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Home My WebLink About99-05438 (2) No. 99-,< 3F CIYII Term 0,?, a4wx `e lc VS, i r i Court of Common Pleas Cumb. Co. i 1 i iy 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERMAN AQUISITION, LP ?q-?? ?? Plaintiff NO. Vs. ROBERT M CRAWFORD Defendant(s) VS. COMMERCE BANK Garnishee(s) CIVIL ACTION - LAW PRAECIPE TO DISSOLVE GARNISHMENT To the Prothonotary: Please release the Lis Pandas against COMMERCE BANK, garnishee in the above -entitled case. Dated: Respectfully Submitted, Amy F. Doy a #87062 Daniel F. Wolfson #20617 Philip C. Warholic #86341 t i' Gr Sppus.'1, 8L7371 a Davi 52. Galloway #87326 Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3`d Floor Camp Hill, PA 17011 (717) 303-6700 W&A File No. 119645648 0 0 1 Gam. 4 , 228 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERMAN AQUISITION, LP N0. ASSIGNEE OF sy , Plaintiff "- ' vs. ROBERT M CRAWFORD CIVIL ACTION-LAW I 407 BEAVER AVE APT J ENOLA PA 17025-2309 Defendant(s) flnslv«s 4e INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION TO: PURSUANT TO RULE 3114 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN'SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE A. 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. B. The term."Defendant(s)" leans the individual(s) or entity against whom the Writ of Execution was issued. C. "You" means the main office and all branch offices, representatives, employees, and agents of your organization. D. By service of the Writ of Execution upon you, all property of'the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, and an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. SS# 205 58 6839 ORALEX/PAWRIT W&A FILE NO, 119645648 226 PLAINTIFF'S INTERROGATORIES TO GARNISHEE ' DEFENDANT(S) -,ROBERT M CRAWFORD ?407 BEAVER AVE APT J ENOLA PA 17025-2309 ' "-SSA/ 205 58 6839 1. DEPOSITORY ACCOUNTS: At the time you were served or at any sul;iequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts wi;b your institution. If ¦o, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each.account. . If the Defendant(s) maintains any of these jointly with any other person, or' persons, give their name and address. Defendant has account 537017535 with a balance of $ -37.08, (negative) at the time sefved. 1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. No. 2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box o boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amoun of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons, give their full name and address. No. 3. PERSONAL PROPERTY: At the time you were served or at any subsequent - time, state whether or not Defendant(s) owns any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whethe or not there are any encumbrances or liens holders, the present balance of the encumbrance. State where and when the encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. See answer to question 1. 4. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) whic are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). No. ORALE2/PAWRIT W&A FILE NO. 119645648 227 i 1 ' 5. PROPERTY: At the time you were served or at any subsequent time, was there in your possession, custody, or control or in the joining possession, custody, or control of yourself and one or more other persons any property of any nature owned solely or in part by any Defendant(s)? If so, please describe for each Defendant(s) each item of property including its value. See answer to question 1. e 6. REAL PROPERTY: At the time you were served or at any subsequent time, did you hold legal, or equit}ble title to any property of any nature owned solely or in part by the Defendant(s) or in which and Defendant(s) held or claimed any interest? If so, describe for each Defendant(s) each item of property including its value and the interest held by the Defendant(s). See answer to question 1. 7. PROPERTY HELD AS A FIDUCIARY: At -the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(q) the nature of the property including its value and the interest of Defendant (a). No. 8. TRANSFER OF PROPERTY: At any time before or after you,were served, die any Defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent. If so, for each Defendant(s) describe the property transferred or delivered including the dates of delivery or transfer and state the consideration paid. Defendant made transfers in the ordinary course prior to service. 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charged by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer. If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. $100.00 processing fee. Amy F. Doyle #87062 / ISaniel F. Wolfson $2C Philip C. WarhoPis #86341 / Andrew C. Spears 1)87 David R. Galloway #87326 / Tonilyn N. Chippie x/87 BANK/HARRISBURG Ronald H. Abramson x/94266 / Ronald S. Canter #94 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection l'n 4660 Trindle Road, 3rd Flo or , Camp Hill, PA 17011 1? I 1111 (717) 303-6700 Date: I d9?p?' ?: O r°' ?' f_ u?''i ?? •..? -_ ?'.` ?!?; 2 G'. -r -- ::?`_ -,. L fr_r m F(' ??? Lr_ G ?? } ?? l,l COMMONWEALTH OF PENNSYLVANIA] - ?y3(?NOTI COUNTY OF: CUMBERLAND Map. D"I. No.' 09-2-01 DJ Name Mon. PAIDI A P. CORREAL Add"" EAST WING - COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA Taiaohone (717) 240-6564 17013-0000 CE OF JUDGMENT/TRANSCRIP o PLAINTIFF: CIVIL CASE NAME and ADDRESS rSEARS,ROEBUCK 6 COMPANY 267 E.MARKET ST. YORK, PA 17403 L J VS. DEFENDANT: NAME and ADDRESS rCRAWFORD, ROBERT M 1 137 N.WEST STREET CARLISLE, PA 17013 C/O WOLFSON & ASSOCIATES P.C. L -1 267 E.MARKET ST. Docket No.: CV-0000219-99 YORK, PA 17403 Date Filed: 4/27/99 THIS IS TO NOTIFY YOU THAT: Judgment: FOR PT.ATNTTpp __ _ ® Judgment was entered for: (Name) gRARa RnRRnrrr a rnmPawy ® Judgment was entered against: (Name) epnwpnpn RnsRpm m in the amount of $ 6,727 7A on: 7 Defendants are jointly and severally liable. (Date of Judgment) 71112/49 (Date & Time) 7 Damages will be assessed on: This case dismissed without prejudice. Amount of Judgment Subject to Attachment/Act 5 of 1996 $ 7 Levy is stayed for_ days or F? generally stayed. Objection to levy has been filed and hearing will be held: Dater Placc: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE E""""N...TTRRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PRO ryT pNOT?p,RY/CLERK OF THE-CQlURT OF C0 PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY THIS f4 ICE OF JUPQENL yr IA4NSCRIPT O'''WITH YOUR NOTICE OF APPEAL. 7-12-99 Dat District Justice I certify that this is a tr and orrect opy her o f proceed' containing the judgment. 7-12-99 Date , District Justice Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Post Judgment Credits Post Judgment Costs $ j Certified Judgment Total My commission expires first Monday of January, 2000 SEAL AOPC 31599 I l:_ ? I L N7tnP ! i I _JI 10 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA SEARS, ROEBUCK AND COMPANY, NO. Plaintiff VS. ROBERT M. CRAWFORD, CIVIL ACTION- LAW Defendant ENTRY OF APPEARANCE Please enter the appearance of Daniel F. Wolfson, Esquire as the Attorney for the Plaintiff. Respectfully Submitted, Date: 7 0 Daniel F. Wolfson, Esquire ol?" WOLFSON at ASSOCIATES, P.C. 267 E. Market Street York, Pennsylvania 17403 Telephone No. (717) 846-1252 Attorney I.D. # 20617 Attorney for Plaintiff i.u U ' bJ u l T `i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SEARS ROEBUCK AND COMPANY, Plaintiff VS. NO. ROBERT M. CRAWFORD Defendant NOTICE OF ORDER, DECREE OR JUDGMENT TO: ( ) PLAINTIFF (X) DEFENDANT ( ) GARNISHEE ( ) ADDITIONAL DEFENDANT YOU ARE HEREBY NOTIFIED THAT THE FOLLOWING ORDER, DECREE OR JUDGMENT HAS BEEN ENTERED AGAINST YOU ON IN ACCORDANCE WITH THE PROVISIONS OF PA.R.C.P. 236 ( ) DECREE NISI INEQUITY ( ) FINAL DECREE IN EQUITY (X) JUDGMENT OF ( ) CONFESSION () VERDICT (X) DEFAULT () NON-SUIT ( ) NON-PROS () ARBITRATION AWARD () JUDGMENT IS IN THE AMOUNT OF $ PLUS COSTS. $ FOR A TOTAL OF $ (X) DISTRICT JUSTICE TRANSCRIPT OF JUDGMENT IN CIVIL ACTION IN THE AMOUNT OF $6632.28 PLUS COSTS $95.50, FOR A TOTAL OF $6727.78. ( ) IF NOT SATISFIED WITHIN SIXTY (60) DAYS, YOUR MOTOR VEHICLE OPERATOR'S LICENSE WILL BE SUSPENDED BY THE PENNSYLVANIA DEPARTMENT OF TRANSPORTATION PROTHONOT RY BY IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CO TACT: NAME OF (ATTORNEY/FILING PARTY): WOLFSON & ASSOCIATES, P.C. ADDRESS: 267 EAST MARKET STREET YORK, PENNSYLVANIA 17403 TELEPHONE NUMBER: (717) 846.1252 OR 800-321.8467 c. J ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Sherman Acquisition, LP assignee of Sears, Roebuck and Co. V. Robert M. Crawford Plaintiff Defendants. No. 99-5438-CIVIL CIVIL ACTION NOTICE OF STAY AND SUGGESTION OF BANKRUPTCY To the Prothonotary: On or about February 7, 2006, Defendants Robert M. Crawford filed a voluntary Chapter 7 proceeding in the United States Bankruptcy Court, Middle District of Pennsylvania, docketed at 1-06-00173. 3. As a result, this matter is STAYED by operation of Section 362 of the Bankruptcy Code. Respectfully submitted, Sarah McCarroll Attorney I.D. No. 91102 Law Office of John P. Neblett 2040 Linglestown Road, Suite 203 Harrisburg, PA 17110 717.671.8454 Counsel for Defendants Robert M. Crawford CERTIFICATE OF SERVICE I hereby certify on that on this 7`h day of February, 2006 1 caused to be served a true and correct copy of the foregoing pleading via United States Mail, first class, postage prepaid, addressed as follows: Wolpoff & Abramson, LLP 4660 Trindle Road 3`a Floor Camp Hill, PA 17011 Sarah McCarroll Law Office of John P. Neblett 2040 Linglestown Road, Suite 203 Harrisburg, PA 17110 717.671.8454 ? ?. M [Cw n Lu - r-i i.•? O o N U r SHERIFF'S RETURN - GARNISHEE CASE NO: 1999-05438 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND SEARS ROEBUCK & COMPANY VS CRAWFORD ROBERT M And now SHANNON SHERTZER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:40 Hours, on the 25th day of January , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT CRAWFORD ROBERT M in the hands, possession, or control of the within named Garnishee COMMERCE BANK 100 SENATE AVE CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to DEBBIE MILLER (PRESIDENTS ASSISTANT) , personally three copies of interogatories together with 3 true and attested copies of the within the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 01/26 Sworn and subscribed to before me this day of a un.r A.D. Pr onota OF EXECUTION and made So an Alfa 7 R. Thomas Kline Sheriff of Cumberland County /2006 By Deputy eriff • 225 ' - 1 ' PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 - - -- SHERMAN AQUISITION LP J , ASSIGNEE OF IN THE COURT OF COMMON PLEAS OP SEARS, ROEBUCK AND CO. CUMBERLAND COUNTY, PENNSYLVANIA •ti .15 SOUTH MAIN STREET GREENVILLE S.C. 29601 Plaintiff , e -' Va. JJ JUDGMENT NO. 99_ g4l3p ROBERT M CRAWFORD \ 407 BEAVER AVE APT J ENOLA PA 17025-2309 PRAECIPE FOR WRIT OF EXECUTION Defendant(s) (MONEY JUDGMENT) To the Prothonotary: PLEASE ISSUE WRIT (1) Di OF EXECUTION' IN THE ABOVE MATTER, rected to the Sheriff of CUMBER (2) i t LAND COUNTY, Pennsylvania; aga ns , ROBERT M CRAWFORD 407 'BEAVER AVE APT J ,y ENOLA PA 17025-2309 (3) and against, COMMERCE BANK Defendant (s); 100 SENATE AVE CAMP HILL PA 17011-2309 Garnishee(s); (4) and index this writ (a) against, ROBERT M CRAWFORD (b) against, COMMERCE BANK Defendant(s) and Garnishee(a), as a lis pendens against the real property of the Defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property) *** GARNISH ONLY *** You are directed to attach the property of the Defendant(s) not levied upon in the possession of COMMERCE BANK 100 SENATE AVE CAMP HILL PA 17011-2309 Garnishee(s) All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount due Interest from 09/03/1999 At an interest rate of 6% per year Dated: 1 / $ 6727.78 To Be Determined $ 6727.78 Plus coats & interest Amy F. Doyle #87062 / Daniel F. Wolfson 1`20617 Philip C. Wa holic #86341 / Andrew C. Spears #87737 David R. Galloway /87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection IY) ? ` :V li ° Q r r G 0 W -f- 1 WRIT OF EXECUTION and/or ATTACHMENT J -? COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 99-5438 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SHERMAN ACQUISITION, LP ASSIGNEE OF SEARS, ROEBUCK AND CO., Plaintiff (s) From ROBERT M. CRAWFORD, 407 BEAVER AVE APT J, ENOLA, PA 17025-2309 (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 COMMERCE BANK, 100 SENATE AVE., CAMP HILL, PA 17011-2309 -- ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 $6727.78 L.L. $.50 Interest FROM 9/3/99 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $32.25 Plaintiff Paid Date: JANUARY 12, 2006 (Seal) Due Prothy SI.00 Other Costs /?./c/may Prothono/ta/yy Deputy REQUESTING PARTY: Name PHILIP C. WARHOLIC, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD 3an FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 86341 AS OF CASE# ,999- s-vs? HAS BEEN SCANNED. ALL EARLIER FILINGS TO THIS CASE HAVE BEEN MICROFILMED. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 99-5438 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SHERMAN ACQUISITION, LP ASSIGNEE OF SEARS, ROEBUCK AND CO., Plaintiff (s) From ROBERT M. CRAWFORD, 407 BEAVER AVE APT J, ENOLA, PA 17025-2309 (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 COMMERCE BANK, 100 SENATE AVE., CAMP HILL, PA 17011-2309 - - ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 $6727.78 L.L. $.50 Interest FROM 9/3/99 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $32.25 Plaintiff Paid Date: JANUARY 12, 2006 (Seal) Due Prothy $1.00 Other Costs l' A /' / a ,-: ? '-, Z:rothhmnota -4 - - - J ?a? , 0, 5?? Deputy REQUESTING PARTY: Name PHILIP C. WARHOLIC, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD 31LD FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 86341 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs 93.54 Docketing 18.00 56.46 Poundage 1.84 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 10/04/06 Mileage 13.20 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 93.54 4,, So Answers R. Thomas Kline, Sheriff B ?ry.JUAL -ky??? S I .8 V E Z Ndr 9001 tad ',kIHfi0J tJ 1d3dWf]J JJIUHS 3H1 J0 301330 0 ': F J IZI kS4 04