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HomeMy WebLinkAbout99-05075 No. R - sozs CIA Term VS. > Court of Common Pleas Cumb. Co. l ?-??? ? ?y. .? -,.,, ? ?u LG ?IIJ ?`' ?? J m i 3 e o .+ a? 4 ? n s Ci ?I +1 Y? ? P v? O m N t 0 0 O {; w V' ZL b ? ( . ? 3 ? L i S ? >>y? ? B?v ? fA N WFNIO VDMItP'IF[YI(PIFH10 plllYO/ OOAIWM1Y0?1 ilYUTY SERRA'1'RLLI. SCIIIFYMAN, BROWN & CALIIOO N, P.C. S'- r. 1111 IJxn I......... we Run" Ilnxxiun'xu, PA 1)1111.9x)11 JACQUELINE M. MUROSKI, Plaintiff VS. MICHAEL A. NUROSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5075 CIVIL CIVIL ACTION - LAW JUDGMENT PRAECIPE TO ENTER JUDGMENT AGAINST GARwIBEER PIDEL•ITY BROKERAGE BERVICRB. INC. TO THE PROTHONOTARY: Please enter judgment in the amount of $4,700.00; plus costs of $180.00 and interest in the amount of $88.00, in favor of Plaintiff and against Garnishee, Fidelity Brokerage Services, Inc. Respectfully submitted, Lo t. Serratelli, Esquire SE TELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff Ye; JACQUELINE M. MUROSKI, Plaintiff VS. MICHAEL A. MUROSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW TO: Fidelity Brokerage Services, me Garnishee(s) You are hereby notified that on , 19_, the following Judgment has been entered against you in the above- captioned case: DATE: /-'Z' fro Prothon ary/,Ne, I hereby certify that the name and address of the proper person(s) to receive this notice is: A Fidelity Brokerage Services- Inc. Garnishee/a Garnishee/as Por este medio se le esta notificando que el _ de del 19 , el la siguiente Fallo he sido anotado en contra suya en el caso mencionado en epigrafe. FECHA: Protonotario Certifico que la siguiente dirrecion es la del defendido/a segun idicada on el certificado de residencia: Lori K. Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 0 0 Jacqueline M. Muroski, ) Plaintiff ) IN THE COURT OF COMMON V. ) PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Michael A. Muroski, Defendant ) Civil No. 99-5075 Now comes Fidelity Brokerage Services Inc., the Garnishee named herein, and makes the following Amended Answers to Interrogatories to Garnishee propounded by the Plamti% Jacqueline M. Muroski: Interrogatory No. I: At the time your were served or any time thereafter, did you owe the Defendant any money or were you liable to Defendant on any negotiable or other written instrument, or did Defendant Claim that you owed him/her any money or were liable to him/her for any reason? Answer No. 1 Not Applicable Interrogatory No. 2: At the time you were served or any time thereafter, 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 No. 2 W See Attachment A. C:0 0 Interrogatory No. 3 At the time you were served or any time thereafter, 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 No. 3 No Interrogatory No. 4 At the time you were served or at any time thereafter, did you hold as fiduciary any property in which the Defendant had an interest? Answer No. 4 No Interrogatory No. 5 At the time you were sewed or any time thereafter, 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? Answer No. 5 No Interrogatory No. 6 At the time after you were served, did you pay, transfer or deliver any money or property to the Defendant or any person or place pursuant to Defendant's direction or otherwise discharge any claim of the Defendant against you? Answer No. 6 No Interrogatory No. 7 List all accounts of the Defendant maintained by you and amounts therein. Answer No. 7 . O See Attachment A. ATTACMUENT A Fidelity Brokerage Services, Inc. ("FBSI') states that at the time of service of the writ of Execution, October 29, 1999, it had in its possession the following property, held individually in the name of the defendant, Michael Muroski: An individual brokerage account containing securities with a value excess of the total amount of the Money Judgement. FBSI further states that the above listed account remains restricted against withdrawals pending receipt of a currently (within 60 days) and originally certified Order issued by a court of competent jurisdiction directing FBSI to redeem specific assets to satisfied the judgement, and/or a currently (within 60 days) and originally certified Release of Gamishee. Please be sure all fugue service is directed to an made upon the appropriate corporate entity at the above address, attention Legal Support, mail zone VI IA. Signed under the penalty oa Perjury by Susan Daoulabani, Agent and Employee of Fidelity Service Company, this 22 day of November 1999. Susan Daoulabani , Agent and Employee Fidelity Service Company 82 Devonshire Street Boston, MA 02109 ©' JACQUELINE M. MUROSKI, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO.: 99-5075 CIVIL, MICHAEL A. MUROSKI, Defendant TO: FIDELITY BROKERAGE SERVICES, INC. Mellon Bank Center Ground Floor 1735 Market Street Philadelphia, PA 19103 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. 1. At the time you were served or any time thereafter, did you owe the Defendant any money or were you liable to Defendant on any negotiable or other written instrument, or did Defendant claim that you owed him/her any money or were liable to him/her for any reason? ANSWER: Please see enclosed answer 0 2. At the time you were served or any time thereafter, 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: Please see enclosed answer 2 0 3. At the time you were served or any time thereafter, 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: Please see enclosed answer 0 4. At the time you were served or at any time thereafter, did you hold as fiduciary any property in which the Defendant had an interest? ANSWER: Please see enclosed answer 4 Q 5. At the time you were served or any time thereafter, 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? ANSWER: Please see enclosed answer 0 6. At the time after you were served, did you pay, transfer or deliver any money or property to the Defendant or any person or place pursuant to Defendant's direction or otherwise discharge any claim of the Defendant against you? ANSWER: Please see enclosed answer 6 0 7. List all accounts of the Defendant maintained by you and amounts therein. ANSWER: Please see enclosed answer SERRATELLI, SCHIFFMAN, BROWN at CALHOON, PC Dated: Lori K. Serratelli, Esquire I.D. No.: 27426 Suite 201, 2080 Linglestown Road Harrisburg, PA 17110 (717) 540.9170 7 ? d r o c? .= ? : uj??• U . .?il?J ? ll-:?' 1.: .i ILY U a U WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-5075 CIVIL 19 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF PFITLADRT.PHTA COUNTY: To satisfy the debt, interest and costs due Jacaueline M. Muroski frorMichael A. Muroski 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 Fidelity Brokerage Services, Inc. asfall Seize any and all accounts of any nature held by Garnishee, including but not limited to the Ultra Service Account X47-100897. GARNISHEE(S) 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 leviedupon an subject to attachment isfound in the possessionof anyoneolher than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,700.00 L.L $.50 Interest Due Prothy $1.00 Atty'sComm % Other Costs State Tax due $.50 Ally Paid $32.50 Plaintiff Paid 0,qp.tember 3, 1999 REQUESTING PARTY: Name Lori A. Serratelli, Esq. CURTIS R. LONG Proth not T14A Civil Division by: (7 c 1 J Deputy Address: 2080 Linglestown Rd. , Ste. 201 Harrisburg PA 17110 Attorney for: Plaintiff Telephone: Supreme Court ID No. -rPIto?HON -is PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 IN THE COURT OF COMMON PLEAS OF CUMBERLAND JACQUELINE M. MUROSKI, COUNTY, PENNSYLVANIA Plaintiff Writ No. 99-5075 CIVIL Term 19 No. 99-5075 CIVIL Term 19 vs MICHAEL A. MUROSKI, Defend Amount due -$ 4,700.00 Interest AM's Comm. and Costs 3 TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Philadelphia _. County, Pennsvivania; (2) against Michael A. Muroski __ Defendant(s); (3) and against Fidelity Arokerag. _Services,_ Inc (4) and irides this wtit (a) against-- Michael A. Muroski__ _ and (b) against __ Fidelit?Brokerage Services,-Inc.__- .-.. ----'-- '-- - -`--- - ------ Gamishee(s), as a lis pendens against the real property of ;he Jarutdant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any sperific iirection to Sheriff) Furnish 4 copies for real estate levy) The Sheriff is hereby directed to seize any and all accounts of any nature of Defendant, Michael A. Muroski, held by Garnishee, including but not limited to the Ultra Service Account X47-100897. (S) Exemption has (uot) been waived. 11 Dated LI?_l..__._.-. Attorney fur Plaintiff(s) 'Pap.p n ruapuaJ it t w Mm vapid pup P043,111 q raynwrl . JO auau a41 nl 4ndoaJ Pa )I Aluo palaldwaa a '1'1001[ olm rag 9 Plnu4o (4) (0) 4dultnd '(4) 001[ nntl oag AMInu041u,d a41 Aq Alumna it q; ul mnoa Jn It pu)nba in Sultapul Alunna,a4lour 01 .annl IIJ1241 u04M 'n)001 It 9n" 49 pt.Nn4Inv n P i t n'oaumnl Ju AJunma a41 ul mminaota o41 Jo Sul aopul Jl Alum pal aldwoa 04 P1nu4. (r) (0) 4dulutd 'IPM a41 ul papnloul 09 nl 9 aa44unO Pawm • )1 Aluo Paltlduwa aq plnn4l oau9t) (r) 4du/rad •Dannl 4a14m w Alunui a41 Its pua4. a41 nl Alum polao,lp aq Alas Iuawalpnl Pal,apunl t um onn n nu.n. bholr •Iny ,apup a4 P1110V Alumna till '(4)[0117 aln„ Aq paauo4lnn n Alumna a4lnuv Y' JJPa4a i41 01 paloa,IP 11 IPM *41 u'4-(I) Ildviliwndispun UON U O. C C _0 F; F? F• H U W m 'a `" a a > O o U. W >^ 1 y ? V E W IL I t o a Z D 7 i fY i•: i= 7 I ;. C.'. .:a lJ V;Zzi :v v ;1 Jo (aT?)C ' (.y ?' M rLD 47% -vo c. Ili z g o +, 0 ? N < O O 6 w W , 3 Z ? y s - i. n n h J ? ea G W H MM wrn•?Oaa anY Call. -A 9.11. W Iala1 W AL Mal Will N L,. lTru u SERRATELLI, SCH I FFMAN, BROWN & CALHOON, P.C. Sum 201 2080 LING1 KfMV ROAD HAR615aUa4.PA 17110-9670 JACQUELINE M. MUROSKI, Plaintiff VS. MICHAEL A. MUROSKI, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. q C1 - sO %5 O??LALL' CIVIL ACTION - LAW JUDGMENT Please enter judgment in the amount of $4,700.00 in favor of Plaintiff and against Defendant, per the Certification of Arrearage attached hereto. Respectfully submitted, LorVK.( Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff f. frc i In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 Fax: (717) 240.6248 AUGUST 10, 1999 Plaintiff Name: JACQUELINE M. MUROSKI Defendant Name: MICHAEL MUROSKI Docket Number: 98-4949 CIVIL PACSES Case Number: 598101058 Other State ID Number: Please note: An correspondence mast include the PACSES Care Number. Certification of Arrearaee I, R. J. Shadday , hereby certify that arrearages on the above captioned support order as of AUGUST 10, 1999 total $ 4, 700.00 .6 0 95 - Date Ignatu e State Form N Form EN-003 Service Type M Worker lD 21205 JACQUELINE M. NUROSKI, Plaintiff Vs. MICHAEL A. MUROSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW TO Michael n Mirnaki Defendant(s) You are hereby notified that on the following CU ?you 19Judgmen t has been entered e above- captioned case: DATE: Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: A Michael A Muroski Defendido/a Defendidos/as Por este medic se le esta notificando que el de del 19 , el la siguiente Fallo ha sido anotado en contra suya en el caso mencionado en epigrafe. FECHA: Protonotario Certifico que la siguiente dirrecion es la del defendido/a segun idicada en el certificado de residencia: Michael A. Mtrroski 20109 Frew EquarP - Ashburn VA 20147-333 Lq i(K ratelli, Esquire S RRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170