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Home My WebLink About99-03091d 1 ? r.. ??? z e vl 'flh r??? n?;•;?, ? ( ? i' j . ? ? .?r, y? ?t? ; {??: ?. if _ ?t+ Y: ?? - ???? f ? '^`;?( ? .?B :..I. ?.:::} _ l ?1 ?7. .. ? .. ,4 1. S°i ?? ,, `_n , , '. d? ?' ?0 ! ?f '?e ? ii'? ? 4A ? , ? r 1 ! , ;;C, ? 'N ? ? 'u ? u 1 ? 4: ',i, :g? t:. ' }'w ey h?}yy•? ? ? ?? .. i CC W iz.' I .; ? 1 . _ ;Y? i 1 .,?t t: .. ?a",q . ,}: t?R jpr - t4r .{? 4 :: ?%x ei,;? , i? 3.i .? r jw ':}? ).?, ^ ? ? ? ? ? ? 4 I ;? r ? o .- :. i?fX r. ,.. ""'. /`SLIAtl?1tG?Cds? L?'CZJ !AC V`>L' U G?ao C1iPca¢?(.zt? .w o,.r ..tivltrla? .?iru? . lrl7tur at .r42. C'A....cr .?..? JV.v ,oczu?/, 7l`Ic¢ ,?< <„td -cea?? ?? rs=:de.. /.J.la?`iG tom' 4aa ,oa,.' a,- , ^ ? . 4""l t2 q? ' On 4 r .5-?l wt -1 0 a Z4t .i PYS510 Cumberland County Prothonotary's Office Page 1 Civil Case Inquiry 1999-03091 TINDALL ELIZABETH J (vs) DICKSON DAVID C III Reference No..: Filed........: 5/21/1999 Case Type.....: EXEMPLIFIED RECORD Time.........: 2:23 Judgment...... 277772.08 Execution Date 6111If1999 Judge Assigned: OLER J WESLEY JR Jury Trial.... Disposed Desc.: Disposed Date. 0/00/0000 -,----------- Case Comments ------ - -- Higher Crt 1.: Higher Crt 2.: General Index Attorney Info TINDALL ELIZABETH J PLAINTIFF 7 FALLS GLEN COURT PARKTON MD 21120 DICKSON DAVID C III DEFENDANT 2810 MYRTLE DR MECHANICSBURG PA 17055 KEYSTONE FINANCIAL GARNISHEE Judgment Index Amount DICKSON DAVID C III 277,772.08 DICKSON DAVID C III 277,772.08 DICKSON DAVID C III 277,772.08 KEYSTONE FINANCIAL KEYSTONE FINANCIAL 1,39366 . DICKSON DAVID C III 277,772 .08 KEYSTONE FINANCIAL BRENNEMAN KEITH O Date 6/11%1999 12%06%1999 2%09%2000 4/18/2000 Desc EXEMPLIFIED RECORD WRIT OF EXECUTION WRIT OF EXECUTION PRAECIPE JUDGMENT ORDER OF COURT WRIT OF EXECUTION SATISFACTION * Date Entries FIRST ENTRY - - - - - - - - _ 5/21/1999 EXEMPLIFIED RECORD FROM MARYLAND BALTIMORE COUNTY ------------------------------------------------------------------ 5/21/1999 NOTICE MAILED TO DEFENDANT ----------------------------------------------------------------- 5/21/1999 AFFIDAVIT PURSUANT TO 42 PA C S A 4306(0)(1) -------------------------------------------------------------------- 5/25/1999 AFFIDAVIT OF SERVICE ---- ----------- 6/11/1999 PRAECIPE FOR WRIT OF EXECUTION AND WRIT OF EXECUTION ISSUED PD ATTY $2.50 $1.00 COUNTY & $0.50 LL - -------------------- 8/16/1999 OBJECTION - TO - SHERIFF'S-DETERMINATION - - - - -=- ----- - -- -- --- - ---------- ------------------------------------------------------------------- 8/17/1999 SHERIFF'S RETURN (PROPERTY CLAIM DETERMINATION) CLAIMANT DEIRDRE DICKSON IS PRIMA FACIE OWNER OF THE PROPERTY SET FORTH THEREIN ---------------------------------------------------------------°--- 10/04/1999 MOTION FOR ORDER TO COMPEL DEIDRE L DICKSON TO SUBMIT TO DEPOSITION ------------------------------------------------------------------- 10/21/1999 PRAECIPE FOR WRIT OF EXECUTION AND WRIT OF EXECUTION ISSUED $1.00 COUNTY GARNISHEE KEYSTONE FINACNIAL ------------------------------------------------------------------- 10/21/1999 ORDER - DATED 10/19/99 - IN RE MOTION FOR ORDER TO COMPEL DEIDRE L DICKSON TO SUBMIT TO DEPOSITION - DEIRDRE L DICKSON IS TO ATTEND HER DEPOSITION SCHEDULED AT THE OFFICES OF SNELBAKER BRENNEMAN & SPARE PC ON 0/28/99 1:30 PM - BY J WESLEY OLER JR J - NOTICE MAILED 10/22 99 ------------------------------------------------------------------- 10/27/1999 SHERIFF'S RETURN FILED LITIGANT : DICKSON DAVID C III SERVED GARNISHEEE KEYSTONE FINANCIAL : 10/27/9 COSTS : $ 00.00 -------------------------------------------------------------- 12/06/1999 PRAECIPE-ENTERING JUDGMENT AGAINST GARNISHEE AND-JUDGMENT-ENTERED-- ------------------------------- - --------------------------------- 12/06/'1999 NOTICE MAILED TO DEFENDANTS ------------------------------------------------------------------- 12/06/1999 IMPORTANT NOTICE FILED PYS510 Cumberland County Prothonotary's Office Civil Case Inquiry 1999-03091 TINDALL ELIZABETH J (vs) DICKSON DAVID C III Reference No..: Case Type.....: EXEMPLIFIED RECORD Judgment..... 277772.08 Judge Assigned: OLER J WESLEY JR Disposed Desc.: ------------ Case Comments ------------- 12/08/1999 12/10/1999 1/12/2000 1/18/2000 1/18/2000 1/21/2000 Page Filed........: 5/21/1999 Time.........: 2:23 Execution Date 6/11/1999 Jury Trial.... Disposed Date. 0/00/0000 Higher Crt 1.: Higher Crt 2.: MOTION TO SCHEDULE A HEARING TO ASSESS AMOUMT OF JUDGMENT AGAINST GARNISHEE KEYSTONE FINANCIAL ------------------------------------------------------------------- ORDER DATED 12/10/99 - IN RE MOTION TO SCHEDULE A HEARING TO ASSESS AMOUNT OF JUDGMENT AGAINST GARNISHEE KEYSTONE FINANCIAL - HEARING/3 0gg1:30 PM CR 1 - BY J WESLEY OLER JR J - NOTICE AILS I2 -12, / ------------------------------------------------------ NOTICE OF ASSESSMENT OF DAMAGES ------------------------------------------------------------------- MOTION FOR ORDER APPROVING STIPULATION ASSESSING AMOUNT OF DAMAGES ------------------------------------------------------------------- STIPULATION ------------------------------------------------------------------- ORDER - DATED JANUARY 20 2000 - IT IS HEREBY ORDERED THAT SAID STIPULATION IS APPROVED AND A MONEY' JUDGMENT IS HEREBY ENTERED IN-FAVOR OF-PLAINTIFF_AND AGAINST KEYSTONE FINANCIAL GARNISHEE IN BY THE COURT J WESLEY OLER JR COPIES MAILED ------------------------------------------------------------------- 2/02/2000 PRAECIPE TO WITHDRAW THE MOTION OF PLAINTIFF ELIZABETH J TINDALL TO SCHEUDLE A HEARING TO ASSESS THE AMOUNT OF JUDGMENT AGAINST KEYSTONE FINANCIAL - BY KEITH 0 BRENNEMAN ESQ ------------------------------------------------------------------- 2/02/2000 ORDER OF COURT - DATED 2/1/00 - HEARING 2/3/00 IS CANCELLED - BY J WESLEY OLER JR J - COPIES MAILED 2/3/00 ------------------------------------------------------------------- 2/09/2000 PRA.ECIPE FOR WRIT OF EXECUTION AND WRIT OF EXECUTION ISSUED DIRECTED TO DAUPHIN COUNTY $1.00 CO DUE -------------------------------------------------------------------- 4/05/2000 PETITION FOR SUPPLEMENTARY RELIEF IN AID OF EXECUTION PURSUANT TO PA.RCP 3118(A) ------------------------------------------------------------------- 4/07/2000 AIDE //RE PE OF EXECUTTION6//PURUSANT TO PATRCPO3118R(A)U- HEARINGRONR5/15/OON AT 2:30 PM CR 1 CUMBERLAND COUNTY COU THOUSE CARLISLE PA BY J WESLEY OLER JR J COPIES MAILED 4/700 ------------------------------------------------------------------- 4/18/2000 PRAECIPE TO SATISFY GARNISHEE KEYSTONE FINANCIAL FORMERLY FINANCIAL TRUST ONLY BY KEITH O BRENNEMAN ESQ ------------------------------------------------------------------- 5/17/2000 SHERIFF'S RETURN (WRIT RETURNED ABANDONDED - NO ACTION TAKEN IN SHERIFFXS MONTHS) COSTS $64.89 SHERIFF PD ATTY $1.00 COUNTY (CUMBERLAND & OCOORETURN) ------------------------------------------------------------------- 5/17/2000 LASTISIXSMRETURN (WRIT RETURNED$ABOODONODEDY- NO ACTION TAKEN IN SHERIFF'S COSTS $60.28 PD ATTY (GARNISHEE - KEYSTONE FINANCIAL) --------------------------------------------$$----------------------- 5/17/2000 AMODIIRECTDUE AND OWING UNDER DATED 1/13/00 ED TO HEREAFTER PUTHEGNFURTHER ORDER OF ICOURT FAVORPAY DAVID C DICKSON III DEFT TO THE CUMBERLAND COUNTY PROTHONOTARY BY THE COURT J WESLEY OLER JR J COPIES MAILED 5/17/00 ------------------------------------------------------------------- 6/O8/2000 BOND PD BY DAVID C DICKSON III FOR MAY PYMT - CHECK # 7202 $811.15 FROM CHIROPLUS OF LOCUST LANE INC ------------------------------------------------------------------- 6/30/2000 BOND - ISSUED BY CHIROPLUS OF LOCUST FOR DAVID C DICKSON III - CHECK # 4253 IN THE AMOUNT OF $811.15 - JUNE PAYMENT ---------------------------------------------------------------'---- 8/30/2000 BOND - BY CHIROPLUS OF LOCUT LANE INC - JULY PYMT DAVID DICKSON- 811.15 ------------------------------------------------------------------- 8/16/2000 BOND - ISSUED BY CHIROPLUS OF LOCUST ''FOR DAVID C DICKSON III - V (CH CK # 7552) IN THE AMOUNT OF 811.15 PYS510 Cumberland County Prothonotary's office Page 3 Civil Case Inquiry 1999-03091 TINDALL ELIZABETH J (vs) DI CKSON DAVID C III Reference No..: Filed........: 5/21 1999 Case Type ..... : EXEMPLIFIED RECORD Time.........: 2:23 Judgment..... 277772.08 Execution Date 6/11 1999 Judge Assigned: OLER J WESLEY JR Jury Trial.... Disposed Desc.: Disposed Date. 0/00/0000 ------------ Cas e Comments ----------- -- Higher Crt 1.: - Higher Crt 2.: ----- 3/01/2001 BOND -------------- ------- - ISSUED BY CHIROPLUS -------------- ---------- OF LOCUST LANE INC FOR DAVID ----------- C DICKSON III ( CHECK #)7810) IN THE AMOUNT OF $811.00. - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - * Escrow Information * Fees & Debits Be Bal P is/Ad' End Bat EX RECORD SAT 10.00 10.00 .00 SATISFACTION 5.00 5.00 .00 WRIT OF EXEC 15.00 15.00 .00 WRIT OF XEC 15.00 15.00 .00 WRIT TAX EXEC .50 .50 .00 JDMT 9.00 9.00 .00 JDMT 9.00 9.00 .00 WRIT OF XEC 15.00 15.00 .00 WRIT TAX EXEC .50 .50 .00 SATISFAC ION 5.00 5.00 .00 SHFF RETURN FEE 1.00 1.00 .00 LAW LIB FEE .50 .50 .00 SHFF RETURN FEE 1.00 1.00 .00 BOND 811.15 811.15 .00 BOND 811.15 811.15 .00 BOND 811.15 811.15 .00 BOND 811.15 811.15 .00 BOND 811.15 811.15 .00 BOND 811.00 -------------- 811.00 ------ .00 4953.25 ---- --- 4953.25 --------- .00 ******************************************************************************** * End of Case Information ******************************************************************************** IN THE OCdW OF CQ-UN PLEAS OF C'[ZMMU AND aXM, PEN EnVANLA CIVIL DIVISION File No. 99-3091 ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. . Costs Amount Due $277,772.08 . Interest from May 21 , 1999 * gS8.9(o : Atty's Comm N/A DAVID C. DICKSON, III, - Defendant TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ of execution in the above natter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the defendant(s) any and all personal property of Defendant David C. Dickson, III located at 2810 Myrtle Drive, Mechanicsburg, Pennsylvania. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of 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) 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 e? DATE: June 11, 1999 Signature: 7?. Print Name: Keith 0. Brenneman, Esquire 44 W. Main Street 147077 Address: Mechanicsburg, PA 17055 Attorney for:l'laintiff Elizabeth J. Tindall Telephone: (717) 697-8528 Suprare Court ID No.: 47077 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. C D T % Z1 C[: G "1 T Cz r'C -V 7r' 1C. 5' C_ N Unl UI -C ?v 11 r ?C a, b n r j '? ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW OBJECTION TO SHERIFF'S DETERMINATION TO THE PROTHONOTARY: Please enter objection to the Sheriff's determination of ownership of the property referred to in the Property Claim dated July 27, 1999 entered by Deirdre Dickson in the above- captioned matter. SNELBAKER, BRENNEMAN & SPARE, P. C. By. Keith 0. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall LAW OrrICL6 SNELGARER. BRENNEMAN & SPARE Date: August 16, 1999 CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing objection to Sheriff's Determination to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Wendy D. Bowie, Esquire Ira H. Weinstock, P. C. Suite 100 800 North Second Street Harrisburg, PA 17102 A Keith 0. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 West Main Street P. 0. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Elizabeth J. Tindall Date: August 16, 1999 LAW OlrtCLs SNELOAKER? BRENNEMAN & SPARE S- 101, to N '4i -1 BZC m ?2 o? U A ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 1 pl LCld CIVIL ACTION - LAW AFFIDAVIT PURSUANT TO 42 Pa.C.S.A. S 4306(c)(1) COMMONWEALTH OF PENNSYLVANIA) SS. COUNTY OF CUMBERLAND ) Keith 0. Brenneman, Esquire, being duly sworn according to law deposes and says: that he is the attorney for judgment creditor, Elizabeth J. Tindall, who is the judgment creditor by virtue of the judgment entered in favor of Elizabeth J. Tindall against Defendant David C. Dickson, III in the Circuit Court for Baltimore County, Maryland docketed to Civil Case No. 03-C-97- 011939; that the judgment creditor°s address is as follows: Elizabeth J. Tindall 7 Falls Glen Court Parkton, MD 21120; that the name and last known post office address of the judgment debtor, David C. Dickson, III, is as follows: David C. Dickson, III 2810 Myrtle Drive Mechanicsburg, PA 17055; L W OFFICC6 SNELOAKER• BRENNEMAN & SPARE that the above referenced foreign judgment entered in Maryland is valid, enforceable and unsatisfied; and that the foregoing facts are true and correct to the best of his knowledge, information and belief. SNELBAKHR, BRENNEMAN & SPARE, P. C. Z BY: I d?'o Ko t1 AO. Brenneman, Esquire Supreme Ct. ID ,#47077 44 Want Main Street Mechanicsburg, PA 17055 (717) 697^8528 Attorneys for. Plaintiff Date: May 21, 1999 Elizabeth J. Tindall Sworn to and subscribed before me this 21st day of May, 19!)9. `Notary P b is M. My E? 11 LAW OFFICL/ SNELOAKER, BRENNEMAN fk SPARC 0 Cl) Y ? N ? l l .. Ll A ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- .36?1 cIU« CIVIL ACTION - LAW AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) SS. COUNTY OF CUMBERLAND ) Keith 0. Brenneman, Esquire, being duly sworn according to uw OFFICES SNELRAKER. BRENNEMAN & SPARE law deposes and says: that he is the attorney for Plaintiff Elizabeth J. Tindall; that on May 21, 1999 he did send by regular first class mail, postage prepaid, notice of the filing of the judgment transferred and entered in the above case, together with a copy of, the praecipe entering judgment and the documents transferring judgment to the Court of Common Pleas of Cumberland County, Pennsylvania to Defendant David C. Dickson, III at his last know post office address of: 2810 Myrtle Drive, Mechanicsburg, Pennsylvania 17055; that a copy of the cover letter transmitting the above documents to Defendant is attached hereto and incorporated by reference herein as "Exhibit A"; that the original Certificate of Mailing (PS FORM 3817) noting mailing of the documents and cover letter aforesaid to the Defendant is attached hereto and incorporated by reference herein as "Exhibit B"; that the notice made reference to herein .. as having been given to the Defendant was in accordance wtih 42 Pa.C.S.A. 5 4306(c)(2); and that the foregoing facts are true and correct to the best of his knowledge, information and belief. SNELBAKER, BRENNEMAN & SPARE, P. C. By: ^I•• Keith O. Brenneman, Esquire Supreme Ct. ID #47077 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Date: May 21, 1999 Elizabeth J. Tindall Sworn to and subscribed before me this 21st day of May, 1999. Notary Public 9btmial3eef Chf16 MM.WhiW. ryPUWiC MWw4mb xp Boro. cures npdt Omft MyCommkwnExpRrsSept 17 2wi Member. PennsyNwia Associaban of NWxft LAW OFFICCS SNELOAKER. BRENNEMAN & SPARE SNELBAKER, BRENNEMAN 8 SPARE A PROFESSIONAL CORPORAIIoN ATTORNEYS AT LAW AA WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 RICHARD C. SNELBAKER KEITH O. BRENNEMAN PHILIP H. SPARE 717.697.6528 May 21, 1999 David C. Dickson, III 2810 Myrtle Drive Mechanicsburg, PA 17055 Re: Elizabeth J. Tindall v Dear Mr. Dickson: David C. Dickson, III P. O. BOX 316 FACSIMILE L70 697.7681 I write to notify you that on May 21, 1999 a judgment was entered against you in the Court of Common Please of Cumberland County, Pennsylvania in the amount of $277,772.08 in accordance with a judgment transferred to Cumberland County, Pennsylvania from the Circuit Court for Baltimore County, Maryland. Enclosed please find a copy of the Praecipe To Enter Judgment, a copy of the exemplified record concerning the judgment that was transferred as well as a copy of the docket entries for case go. 03-C-97-011939 in the Circuit Court for Baltimore County, Maryland. Finally, I am enclosing a copy of an Affidavit pursuant to 42 Pa.C.S.A. S 4306(c)(1). Please be guided accordingly. Yours truly, Keith 0. Brenneman KOB/sz Enclosures CC: John M. Kerney, Esquire (w/enclosures) Elizabeth J. Tindall (w/enclosures) EXHIBIT A U. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, D PROVIDE FOR INSURANCE-POSTMASTER ?C Received From: Keith O. Brenneman, Es t-' y W. sin Street NA ?o Merhanighurg. PA SS01 One piece of ordinary mall addressed to; David C. Dickson, III 2810 Myrtle Drive -MPChanic;hnrg, PA 17055 _ PS Form 3817, Mar. 1989 'U.S.G.R.O.: 1992•3208714111237 EXHIBIT B uw OFFICCa SNELBAKER. BRENNEMAN & SPARE $N M `db F m o?y n C' o? 3)K 9 N dO ONJ?D /Cn c-o =M 000 0 oa m A S m c? ci m v a -?? - . _.. _ :?.?c __ ; <. ?,_ .. . ?;; ? , ` ? ?? ?- ' ?? :? ? ;,.:? .. -, ?- ?, ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-'?7/ ???? CIVIL ACTION - LAW PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Please enter judgment in favor of Plaintiff Elizabeth J. Tindall and against Defendant David C. Dickson, III, in the amount of $277,772.08 in accordance with the attached transferred judgment. SNELBAKER, BRENNEMAN & SPARE, P. C vt'( Cet44R By: Keith O. Brenneman, Esquire Supreme Ct. ID #47077 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall LAW orrICE6 SNELBAKER, BRENNEMAN B SPARE Date: May 21, 1999 ') ? ??? CV-de State cf Maryland, Baltimore County, to wit: I. ____ SUZANNG_ MENSH----------- Clerk of the Circuit Court for Baltimore County in the State of Maryland, the same being a Court of Law and Record, do certify that the aforegoing IS A_TRUE_PHOTO COPY_OF_CASE HIST0RY1,JUDGP1ENT AND ORDER FILED IN a1lGK.ET_SM,:_P,.ASE_NR._f]3_?_R7___OJ.a.43.4,_?LJrZA$>?TH_J._ TINDALL t/a/k Ei.IZNiET1i__ L._ DICKSObt, _LLI_TILEL?_I_?IRCUIT _COURT _FOR_BALTIMORE_ COUNTY ---------------------------------------------------------------------------------------- Mary IN TESTIMONY WHEREOF, I hereunto subscribe my name and affix the seal of the said court, this ---- 13th_-__ day of-MAY ----------------------- nineteen hundred and Ninety----- NINE ----------------- Test: Clerk of th ircuit Court for alum I, --JOHN _GRASf1N_TURDLBULL,19residing Judge of the Circuit Court for Baltimore County in the State aforesaid, do certify, that the aforegoing Attestation of BRZANUL MENMIi__________ Clerk of the Circuit Court for said County, is in due form, and by the proper officer, who is the custodian of the Records and Papers of the Cirff u' Court for Baltimore County, and is now in office. Given under my hand, at Towson, tL4JZ__day _______ _M ay______________ in the year of our Lord one thousand nine hundred and -Xc__j___.N-IMI ------ ----- j--_jWi- -----w------- udge IN TESTIMONY WHEREOF, I hereunto subscribe my name and affix the seal of the said Court, this__ 13TH - ------------- day of___May -_____________________nineteen hundred and Ninety ------ AI.NE ---------------- Test: Clerk of the rcuit Court for Baltimore County. State of Maryland, Baltimore County, to wit: SUZANNE MENSH --------------------------__ Clerk of the Circuit Court for Baltimore County, the I,----- JOHN same being a Court of Law and Record, do certify that the Honorable _______GRASON _TURNBULL, I I by whom the above certificate was given, and who hath thereto subscribed his name, was at the time of so doing Judge of the Circuit Court for Baltimore County, duly elected, commissioned and qualified, CIRCUIT COURT FOR BALTIMORE COULITY Suzanne Mensh Clerk of the Circuit Court County Courts Building 401 Bosley Avenue P.O. Box 6754 Towson, MD 21285-6754 (410)-887-2601, TTY for Deaf: (800)-735-2258 Maryland Toll Free Number (800) 938-5802 N 0 T I C E O F R E C O R D E D J U D G M E N T Case Number 03-C-97-011939 C I V I L Tindall vs Dickson I HEREBY CERTIFY that the following Judgment has been recorded in this Court in the above entitled case: Judgment Against: Dickson, David C III 30 East Padonia Road Suite 502 Timonium, MD 21093 Judgment in Favor of: Judgment Entry Date: Amount of Judgment: PreJudgment Interest: Appearance Fee: Filing Fee: Tindall, Elizabeth J 04/06/99 $277,772.08 $.00 $.00 $.00 plus interest and costs Other Fee: $.00 Service Fee: $.00 Witness Fee: $.00 Attorney Fee: $.00 IN TESTIMONY WHEREOF, I hereunto set my hand and affix the seal of this Court. ` ( ?h Suz 3I1 E Me ri ?O?r ?OUr Clerk of the Circuit Court, per Issued: 04/06/99 f.1 ELIZABETH J. TINDALL * IN THE f/k/a Elizabeth J. Dickson * CIRCUIT COURT Plaintiff * FOR V. * BALTIMORE COUNTY DAVID C. DICKSON, III * Case No.: 03-C-97-011939 Defendant * ORDER Upon consideration of the Second Amended Complaint filed by the Plaintiff herein and the answer thereto filed by the Defendant, it is this day . ? 1 1914,,y the Circuit Court of Baltimore County - ORDERED that pursuant to the Second Amended Complaint, the Answer and ' testimony taken on March 31, 1999 that judgment is entered in the Second Amended Complaint filed herein against the Defendant, David C. Dickson, III, In favor of Elizabeth J. Tindall under Count 1 of the Second Amended Complaint in the amount of Two Hundred Seventy Seven Thousand Seven Hundred Seventy Two Dollars and 08 Cents ($277,772.08). JUDGE GtIO.?-?- F«ED APR 0 9 1999 CIRCUIT COURT FOR BALTIMORE COUNTY Suzanne Mensh Clerk of the Circuit Court County Courts Building 401 Bosley Avenue P.O. Box 6754 Towson, MD 21285-6754 (410)-887-2601, TTY for Deaf: (800)-735-2258 Maryland Toll Free Number (800) 938-5802 05/13/99 Tindall vs Dickson Case Number: 03-C-97-011939 CN Date Filed: 12/16/97 Status: Open/Active Judge Assigned: To Be Assigned, CA S E H I S T O R Y CONSOLIDATED/RELATED CASES Lead CaseID: 03-C-98-004917 SubCaseID Type Start End ------ ---- -------- ------- 03-C-97.011939 T 12/10/98 INVOLVED PARTIES Type Num Name(Last,First,Mid,Title) Entered ........ .................................... .--------------------- ................. ........ PLT 001 Tindall, Elizabeth J 12/16/97 7 Falls Glen Court Parkton. MD 21120 Attorney: 0015019 Kerney, John M 12/16/97 Law Offices Of John M. Kerney Suite 100 21 W Susquehanna Ave Towson. MD 21204 (410)337.5407 FKA Dickson, Elizabeth J MED 001 BOGRIS, GEORGE D. ESO 01/16/98 Capacity : MEDIATOR 401 WASHINGTON AVE14UE 03-C-'97,-011939 Date: 05/13/99 Time: 13:31 TOWSON. MD 21204 Type Num Name(Last,First,Mid,Title) Entered .... .... ........................................................................... ........ DEF 001 Dickson. David C. III 12/16/97 30 East Padonia Road Suite 502 Timonium, MD 21093 Attorney: 0004951 Webb, Thomas E 01/12/98 Webb 8 Blitz, L L C 1301 York Road Suite 506/Heaver Plaza Lutherville. MD 21093 (410)321-1896 CALENDAR EVENTS Date Time Dur Cer Evnt Lvl Jdg Day Of Rslt By ResultDt Jdg T Notice Rec ------------------------------------------------------------------------ - ------- 09/28/98 09:30A 020 yes MOTN D TBA 01 /01 08/06/98 03/31/99 09:30A 06H yes CITR D LRD 01 /02 CON C 03/31/99 LRD P 12/02/98 Y Stenographer(s): Debbie Lambert 04/01/99 09:30A 06H yes CITR D LRD 02 102 VAC C 03/31/99 P 06/23/99 09:30A 06H yes CITR D LRD 01 /01 P JUDGE HISTORY JUDGE ASSIGNED Type Assign Date Removal RSN ..... ---------------- ---- ---------=- ---........ TBA To Be Assigned, J 12/16/97 DOCUMENT TRACKING Page: 2 Ruling/ Num/Seq Description Filed Received Party Routed Closed Closed User ID Entered ....... ......... -------- -------- -------- ---- ------ ------- ..-.- -------. ------......... 0001000 Complaint 12/16/97 12/16/97 TBA PLT001 KH KH 12/16/97 0001001 Answer with Request for Jury Trial 01/12/98 01/09/98 TBA DEFO01 OFF OFF 01/12198 (No DCM). 0001002 Amended answer 02/27/98 02/27/98 TBA DEF001 PH PH 02/27/98 0002000 Writ of Summons - Civil 12/16/97 12/16/97 TBA 6EFG01 12/16/97 12/16/97 KH KH 12/16/97 03-C=97-011939 Date: 05/13/99 Time: 13:31 Ruling/ Num/Seq ------- Description ---------------------------------- Filed Received Party Routed Closed 0003000 - Scheduling Order ----• -------- 01116/98 -------- 01/16/98 ---- TBA ------ 000 ------•- --•-••-- 01/16/98 0004000 Motion for Protective Order 02/03/98 02/02/98 CMK DEF001 Denied 0004001 Answer 02/09/98 02/09/98 TBA PLT001 0005000 Request for Hearing/Motion for 02/05/98 02/04/98 TBA DEF001 Protective order 0006000 Memorandum 06/04/98 06/02/98 TBA DEF00] 0006001 Response to Memorandum 06/15/98 06112/98 TBA PLTOOI with Exhibits. (No DCM). 0007000 Hearing Notice 08/06/98 08/06/98 TBA 000 0008000 **Motion for Sanctions 09/08/98 09/03/98 CMK PLTOOI 0008001 Answer** 09/17/98 09/16/98 TBA DEF0o1 0009000 Line Dismissing Motion for Sanctions 09/30/98 09/29/98 TBA PLT001 0010000 Line of Dismissal /Motion for Sanctions 10/05/98 10/05/98 TBA PLTOOI 0011000 Motion to Alter/Amend Judgment 10/26/98 10/26/98 TBA DEF001 by Confession 0012000 Hearing Notice 12/02/98 12/02/98 TBA 000 0013000 Order to consolidate 12/10/98 REC 000 ** 03-C-98-4917 and 03-C-97-11939 0014000 Motions Ruling deternining Motion to 12/15/98 12/15/98 JOH 000 modify not requiring Court's considerati on. 0015000 Amended Complaint 12/18/98 12/17/98 TBA PLTOOI (No DCM). 0015001 Answer 12/22/98 12/21/98 TBA DEF001 0016000 Motion for Sanctions 02/16/99 02/12/99 AW PLT001 Defdt. shall produce documents within 7 days. 0017000 Certificate of Rule 2.431/Sanctions 02/17/99 TBA PLTOOI 0018000 Open Court Proceeding 03/31/99 LRD 000 March 31. 1999. Hon. Lawrence R. Daniels . Hearing had re: Amended Complaint (p.15000.) Testimony taken. Ca se recessed; to be reset by the court. Page: 3 Closed User ID Entered - -------- ------- -------- 01/16/98 JD JD 01/16/98 09/24/98 JH JH 02/03198 SO SD 02/09/98 DR DR 02/05/96 06/04/98 SO 50 06/04/98 OFF OFF 06/15/98 08/06/98 08/06/98 BK BK .08/06/98 Ruled 09/24/98 DR JH 09/08/98 PH PH 09/17/98 DR DR 09/30198 DR DR 10/05/98 DR DR 10/26/98 12/02/98 12/02/98 JD JD 12/02/98 Granted 12/10/98 JH JH 12/10/98 Ruled 12/15/98 MR MR 12/15/98 DFF OFF 12/18/98 PH PH 12/22/98 Granted 03/11/99 CKC MR 02/16/99 CKC CKC 02/17/99 MB MB 03/31/99 03-C-87-011939 Date: 05/1 3/99 Time: 13:31 Pa ger 4 Num/Seq Description ....................................... Filed . ........ Received _.._ Party Routed Ruling/ Closed Closed User ID Entered 0019000 Second Amended Complaint 04/06/99 .... ... TBA . ...... PLT001 PH PH 04/06/99 0019001 Answer 04/06/99 04/06/99 TBA DEF001 PH PH 04/06/99 0020000 Order entering Judgment under count 1 04/06/99 LRD 000 Granted 04/06/99 PH PH of the second amended complaint 04/06/99 0021000 Copies of judgment sent per Rule 1-324. 04/06/99 TBA 000 PH PH 04/06/99 0022000 Judgment Entered 04/06/99 04/06/99 TBA 000 04/06/99 04/06/99 PH PH 04/06/99 0023000 Notice of Recorded Judgment 04/06/99 04/06/99 TBA 000 04/06/99 04/06/99 PH PH 04/06/99 SERVICE Name Issued Response Served Returned Agency Party Text --._.__._-' --..-- Dickson David 12/16/97 01/15/98 Fps DEF001 WRIT OF SUMMONS TICKLE Code Tickle Name Status Expires #Days AutoExpire GoAhead From Type Num Seq CTOS Create Tickle On Ser OPEN 12/16/97 0 no no 000 000 NCDT Notice Of Contemplat CANCEL 04/15/98 120 no no DART D 000 000 TANS 1st Answer Tickle OPEN 01/09/98 0 no no DART D 001 001 SLTR Set List For Trial CANCEL 01/09/98 0 yes no TANS T 001 001 SLMR Set List For Notions CANCEL 02/24/98 22 no no SLMM T 000 000 SLMM Set List Motions Mar DONE 10/30/00 999 yes yes DANS D 000 000 SLMH Set List For Motions CANCEL 02/09/98 0 no 110 '11-MM T 000 000 SLMR Set List For Motions CANCEL 09/25/98 22 no no DANS D 000 000 SLMR Set List For Motion; CANCEL 11/17198 22 no no MJAA D 000 000 03-C-97-011939 Date: 05/13/99 Time: 13:31 Page: 5 Code Tickle Name Status Expires #Days AutoExpire GOAhedd From Type Num Seq ..-- - .....'--' ...................... ..... ................. .... .... ... ... SLMR Set List For Motions CANCEL 03/06/99 22 no no MSAN D 000 000 001 MONEY JUDGMENT BEGIN JUDGMENT(S) - CASE HISTORY ORIGINAL JUDGMENT Judgment Against Judgment in Favor of Judgment Entry Date Amount of Judgment Interest Amount Court Costs Attorney Fee Dickson. David C III Tindall. Elizabeth J 04/06/99 $277.772.08 S.00 S.00 $.Do plus interest and costs END JUDGMENT(S) - CASE HISTORY DIFFERENTIATED CASE MANAGEMENT TRACKS AND MILESTONES Track : CM Description: CIVIL MEDIATION Custom: Yes Assign Date: 01/16/98 Order Date : 01116/98 Start Date : 01/16/98 Remove Date: Milestone Scheduled -------- Target Actual -------- ..-----. Status . -.-------- .............. '-------------------------- - Motions to Dismiss under MD. Rule 2-322( 01/31/98 OPEN Plaintiff's Expert Reports or Md.Rule2-4 04/16/98 OPEN Defendant's Expert Reports or Md.Rule2.4 05/16/98 OPEN Joinder of Additional Parties Deadline i 05/16/98 OPEN Dismissal Notice for unserved defendants 05/16/98 OPEN Discovery must by completed by 06/30/98 OPEN All Motions (excluding Motions in Limine 07/15/98 OPEN Mediation(ADR deadline) must be complete 07/15/98 OPEN c : °: ? ?o t?_ (?'?? ?:? ?? g ?? ?; ?. ? ? ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID C. DICKSON, III, Defendant and RANDY S. FREDERICK, D.C.,: Garnishee CIVIL ACTION - LAW No. 99-3091 CIVIL TERM ORDER OF COURT AND NOW, this 15th day of May, 2000, upon consideration of Plaintiff's Petition for. Supplementary Relief in Aid of Execution Pursuant to Pa. R.C.P. 3118(a), and following a hearing, the Garnishee, Randy S. Frederick, is directed to hereafter, pending further Order of Court, pay the amounts due and owing under the note dated January 13, 1998, in favor of David C. Dickson, III, Defendant, to the Cumberland County Prothonotary. The Court will schedule a further hearing in this matter at the request of either counsel. By the Court, Keith Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 For the Plaintiff J.//Wesley Ole , Jr.', Uj. O?,5 , qO -1 0 K3 Qr t, Wendy D. Bowie, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 For the Defendant Randy S. Frederick 4607 Locust Lane Harrisburg, PA 17109 Garnishee wcy 1; RECEIPT FOR PAYMENT Cumberland County Prothonotary's Office Receipt Date 5/25/2000 i Carlisle, Pa 17013 Receipt Time 15e28s1g t. Receipt No. 96056 i TINDALL ELIZABETH J (VS) DICKSON DAVID C III Case Number 1999-03091 Received of RKS PF BY CHIROPLUS OF LOCUST LANE INC Total Check... + 811.15 Check No. 7176 Total Cash.... + .00 f Change........ - .00 Receipt total. 811.15 ----------------------- Distribution Of Payment ---------------------------- Transaction Description Payment Amount BOND 811.15 PROTHONOTARY ESCROW 811.15 j' ?p?etV of ,?tttn?ttr?,ld R.11 IOMAS KLINE Sheriff EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 RONNYR.ANDERSON Chief Deputy PATRICIA A. SHATTO Real Estate Deputy August 10, 1999 / Elizabeth J. Tindall f/k/a Elizabeth J. ? Dickson -vs- David C. Dickson, III No. 99-3091 Civil Term Property Claim Determination Dear Sir Reference is made to Property Claim dated July 27, 1999 entered by Deirdre Dickson, and pertaining to Execution No. 99-3091 Civil Tema, Elizabeth J. Tindall f/k/a Elizabeth J. Dickson -vs- David C. Dickson, III. R. Thomas Kline, Sheriff, has determined that the claimant, Deirdre Dickson, in the abovementioned property claim, is prima facie the owner of the property set forth therein. C-- ?o .0 a 7 ++ l. T1 c ? ai f77 ' r V)Z u y ?7 c? So an er R. Thomas Kline, Sheriff B/2DC Deliuty eriff cc: Keith Brenneman, Atty. for Pltff. David C. Dickson, Deft. Deirdre Dickson, Claimant Y NOTICE OF PROPERTY CLAIM In The Court of Common Pleas of ......... .Eli.z.a.be.th...J......Tindall.,..... former.l.y Cumberland County, Pennsylvania Known as Elizabeth J. Dickson VS. ) David C. Dickson, III ............................................................................................... No....99-3.091. 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 ...... Derdre , L,., , Dicks,gn, , , , , , , , , , , claiming property listed therein. Unless an appraisal of the prop- erty is requested within (10) 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:.. July..27 ,..1999...... . CC: Keith Brenneman atty for PI,tf David C. Dickson III deft Ira Weinstock Atty for Claimant ?`?,.srweaeVC' ....................................... Sheriff of Cumberland County I11• ? dt/..aar, . ?s2........ . Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. NO. 99-3091 DAVID C. DICKSON, III, Defendant : CIVIL ACTION - LAW PROPERTY CLAIM TO THE, SHERIFF: 1. The property listed below and levied upon in this case is not the property of the defendant but is the property of the undersigned. A list of the claimed property and the values thereof are: (a) Living Room Current Value 1. Sofa ............................................. Unknown 2. Love Seat ......................................... Unknown 3. Chairs (4) ......................................... Unknown 4. Coffee & End Tables ................................. Unknown 5. Miscellaneous Furniture (Locker) ....................... Unknown 6. Rugs ............................................. Unknown 7. Pictures ........................................... Unknown 8. Mirrors ........................................ Unknown 9. Television ......................................... Unknown 10. VCR ........................................... Unknown 11. Stereo ............................ Unknown ................ 12. Video Games ...................................... Unknown 13. Telephone ......................................... Unknown (b) Dining Room I. Table ............................................ Unknown 2. Chairs (8) ......................................... Unknown 3. Buffet. ........................................ Unknown 4. Silverware 5. ................................ . . . .. .. . . Rugs ...... Unknown 6. ........................... ... . Chinaware Unknown 7. .................................... Hutch Unknown ................... ...................... Unknown (c) Kitchen 1. Microwave . 2 ................ ....................... Unknown . Utensils ....... 3 ............................. . . ... . . Unknown . Pots/Pans ...... 4 ...................... Unknown . Iron ......... .................................... Unknown 5. Ironing Board 6 ...................................... Unknown . Refrigerator .............................. . . . . . . Unknown 7. Stove ....................................... . ... Unknown 8. Washer 9 .................................... . . ... . . Unknown . Dryer .................................. Unknown 10. Freezer ......................................... Unknown 11. Mixer ........................................ . .. Unknown 12 Blender . 13. ........................................ Coffee Pot Unknown ........................... Unknown 14. Toaster ........................................... Unknown (d) Bedrooms 1. Bed (V 2"d 4'") 2 , , .................................... Ch i "d Unknown . a rs (2 ) ................................. Unknown 3. Lamps (15') ........................................ Unknown 4. Rugs (P) ..... .... ........................ Unknown 5. .... Night Stand (V 41) 6 , ................................. T l i i " 1 Unknown . e ev s on (1 , 2 ) .................................. Unknown 7. Clock (2") ........................................ Unknown 8. 2 Exercise Machines ... 9. .............................. Sewing Machine Unknown .................................... Unknown 10. 3 Security Cameras ......... U k ......................... n nown (e) Study 1. Computer ............. Unknown 2. Entertainment Center ................................ Unknown 3. Television ......................................... Unknown 4. Desk & Chair ...................................... Unknown 5. Credenzas .......................................... Unknown 6. 3 Security Cameras .................................. Unknown 7. Filing Cabinet ....................................... Unknown -2- (1) TV Room 2. I. Television ......................................... Unknown 2. Rugs ......................... Unknown .................... 3. CD Player ......................................... Unknown 4. VCR .............. Unknown ............................... 5. 5 speakers, Surround sound ........................... Unknown 6. 3 Chairs .......................................... Unknown 7. Couch ............................... Unknown ............. 8. End Table ......................................... Unknown (g) Garage 1. Sears Lawnmower 2. ....... ..... Power Drill Unknown 3. ........................................ Garden Tools Unknown 4. ...................................... Skis Unknown 5. ............................................. Television & Stand Unknown 6. .................................. 1 Gas Grill Unknown ........................................ Unknown (h) Entry Way I . 2 Bookshelves with knick knacks 2. ....................... 4 Marble Exdibit Stands Unknown 3. .............................. Pool Table Unknown ........................................ Unknown (i) Miscellaneous I. Wheelbarrow 2. ...................................... 3 chairs Unknown 3. ........................................... Table Tennis Table Unknown 4. .................................. Sears Yard Tractor Unknown 5. .................................. Chain Saw Unknown 6. ........................................ Bicycle ... Unknown 7. ........................................ Tennis Rackets Unknown 8. ..................................... 1 Cut Off saw Unknown 9. ...................................... 2 Air Com resso Unknown 10. p rs .................................. Seed Spreader . Unknown 11. ................... .. .. .............. Toyota Landcruiser Unknown 12. .................................. Miscellaneous Hand Tools Unknown ............................ Unknown The claimant obtained title to the property as follows: (a) Living Room 1. Sofa .............. Claimant purchased in approximately 1997-1998 2. Love Seat ........... Claimant purchased in approximately 1997-1998 -3- 3. Chairs (4) .. Claimant purchased (2) in approximately 1997-1998 (2) gifts 4. Coffee & End Tables ... Claimant purchased in approximately 1994, 1 gift 5. Miscellaneous Furniture (Locker) ...... Claimant purchased & refinished 6. Rugs ........................................ Marital Property 7. Pictures .................... Purchased by Claimant in 1997 or 1998 8. Mirrors ...................................... Marital Property 9. Television ..................... Claimant purchased while in college 10. VCR ........................................ Marital Property 11. Stereo ............................ Purchased by Claimant in 1984 12. Video Games ............ Purchased by Claimant between 1996-1998 13. Telephone .................................... Gift to Claimant (b) Dining Room 1. Table ................................ Wedding gift to Claimant 2. Chairs (8) ............................. Wedding gift to Claimant 3. Buffet ................................ Wedding gift to Claimant 4. Silverware ............................ Christmas gift to Claimant 5. China ........................ Gift to Claimant from Grandmother 6. Rugs ........................................ Marital property 7. Hutch ................................ Wedding gift to Claimant (e) Kitchen 1. Microwave .............. Purchased by Claimant between 1994-1998 2. Utensils ................. .............. Wedding gift to Claimant 3. Pots/Pans ............... .............. Birthday gift to Claimant 4. Iron ................... ........ Purchased by Claimant in college 5. Ironing Board ............ ........ Purchased by Claimant in college 6. Refrigerator ............. Purchased by Claimant between 1994-1998 7. Stove .................. Purchased by Claimant between 1994-1998 8. Washer ................. Purchased by Claimant between 1994-1998 9. Dryer .................. Purchased by Claimant between 1994-1998 10. Freezer ................. Purchased by Claimant between 1994-1998 11. Mixer :..................... Purchased by Claimant - time unknown 12. Blender .................. ... Purchased by Claimant - time unknown 13. Coffee Pot ............... ...................... Christmas gift 14. Toaster .................. ............. Gift, approximately 1992 (d) Bedrooms I . Bed (Is'. 2nd, 4'") 1 owned by Claimant for years, 2 purchased by Claimant 2. Chairs (2nd) ........................ Purchased by Claimant in 1995 3. Lamps (I') .................... Purchased by Claimant in Baltimore 4. Rugs (I") .................................... Marital Property -4- 5. Night Stand (1", 4") 1 Purchased by Claimant, I gift refmished by Clamant 6. Television (1", 2nd) ...... • • • , ...... • • • • • • • • Purchased by Claimant 7. Clock (2"d) ......... • .. Belonged to Claimant for years 8. 2 Exercise Machines ......... 1 Purchased by Claimant, 1 Birthday Gift 9. Sewing Machine ................. Gift from Claimant's Grandmother 10. 3 Security Cameras ..................... • • • • ... Marital property (e) Study 1. Computer .............. 2. Entertainment Center • .' ' ' ' ' ' • • Purchased by Claimant in 1992 • • . • Marital property - built in to residence 3• Television ............... Purchased by Claimant between 1994-1998 4. Desk & Chair ......................... 5. Credenza ............. • • • • Marital property "'••••••••••••• Marital property 6. 3 Security Cameras ........ • .. . 7• Filing Cabinet ........ • ...• .• • .• • ..' ' ' ' ' ' • • Marital property ........................ Marital property TV Room 1 • Television ........... .. Purchased by Claimant in 1995 2. Rugs ........... Purchased by Claimant in Towson MD, date uncertain 3. CD Player ............... Purchased by Claimant between 1994-1998 4. VCR .............. Purchased by Claimant at same time as CD Player 5. 5 speakers, Surround sound ...... 6• 3 Chairs Purchased at same time as CD Player Purchased by Claimant in Towson 7. Couch ......................... Purchased by Clamant in Towson 8. End 'fable ............. Purchased by Claimant at Montgomery Wards (g) Garage 1. Sears Lawnmower ............... Gift to Claimant about 4 years ago 2. Power Drill ............... Gift from Claimant's Father & Grandfather 3. Garden Tools ............ Gift to Claimant from Father & Grandfather 4. Skis Owned by Claimant for years 5. Television & Stand • . 6. Gas Grill .............. New gas grill was birthday Claimant for years y present to Claimant (h) Entry Way 1. 2 Bookshelves with knick knacks ........... 2. 4 Marble Exhibit Stands . Plastic stands purchased Wedding gifl to & finished by Claimant 3. Pool Table ................ Purchased by Claimant, Marital Property (i) Miscellaneous I • Wheelba%Tow ... Purchased by Claimant at Hechingers about 2 years ago 2. 3 chairs ...................... . ............... Marital property -5- 3. Table Tennis Table ............................. Marital property 4. Sears Yard Tractor .......... Purchased by Claimant about 3 years ago 5. Chain Saw ........... Purchased by Claimant at Lowe's 3-4 years ago 6. Bicycle ..................... Purchased by Claimant - date uncertain 7. Tennis Rackets ................... Claimant has owned since college 8. 1 Cut Off saw ................. Gift from Claimant's father years ago 9. 2 Air Compressors ........................ Purchased by Claimant 10. Seed Spreader ... Purchased by Claimant at Hechingers, Marital Property 11. Toyota Landcruiser .......... Purchased by, and registered to Claimant 12. Miscellaneous Hand Tools .. Gift to Claimant from Father & Grandfather Respectfully Submitted, IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, PA 17102 Phone: 717-238-1657 By; %;. Dlc-?- ? • 46d IRA H. WEINSTOCK By: WENDY ULLEA BOWIE -6- VERIFICATION I verify that the statements contained in the attached CLAIM FOR PROPERTY are true and correct to the best of my knowledge, information, and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Dated: a 2,3 1 ?? CERTIFICATE OF SERVICE I, Wendy Dullea Bowie, Esquire, hereby certify that on the date stated below, I served the attached PROPERTY CLAIM upon the person named below, at the stated address, by first class postage paid United States mail Keith O. Brenneman, Esquire SNELBAKER9 BRENNEMAN & SPARE 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055 WE Y DULLEA BOWIE Dated: July 26, 1999 I u 44 *' o 444 fu z w x +1 ro a H W . r C ?l m b H W a as ? a E H z a W Q 0 z H W !A , 7 I x ro H Q Q H H z a M m W c U wrn mxu a Q > H -I Q H u °u w v Q z h Q H E 0 a a: N N U < O 3 zr=0W i Yy ? W 4 W V z z O OS S N M W 4 YINYA'li SNN3d 66, wn LE i i ca Mr A:ni:. _dW10 dl1Si3Hs 3111 !0 3:113j0 IN THE COURT OF CChM7N PLEAS OF CUIBBERLAND COUNTY, PENNSYLVANIA ELIZABETH J. TINDALL, known as ELIZABETH J. V. # DAVID C. DICKSON,III, AW4.PA I7o5s CIVIL DIVISION formerly I DICKSON, Plaintiff Fi e 99-3091 : Amount Due $277,772.08 : Interest from May 21, 1999 $8,333.16 : Atty's Cortm NIA Defendant Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR E(BCUPION 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) any and all bank accounts savings accounts fund accounts and other accounts titled alone.in the name of David C. Dickson III, including u no smite to accoun num er a Keystone inancla formerly Financial Trust, Garnishee, One West High-Street, Carlisle Pennsylvania PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) any and all bank accounts, savings account's, fund accounts and other accounts titled alone in thb name-of David C. Dickson III, including but not limited to account number 3780739052, at Keystone Finane a f-eEmeEjy-F4rnaaeia1 Trust, Garnishee, gee Wes High Street, r=a lisle and all other property of the defendant(s) in the possession, custody or control of the PA 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 jb?An. DATE: October 21, 1999 Signature: 11''0' J?= Print Name: Keith O. Brenneman Address: 44 W. Main Street Mechanicsburg PA 17055 Attorney for: Plaintiff Telephone: (717) 697-8528 Supreme Court ID No.: 47077 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. 8?1 V ?pa n L c w K ? :f Z N - - Jm v,.: lm C S W -G V v I I 1` ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant SHERIFF'S INTERPLEADER Deirdre L. Dickson, Property Claimant V. Elizabeth J. Tindall, Defendant in Interpleader V. LAW OFMCS SNELOAKER. BRENNEMAN & SPARE David C. Dickson, III, Defendant in Interpleader IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW ORDER AND NOW, this day of e7 C - , 1999 upon consideration of the Motion to Compel of Plaintiff, it is hereby ORDERED that Deirdre L. Dickson is to attend her deposition scheduled at the offices of Snelbaker, Brenneman & Spare, P. C., a8 44 W. Main Street, Mechanicsburg, Pennsylvania on October -2!t', 1999 at I S S7 C+C j f ?1 zf I C C o-?J{ 30 m . ViSC?/? I . _.. BY THE COURT: 2` Luu.15LII1 1Y23 •i'CI? L ;. .1 LA )LC. J. ELIZABETH J. TINDALL,. formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW SHERIFF'S INTERPLEADER Deirdre L. Dickson, Property Claimant V. Elizabeth J. Tindall, Defendant in Interpleader V. David C. Dickson, III, Defendant in Interpleader MOTION FOR ORDER TO COMPEL DEIRDRE L. DICKSON TO SUBMIT TO DEPOSITION Plaintiff Elizabeth J. Tindall by her attorneys, Snelbaker, Brenneman & spare, P. C. submits this Motion For order to Compel Deirdre L. Dickson to submit to a deposition and in support thereof states the following: 1. Plaintiff is in the process of executing upon a judgment against Defendant David C. Dickson, III, transferred from the state of Maryland to Cumberland County, Pennsylvania. 2. On August 27, 1999 Plaintiff's counsel served upon LAW OFFICES SNELUAKER• BRENNEMAN & SPARC_ counsel for Property Claimant Deirdre L. Dickson a Notice to Attend directing Deirdre L. Dickson to submit to a deposition at the offices of Snelbaker, Brenneman & Spare, P. C. on September 30, 1999 at 10:00 A.M. A true and correct copy of the Notice to Attend served upon counsel for Deirdre L. Dickson is attached hereto and incorporated by reference herein as "Exhibit All. 3. The deposition of Deirdre L. Dickson was scheduled by Plaintiff's counsel after giving counsel for Deirdre L. Dickson the opportunity to ascertain dates when both Deirdre L. Dickson and her counsel would be available for her deposition. 4. On September 28, 1999, two days prior to the scheduled deposition of Deirdre L. Dickson, counsel for Deirdre L. Dickson advised that the deposition scheduled for September 30, 1999 needed to be cancelled. 5. Counsel for Deirdre L. Dickson has requested that the deposition for Deirdre L. Dickson be noticed for October 21, 1999 at 10:00 A.M. WHEREFORE, Plaintiff requests this Court to issue an Order compelling Deirdre L. Dickson to attend her deposition scheduled for October 21, 1999 at 10:00 A.M. SNELBAKER, BRENNEMAN & SPARE, P. C. By: LI Keith 0. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall LAW Of FICE'+ SNEL"AKER. BRENNEMAN Date: October 4, 1999 & SPARE -2- VERIFICATION I verify that the statements made in the foregoing Motion 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. Keith 0. Brenneman Date: October 4, 1999 LAw orris SNELRAKER, BRENNLMAN & SPARC ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW SHERIFF'S INTERPLEADER Deirdre L. Dickson, Property Claimant V. Elizabeth J. Tindall, Defendant in Interpleader V. David C. Dickson, III, Defendant in Interpleader NOTICE TO ATTEND I Y........ ,. •.N1 1 1,,,1 . it. 111!1 fill[ MAN ll '.Pr... TO: Deirdre L. Dickson 2810 Myrtle Drive Mechanicsburg, PA 17055 (1) You are directed to come to the offices of Snelbaker, Brenneman & Spare, P. C. at Mechanicsburg, Pennsylvania, on September 30, 1999 at 10:00 o'clock A.M., to testify on behalf of Elizabeth J. Tindall in the above case, and to remain until j excused. (2) And bring with you the following: any receipts, bills of sale, titles and any and all other documents that pertain, ! relate or in any way refer to your ownership of the property claimed in the Property Claim filed in the above matter on I behalf of Deirdre L. Dickson. i EXHIBIT A I If you fail to attend or to produce the documents or things required by this Notice To Attend, you may be subject to the sanctions authorized by Rule 214.5 of the Pennsylvania Rules of Civil Procedure. SNELBAKER, /BBRE?NNEMAN & SPARE, P. C. I BY: I Keith o. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: August 27, 1999 I I i i i i LAw orrlcu SNELBAKER, BRENNEMAN & SPARE II -2- CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the i foregoing Notice to Attend to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS: I Wendy D. Bowie, Esquire Ira H. Weinstock, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 West Main Street P. O. Box 318 Mechanicsburg, PA 17055 j (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall I Date: August 27, 1999 LAW GFFICL6 SNELBAKER, BRENNEMAN & SPAnE CERTIFICATE OF SERVICE IF KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing motion to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Wendy D. Bowie, Esquire Ira H. Weinstock, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 IkAWVWL'?? Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 West Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: October 4, 1999 Law OFFICE.' I? SNELBAKER. BRENNEMAN & SPARE _ F-- Ci d'. CJ ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee TO: Keystone Financial, Garnishee Date of Notice: November 23, 1999 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEAPING 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, Pennsylvania 17013 (717) 249-3166 SNELBAKER, RENNEMAN & SPARE, P. C. BY?7 ?lll LAW OFFIGLG Keith 0. Brenneman, Esquire SNELOAKER. 44 W. Main Street BRENNEMAN Mechanicsburg, PA 17055 & SPARE: NRE (717) 697-8528 II Attorneys for Plaintiff CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing important Notice to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Keystone Financial One West High Street Carlisle, PA 17013 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 West Main Street P. 0. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: November 23, 1999 LAW OFFICE, SNELUAKER. BRENNEMAN & SPARE Ll l ? ?? - C . : Jj 1 l? fJ, CJ SHERIFF'S RETURN - GARNISHEE CASE NO: 1999-03091 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TINDALL ELIZABETH J VS. DICKSON DAVID C III And now HAROLD WEARY , Sheriff or Deputy Sheriff of CUMBERLAND , County, who being duly sworn according to law, at 1425:00 HOURS, on the 27th day of October , 1999, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named defendant DICKSON DAVID C III in the hands, possession, or control of the within named Garnishee KEYSTONE FINANCIAL by then and there summoning the said Garnishee at ONE WEST HIGH ST. CARLISLE. PA 1 CUMBERLAND County, Pennsylvania, by handing to SHAWNNA SMITH, CUSTOMER SERVICE REPRESENTATIVE , 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 .00 Affidavit .00 ?. Surcharge .00 R-Thomas amine, Sheriff -00/00/0000 by epu y $Teri - Sworn and subscribed to before me this .2? `: day of 19 A.D. ? ioiio aL ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee ORDER AND NOW, this (D?^ day of Pe-e-^ eJ upon consideration of the Motion of Plaintiff Elizabeth J. Tindall to schedule a hearing to assess the amount of a judgment against Garnishee Keystone Financial, it is hereby ORDERED that a hearing ?jis?,tl scheduled on the foregoing Motion for the .3114E day of 7-is ' ZOO , at .190 o'clock f- m. in Courtroom No. of the Cumberland County Courthouse in Carlisle, Pennsylvania. A copy of this order together with a Notice of Assessment LAW OrVICL5 SNELOAKCR, BRENNEMAN a SPARC of Damages in the form provided by Pa.R.C.P. 3146(2) shall be served upon counsel for Defendant David C. Dickson, III and Garnishee Keystone Financial or any counsel that may enter his or her appearance on behalf of said Garnishee no later than 20 days prior to the scheduled hearing. BY THE COURT: LAW OFFICEU SNELOAKER, BRENNEMAN & SPARE i 1 ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff. V. DAVID C. DICKSON, III, Defendant and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW MOTION TO SCHEDULE A HEARING TO ASSESS AMOUNT OF JUDGMENT AGAINST GARNISHEE KEYSTONE FINANCIAL Plaintiff Elizabeth J. Tindall, by her attorneys, Snelbaker, Brenneman & Spare, P. C., moves this Court to schedule a hearing to assess the amount of judgment against Garnishee Keystone Financial and in support thereof states the following: 1. On June 11, 1999 Plaintiff entered judgment against Defendant David C. Dickson, III in the amount of $277,772.08 together with interest and costs. 2. On October 21, 1999 Plaintiff filed a Praecipe for Writ of Execution against all bank and other accounts in the name of David C. Dickson, III at Keystone Financial, Garnishee. 3. Garnishee Keystone Financial was served by the office of the Sheriff of Cumberland County with the Writ of Execution LAW OFFICLS SNELRAKLR. on October 27, 1999. ORLNNLM.AN & SPARC 11 4. On November 1, 1999 Interrogatories in Attachment to Garnishee were served upon Keystone Financial by Plaintiff's attorney. Said Interrogatories were endorsed with a Notice to file Answers to the Interrogatories within twenty (20) days after service of the Interrogatories and that failure to do so may result in a judgment against Keystone Financial, Garnishee. 5. On November 23, 1999 an Important Notice was served upon Keystone Financial, Garnishee, due to its failure to respond to the Interrogatories served on November 1, 1999. 6. Due to Keystone Financial's failure to respond to the Interrogatories and subsequent Important Notice, on December 6, 1999 Plaintiff Elizabeth J. Tindall entered judgment against Keystone Financial in an unliquidated amount pursuant to Pa.R.C.P. 3146(a)(1). A true and correct copy of the Praecipe filed December 6, 1999 by Plaintiff noting judgment against Garnishee Keystone Financial is attached hereto and incorporated by reference herein as "Exhibit 1". That Exhibit contains true and correct copies of the Interrogatories and Important Notice served upon Garnishee Keystone Financial. 7. In accordance with Pa.R.C.P. 3146(a) (1) Plaintiff requests this Court to schedule a hearing to assess the amount of the judgment to be entered against Keystone Financial. LAW OFFICLA, SNELOAKER. -2 - BRENNEMAN & SPARE B. Plaintiff's counsel has received no communication from Keystone Financial or counsel representing Garnishee Keystone Financial. WHEREFORE, Plaintiff requests this Court to schedule a hearing for purposes of assessing the amount of the judgment against Keystone Financial. SNELBAKER, BRENNEMAN & SPARE, P. C. BY: Keith 0. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: December 7, 1999 uw OFfJCLs SNELRAKER. BRENNEMAN a SPARE u -3- VERIFICATION I verify that the statements made in the foregoing Motion are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4909 relating to unsworn falsification to authorities. I , t Keith O. Brenneman Date: December 7, 1999 LAW CFriCCG SNEL.DAKER. BRENNEMAN & SPARE ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW'.:; • c, PRAECIPE TO ENTER JUDGMENT AGAINST GARNISHEE PURSUANT TO Pa.R.C.P. 3146(a)(1) TO THE PROTHONOTARY: Please enter judgment in favor of Plaintiff Elizabeth J. Tindall and against Garnishee Keystone Financial, formerly Financial Trust, in an unliquidated amount pursuant to Pa.R.C.P. 3146(a) (1) for failure of the Garnishee to file an Answer to Interrogatories containing a Notice to Answer which was served upon the Garnishee on November 1, 1999. A true and correct copy of the Interrogatories served upon the Garnishee is attached hereto and incorporated by reference herein as "Exhibit A". An Important Notice indicating the intention of the LAW OFFICES SNELOAKER. BRENNEMAN & SPARE Plaintiff to take a default judgment against the Garnishee was served upon the Garnishee on November 23, 1999, a true and EXHIBIT 1 correct of which Important Notice is attached hereto and incorporated by reference herein as "Exhibit B". SNELBAKER, BRENNEMAN & SPARE, P. C. By: I ljtAZe,?? Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: December 6, 1999 uw ornCts SNEIQAKER. BRENNEMAN @ SPARE CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Praecipe to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Wendy D. Bowie, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 Keystone Financial One West High Street Carlisle, PA 17013 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: December 6, 1999 uw ornccc SNELOAKER. 13RENNEMAN & SPARE ELIZABETH J. TINDALL, IN THE COURT OF COMMON PLEAS OF formerly known as ELIZABETH CUMBERLAND COUNTY, PENNSYLVANIA J. DICKSON, Plaintiff NO. 99-3091 CIVIL V. CIVIL ACTION - LAW DAVID C. DICKSON, III, Defendant and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee INTERROGATORIES IN ATTACHMENT TO GARNISHEE KEYSTONE FINANCIAL FORMERLY FINANCIAL TRUST TO: Keystone Financial, formerly Financial Trust, Garnishee One West High Street Carlisle, PA 17013 IMPORTANT NOTICE You are required to file Answers to the following Interrogatories within twenty (20) days after service of this document upon you. Failure to do so may result in a judgment against you. INSTRUCTIONS "You" shall mean and refer to the main office and all LAW OFFICES SNELBAKER, BRENNEMAN & SPARE branch offices of Keystone Financial, formerly Financial Trust. "Defendant" shall mean and refer to David C. Dickson, III or any person, firm or entity acting at the direction of or on behalf of. David C. Dickson, III. 11 The reference to "time you were served" is a reference to October 27, 1999, the date when the Writ was served upon Keystone Financial. EXHIBIT A INTERROGATORIES 1. At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? ANSWER: 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? ANSWER: uw OFFICES SNELBAKER. BRENNEMAN & SPARE -2- 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? ANSWER: 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? ANSWER: Law CIIIC[1 & SPARE -3- 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 therefor? ANSWER: 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 his direction or otherwise discharge any claim of the Defendant against you? ANSWER: uw OFFICES SNELBAKER, BRENNEMAN Q SPARE -4- 7. Identify any and all accounts titled alone in the name of the Defendant, providing the account number and a description of the type or kind of account (e.g. checking, savings, fund, investment, etc.) and the balance in said account or accounts as of October 27, 1999? ANSWER: SNELBAKER, BRENNEMAN & SPARE, P. c. By: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall uw OFFICE, Date: November 1, 1999 SPARC 11 _5_ CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Interrogatories to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Keystone Financial One West High Street Carlisle, PA 17013 Wendy D. Bowie, Esquire Ira H. Weinstock, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 West Main Street P. 0. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: November 1, 1999 uw orncca SNELBAKER. BRENNEMAN & SPARE ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee TO: Keystone Financial, Garnishee Date of Notice: November 23, 1999 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 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, Pennsylvania 17013 (717) 249-3166 SNELBAKER, RENNEMAN & SPARE, P. C. B 7 ee Z"v y: LAW WICE9 SNELBAKER. BRENNEMAN & SPARE Keith 0. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff EXHIBIT B CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Important Notice to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Keystone Financial One West High Street Carlisle, PA 17013 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 West Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: November 23, 1999 uw OFFICES SNELBAKER. BRENNEMAN & SPARE CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Motion to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Wendy D. Bowie, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 Keystone Financial One West High Street Carlisle, PA 17013 lzf? Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: December 7, 1999 LAW OFFICLG SNELOAKER. BRENNEMAN & SPARE m t r %. ?LJ Ul - J.. C:) U U x ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee PRAECIPE TO TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW JUDGMENT AGAINST GARNISHEE Pa.R.C.P. 3146(a)(1) Please enter judgment in favor of Plaintiff Elizabeth J. Tindall and against Garnishee Keystone Financial, formerly Financial Trust, in an unliquidated amount pursuant to Pa.R.C.P. 3146(a) (1) for failure of the Garnishee to file an Answer to Interrogatories containing a Notice to Answer which was served upon the Garnishee on November 1, 1999. A true and correct copy) of the Interrogatories served upon the Garnishee is attached hereto and incorporated by reference herein as "Exhibit All. An Important Notice indicating the intention of the Plaintiff to take a default judgment against the Garnishee was LAW DFFlCCS II SNEIOAKER. served upon the Garnishee on November 23, 1999, a true and BRENNEMAN & SPAR[ correct of which Important Notice is attached hereto and incorporated by reference herein as "Exhibit B". SNELBAKER, BRENNEMAN 6 SPARE, P. C. By: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: December 6, 1999 LAW OFFKCs SNELRAKER. BRENNEMAN & SPARE CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Praecipe to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS: Wendy D. Bowie, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 Keystone Financial One West High Street Carlisle, PA 17013 ?/,.?hY?w?-- Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. 0. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: December 6, 1999 LAW OFFICEG SNEl6AKER. BRENNEMAN & SPARE ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW INTERROGATORIES IN ATTACHMENT TO GARNISHEE KEYSTONE FINANCIA. L FORMERLY FINANCIAL TRUST TO: Keystone Financial, formerly Financial Trust, Garnishee One West High Street Carlisle, PA 17013 IMPORTANT NOTICE You are required to file Answers to the following Interrogatories within twenty (20) days after service of this document upon you. Failure to do so may result in a judgment against you. INSTRUCTIONS "You" shall mean and refer to the main office and all Lew OFFlccs SNELGAKER. BRENNEMAN & SPARE branch offices of Keystone Financial, formerly Financial Trust. "Defendant" shall mean and refer to David C. Dickson, III or any person, firm or entity acting at the direction of or on behalf of David C. Dickson, III. Keystone Financial. The reference to "time you were served" is a reference to October 27, 1999, the date when the writ was served upon EXHIBIT A INTERROGATORIES LAW OFFICES ?I SNELBAKER. BRENNEMAN & SPARE 1. At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? ANSWER: 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? ANSWER: -2- 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? ANSWER: 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? ANSWER: Low OFFICES SNELSAKER. BRENNEMAN' &SPARE - 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 therefor? ANSWER: 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 his direction or otherwise discharge any claim of the Defendant against you? ANSWER: LAW OFFICES SNELDAKER. BRENNEMAN & SPARE -4- 7. Identify any and all accounts titled alone in the name of the Defendant, providing the account number and a description of the type or kind of account (e.g. checking, savings, fund, investment, etc.) and the balance in said account or accounts as of October 27, 1999? ANSWER: LAW OFFICES SNELBAKER. BRENNEMAN a SPARE SNELBAKER, BRENNEMAN & SPARE, P. C. By. Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: November 1, 1999 -5- CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Interrogatories to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Keystone Financial One West High Street Carlisle, PA 17013 Wendy D. Bowie, Esquire Ira H. Weinstock, Esquire suite 100 800 North Second Street Harrisburg, PA 17102 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 West main street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: November 1, 1999 LAW Of IIC[5 SNELOAKER. BRENNEMAN & SPARE ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW TO: Keystone Financial, Garnishee Date of Notice: November 23, 1999 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 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, Pennsylvania 17013 (717) 249-3166 LAw omccc SNCLOAKCR. BRENNCMAN & SPARC SNELBAKERf,RE(N?N?EMAN & SPARE, P. C. Y: Keith 0. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff EXHIBIT B CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the Iforegoing Important Notice to be served upon the person and in ;the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Keystone Financial One West High Street Carlisle, PA 17013 Keith 0. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 West Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: November 23, 1999 "A OFFICE. SNELOAKER, BRENNEMAN & SPARE co 1 L , ff. U (a .J . t ELIZABETH J. TINDALL, IN THE COURT OF COMMON PLEAS OF formerly known as ELIZABETH CUMBERLAND COUNTY, PENNSYLVANIA J. DICKSON, Plaintiff NO. 99-3091 CIVIL vs. DAVID C. DICKSON, 111, Defendant and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee CIVIL ACTION - LAW NOTICE OF ASSESSMENT OF DAMAGES 11 TO: KEYSTONE FINANCIAL, Garnishee: II On October 27, 1999, you were served with a writ of execution as a garnishee and were notified of your duties under it. Judgment has been entered against you because you have failed to answer the interrogatories served after the writ. The court will assess the amount of the judgment at a hearing to be held on February 3, 2000 at 1:30 P.M., in Courtroom 1, Cumberland County Courthouse, Carlisle, Pennsylvania. If you fail to appear, damages will be assessed against you in the amount of thejudgment of the plaintiff against the defendant, $277,772.08, together with interest, costs and reasonable expenses including attorney's fees, whether or not you may owe anything to the defendant or hold any of the defendant's property. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, uw orr,ccs SNELOAKER. BRENNEMAN & SPARE 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 SNELBAKER, BRENNEMAN & SPARE, P. C. By:_ Keith 0. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Elizabeth J. Tindall Date: January 12, 2000 uw CrrICE6 SNELBAKCR. BRENNEMAN S SPARE CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Notice be served upon the persons and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS: William A. Duncan, Esquire 1 Irvine Row Carlisle, PA 17013 Keystone Financial One West High Street Carlisle, PA 17013 Wendy D. Bowie, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 VA*Wzt'? Keith 0. Brenneman, Esquire SNELBAKI-11, BRENNEMAN & SPARE, P. C. 44 W. Main Street 13. O. Box 318 Mechanicsburg, PA 17055 (717) 697.8528 Attorneys for Elizabeth 1. Tindall January 12, 2000 LAW OFFICC6 SNELOAKW, BRENNEMAN & SPARE r' turd u ? ?s ; ?: x Vd h .,z i?w r ,-i U G 0 ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. DAVID C. DICKSON, III, Defendant CIVIL ACTION - LAW V. KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee NO. 99-3091 CIVIL TERM ORDER OF COURT AND NOW, this I" day of February, 2000, upon consideration of tile 111111ched letter from Keith O. Brenneman, Esq., attorney for Plaintil7, the hearing previously scheduled for February 3, 2000, is cancelled. BY THE COURT, J. Keith O. Brenneman, Esq. 44 West Main Street Mechanicsburg, PA 17055 Attorney for Plaintiff Wendy D. Bowie, Esq. Ira H. Weinstock, Esq. Suite 100 800 North Second Street Harrisburg, PA 17102 Attorneys for Defendant ,`'"!"""" -/rru .?-,3-00 RK5 Keystone Financial One West High Street Carlisle, PA 17013 Garnishee sc A- SNELBAKER, BRENNEMAN 8 SPARE A PROE!'SSIONAL CORPORAI ION ATTORNEYS AT LAW 44 WEST MAIN STREr..T MECHANICSBURG, PENNSYLVANIA 17055 RICHARD C, SNELBAKER Kum a BRENNEMAN PHILIP H. SPARE 717.607.8528 January 31, 2000 The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Re: Tindall v. Dickson and Keystone Financial No. 99-3091 Civil Dear Judge Oler: P. O. BOX 318 FACSIMILE (717) 697.7681 Your calendar will reflect that you have a hearing scheduled on Thursday, February 3, 2000 at 1:30 p.m. for purposes of assessing the amount of a judgment. against Garnishee Keystone Financial in the above matter. I write to advise that the matter involving Keystone Financial has been resolved and there is no need for the hearing as scheduled. I am submitting to the Prothonotary this date a Praecipe withdrawing the Motion of Plaintiff to schedule a hearing in this matter. Yours truly, Keith 0. Brenneman KOB/sz CC: William A. Duncan, Esquire Wendy D. Bowie, Esquire CLJ 1 ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff vs. DAVID C. DICKSON, 111, Defendant and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee PRAECIPE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW TO THE PROTHONOTARY: Please withdraw the Motion of Plaintiff Elizabeth J. Tindall to schedule a hearing to assess the amount of judgment against Keystone Financial in the above matter. SNELBAKER, BRENNEMAN & SPARE, P. C. Date: January 31, 2000 By: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall LAW OFFICR SNELMAKER. BRENNEMAIJ & SPARE CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Praecipe to be served upon the persons and in the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID, ADDRESSED AS FOLLOWS: William A. Duncan, Esquire 1 Irvine Row Carlisle, PA 17013 Wendy D. Bowie, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 Keith 0. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. 0. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: January 31, 2000 LAW OFrlcrc SNELOAKER. 13RENNEMAN & SPARE C, J i- t" Li t]I:J L I ' n ? ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff vs. DAVID C. DICKSON, III, Defendant and '"W OFFICES SNELSAKER. BRENNEMAN & Sr-ARE KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LAW ORDER AND NOW, this Z CA day of T ZnU zJ1 , 2000 upon consideration of the Stipulation of the parties and the Motion For Order Approving Stipulation Assessing Amount of Judgment, it is hereby ORDERED that said Stipulation is APPROVED and that a money judgment is hereby entered in favor of Plaintiff Elizabeth J. Tindall and against Keystone Financial, Garnishee in the amount of $1,393.66. BY THE COURT: w CIO F,LI .AI31.11-I J '1'1NDA1J- 16unerly l;nuwl, as lild%A131-A H i I)J("YS'(JN Niaiutifl ( vs DAVII) C UJ(,KSON. lU. 1)eti:ndanl and KIiY$7'()NJi FINANCIAL, fvnnerk, Financial 't'rust, Garnishee IN THE COUKT OF COh9A90N PLEAS OF CUMBERLAND COUNTY. PENNS)T :ANIA NO 99-3091 CIVIL CIVIL ACTION - LAW t4-') IgN' 1 qg JKI)1:_EZ_AP!'}t]\ 1NC S I'1PUL.ATION 65515$JN(,PMC)[r\'1 ()F,_Da?lAt ES -- 1'Jeiutifl'1';lizabeth J. '1'ili6,jj, b)- her attorneys, Sneltiaker, Brenneman Spare; 11. C. Subinit's this.M.otion and in support thereof states the following: 1. f bl December ti, 1999 Plaintiff entw,ed judgment against Garnishee 1Seysl??ne h'iuan? ii11 in an unhgwd lted aulount Pursuant to a praecipe Sled in a?!'ulvlonrxe will) due u, Keystone F'inancial's failure to file Anr.wel,5 lip Illlerrogau>riea served upon Ow-nishee November 1, 1999. 1. On I)ecenlbcn• 10, 1"19!1, upon Motion of the Plaintiff, this Court scheduled u hearing lip assess the wnulult 411'jndgnu ul. nt ainst ICeystone Financial for Vchl"l;wy :1, 2000 ill 1::j() 11 111, ill 1. .1. Hillce Ihn enlry t&a jUdgO1N11 11911in.41. Klryslone Financial, Keystone „•, 1'?IIIi111C1i11 Mils sllllllllll,91 Allti\VI.1'ti I11 Plaillt1U'V lll((y1-09-1001-ivS indicating it is in Won iw4.i„ 1, 141,oi u"" c"" Pussl+ssion u(bnuk ulcounts lined in Uu uunu of Urtivldiult David C. Dickson with h;lulu/I+s lulalillgl,;l!Y,tlili, 4. Garnishee Keystone Financial, through its counsel, has entered into a Stipulation with Plaintiff stipulating to the assessment of the amount of judgment and the entry of judgment against Keystone Financial in the amount of $1,393.66. A true and correct copy of the Stipulation noted above is attached hereto and incorporated by -reference herein as "Exhibit A". WHEREFORE, Plaintiff requests this Court to enter an Order approving the parties' Stipulation, assessing the amount of judgment against Garnishee Keystone Financial at $1,393.66 and entering a money judgment against Keystone Financial in the amount of $1,393.66 and in favor of Plaintiff' Elizabeth J. Tindall. SNELBAKER, BRENNEMAN & SPARE, P. C. By. Keith 0. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697.8528 Attorneys for Plaintiff uw orrice, SNELOAKER, BRENNEMAN & SPARE Date: January 18, 2000 1 - .7. ELIZABETH J. TINDALL, formerly known as ELIZABETH 1. DICKSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL vs. DAVID C. DICKSON, III, Defendant CIVIL ACTION - LAW and KEYSTONE FINANCIAL, f'orrnerIv Financial Trust, Garnishee STIPULATION Keystone Financial, by its attorney, William A. Duncan, Esquire, and Plaintiff Elizabeth J. Tindall, by her attorney, Keith 0. Brenneman, Esquire, hereby enter into this Stipulation with frill authority of their respective clients as follows: I. The amount of the judgment assessed against Garnishee Keystone Financial in this action is $1,393.66, which amount represents the balance of bank accounts in possession of Keystone Financial titled in the name of Defendant David C. Dickson. 2. A moneyjudgment is entered against Keystone Financial and in favor of Plaintiff J. Tindall in the amount of $1,393.66. 3. The parties through their attorneys agree that this Stipulation shall be submitted to the LAW OFFICES SNELBAKER, BRENNEMAN & SPARE EXHIBIT A uw OFFICES SNELBAKER. BRENNEMAN & SPARE Court for approval. DUNCAN & HARTMAN, P. C. t\ By: y tU C UV? William A. Duncan, Esquire One Irvine Row Carlisle, PA 17013 Attorneys for Keystone Financial q '71 C? Date: ...% _2" SNELBAKER,BRENNEMAN & SPARE, P.C. By: Jei O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 Attorneys for Plaintiff Elizabeth J. Tindall Date: I14 JA,Vw*e'tj 2ezc4 CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Motion be served upon the persons and in the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: William A. Duncan, Esquire 1 Irvine Row Carlisle, PA 1.7013 Wendy D. Bowie, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 Keith 0. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. 0. Box 318 Mechanicsburg, PA 17055 (717) 697.8528 Attorneys for Elizabeth J. Tindall Date: January 18, 2000 uw ornccs SNELOAKER. BRENNEMAN & SPARE ._.. ._ __ ...... ? ;r' ;; k k i?1 i ?1 1` JAN J 9 2000v ELIZABETH J. TINDALL, IN THE COURT OF COMMON PLEAS OF formerly known as ELIZABETH CUMBERLAND COUNTY, PENNSYLVANIA J. DICKSON, Plaintiff : NO. 99-3091 CIVIL vs. DAVID C. DICKSON, 111, CIVIL ACTION -LAW Defendant and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee STIPULATION Keystone Financial, by its attorney, William A. Duncan, Esquire, and Plaintiff Elizabeth 1. Tindall, by her attorney, Keith O. Brenneman, Esquire, hereby enter into this Stipulation with full authority of their respective clients as follows: L The amount of the judgment assessed against Garnishee Keystone Financial in this action is $1,393.66, which amount represents the balance of bank accounts in possession of Keystone Financial titled in the name of Defendant David C. Dickson. 2. A money judgment is entered against Keystone Financial and in favor of Plaintiff J. Tindall in the amount of$1,393.66. 3. The parties through their attorneys agree that this Stipulation shall be submitted to the LAW OFFICES SNELSAKER, BRENNEMAN & SPARE r-. LAW OFFICES SNELOAKER. BRENNEMAN & SPARE Court for approval. DUNCAN & HARTMAN, P. C. By:, \, William A. Duncan, Esquire One Irvine Row Carlisle, PA 17013 Attorneys for Keystone Financial Date: '?I VU? ?? t i? SNELBAKER, BRENNEMAN & SPARE, P.C. By: Date: ytf ANkJei 00.Brenneman, Esquire Mechanicsburg, PA 17055 2 44 W. Alain Street Attorneys for Plaintiff Elizabeth J. Tindall 0. ? cr^ r? C .y CC) i:9 _ cu ... .,_.. INL li_ O O C> IN THE COURT OF COMMON PLEAS OF CUFMERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ELIZABETH J. TINDALL, Plaintiff : File No. 99-3091 V. : Amount Due $277,772.08 DAVID C. DICKSON, III, Defendant : Interestfram May 21, 1999: $8,333.16 and : Atty's Comm N/A RANDY S. FREDERICK, D.C... Garnishee V4,17 Lota5TG4.v6, e4 17707 TO THE PROTHONOTARY OF THE SAID COURT: . 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 ELUTION 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) PRAECIPE FOR ATTACIr4aU ENDCUI'ION Issue writ of attachment to the Sheriff of Dauphin 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) Any and all payments due and owing Defendant pursuant to the terms of a Note dated 1/13/98 together with anv and all other payments due by Garnishee to Defendant and any and all other property of Defendant in Possession of Garnishee. 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 t.. DATE; February 8, 2000 Signature: Print Name: Keith O. Brenneman Address: 44 W. Main Street Mechanicsburg, PA 17055 Attorney for: Plaintiff Elizabeth J. Tindall Telephone: (717) 697-8528 Supreme Court ID too.: 47077 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. I ra n ?.? C C, n ?- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-3091 CIVIL fib Term COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF _ Dauphin COUNTY: To satisfy the debt, interest and costs due Elizabeth J. Tindall PLAINTIFF(S) from David C. Dickson, III and Randy S. Frederick. D.C.. 4607 Locust Lane Harrisburg, PA 17109 - Garnishee (1) You are directed to levy upon the properly 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 Any and all payments due and owing Defendant pursuant to the terms of a Note dated 1/13/98 together with any and all other payments due by Garnishee to Defendant and any and all other property of Defendant in possession of Garnishee. 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 properly of the defendant(s) or otherwise disposing thereof; (3) Ifpropertyofthedefendant(s)notlevieduponansubjecttoattachment isfoundinthepossession 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 $277,772.08 L.L. Interest from Ally's Comm Atty Paid _ Plaintiff Paid Due Frothy Other Costs 00 Date: _ Febntz-ty 9. 2000 n. Tnng Prolhooonnnotarry, Civil Division / - - `?- Deputy REQUESTING PARTY: Name Keith O. Brenneman, Esq. Address: 44 W. Main Street Mechanicsburg, PA 17055 Attorney for: Pi a; nr; f f Telephone: 717-697-8528 21, 1999: $8,333.16 Supreme Court ID No. 47077 1y ELIZABETH J. TINDALL, Formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant and RANDY S. FREDERICK, D.C., Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL ACTION - LAW ORDER AND NOW, this day of ti? 1 ` 2000 upon consideration of the Petition For Supplementary Relief In Aid of Execution, in accordance with Pa.R.C.P. 3118(a), a hearing is hereby scheduled for the /S.6& day of , 2000 at 9; 30 o'clock T .M. in Courtroom No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT: "W ornccs SNELOAKER. BRENNCMAN & SPARE 0O Q? ELIZABETH J. TINDALL, Formerly known as ELIZABETH J. DICKSON, Plaintiff V. DAVID C. DICKSON, III, Defendant and RANDY S. FREDERICK, D.C., Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 99-3091 CIVIL ACTION - LAW PETITION FOR SUPPLEMENTARY RELIEF IN AID OF EXECUTION PURSUANT TO Pa.R.C.P. 3118(al Plaintiff Elizabeth J. Tindall by her attorneys, Snelbaker, Brenneman & Spare, P. C., submits this Petition for Supplementary Relief in Aid of Execution as follows: 1. On February 9, 2000 Plaintiff filed a Praecipe for Attachment Execution in this action for the issuance of a Writ of Attachment to the Sheriff of Dauphin County directing the attachment of Garnishee Randy S. Frederick for, inter alia, all payments due and owing Defendant pursuant to the terms of a Note dated January 13, 1998. A true and correct copy of the aforementioned Praecipe for Attachment Execution is attached hereto and incorporated by reference herein as "Exhibit A". 2. On February 22, 2000 the Office of the Sheriff of Dauphin County, Pennsylvania served a Writ of Execution and/or Attachment together with interrogatories in Attachment upon Garnishee Randy S. Frederick. A true and correct copy of the Writ of Execution and/or Lew or.«s Attachment served upon Garnishee Randy S. Frederick is attached hereto and incorporated by SNCLRAKER, BRENNEMAN reference herein as "Exhibit B". & SPARE 3. The Writ of Execution and/or Attachment served upon the Garnishee notified the Garnishee that he is "enjoined from paying any debt to or for the account of the Defendant. 4. On April 3, 2000 Plaintiff's counsel received a copy of Garnishee's Answers to Interrogatories in Attachment. A true and correct copy of the Answers to Interrogatories in Attachment are attached hereto and incorporated by reference herein as "Exhibit C". 5. In accordance with Garnishee's Answers to Interrogatories in Attachment, Garnishee acknowledged owing money to Defendant pursuant to the terms of a Note dated January 13, 1998. Garnishee further indicates Defendant assigned, with Garnishee's consent, Defendant's interest in the Note to Defendant and his wife as tenants by the entireties on or about March 9, 1999. (See Answer to Interrogatory 1, Exhibit C.) 6. Contrary to the directions contained in the Writ of Execution and/or Attachment, Garnishee continues to make payment to Defendant pursuant to the Note after service of the Writ upon Garnishee. (See Answer to Interrogatory 6, Exhibit C.) WHEREFORE, Plaintiff requests this Court to: A. Enjoin the Garnishee Randy S. Frederick from transferring or paying to Defendant and/or Defendant's wife amounts due Defendant under the Note of January 13, 1998, B. Require the Garnishee to post bond or security with this Court for purposes of ensuring no further payment by Garnishee to Defendant and/or Defendant's wife; -2- LAW on9ccc SNELOAKER. 13RENNEMAN & SPARC C. Direct Garnishee to account for and itemize all payments made to Defendant and/or Defendant's wife after Garnishee's receipt of the Writ of Execution and/or Attachment; and D. Grant such other and further relief as this Court deems necessary and appropriate under the circumstances. SNELBAKER, BRENNEMAN & SPARE, P. C. LAW or"CEC I) SNELRAKLR. BRENNEMAN & SPARE I 4 V(lt4 ?- BY: Keith 0. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff / Elizabeth J. Elizabeth J.'nndall Date: At, it (, y OWO -3- IN THE COURT OF CXHION PLEAS OF CUb1BERLAND COUNTY, PENNSYLVANIA CIVIL DI VISION ELIZABETH J. TINDALL, Plaintiff ' File No. 99-3091 V. : Amount Due $277,772.08 DAVID C. DICKSON, III, Defendant : Interest from May 21,1999: $8,333.16 and : Atty's Corm N/A RANDY S. FREDERICK, D.C.., Garnishee • Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. - PRAECIPE FOR EXECUTION Issue writ of execution in the above matter to the Sheriff of County, for debt, interest and costs upon the following described property:-of the defendant(s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Dauphin 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) Any and all payments due and owing Defendant pursuant to the terms of a Note dated 1/13/9A fnnei-hnr .o;th nn" nnA all otner payments aue by Garnishee to Defendant and any and all other proper, of Defendant in Possession of Garnishee. 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 eexxhi t.. DATE: February 8, 2000 Signature: fll. y4"?1? Print Name: Keith O. Brenneman Address: 44 W. Main Street Mechanicsburg, PA 17055 Attorney for: Plaintiff Elizabeth J. Tindall Telephone: (717) 697-8528 Supreme Court ID No.: 47077 EXHIBIT A 30G N WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Dauphin COUNTY: To satisfy the debt, Interest and costs due Elizabeth J. Tindall PLAINTIFF(S) from David C. Dickson III and Randy S. Frederick, D.C., 4607 Locust Lane. Harrisburg, PA 17109 - Garnishee 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 Any and all payments due and owing Defendant pursuant to the terms of a Note dated 1/13/98 together with any and all other payments due by Garnishee to Defendant and any and all other property of Defendant in possession of Garnishee. as follows: and to notify the gamishee(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 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 $277,772.08 Interest from May 21, 1999: $8,333.16 Ally's Comm -% Atty Paid _ s64 _nn Plaintiff Paid _ L.L. Due Prothy $1.00 Other Costs Date: February 9?I,n00 rS•-+ o rang Prothonotary,?Civilill Division /- Eby' Deputy REQUESTING PARTY: Name Keith 0. Brenneman, Esq. Address: 44 W. Main Street Mechanicsburg„ PA 17055 Attorney for: P1,; nH ff Telephone: 717-697-8528 Supreme Court ID No. 47077 aooa NO. 99-3091 CIVIL fOt Terns CIVIL ACTION - LAW TRUE COPY FROM RECORD to Testimony whereof, I here wito sot nt)r hand and the seal of said rt at Carlisle, Pa. iN day of ?Cw7• Drotho otary EXHIBIT B 03/31/2600 19':58 FAX 717 8439099 CoOntess,Cllhatt,Andreas Q0.02, 02/2312000 15:3e 7175458510 CHIROPLUS PACE 04 ELIZABETH J. TINDALL, Formerly known as ELIZABETH : IN TIiP COURT OF COMMON PLEAS OF J. DICKSON, : CUMBERLAND COUNTY, PENNSYLVNIA A Plaintiff V. N0. 99,3091 DAVID C. DICKSON, III CI''ACTION -LAW , Defendant j and j RANDY S: FREDERICK, D,C Garnishee rN....--- ANSWERS TO TO: Randy S. Frederick, D.C. 4607 Locust Lane Harrisburg, PA 17109 , ZED ZIANT N"T You are required to file Answers to the fbllowil!g Interrogatories within twenty (20) days after service of this document upon you. Failure to do so may result in a judgment against you. "You" shall mean and refer to Randy S. Frederik, D.C. "Defendant" shall mean and refer to David C. Dickson, III or any person, firm or entity acting at the direction of or on behalf of David C. Aick?on, I1T. 4w 01MCES The reference to "time you were served" is a refprcnce to the dale when the Writ was +JN[IYARGR, BRCNNCM/N served upon you. d 51-ARE BXHIBIT C 03/31/2000 13:tO FAX 717 8430030 countess,GI1b6rt,Andrews Z003 32/23/2000 15:38 71754581518 CHIROPLUS PAGE 05 • rNTE12R0 rA QtZiES 1. At the time you were served or at any subsequent time did you owe the Defendant any money or were liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? ANSWER: I owe money to a Dr. Dickson pursuant to a term Note signed by me on January 13, 1998 in favor of David Dickson, D.C. and Andrew Madeira, D in the principal amount of $90,000. I am m#ing payments pursuant to that Note to each of Dr. Dickson and Dr. Madeira in the amount of $811.15. Dr. Dickson's interest in the Note was assigned by Dr. Dickson to himself and his wife, Deirdre L.. Dickson, as tenants by the entireties which assignment was consented by me pursuant, to a document dated on or about March 9, 1999. 2. Xt the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custodyoY control of yourself and one or more other persons any property of any nature owned solely or in part' by the Defendant? ANSWER: In January of 1998; I purchased all of,Dr. Dickson's stock in ChiroPlus of Locust Lane, Inc. As security for the unpaid balance of the purchase price (see No. 1 above), I granted to Dr. Dickson a security interest in said stock. err,aas 6WAKE.• NN[MAN SPARE f '2' 05/31/2000 12:59 FAX 717 8439039 02/23/2800 15:38 7175458FID Countess, Gil bet, t, Andrews CHIROPWS 'v Q004 PAGE 06 _- ' 1 1 3. At the time you were served or at any subsequent time did you hold legal; ti•tic to any property of any nature owned solely Orin part by the Defendant or in which Defendant held or claimed any interest? ANSWER: See No. 2. 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? ANSWER: See No. 2. WPMCC n SraRe If ?? -3- 09/91/2000 14:00 FAX 717 8199099 02/23/2000 15:38 717545857.0 C01111tess, Gilbert, Andrews [a 005 CHIROPLUS PAGE 07 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 therefor? ANSWER: No. 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 his direction or otherwise discharge any claim of the Defendant against you? ANSWER: I have continued to make payments to Dr. Dickson pursuant to the Judgment Note referred to in Aifsweic-r5*-Vd'. I: SNCLMAKER. BKENNCNAN -4- . a SPARC II 09%91:2000 14:00 FAX 717 8490050 02/23/2000 15:38 7175458F?,0 Ovlcrt COuntess,GIlberL,Andrews CH1ROPl.US l2l 000 PAGE 08 7. State any and all amounts owed to Defendant at the time you were served; identify any property of-Defendant held by you at the time you were served and identify and describe any and all documents (e.g. note, mortgage, agreements, etc•) upon which you presently owe or under which you are presently making payments to Defendant. ANSWER: The balance on the original Note specified in the 'answer to No. 1 SNELBAKER, BRENNEh1AN & SPARE, P• C. BY: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17955 (717) 697.8525 Attorneys for Plaintiff Date: February 8, 2000 Elizabeth I Tindall L G1-ARE . ?? -5- 03/31,;2000 14:01 FAX 717 $490030 Cotintess,GIIbert,Andrews (6007 VERIFICATION I, the undersigned, Randy S. Frederick, D.C., hereby affirm that the facts contained in the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of IS Pa.C.S. Section 4904 relating to unworn falsification to authorities. Dated: Randy S. red D.C. CERTIFICATE OF SERVICE 1, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Petition be served upon the person and in the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Randy S. Frederick 4607 Locust Lane Harrisburg, PA 17109 Ronald Perry, Esquire 29 North Duke Street York, PA 17401-1282 Wendy D. Bowie, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 Keith 0. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. 0. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff J. Tindall Date: Pei/ ?? ZnvO LAW OFFICES ???'IIII SNELRAKER. BRENNEMAN & SPARE '- -• ti v, _? ? 4_:: -? ??.i _- l., il. _ ?' i:.' ?7 .. ???_ f! ? f?i?i . r-? ... u. ..7 -_? O v iJ ELIZABETH J. TINDALL, formerly known as ELIZABETH J. DICKSON, Plaintiff vs. DAVID C. DICKSON, III, Defendant and KEYSTONE FINANCIAL, formerly Financial Trust, Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3091 CIVIL CIVIL ACTION - LANV PRAECIPE TO THE PROTHONOTARY: Please mark the judgment entered against the Garnishee Keystone Financial, formerly Financial Trust in the above-captioned matter satisfied upon your docket and indices. SNELBAKER, BRENNEMAN & SPARE, P. C. . Jz?ffz'l Keith 0. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall LAW OFFMC6 SNCLOAKER. BRENNEMAN AN Date. April 14, 2000 & SPARE CERTIFICATE OF SERVICE I, KEITH 0. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Praecipe to be served upon the persons and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS: William A. Duncan, Esquire 1 Irvine Row Carlisle, PA 17013 Wendy D. Bowie, Esquire Suite 100 800 North Second Street Harrisburg, PA 17102 fa4?r?? ILAW OFFICES SNELSAKER• BRENNEMAN & SPARE Keith 0. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. 0. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Elizabeth J. Tindall Date: April 14, 2000 a- r 00 c? -13 ? Nir", 31218.7Vwthor+NP\U*sr•SLIU THIS AORBB1 M, made as of this E! day of January, 1998, between DAVID D4cKSON, D.C., or his assigns, (hereinafter referred to as 'Dickson") and ANDREW MADEIRA, D.C., or his assigns, (hereiAaftar referred to as "Madeira"), (sometimes hereinafter jointly referred to as "Sellers") and RANDY S. FREDERICK, D.C -I(hereinafter referred to as "Buyer"). WHEREAS, Dickson owns 333 shares of the issued and outstanding cap4al stock of chiroPlus of Locust Lane, Inc. Of 4607 Locust Lan, Harrisburg, Pennsylvania 17109 (hereinafter referred to as corporation"); and WHEREAS, M deira owns 333 shares of the issued and outstanding cap tal stock of Corporation; and WHEREAS, Htyer owns 333 shares of the issued and outstanding capital stock o Corporation; and WI[mmEAS, B yer desires to acquire all of the issued and outstanding cap tal stock of corporation owned by Sellers. NOW, THISiORE, in consideration of the mutual covenants herein contained as well as for other good and valuable consideration, ?hs receipt and adequacy of which are hereby acknowledged, a?d intending to be legally bound hereby, the parties agree ao follows: 1. Sell+ deliver to Buya? and outstanding,3c consisting of 656 i Dollar per shard, hereby agree to sell, assign, transfer and who hereby agrees to purchase all of the issued 3pital stock of Corporation owned by Sellers, shares, having a par value of one ($1.00) fully paid and non-assessable. 5?(5)ao w?Y 9121a.1\Authcr-RP\USB•5lR 2. The total price to be paid by Buyer to sellers shall be One Hundred Fifty!Thousand ($150,000.00) Dollars, of which Seventy-Five Thousand ($75,000.00) Dollars shall be paid to Dickson and Seven y-Five Thousand ($75,000.00) Dollars shall be 1 paid to Madeira. Said purchase price is to be paid by cash or approved check at closing. Provided, however, that Sellers agree that in lieu of t4 full purchase pries in cash or approved check at settlement as Lreinabove provided, they shall accept a sum equal to no less Than Sixty Thousand ($60,000.00) Dollars, to be split in equal shores among the sellers, with the balance of Ninety Thousand (90,000.00) Dollars to be paid by Buyer to Sellers in equal lonthly payments of principal and interest in I the amount of One!Thousand, Six Hundred, Twenty-two and 32/100 i ($1622.30) Dollar , based on a six (6) year amortization schedule and at an annual ?nterest rate equal to nine (9%) percent. Said balance due shall;be secured by Buyer's promissory note calling A for said equal m+hly payments beginning one month following closing and conti6ing until paid in full. 3. In the vent that Buyer does not pay the full purchase price in cash at closing, Buyer agrees that, as additional security for the potes granted to Sellers as provided for in I Paragraph 2 herein above, Buyer hereby agrees to pledge all i shares of capital stock of the Corporation which are acquired under this Agreem nt, or any shares issued in substitution therefor, such pledge to be on the condition that until default I in principal. or interest on the note, said shares shall be deemed to be owned by Buyer who may exercise all rights as owner 2 31218. therein. In orler to make this provision self-executing, Buyer hereby agrees t? deliver certificates of capital stock of the Corporation to uyer'a attorney, Ronald Perry, Gilbert, Esquire, at settlement, iogether with the stock powers attached and completed in su h form as shall allow the immediate transfer of such shares to iellers in the event of default, together with resignation of #uyer as Director and officer of the Corporation, signed by them Put undated. 4. Closi?g shall be held in the office of Buyer's attorney, Ronal Perry, Esquire, countess Gilbert Andrews, 29 North Duke Strtact t, York, Pennsylvania, on or before January 13, 1998 with the a date to be selected by Buyer pursuant to written notice ?o sellers not lass than one week in advance. Time is of the seance of this Agreement. By written agreement between the Buy r and Sellers said closing data may be either accelerated or xtended. 5. sell4s represent and warrant that Sellers, and each of them, have good absolute and marketable title to the Corporation stock free and ?lear of all liens, claims, encumbrances and restrictions of! every kind. Sellers have the complete and unrestricted ri?jht, power and authority to sell, transfer and assign the Corpll'ration stock pursuant to this contract; and the delivery of the Corporation stock to Buyer as contemplated in this contract will vest in Buyer good, absolute and marketable title to all of1the Corporation stock free and clear of all liens, claims, yncumbrances and restrictions of every kind. 3 i J121B.7 Uuthor•av\US?r•sLR 6. Sellers represent and warrant that the Corporation is a duly organized anc? validly existing Pennsylvania corporation in good standing wi all requisite corporate power and authority to carry on its busi sea as presently conducted. 7. sellers represent that Buyer has access to all instruments relating to the Corporation's long-term and short- term indebtedness,llI if any, and that the Corporation is not in any default for viola ion of any provision of its outstanding long- term or short-to indebtedness. 8. Sellers represent and warrant that there are no outstanding optio s, contracts, commitments, warranties, agreements or other rights of any character affecting or relating in any manner to the issuance of the Corporation's capital 4tock or entitling anyone to acquire the Corporation's capital stock or other securities.I i g. The parties acknowledge that Buyer is in possession of the Corporation's most recent balance sheet and the related statement of income and retained earnings. Both financial statements are inlaccordance with the books and records of the Corporation, fairy present the financial condition of the corporation at such dates and the results of its operations for the specified per ods, and were prepared in accordance with generally accepte(I accounting principals applied on a basis consistent with p4ior accounting periods, and, with respect to all contracts and commitments of the Corporation, reflect adequate reserves,for all reasonably anticipated losses and costs in excess of anticipated income- 4 31210. lo. sellexjs represent and warrant that the balance sheet discloses all o4 the debts, liabilities and obligations of any nature, whether Lbsoluta, accrued, contingent or otherwise, and whether due or Leo become due, of the corporation at the balance sheet date (exci t debts, liabilities and obligations that are not required toe reflected in the balance sheet in accordance with generally a? ceptad accounting principals), and includes I appropriate res ves for all taxes and other liabilities accrued or due at the ba}Lance sheet date but not yet payable. 11. Sellers represent that the corporation has duly filed I all federal, state and local tax returns required to be filed by it and has file4 all federal, state and local taxes required to be paid with resI Pect to the periods covered by the returns. 12. In the event that after the closing date a deficiency is determined inlthe amount of federal or state tax payable by the corporation relating to periods prior to the closing date, sellers agree to?be responsible on a pro rata basis with respect to their ownersh'p of stock in the corporation for the payment of { said deficiency. i 13. Sellers represent that the respective books of account and minute books of the Corporation are complete and correct and reflect all those transactions involving its business that 1 properly should nave been set forth in such books. 14. Unlessj8uyer consents in writing to the contrary, from the effective date of this Agreement through and until final Closing hereunder, Sellars will cause the Corporation to opera only in the ordinary course of business. Sellers shall not cause 5 7121E.1\Uuthor.Rp\uLaro9LR the corporation td incur any debts, enter into any transaction or perform any act tiat would constitute a breach of the i ropraaant$tions, 4arranties or agreements contained in this contract. 15. Sellerslahall deliver to Buyer at the closing, written resignations of S filers as officers, directors and employees of the Corporation. ; 16. In aceoidance with the provisions of this Agreement, Sellers agree to 4eliver to Buyer at settlement, all of the Corporation's recIrds, including its minute book and stock transfer ledger, is well as stock certificates representing 666 shares of the outgtanding capital stock of the Corporation, duly endorsed in blank with signatures guaranteed by a bank, attorney or notary public, together with their resignation as officers and directors of the corporation. 17. It is hereby understood and agreed that the sale by Sellers of their tock in the corporation to Buyer shall constitute a land complete release by Sellers of all claims and demands of an kind on their part against the Corporation, except as sat for h in paragraphs 1. and 2. hereof and Sellers do hereby release an forever discharge the Corporation of any and all claims, debts demands, sums of money and obligations of any kind, which it, its successors and assigns may now or hereafter have against the orporation. IS. The Sel ers covenant and agree that for a period of five (5) years following closing hereunder, they will not compete with Corporation hr Buyer either individually or as a partner, 6 1 31218AWthoroRP\UseraM i shareholder, dirlector or employee in the practice of chiropractic medicine within ',a radius of, five (5) miles of corporationrs i principal place of business, 4607 Locust Lane, Harrisburg, Pennsylvania 17]109. In connection therewith, the Sellers acknowledge that the remedies at law for any breach by either of I them of any of the provisions of this paragraph will be inadequate relief against them in the event of any such breach and they furthe> t j acknowledge and warrant that they will be fully able to earn aniadequate livelihood for themselves and their dependents if thin paragraph should be specifically enforced against them. If the proi I risions of this paragraph should be held to be invalid, illegaj, or unenforceable by a court of competent jurisdiction be?auae of the time limitation or geographical area herein provided such provisions shall nevertheless be effective and enforceable for such period of time and/or such geographical area as may be ?eld to be reasonable by such court. In additiop to any other rights which Buyer may have hereunder upon default by Seller or either of them, Buyer shall have the right Zo secure injunctive relief to prevent Sellers, or either of them, from violating the non-competition directive under this paragraph. In the event that Buyer elects to pursue t said injunctive relief, Buyer shall not be required to post a bond in any jurisdiction in which said injunctive relief is requested. 1 19. All negotiations between the parties are merged in this Agreement, and !there are no understandings or agreements other 7 J 31118.1 VWthx4P\Uagr4LR i than those incorporated herein. This Agreement may not be modified except by1an instrument in writing duly executed by the i parties. 20. All obligations, warranties and representations made by the Sellers in thO Agreement. shall survive the closing. 21. This Agr?ement shall bind the parties hereto, their respective successors and assigns. This Agreement shall be construed for all purposes under and in accordance with the laws of the Commonwealth of Pennsylvania. 22. Each of tithe parties shall bear all expenses incurred by him in connection with this contract and in the consummation of and preparation fo the transactions contemplated by this i contract. 23. Neither this contract nor any right created by this contract shall bedassignable by either sellers or Buyer without the prior written !consent of the other. 24. This contract may be executed in two or more counter- parts, each of which shall be deemed an original, but all of which together shill constitute one and the same instrument. 25. It is tl?a intention of the parties that the laws of the commonwealth of Pennsylvania shall govern the validity of the contract, the construction of its terms and the interpretation of the rights and du4ies of the parties. i 8 aura. IN WITNEBSjWHEREOF# and intending to be legally bound hereby the parties have executed this Agreement the year and day first above written. Witness: S DWid i D k Aifdrew Madeira, D.C. BUYER Rand S. Freder ck, D. . 9 RAMY 8, FREDER> X r D. C. s S9o,oo0.00 T6 _ DATED: JANDARY 13, 1990 DAVID DICKSON, D.1c. and ANDREW MADEIRA, D.C. I AT: York, Yenamylvania FOR VALUE RECEIVED, the undersigned ("Borrower") promises to pay to the order of David Dickson, D.C. and Andrew Madeira, D.C., the principal sum; of Ninety Thousand ($90,000.00) Dollars, lawful money of the United States of America, together with interest thereon, as herein I after provided. 1. Payment principal and Interest. Principal and interest due hereunder sha 1 be paid in seventy-two (72) equal consecutive monthly installments of principal and interest at the fixed rate provided in Paragraph 2 below. Equal monthly installments of principal and interest at the fixed rate provided in Paragraph 2 below shall be m de on the 13th day of each month commencing February 13, 1998 and ending January 13, 2004. 2. Interest' From the date hereof until paid, the unpaid balance of principal from time to time outstanding shall bear interest at the to of nine (9%) percent per annum. Interest shall be calculated on the basis of a 365-day year for the actual number of days elapsed. The amount of the 3. monthly installme is of principal and interest at the fixed rate provided in Parag aph Twenty-Two and 3% 100 2 above shall all re one Thousand Six Hundred 4. Annicat?On CC payment9. Each payment shall be applied first to interest on the unpaid balance of principal, then to any costs, charges or ?expenses due Lender under this Note and finally to the unpaid balance of principal due hereunder. 5. Date 0 Payment. If any payment of principal and/or interest becomes due and payable on a Saturday, Sunday or a business holiday i the Commonwealth of Pennsylvania, the maturity thereof shall be extended to the next succeeding business day and interest thereon shall be payable at the rate herein specified during such extension. 6. &ate C es, in the event that any payment of principal and/or interest becomes overdue for a period in excess of fifteen (15) days, a late charge of five cents for each dollar so overdue may be charged by the Lender for the purpose of defraying expenses S1/?1 ?' 4.,Cy incident to the handling of such delinquency. i 7. prebavm4nt. Borrower may prepay the principal amount outstanding in whole or in part at any time without penalty. Any partial prepayment shall be applied against the principal amount then outstanding I but shall not postpone the due date of any subsequent installment. i a. Confess on _af- Judgment. Borrower hereby irrevocably authorizes and emowers the Prothonotary, Clerk of Courts or any attorney of any gqourt of record in Pennsylvania or elsewhere to appear for and cdn£ess judgment against Borrower at one or more times and in favo? of Lender, its successors and assigns, with or without defalcation, for the debt evidenced by this Note with accrued interest #hereon, together with any and all charges, taxes and liens paid byi Lender, its successors and assigns, and in any manner affecting or chargeable against any collateral given to attorney's fees !for collection. Borrower hereby waives and releases all erro*s which may occur in such proceeding. 9, Waiver. ill borrowers, endorsers, sureties and guarantors hereby waive damaAd, presentment, dishonor and notice of dishonor and assent to any !extension or postponement of the time of payment or any other, ind;lgence and to any substitutions, exchanges or releases of collateral granted to Borrower by Lender. 10. Construction. The words "Borrower" and "Lender" include singular or plural, and the respective heirs, executors, administrators, successors and assigns of Borrower and Lender, as the case may be- This Note shall be.governed by the laws of the Commonwealth of Pennsylvania. i 12. govern I.1,,ty of provisions. Any provision of this Note which is prohib ed or unenforceable under the laws applicable hereto shall be i effective to the extent of such prohibition or unenforceability without affecting the validity or enforceability of the remaining *rovisions of this Note. 19, ent 'fault. If following fifteen (18) days written notice fr m Lender to Borrower, any of the following events ("Events of Defau,t") shall occur: (a) Tle Borrower fails to pay the principal of, or interest on, the IIote, as and when due and payable or shall fail to perform or observe any term, covenant or condition under the Note; or (b) Any representation or warranty made or deemed made by the Borrower it the Note shall prove to have been incorrect in any material resp¢ct on or as of the date made or deemed made; then, and in any ! such event, Lender may declare this Note, all ti ihtereat here be forthwith interest, and and payable, notice of any Borrower. 14. Am termination, or any departure 1 shall in any evt and signed by 1 effective only purpose for whi, 15. F-0-ltaiv exercise, and no under the Note sl single or partial further exercise remedies provided any remedies prov and all other amounts payable under this Note to and payable, whereupon this Note, all such such amounts shall become and be forthwith due hout presentment, demand, protest, or further , all of which are hereby expressly waived by the uoaas?s, aco. No amendment, modification, iver of any provision of the Note, nor consent to the Borrower from the provisions of the Note, be effective unless the same shall be in writing der, and then such waiver or consent shall be the specific instance and for the specific given. 1r; Remediss. No failure on the part of Lender to lelay in exercising, any right, power, or remedy all operate as a waiver thereof; nor shall any exercise of any such right preclude any other or :hereof or the exercise of any other right. The in the Note are cumulative and not exclusive of .ded by law. 16. oe and Assions. This note shall be binding upon and inure to t e benefit of Borrower and Lender and their respective heirs, ersonal representatives, successors and assigns, except that Borro er may not assign or transfer any of Borrowers rights hereunder fithout the prior written consent of Lender. IN WITNESS be executed the Witness: REOF, the Borrower has caused these presents to and year first above written. I CONSENT TO ASSIGNMENT AGREEMENT This consent to Assignment Agreement is made as of this 1 day of MARCH 1999, by and between D4VID C. DICKAON, Mt D.C. (hereinafter individually referred to as "Dickson") and ANDREW MADERIA, D.C. (Dickson and Maderia hereinafter collectively referred to as the "Sellersih), RANDY S. FREDERIM D.C. (the "Buyer"), and DEIRDRE L, DICKSON. WITNESSETH i WHEREAS, by Agreement dated January 13, 1998 ("Agreement") Sellers agreed to sell and Buyer agreed to purq)rase all of the shares of issued and outstanding capital stock of ChiroPlus of Locust Land, P.C. ("Corporation") owned by Sellers; and WHEREAS, pur?uant to the terms of the Agreement, Buyer executed a term note in favor of Sellers Hated January 13, 1998 (the "Note") setting forth terms of payment to Sellers of the Ninety Thousand (S91),000) Dollar balance of purchase price due under the terms of the Agreement; and WHEREAS, purjrutrt to the terms of the Agreement, as security for satisfaction of his payment obligation under the terms of the Note, Buyer pledged all shares of capital stock of the Corporation which he acquired under the`Agreement; and I WHEREAS, Bu?er has been requested to consent to the assignment from Dickson to Dickson and his wife, Nirdre L. Dickson, as Tenants by the Entireties, of all of Dickson's rights under the Agreement and Note; and WHEREAS, Buyer has agreed to the consent to said assignment subject to the conditions hereof. NOW9 THEREFORE, for good and valuable consideration, the receipt and adequacy of which are hereby acknowledged, the patties agree as follows; 1. Dickson *grees that his assignment of his rights under the Agreement and Note shall not include his right to the shares of capital stock of Corporation pledged by Buyer pursuant to paragraph 3 of the A? eement and further agrees that, upon any default by Buyer under the terms of the Agreement,i any rights to the capital stock of Corporation which Dickson may have under the Agreement shall remain personal tights of Dickson which rights are not transferable by Dickson to his wife or airy other party without the express written consent of Buyer, which consent is hereby withheld. 51151063 IA)Cy 2. Deirdre L. Dickson Ogren to the restriction on assignment contained in Paragraph 1 hereinabove, IN WTINESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. Witness: r "E4 D.C.. `artd.? 4eir a L. Yckson sR=&dy E k (SEAL) handy S nck r lr, 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 1.27 Law Library .50 Prothonotary 1.00 Service 16.12 Surcharge 8.00 Levy 20.00 $64.89 Advance Costs: $150.00 Sheriff's Costs: 64.89 $ 85.11 Refund to atty on 5/3/00 So Annswe s: Vn! R. Thomas Kline, Sheriff Sworn and subscribed to before me This /7 " day of Oyu,, 2000, A.D.? (? ,av., tQaty P thonotary BY4odil ny?,_t;L Deputy Sheriff ew* at GEV S"4 ,o 'r .n LO 0 jJ A4, ssa ?r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-3091 CIVIL X91 TEtN COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Ctsnberland COUNTY: To satisfy the debt, interest and costs due Elizabeth J. Tindall formerly known as Elizabeth J. -Dickson PLAINTIFF(S) from- David r Dickson. TTT 281p_phrtla nri?a M- hanirchiirgpa. 17055 (1) You are directed to levy upon the property of the defendant(s) and to any and all pa=nal property o f fendant David C% Dickson TTT 1o=-ted at 2!310 -MYrtlP Drive, Mechanicsburg, penngyly ni (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 levied uponansubjecltoattachment is found inthepossessionofanyoneother than a named garnishee, you are directed to notify him/her that he/she has been added as agarnisheea; dise„joinedasabove stated. AmrounntDue $27772 _ nrt L.L. $0.50 In?teresMt ay 21, 1999 g958-86 Due Prothy. 1.00 Ally's Comm Ally Paid Plaintiff P Date: June 11, 1999 % N/A Oiher Costs Curtis R. Prothonotary, Civil Division REQUESTING PARTY: Name Keith O. Brenneman, Esq. Address: 44 West Main Street _MeChanic burn Pa. 17D5:1__ Attorneyfor: P]ai-miff _ Telephone: ( 717) 697-957g__ ?_- Supreme Court ID No. 4 7077 by: C /1? CD Deputy R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. No action has been aril taken in the last six months. cam. Sheriff's Costs: Advance Costs: $150.00 Docketing $1.8.00 Sheriff's Costs: 60.28 Poundage 1.18 Prothonotarv 1.00 Service 3.10 Garnishee 9.00 $ 89.72 Refund to atty on 5/3/00 Surcharge 8.00 Levy 20.00 $60.28 Sworn and subscribed to before me This /7t(I day of 2000, A.D. ^6:, . thonotary So Answ R. Thomas Kline, Sheriff BY? h S Deput Sheriff .n w 0 NV A ss, ud 4L r ig ? 3fr`ts 3k:. rc 3;x30 C/zlivil ??.'1SL7V WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-3091 CIVIL 19 _ COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF Cunberland COUNTY: To satisfy the debt, interest and costs due Elizabeth J. Tindall formerly known as Elizabeth J. Dickson „ PLAINTIFF(S) from David r._Di zk?TTT 2810 Myrtle Dr. Mechanicsburg, PA 17055 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 Keystone Financial , formerly Financial Trust, Garnishee, One West High Street Carlisle, PA iARNISHEE(S) as follows: accounts titled ano 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 thedefendant(s) not leviedupon an subjectto 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_ $277,772.08 _ L.L. Interest _ from May 21, 1999 $8,333. 16 Due Prothy $1.00 Ally's Comm Ally Paid Plaintiff F $15.50 Date: October 21, 1999 REQUESTING PARTY: Name Keith O. Brenneman, Address: 44 W. Main Street Attorney for --Mechar?icsburg,-PA 170-55 - Plaintiff Other Costs Curtis R. Long Prothonotary, Civil Division by --??4Ltrz QZ -7 Al -Deputy Telephone: lL717) 697-8528 Supreme Court ID No. 47077 CHIILOPLUS 017 LOCUST LAND, INC. 4607 L[)Cl!S'I LANI'. HARRISBURG, PA 17109 ?allhrst cao7_ 7810 X19 rllllm ll.nl 2/28/2001 PAY TO THE CUMBERLAND COLINTY PROTI IONO'LARY S 81 LW Eight Hundred Eleven and 00/I00rrrrrrrrrrrrrrrrrrrrrrr rrrrrrrrrrrrrrrr rrrr rrrrrrnr rr rrrrrrr rrrrrrrrrrrrr rrrrr nrr DOLLARS CUMBERI.AND COUNTY 1'It0'1'IIONOTARY ATI'N: RENEE SIMPSON ICOURT HOUSE SQUARE CARLISLE, PA 17013 CIVIL 1199-3091 T 11400781011' 1:0313008341: 674S,l1429Ia, i ?lk J