Loading...
HomeMy WebLinkAbout99-06003;.-:; ?: xi ,. i l?J U J V C6 N ?9 J W z e 0 a J Z m N ¢ J u m G a 4 a w z o a w 3 m a g Q m G a z ? n Q m W It m m U 2 SCOTT and LISA BANKERT, : IN THE COURT OF COMMON PLEAS Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. NO: _ Ga)3 Cry T?errq TIMOTHY J. BISHOP, CIVIL ACTION - LAW Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 249-3166 SCOTT and LISA BANKERT, IN THE COURT OF COMMON PLEAS Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. NO: ?- (nC03 TIMOTHY J. BISHOP, CIVIL ACTION -LAW Defendant COMPLAINT 1. Plaintiffs are SCOTT AND LISA BANKERT, (hereinafter referred to as "Plaintiffs") adult individuals residing at 207 E. Portland Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is TIMOTHY J. BISHOP, (hereinafter referred to as "Defendant") an adult individual residing at 119 Chapel Avenue, Carlisle, Cumberland County, Pen sylvania 17013. 3. Plaintiffs are the owners of the premises located at 209 E. Portland Street, Mechanicsburg, Cumberland County, Pennsylvania. 4. Plaintiffs became owners of said premises by a Deed from the Sheriff of Cumberland County, which Deed dated December 7, 1998 was lodged and settlement made with the sheriff. 5. At that time, Defendant did not utilize any legal remedies to overturn the Sheriff sale. 6. When Defendant refused to vacate the property at 209 E. Portland Street, Mechanicsburg, Pennsylvania, Plaintiffs filed a Complaint in Ejectment on January 15, 199. 7. After a hearing before the Honorable J. Wesley Oler on April 26, 1999, an Order was entered on May 7, 1999 finding in favor of Plaintiffs. 8. Said Order was appealed by Defendant on June 3, 1999. 9. Defendant has remained in Plaintiffs' property to the exclusion of Plaintiffs from the time of the transfer of the property through the Sheriffs sale until July 2, 1999 when Defendant was ejected from the property. 10. On July 2, 1999, Defendant filed an Emergency Petition for Supersedeas as Pending Appeal requesting the court to stay the ejectment pending appeal upon the posting of the appropriate se:urity. 11. After a hearing before Judge Oler, Defendant's Petition for Supersedeas was denied on August 30, 1999. Judge Oler further directed that the parties transfer the personalty remaining on the premises sub judice to Defendant. 12. On September 3, 1999, Plaintiffs' counsel forwarded notice to Defendant that the real estate would be accessible from September 13, 1999 until September 22, 199 from 7:00 A.M. until 9:00 P.M. daily so that Defendant can remove his personalty. A copy of said letter is marked as -2- Exhibit "A", attached hereto and incorporated by reference herein. 13. As of the filing of this Complaint, Defendant has not removed his personalty from said property. 14. Because of Defendant's unlawful withholding of the property, Plaintiffs have been deprived of fair rental value of the property since the tax sale on September 28, 1998 to present and will in the future continue to be to be so deprived, to their damage in the amount of $500.00 per month. WHEREFORE, Plaintiffs, SCOTT and LISA BANKERT, pray this Honorable Court to enter judgment against Defendant in the amount of $500.00 per month since September 28, 1998 to the present and continuing until the Defendant's personalty is removed from the property, together with costs and such further relief as may be just. Dated: September 28, 1999 Barbara Sumple-Sullivan-,E'squire Attorney for Plaintiffs 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 -3- EXHIBIT "A" LAW OFFICES BARBARA SUMPLE-SULLIVAN 54D BRIDGE STREET NEW CUMBERLAND. PENXSYLV&NL117070-1031 PHONE (717) 774-1445 FAX (717) 774.7050 September 3, 1999 Mr. Timothy Bishop Mr. Timothy Bishop c/o Joel Bishop C/o Mr. Ken Challenger 119 Chapel Avenue 1696 Ridge Road Carlisle, PA 17013 York Springs, PA 17372 Re: Removal of Personal Property at 209 E. Portland Street, Mechanicsburg, PA Dear Mr. Bishop: By now I assume you have received the Order denying your right to possession. As you are also aware, no appeal is pending before the Superior Court. We must conclude this matter promptly. Per Judge Oler's direction, we would like to resolve the matter amicably. We will make the property at 209 E. Portland Street available to you for ten (10) consecutive days from 7:00 a.m. to 9:00 p.m. daily, beginning September 13, 1999 and ending September 22, 1999. The premises will be unlocked at 7:00 a.m. by Scott or Lisa Bankert and will be locked promptly at 9:00 p.m. At no time will keys to the property, or use the property as a sleeping facility. During the ten days, you will have access to all areas of the property at 209 E. Portland Street in order to remove or discard ALL BELONGINGS both inside and outside. Any belongings remaining inside and/or outside after 9:00 p.m. on September 22, 1999 will be either disposed of or auctioned, as arranged by Scott and Lisa Bankert. Any fees incurred from discarding the leftover items, or monies obtained from auctioning the leftover items, will be the sole responsibility/benefit of Scott and Lisa Bankert. You MUST BE RESPONSIBLE for contacting and disconnecting all utilities, i.e. gas, electric, telephone, cable and heating companies prior to the close of business (4:00 p.m.) On September 22, 1999 since they are in your name. After 9:00 p.m. on September 22, 1999, you are NOT to return to either property (209 E. Portland Street or 20' E. Portland Street) in an attempt to gather additional items or to discuss this matter further. Authorities will be contacted and proper legal actions will be taken. Mr. Timothy Bishop c/o Joel Bishop September 3, 1999 Page 2 Please note I have been authorized to file the attached Complaint for money damages against you. I will refrain if the matter can be fully settled and resolved in accordance with the above and you acknowledge dropping any further appeal attempts. If not, money damages will be sought against you. Barbara Sumple-Sullivan BSS/Id Enclosure cc: Scott and Lisa Bankert P_rr: rnwiue l'UR INSURANCE- POSTMASTEq a Racalvad Fram: ?u Barbara Sumple-Sullivan, Esquire 549 Bridge Street ew um er an °`? PA 070 Ona place or ordine mall addressed m: Mr. Timot?ly Bishop o °ff} yr c m 9 Cho Mr Kan Ch T T F GER d? $ $ N 8o.15a 1696 Ridge Road 'CM u7 Cw` °S York Springs, PA 17372 mCM ° 3 n " x t PS Form 3817, Mar, 1989 GPO : 1993 0 - 151-051 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 One place of ardinary all addr.111d to: Mr. Timothy Bishop C/6 'eel Bishe-P 119 Chapel Avenue Carlisle, PA 17013 PS Form 3817, Mar. 1989 GPO : 1993 0 - 151-051 °o wo" aY ) N C °o? m n ° v c In aim O SI°c, I A FCO a r to mc* n i m SCOTT and LISA BANKERT, IN THE COURT OF COMMON PLEAS Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA V. : NO: TIMOTHY J. BISHOP, CIVIL ACTION - LAW Defendant VERIFICATION We, Scott and Lisa Bankert, hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of our knowledge, information and belief. We understand that any false statements made herein are subject to penalties of IS Pa. C.S.A. §4904 relating to unswom falsification to authorities. DATED: 9 2 SI 1 Cott Bankert Lisa Bankert IN THE CCUR'T OF 024" PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Scott and Lisa Bankert . File No. 99-6003 Civil Action Plaintiffs . Amount Due gF,ann On ulna inhprpct V. Timothy i. Bishop Defendant Interest : Atty's Comn_ 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 natter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) any and all oprsnnalty lnc t'rl at 209 Past Port'land Street Mechanicabura. PA 17055 PRAECIPE FOR ATTACHMENT EXE000TION 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 garn ishee as lis pendens against real estate of the defendant(s) described in the attached bi DATE: November 16, 1999 Signature: Print Name: Barbara Sumple-Sullivan, Esquire Address: 549 Bridge Street New Cumberland, PA 17070 Attorney for: Plaintiffs Telephone: (717) 774-1445 Supreme Court ID No.: 32317 Notes: If real property, supply six copies of description including irrprovements 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. (SIN C mi CD , r vi., - N o?'n - ~ -, -17 v? 1 ?? vl ` 1 1 1'c= n? i? n c C ? ? Cs SHERIFF'S RETURN - REGULAR CASE NO: 1999-06003 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANKERT SCOTT ET AL VS. BISHOP TIMOTHY J JODY SMITH Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT was served upon BISHOP TIMOTHY J the defendant, at 10:06 HOURS, on the 5th day of October 1999 at CUMBERLAND CO. SHERIFF'S DEPT 1 COURTHOUSE SQUARE CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to TIMOTHY BISHOP a true and attested copy of the COMPLAINT together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So ae s Docketing 18.00 i/ Service 3.10 Affidavit .00 Surcharge 8.00 ?A omas ine, eri 0 B BAR. 999 PLE SULLIVAN by Q nCu -7' pu y eri T- Sworn and subscribed to before me this dde "< day of L)Lt 19 19 A. D. QQ. c. r one r_ d 00 v 2 9L ? d -?? ?.` n Ul rc J C4j:.-. \? O G Z 0 3 7 ? a o S in ??^^ a ° i 1. `?? =J v\ 1 Q n QG Q C 1 m Q ? m U 3 W 2 SCOTT and LISA BANKERT, Plaintiffs V. TIMOTHY J. BISHOP, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 99-6003 Civil Action TO: THE PROTHONOTARY OF CUMBERLAND COUNTY Please enter a Judgment of Default in favor of Plaintiff, Scott and Lisa Bankert, and against Defendant, Timothy J. Bishop, for his failure to defend against Plaintiffs Complaint within twenty (20) days of service, which contained a Notice to Defend. Said Complaint was served upon Defendant by a Sheriff of Cumberland County on October 5, 1999. A copy of the Notice to Defend and the Sheriffs Return is attached as Exhibit "A". A Notice of Praecipe for Entry of Default Judgment was served upon the Defendant on October 26, 1999, pursuant to Pa. Rules of Civil Procedure 237.1. A copy of the Notice of Praecipe for Entry of Default Judgment and Certificate of Mailing is attached as Exhibit "B". Please enter a Judgment of Default against the Defendant in the amount of Six Thousand Five Hundred Dollars ($6,500.00) plus interest, costs and fees. Dated: November S, 1999 Barbara Sumple-Sullivan, Esc 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. #32317 Attorney for Plaintiff EXHIBIT "A" SCOTT and LISA BANKERT Plaintiffs V. TIMOTHY J. BISHOP, Defendant IN THE COURT OF COMMON PLEAS CUINIBERLANDCOUNTY, PENNSYLVANIA NO: qq-(.eD03 CIVIL ACTION- LAW NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 249-3166 SHERIFF'S RETURN - REGULAR CASE NO: 1999-06003 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANKERT SCOTT ET AL VS. BISHOP TIMOTHY J JODY SMITH Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT was served upon BISHOP TIMOTHY J defendant, at 10:06 HOURS, on the Sth day of October the 1999 at CUMBERLAND CO. SHERIFF'S DEPT 1 COURT..-.--- CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to TIMOTHY BISHOP a true and attested copy of the COMPLAINT together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answe s Docketing 18.00 Service 3.10 2 Affidavit .00 .Surcharge 8.00 omas ine, ere SZ9:t0 BARBARA-SUMPLE SULLIVAN 10/06/1999 by '=--IRf"llpu y neri Sworn and subscribed to before me this day of 19 A.D. 7T-Ut ono ar EXHIBIT "B" SCOTT and LISA BANKERT, Plaintiffs V. TIMOTHY J. BISHOP, Defendant TO: Mr. Timothy Bishop c/o Joel Bishop 119 Chapel Avenue Carlisle, PA 17013 DATE OF NOTICE: October 26, 1999 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 99-6003 Civil Action - Ti Mr. Timothy Bishop c/o Mr. Ken Challenger 1696 Ridge Road York Springs, PA 17372 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAJLED TO TAKE ACTION REQUIRED OF YOU IN THE ABOVE REFERENCED CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (7pl249-3166 Barbara Sumple3uffiven-tsgwre Attorney for Plaintiffs 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Barbara Sumple-SUll'van Fca +; re 549 Bridge Street' New Cumberland, PA 17070 1 One place of ordinary mall addressed to: I , I1 Mr. Timothy Bishop \ ,! c o Mr. Ken a enger 16Q6 Ridge Road York SRrings, PA 17372 1 PS Form 3817, Mar. 1989 ° yo ?Iu ? A °p-f O C N dO ST TT0 y? am?? m m v x GPO : 1993 0 - 151-051 U.S. POSTAL SERVICE CERTIFICATE MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER .. Received From: Barbara Sumple-Sullivanf Esquire 549 Bridge Street New Cumberland PA 17070 One piece of ordinary mall addressed to: Mr. Timothy Bishop c/o Joel Bishop 119 Chapel Avenue Carlisle, PA 17013 PS Form 3817, Mar. 1989 GPO : 1993 0 - 151-051 z m ? c °{fl ry c in mO -?a• a?v?mr ?'?? SO1:.rnoo ° tO n n Q1 m LAW OFFICES BARBARA SUMPLE-SULLIVAN 540 BRIDGE STREET NEW CMIBERLAND. PENNSYLVANIA 17070.1001 PHONE (717) 774.1445 FAX (717) 774-7050 October 26, 1999 Mr. Timothy Bishop c/o Joel Bishop 119 Chapel Avenue Carlisle, PA 17013 Mr. Timothy Bishop c/o Mr. Ken Challenger 1696 Ridge Road York Springs, PA 17372 Re: Bankert v. Bishop No. 99-60031 Cumberland County Dear Mr. Bishop: Enclosed constituting service on you is the Notice dated October 26, 1999. Please review this matter with your counsel. Very tru ur, Barbara Sumple-Sullivan BSS/ld Enclosure cc: Scott and Lisa Bankert (w/enc.) SCOTT and LISA BANKERT, : IN THE COURT OF COMMON PLEAS Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO: 99-6003 Civil Action TIMOTHY J. BISHOP, Defendant I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of the PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT, in the above-captioned matter upon the following individual(s), by United States first-class mail, postage prepaid, addressed as follows: Mr. Timothy Bishop c/o Joel Bishop 119 Chapel Avenue Carlisle, PA 17013 DATE: November 8, 1999 Mr. Timothy Bishop c/o Mr. Ken Challenger 1696 Ridge Road York Springs, PA 17372 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff Q I ? N N ? „- W U W J N o LL u Lr- 5 N m fl ('7 _ 4 ? ? Q N a ji? z t? ul-_ cr) n _ 1 [L ? o U j A n SCOTT and LISA BANKERT, : IN THE COURT OF COMMON PLEAS Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. NO: 99-6003 Civil Action TIMOTHY J. BISHOP, Defendant PRAECIPE TO ADD GARNISHEES TO PROTHONOTARY Please add Scott and Lisa Bankert as Gamishees to the Writ of Execution issued in the above- captioned action to levy upon all of Defendant's personal property located at 209 East Portland Street, Mechanicsburg, PA 17055. The Bankert's address is 207 E. Portland Street, Mechanicsburg, PA 17055. Defendant's last known addresses are: 216 Market Street, West Fairview, Cumberland County, PA c/o Joel Bishop 119 Chapel Avenue, Carlisle, PA c/o Mr. Ken Challenger 1696 Ridge Road, York Springs, PA Dated: November 24, 1999 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiffs 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 SHERIFF'S RETURN - GARNISHEE CASE NO: 1999-06003 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANKERT SCOTT ET AL VS. BISHOP TIMOTHY J And now KENNETH E. GOSSERT Sheriff or Deputy Sheriff of CUMBERLAND , County, who being duly sworn according to law, at 1900:00 HOURS, on the 15th day of December , 1999, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named defendant BISHOP TIMOTHY J in the hands, possession, or control of the within named Garnishee _ SCOTT AND LISA BANKERT by then and there summoning the said Garnishee at 207 E. PORTLAND ST. MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to LISA BANKERT, ACCEPTED FOR BOTH GARNISHEES personally THREE true and attested copies of the within COMPLAINT and made the contents thereof known to her. Sheriff's Costs: So answers: Docketing .00 i? Service .00 ?i !„. Affidavit .00 ?`?^"""?"'? rJ'"?.rvrti?? Surcharge .00 omas ine, eri X00/00/0000 Sworn and subscribed to before me this //tl- day of?2, c X9 do m7 A.D. by pu I"Fro ono A?K WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO, 99-6003 CIVIL 19 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIREU BERLAND COUNTY: To satisfy the debt, interest and costs due Scott and Lisa Bankert PLAINTIFF(S) from Timothy J. Bishop, 209 E. Portland St., Mechanicsburg PA 17055. DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Any and all personalty at above address. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Scott and Lisa Bankert, 207 E. Portland St., Mechanicsburg PA 17055. (Amended 11-30=99) GARNISHEE(S) as follows: A9}-B&ftrs- pemenafly at 209 E.Pny+I M St'.. mi csbM PA 17055 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 detendant(s) or otherwise disposing thereof; (3) If propertyof the defendant(s) not levied upon an subjectto attachment islound Inthe possessionof anyoneother than a named garnishee, you are directed to notify hinUher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $6,500.00 L L $.50 Interest _ Arty's Comm Arty Paid $101.60 Plaintiff Paid Date: November 22, 1999 REQUESTING PARTY: Name Barbara Sumple-Sullivan, Esq. Address: 549 Bridge St. New Cumberland PA 17070 Attorney for: Plaintiff Telephone: (717) 774-1445 . Due Prothy $1.00 Other Costs CURTIS R. LONG Prothon ary, Division by Deputy Supreme Court ID No. 32317 c C.' R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing $18.00 Poundage 1.75 Law Library .50 Prothonotary 1.00 Service 6.20 Garnishee 18.00 Surcharge 24.00 Levy 20.00 $89.45 Sworn and subscribed to before me This ?I,? day ofL/a? 1999, A.D. moo. "J1&L,O T r thonotary ' Advance Costs: $150.00 Sheriff's Costs: 89.45 $ 60.55 Refund to atty on 12-21-99 So Answer: R. Thomas Kline Sheriff BY`(^^f (,U c DfputyV heriff a VIN'A--J);r,,N;3d 66, HG ho II 6Z ABN ddihzils n:;l j1! 301ZI30 ua-.7G sly n 9CyUG