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HomeMy WebLinkAbout99-03591;: hr ;:.-0 •)?`? ?i t_,, .Y G Stephen J. Hogg, Plaintiff vs. John A. Butcher Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : Civil Action-Law : No.: 99-3591 ORDER tgbjrwln 1 C' V41W -16%(1 AND NOW, this 23`d day of May 2000, Plaintiffs Petition for Supplementary Relief in Aid of Execution is granted. Defendant shall turn over to the Sheriff for execution a 1994 Cadillac automobile, ?l Model FLB, tag # BTT7192, VIN # 1 G6DW52P9RR713062. -H ie f oe?rt Defendant shall comply with his Order oR-ef beforcttle-' Vr f- J 6_11 s I JK q,GL-, - day_ 2000 orbe in-contempt of curt-_ i ? LAW OFFICES OF 'I STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 .. ,, ? ?. ?:: -, ,. , ?: -- ?_ JOMMONWEALTH OF PENNSYLVANIA Cnl INTV Or- CUMHERT,AMn 09-2.01 DJ Nam9 Han PAULA P. CORREAL Atl (BSS EAST WING - COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA Ta16pAane (717) 240-6564 17013-0000 STEPHEN J. HOGG, ESQUIRE 19 S.HANOVER ST. SUITE 101 CARLISLE, PA 17013 NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME and ADDRESS rHOGG, ESQUIRE, STEPHEN J. 7 19 S-HANOVER ST. SUITE 101 LCARLISLE, PA 17013 J DEFENDANT: VS. NAMEand ADDRESS rBUTCHER, JOHN A. -I 332 PINE STREET STEELTON, PA 17113 L J Docket No.: CV-000 0151-99 Date Filed: 4/06/99 THIS IS TO NOTIFY YOU THAT: Judgment. nR1?At7LT TTTDGNM4T ^T TE ® Judgment was entered for: (Name) xnaa. uaQnTRR 4TRDHrr.* T Q Judgment was entered against: (Name). _ ]STITCHER JOHN A- in the amount of $ 1,1111f; nn on: Defendants are jointly and severally liable. F] Damages will be assessed on: This case dismissed without prejudice. E Amount of Judgment Subject to Attachment/Act 5 of 1996 $ F1 Levy is stayed for days or ? generally stayed. Objection to levy has been filed and hearing will be held: (Date of Judgment) _ r/i n/gg (Date & Time) (Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total Post Judgment Credits Post Judgment Costs Certified Judgment Total $ I Date: Place: Time: ANY PARTY HAS THE RIGHT APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH TH ROTHON TARY/CLF,RIE Q ? HE 9"RT OF C N PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A PY OF NOTICE S ?L iU?' Y(//TT ANSCRIPIF M WITH YOUR NOTICE OF APPEAL. -? ?-» mace ??* District Justice I certify that this is a tr a an orrect copy h c of e p eeding co taining the judgment. 5-10-99 Dat District Justice My commission expires first Monday of January, 2000 SEAL AOPC 315-99 M a s F o b h a N. I H ti wn p L. v 0 Kr 7 rn c? 3 t?7 E 7 J i ?riCu cu u- U M ?- .r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ` CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ( ) Confessed Judgment Stephen J. Hogg, Esquire, ( ) Other Plaintiff Vs. John A. Butcher, Defendant File No. CV 0999151 99 yla . 99-d3111 Arrount Due 3, 116.00 Interest $75.00 Atty's Comm $200.00 Costs $-1-7&,59- 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 or±.ginal proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. 1)f+k? pk :.v Issue writ of execution in the above natter to the Sheriff of Gaand County, for debt, interest and costs upon the following described property of the defendant(s) John A. Butcher 332 Pine Street, Steelton, PA 17113 Personal Property PRAECIPE FOR ATTACK II T E7iI7C[MON 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) s a lis dens against real estate of the defendant(s) described in the attached G' Signature: DATE: ?z ?? Print Name: Steohen J. Ho Esouire Address: 19 S. Hanover Street, Suite 101 Carlisle. PA 17013 Attorney for: 7alephone: a:r??n, -,??::• IP rr,.: 36812 rA Notes: If real property, supply six copies of description including isprovements 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. 7 ) Vt-` C 1 h r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-3591 CIVIL 10C_04 COUNTY OF CUMBERLAND) CIVIL ACTION • LAW TO THE SHERIFF OF Dauphin COUNTY: To satisfy the debt, interest and costs due Stephen J Hoag Esquire 19 South Hanover Street Suite 101 Carlisle Pa 17013 PLAINTIFF(S) from John A. Butcher 332 Pine Street. Steelton Pa 17113 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Personal Property 332 Pine Street Steelton, Pa. 17113 (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 propertyof thedefendant(s) notlevieduponan subjectlo attachment isfound 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 53.116.00 Interest S 75.00 Atty's Comm % 5200.00 Arty Paid $ 31.75 Plaintiff Paid L.L. Due Prothy 1.00 Other Costs Date: 1nnp 14 199 REQUESTING PARTY: Name RYpphpn .7. Hogga Fa{prirp suite k01 Address: 19 So r H nov Street Carlisle. Pa. 17013 Attorney for: --Curtis R. Long nProthonotary, Civil Division by: , c? lr . 71? cam. Deputy Telephone: (717) 245-2698 Supreme Court ID No. 36812 )kV, a?? 1? ?^0 1694 N 1999 Dauphin County 99-3591 Cumberland County And Now: Nov. 16, 1999, Sheriff of Dauphin County returns Writ of Execution as Expired. So Answers OFFICE OF THE SHERIFF J. R. Lotwick, Sheriff cov, ., t /. uv I- K. ° . 5u '-P4 . Qtr l S,Cq, 6? I-1<j ? . Q an O C= W •„ vr., z o L N ;? rT ?? 1 W 7O r? c ?a Stephen J. Hogg, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, :PENNSYLVANNIA :Civil Division vs. 99 - John A. Butcher, Defendant PRAECIPE TO REISSUE WRIT OF EXECUTION TO THE PROTHONOTARY OF SAID COURT: Please reissue the Writ of Execution in the above captioned matter in favor of the Plaintiff and against the Defendant for the amount of $3,116.00 plus costs and interest: Judgment $3,116.00 Costs $ 170.50 Attorney fees 200.00 Total $3,486.50 Interest $ IWJW ( s°'o 0 (thru 5/10/99 at 10% continuing) TOTAL $3,561.50 Date: A?j X14- $tephen J. Ho g, Esqu" 19 S. Hanover St., Ste. 1 Carlisle, PA 17013 (717) 245-2698 LAW OFflOES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 WRIT OF EXECUTION and/or ATTACHMENT 1l ?- V x, Q9 COMMONWEALTH OF PENNSYLVANIA) NO. 99-3591 CIVIL 1&-TFE 1 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Dauphin COUNTY: To satisfy the debt, interest and costs due St rt ,1, Hogg, EsrnAre 19 South Hanover Street Suite 101, Carlisle. Pa. 17013 PLAINTIFF(S) from John A. Butcher 332 Pine Street Steelton Pa. 17113 DEFENDANT(S) . (1) You are directed to levy upon the property of the defendant(s) and to Personal Property 332 Pine Street, Steelton, Pa. 17113 including but not limited to a 1994 Cadillac tag #BTT7192, VINIG6DW52P9RR713062 (2) You are also directed to attach the properly 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 propenyot the defendant(s) not leviedupon an subjectto attachment isfound in the 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 53.116.00 L. L. $0.50 Interest $ 75.00 Due Prolhy 1.00 Ally's Comm % _$2M.00 Other Costs Any Paid 31.75 Plaintiff Paid Date: .limp 14. 199 REQUESTING PARTY: Name Rtggp,hpn .117_ uL gg, E Address: 19uSouthOHanover Street Carlisle, Pa. 17013 Attorney for: Telephone: (717) 245-2698 Supreme Court ID No. 36812 _ CuEt1s-$, ?.2n9 Prothonotary, Civil Division by G . 71 ?c Cic _ Deputy TRIBE COPY FROM RECORD In Testimony whsroof, I here unto set my hand and tli0 deal of r.lid Court at Carlisle, Pa. Thi,' y ?...day of 1912_ Prothonot ry 71, c 429 0I~ 4J'O? ?/n • G/- of M ?I ?Q O ill [?'; l C. :CI tn 0. to Of' LLI O. N 1 c Illl 1 O ]a 0 m C7 ;0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ( ) Confessed Judgment STr?/?G(/g?v GloG6 (,?f other vs. File No. Ct ~ ?$ Amount Due c r ?J r 00 E Interest ?f o?C9 0 Tokb' 667TC1f15k 331 ('-'Uc StRee-t Stee lrvr,, Pn. I-7113 TO THE PROTHONOTARY OF THE SAID COURT: Atty's Comm 2 00, a D Costs 1 __7?5 0, 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. Issue writ of execution in the above matter to the Sheriff of I U?? 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 I /4 y/ t(l?t- 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 re I estate of the defendant(s) described in the attached exhibit. Date 1 r Z 3T_ Signature: Print Name: Address: Attorney for: Telephone: ?I Supreme Court ID No.: (over) 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. nn) O c W? IV C J J .. U 7T7 - G ? ?~ W A A J WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-3591 CIVIL)M MR4 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Dauphin COUNTY: To satisfy the debt, interest and costs due Stephen J. Hogg, Esq. from John A. Butcher 332 Pine Street, Steelton. Pa. 17113 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Cad'llac Automobile Model F'L, B 1994 Tag t! BTT71g2 Vin• t.6DW5 P9RR71'i06 (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) Ifpropertyofthedefendant(s)notlevied uponansubjecttoattachment isfoundinthepossessionofanyoneother than a named garnishee, you are directed to notify hinvhe r that he/she has been added as a garnishee and is enjoined as above stated. Amount Due 53.116.00 _ L. L. Interest 150.00 Due Prothy s Atty's Comm % $200.00 Other Costs Afty Paid Plaintiff F Date: November 21ll, 1999 Curtis R. Long Prothonotary, Civil Division by: l-/ 6 l rn - ? l ?Lw Deputy REQUESTING PARTY: Name Stephen J Hogg Esa Address: 19 S Hanover Street Attorney for: _ P1 ff Telephone: (717) 245-2698 Supreme Court ID No. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-3591 COUNTY OF CUMBERLAND) S TEFd1 CIVIL ACTION - - LAW TO THE SHERIFF OF Dauphin COUNTY: To satisfy the debt, interest and costs due Stephen J Hogg Es from John A. Butcher 332 Pine Street S egltpn. Pa. 17113 (1) You are directed to levy upon the property of the defendant(s) and to Cadillac A?tomob'to Mcx7Pt FT. g 19ga mag k arr?tg? y;n ??? +?? (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 Properlyof thedefendant(s) not levied upon an subject to attachment is found in the 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 L. L. Interest __ 150.00 Atty's Comm % __$200.00 Arty Paid 44 5 Plaintiff Paid Due Prothy $1.00 Other Costs Date: November 2a, 1999 REQUESTING PARTY: Name Stephen i. Hogg. Esg Address: 19 S. Hanover Sfr et rtial Pa Attorney for: Piff Curtis R. Long nn Prothonotary, Civil Division by: Deputy Telephone:_ (717) 245-7698 Supreme Court ID No. LAWOR CE90F sz'lee> MJ.110GG 19S. HANOVER STREET • SUITE 101 CARLISLE, PENNSYLVANIA 17013 TELEPHONE (717) 246.2695 FAX (717) 2450529 November 22, 1999 Dauphin County Sheriffs Office Attn: Peggy Dauphin County Courthouse Front & Market Streets Harrisburg, PA 17101 Re: Stephen J. Hogg, Esquire V. John A. Butcher No. 1694N99 Civil Term INSTRUCTION SHEET John A. Butcher 332 Pine Street Steelton, PA 17113 Dear Sheriffs Office: Please execute on the following vehicle in regard to the enclosed reissued Writ of Execution: Make: Cadillac Model: FLB Year: 1994 Tag #: BTT7192 VIN: 1 G6DW52P9RR713062 If you have any questions, please contact my office. Thank you for your attention in this matter. Sincerely, / / r J. Hogg, Es u' SJH/Ikg Enclosure MAY 0120006' s-a -0 0 Acd' Stephen J. Hogg, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA VS. : Civil Action-Law : No.: 993591 John A. Butcher Defendant ORDER -/4all "7,.1001) AND NOWhit is Wereby ordered and decreed that a hearing shall be held on the , day of ?'} Yl 2000 at ?I , 3b 1)./A. Courtroom a of the Cumberland County Court of Common Pleas at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania to determine whether the Defendant shall be ordered to make available to the Sheriffs office any personal property for execution to satisfy the underlying Judgment. Plaintiff, after a reasonable attempt to serve this notice, shall be permitted to provide notice by publication. UW OFF CE9 OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 Stephen J. Hogg, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA VS. John A. Butcher Defendant : Civil Action-Law : No.: 994591 PETITION FOR SUPPLEMENTARY RELIEF IN AID OF EXECUTION Plaintiff files this Petition For Supplementary Relief In Aid Of Execution based on the following: Plaintiff obtained a Judgment against Defendant by Judgment Order dated 05/10/99 by District Justice Paula P. Correal in the amount of $3,116.00. LAW OR CE9 OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 2. Defendant has made no effort to satisfy the Judgment. 3. Plaintiff attempted to execute on the Judgment by levying on the Defendant's personal property at his last known address of 332 Pine Street, Steelton, Pennsylvania. 4. Defendant's last known address is an unoccupied residence and the Sheriffs office has been unable to complete a levy. 5. It is the Plaintiffs belief that the Defendant uses the above address as his mailing address and continues to receive all mail addressed to him at that address. 6. It is Plaintiffs belief that the Defendant is intentionally concealing his whereabouts and the whereabouts of his personal property specifically the 1994 Cadillac automobile, Model FL B, Tag #BTT7192, VIN#:1 G6DW52P9RR713062. Under Pennsylvania Rule of Civil Procedure §3118, the Plaintiff requests an Order directed to the Defendant to turn over to the Sheriff for execution all personal property and specifically the 1994 Cadillac automobile, Model FL B, Tag#BTT7192, VIN#1 G6DW52P9RR713062. 8. Also under §3118 of the PRCP, the Plaintiff requests other such relief as the Court deems necessary and appropriate. 9. Plaintiff further anticipates that the Defendant will attempt to avoid service of notice of this petition and notice of a hearing and request this Court to authorize notice by publication. Date: 2 7/0'0 ephen J. Hogg, E Attorney for Plaintiff uwoFFICES of STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 10i CARLISLE. PA 17013 VERIFICATION uW OFFICES OF STEPHEN J. HOGG 18 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 I verify that the statements made in this Petition to the Cumberland County Court of Common Pleas, are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904, relating to unsworn falsification to authorities. Date: L 0 0 CERTIFICATE OF SERVICE I, Stephen J. Hogg, Esquire, Attorney for Plaintiff, hereby certify that I did on this day serve one true and correct copy of the attached Petition by United States Mail, postage pre-paid, from Carlisle, Pennsylvania, on the following: John A. Butcher 332 Pine Street Steelton, Pennsylvania 17113 Date: _I Z7 o Attorney for Plaintiff 0 19 S. Hanover Street, Ste. 101 Carlisle, PA 17013 (717) 245-2698 uw OFFrES OF STEPHENJ.HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 i? Stephen J. Hogg, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA vs• : Civil Action-Law : No.: 99-3591 John A. Butcher Defendant RDER AND NOW, this _ day of 2000, Defendant having failed to comply with the Order dated May 23, 2000 in which he had 15 days to turn his 1994 Cadillac automobile over to the Cumberland County Sheriffs department. Defendant is hereby found to be in contempt of Court. Defendant shall be fined , to be paid within days of this Order or face imprisonment. Honorable Edgar B. Bayley LAW OFFlOE90F STEPHEN J. HoGG 18 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 Stephen J. Hogg, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA VS. : Civil Action-Law : No.: 99-3591 LAW OFF CES OF TEPHENJ.HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 John A. Butcher Defendant ORDER lOtlrwlM ` 0.V"000lhcl/ AND NOW, this 23`° day of May 2000, Plaintiffs Petition for Supplementary Relief in Aid of Execution is granted. Defendant shall turn over to the Sheriff for execution a 1994 Cadillac automobile, c,?G Model FLB, tag # BTT7192, VIN # 1 G6DW52P9RR713062. 9 to 8otlrt Defendant shall comply with his Order 'w?? day of 2000 or he in ?nn#-mmt-Af*'rAv4-_ TRUE COPY FROM RV-(A)NU in Tedr wny whareot, I here unto set my hanc and the sealmgf said Cou11 at Cartisle, ca. ihle-ca?3 d 0 7? . Prothonotary