1998 at 2:00 PM. My associate, Matthew J. Eshelman, Esquire will do this hearing arv1 he will meet you in the Cumberland County Courthouse on the 4t1j floor at 1:30 PM. You can give him the monies due at that time. As far as the balance of $1,800.00, which is due regarding representation in this case also, I will agree to you paying $1,000.00 by Wednesday, November 25, 1998, and you have agreed to pay the remaining $800.00 by Friday, December 4, 1998. I will file the Motions on time expecting you will honor your commitment to pay the fees necessary for this work to be done. I will expect the first payment by November 25th. Very truly yours, Patrick F. Lauer, Jr., Esq. / PFL/' i cc • f, e EXHIBIT E TEE LAW OFFICES OF PATRICK F. LAVER, JR. 2108 MARKET STREET, AZTEC BUII.DING CAMP EII.L, PENNSYLVANIA 17011 (717) 763.1800 FAR (717) 708.4247 1-800-822-4-LAW 932 N. Second Street Hamislnng, PA 17102 (717) 232-7747 Associate Couwl Matthew J. Eshelmsn, Esq. (Reply to Camp HM Address) 8 S. Hanover Street Carlisle, PA 17015 (717) 240.6971 January 19, 1999 John M. Salapa 239 Walton Street Lemoyne, PA 17043 Re: Comm. v. John Salana Balance Due for Representation Dear John: I want to confirm the new date for your Pre-trial Conference is February 23, 1999 at 9:00 AM at the Cumberland County Courthouse. The trial date will be March 8, 1999. Please be advised you must have all monies paid by the Pre- trial Conference date of February 23, 1999. This continuance has given you some extra time to pay-off your balance of $3,300 which must be paid. Very truly yours, Patrick F. Lauer, Jr., Esq. PFL/jak cc: ile ; EXHIBIT F Q." S-, ,f14 L xxP/ Jk eurveer i[o Sumr ml a mm t .. r ? mueu Exbfbft a THE LAW OFFICES OF PATRICK F. LAUER, JR. 2108 MARKET STREET, AZTEC BUILDING CAMP HILTh PENNSYLVANIA 17011 (717) 763.1800 FAX (717) 763-4247 1-800-822-4-LAW 932 N. Second Street Harrisburg, PA 17102 (717) 232-7747 Associate Counsel Matthew J. Eshelman, Esq. (HePIY to Camp Hill Address) March 19, 1999 John M. Salapa 239 Walton Street Lemoyne, PA 17043 Re: Comm. v. John Salapa Balance Due for Representation Dear John: 8 S. Hanover Street' Carlisle, PA 17013 (717) 249.6971 Please be reminded of the agreement you signed March 9, 1999 regarding your balance due of $3,300.00, attorney fees for services rendered. This balance was to have been paid prior to your case going to trial March 8, 1999. Please be reminded, I have your signed agreement regarding this debt, a copy of which is enclosed for your records. I encourage you to begin making payments on this balance, as you stated in the agreement you signed, immediately. You agreed to pay this balance off in full within 60 days, from the date you signed the agreement, which is a May 8, 1999 deadline. You now have seven (7) weeks left in which to pay off this debt. You could pay $500.00 a week for six weeks, and then one payment of $300.00 for the final payment. However, you may pay the payments as you wish just so they are paid in a timely and regular manner until paid in full by May 8th. I expect your payments to begin imminently. Very truly yours, Patrick F. Lauer, Jr., E PFL/jak sq. cc: file enclosure ti ^ LL ? / {• C J ry `i? 1 l r _ L ; 1L C 7 CJ'. iJ U I ?, v a ti w? ? s QI y rl? rig 9 m u•?iri kid tO S =^ C x U t o S ? f ) .?. ° < E C y 1 N V W a t 'b, , . ? 1 SHERIFF'S RETURN - REGULAR CASE NO: 1999-02844 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LAUER PATRICK F JR VS. SALAPA JOHN M DAWN KELL Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon SALAPA JOHN M the defendant, at 13:52 HOURS, on the 20th day of May 1999 at 239 WALTON STREET LEMOYNE, PA 17043 CUMBERLAND County, Pennsylvania, by handing to JOYCE HERSHOCK (MOTHER) a true and attested copy of the NOTICE AND COMPLAINT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 So answers: Service 9,92 Affidavit .00 Surcharge 8.00 . oma 'e - ine, ,52- 'PATRICK F. LAUER, JR. 05/24/1999 by n f q -- epuLy 5 eri Sworn and subscribed to before me this .2-q Q-- day of 19 A.D.nn ? Ct PATRICK F. LAUER, JR., Plaintiff Vs. JOHN M. SALAPA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 2844 CIVIL ACTION TO: John M. Salapa 239 Walton Street Lemoyne, PA 17043 Date of Notice: July 27, 1999 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Patri k F. Lauer, Jr., Esquire 2108 Market Street Camp Hill, PA 17011 (717) 763-1800 +i 1 ?1tij rn PATRICK F. LAUER, JR., - IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 99 - 2844 JOHN M. SALAPA, CIVIL ACTION Defendant PRAECIPE TO ENTER DEFAULT JUDGMENT TO: THE PROTHONOTARY OF CUMBERLAND COUNTY Please enter judgment against the defendant in the above- captioned matter, John M. Salapa, in the amount of $3,300.00 plus costs and reasonable attorney fee to the Plaintiff on the issue of liability for failure to file an answer within the required time to the complaint which contained a notice to defend. I certify that pursuant to Pa. R. Civ. P., Rule 237.1, written notice of the plaintiff's intention to file this praecipe for entry of default judgment was mailed to the party against whom judgment is to be entered, John M. Salapa, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the Notice is attached hereto as Exhibit "A" and incorporated herein by reference. Respectfully submitted, Date: D PPatrick F. Lauer, Jr., squire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 46430 Tel. (717) 763-1800 EXHIBIT A THE LAW OFFICES OF PATRICK F. LAUER, JR 2108 MARKET STREET, AZTEC BUILDING CAMP H[LL, PENNSYLVANIA 17011 (717) 763-1800 FAX (717) 763-4247 1-800-822-4-LAW 932 N. Second Street Harrisburg, PA 17102 (717) 232.7747 Associate Counsel Matthew J. Eshelman, Esq. (Reply to Camp Hill Address) 8 S. Hanover Street Carlisle, PA 17013 (717) 249-6971 July 27, 1999 John M. Salapa 239 Walton Street Lemoyne, PA 17043 (;' Re: Patrick F. Lauer Jr. v. John M Salapa Dear Mr. Salapa: You were served with a formal complaint on May 20th, 1999. You have failed to respond within the required twenty (20) days and/or meet the arrangement met regarding payment of your debt. You are in default and this is notice that you have ten (10) days to respond to this notice. Very truly yours, P trick F. Lauer, Jr. PFL/jak enclosure. cc: file ,4 PATRICK F. LAUER, JR., Plaintiff Vs. JOHN M. SALAPA, Defendant TO: John M. Salapa 239 Walton Street Lemoyne, PA 17043 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 2844 CIVIL ACTION Date of Notice: July 27, 1999 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 24 9-3 16 6 s - 707id Patrick F. Lauer, Jr., Esquire 2108 Market Street Camp Hill, PA 17011 (717) 763-1800 v? ?L N tl.'" ?I I'.I t]. .. O rn U ?? f U a ti W y m m?_n L ? $ n (??$ <EC H en N V a IN THE COURT OF a"%)N PLEAS OF C[IffiER" COUNTY, PENNSYLVANIA / CIVIL DIVISION • File No. 1999-02844 . Amount Due $3,300.00 ?S• l?I . Interest from October, 1998 TO THE PROTHONOTARY OF THE SAID COURT: : Atty's Comm . Costs 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 MM=ON Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant (s) John M. Salapa 239 Walton Street Lemoyne, PA 17043 PRAECIPE FOR ATTAC HmEW ' 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) checking account with PNC Bank Account ' No. 5000812511; all property within Defendant's possession or ownership. 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 lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: September 15, 1999 Signature: n Print Name: Patrick F. Lauer, Jr. Address: 2108 Market Street Camp Hill, PA 17011 Attorney for: Self Telephone: (717) 763-1800 Supreme Court ID No.: 46430 Notes: If real property, supply six copies of description including irrprovermnts 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. 1 „j `N t \ j t I - J k 1 (^I °11 0 v J SHERIFF'S RETURN - GARNISHEE CASE NO: 1999-02844 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LAUER PATRICK F JR VS. SALAPA JOHN M And now BRIAN BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND County, who being duly sworn according to law, at 1557:00 HOURS, on the 23rd day of September , 1999, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named defendant SALAPA JOHN M in the hands, possession, or control of the within named Garnishee PNC BANK by then and there summoning the said Garnishee at MJ CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to BETH EPPLEY, SERVICE MANAGER AND ADULT IN CHARGE , personally THREE true and attested copies of the within WRIT OF EXECUTION and made the contents thereof known to her. Sheriff's Costs: So answers: Docketing ,00 ?•?? Service Affidavit .00 Surcharge .00 _$.U0 omas Kline, eri 00/00/0000 by epu y ie Sworn and subscribed to before me this fGy day of [fel,_ 19 qL- A.D. `-Pro ?oz o a,•Ty la`s ?p.411-v of ?tttttG?,t???! d R. THOMAS KLINE Sheriff EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 RONNY R. ANDERSON Chief Deputy PATRICIA A. SHATTO Real Estate Deputy November 5, 1999 Patrick F. Lauer -vs- John M. Salapa No. 99-2844 Civil Term vi Property Claim Determinating;,.: Dear Sir Reference is made to Property Claim dated October 25, 1999 entered by Joyce Hershock, and pertaining to Execution No. 99-2844 Civil Term, Patrick F. Lauer, Jr., Esq. -vs- John M. Salapa. R. Thomas Kline, Sheriff, has detennined that the claimant, Joyce Hershock, in the abovementioned property claim, is prima facie the owner of the property set forth therein. So answers } ? y .s? ii Thomas Kline, Sh riff 13y -rrr/Zri De uty S14-riff cc: Patrick F. Lauer, Pltff John M. Salapa, Deft. Joyce Hershock, Claimant NOTICE OF PROPERTY CLAIM kat.r.i.c.k...k....... La ar.......,7.r.F.......EIS,q.t VS. J Otzn ...M.......5 d.d.F?.d ......................................................... 239 Walton St. Lemoyne, PA 17043 In The Court of Common Pleas of Cunnberland County, Pennsylvania No 99-2844 . . Civil Term ................ , . Writ of Execution TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Joyce. Hershoc k .............. . . . . claiming property listed therein. Unless an appraisal of the prop- erty is requested within (I0) days from the date of this notice, the sheriff without making an appraisal will accept the value of the property set forth in the claim. Date: . . .... Oct... . .. 25.,. . 19.9 ............. cc: Patrick F. Lauer, Jr., Atty. John M. Salapa, Defendant Joyce Hershock, Claimant ................... .. ................. Sheriff of Cumberland County e) DeputV PROPERTY CLAIM VS. J0 #A/ /Yl Si?I C/JP? TO THE SHERIFF OF CUMBERLAND COUNTY, PENNA. In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 7 Z;:Zj? The property listed below and levied upon in this case is not the property of the defendaut but is the property of the undersigned. A list of the claimed properly and the values thereof are: LIST OF PROPERTY I VALUE Gild,)-iRS aoo, oa 1- /} M 1°5 /04c, '00 Lti Vra,o N so 0cr ab-, a KING c 00 C o /= F P-ia-7W I; L Lz: ?u'- • Od .C?oo l? ?s Y`? N ? a o oa /1/I C-4t 5 t-&Nns /oo , 00 The Claimant Obtained Title to the Property as Follows: I 'It" I „ - /- I- -, 1 Y w rt- l5 /-ZY o C [f_LLr_-ly/ L 4- / r!l / A/ f `r/t/_= R AR r Ale L? n/s o l? Tv?L? i.t ??t-s /}- G-411V5r- 5q-'A !_°_ cs E'ir?f',y -T'16--i4 r= r= /t c ? nit 4-0.5 7"/ y-G. r- To S U c. Date /9 6c /f49 Claimant Stale of Pennsylvania: County ofCuwberland being duly sworn according to law, deposes and say that the above list in the properly claim are coned and true Sworn and subscribed to before nt2s daa, of -- iy q C_ 0 11 bl I _ IJO:aridl Seel Germeltl J ?Va+?0i0, Notary F%?r??,c lon+oyne &xo. Gundbrdn0 Gountyy MY Comm?sswn rRp??es FsS. 25, :202 __L-jfi= sirocrT l"laimant f?J?-cltrnl s4aoo , o-I / co I OD _-7 o6t-8 nls aa?, urn - C5J~o l?? (-(S:A 6) l'?70 ,u7 W_ 6S 11-/? /Z _. lOD • Ot r- 6 -.-..---.-_.._...- ??"? 1piQD G L ,SSo f?? _ - - 6-l`F f=F po_f _ TJ? Pllf'> N h_ JV 4 W ,-S W g ? I alr- h 1 l? c 1f-/ Il 1 0 r s /3F 1l Roo MS 15/- RAAD X360 yN/ ,6 FD B l'p,oo 6%o0 I3;vU - . __ l0<rb /5 SIS r= A 5 3 cto _ ,. ... _ .-.--...-.-. 11' dCTS J errs C 4,>G 1(4411M . 3 : t ? 5 , ?? v'', va lV.« --- ----------- ,5'rn 11 L- -r/), 13 L 15L 'Y' ov S -t-/ I' tl71"n P4FR . _ _ y • v? ?uolT Sy LY le) -OZ) ff r?J 5 v?r?. rt ?i'?G. jyl /}G. /i i ?/, ' ? ?-oa - pr. 1''I? /(sG?4?1rof4 yfsu ,rte (; U/" 3 'i i I' j ' ,, , . /f c /i o /?ilS /vo. 40 6 L c ,. ------ /YI (S G L is WA/ G ii'1?lRS ?p , «, 1493-5J,f,u/R N . T /i G K? Ds oo Sl ?taoo . u?. _ SD N i/l/? IG?Y .2 K,5?r 7i jar ais' & or3 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. No action has been taken in the last six months. Sheriff's Costs: Docketing $18.00 Poundage 1.95 Law Library .50 Prothonotary 1.00 Service 13.02 Garnishee 9.00 Surcharge 16.00 4evy 40.00 $99.47 Sworn and subscribed to before me t Th day of 7nltac? 2 A.D. P/ tothonotary 0 Advance Costs: $150.00 Sheriff's Costs: 99.47 $ 50.53 So Answers: R. Thomas Kline, Sheriff By Qr)C.l_i.! .J 6 V((? y1 D'eput Sheriff -o .p Y i dINV?I.?rFfM3d 66, Wd ZE £ OZ d3S A.I,. , _:N 10 JAW211S Jill JO 3".11130 CIL ,? e^5pG ?u r1'S 4c' 7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. l ggq_7q4a CIVIL 19 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland -COUNTY: To satisfy the debt, interest and costs due Patrick F. Lauer, Jr. Es q. PLAINTIFF(S) from John M Salapa 239 Walton Street L,en)%me RA 17043 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell ..all property within Defendant's possession or ownership (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of checking account with PNC Bank, Account No. 5000812513. 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 property of the defendant(s) not leviedupon an subject to attachment isfound inthe possession of 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 S3.300.00 Interest from October, 1998 Afty's Comm Atty Paid $108.42 Plaintiff F Date: September 17, 1999 L.L. Due Frothy $1.00 Other Costs Curtis R. Long Prothonotary, Civil Division REQUESTING PARTY: Name Patrick F. Lauer, Jr. _ Address: 210 Market Street . CAM HiD, PA Attorney for: Self _ Telephone: 767-18?D_`____.__. by: -;0?440z Deputy Supreme Court ID No. 46430