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HomeMy WebLinkAbout03-3426CUMBERLAND COUNTY ADULT PROBATION vs. Plaintiff NO. 03 - 3 9J (CIVIL TERM John V. Shoemaker V 2 Ann Street Duncannon, PA 17020 TO THE PROTHONOTARY: Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW RE: NO. 02-2571 CRIMINAL TERM PRAECIPE TO ENTER JUDGMENT Enter judgment in favor of plaintiff, Cumberland County Adult Probation, and against Defendant in the amount of $ 1410.90 pursuant to 42 Pa. C.S.A. Section 9728 as set forth in the attached statement of certified case costs and fines. Dennis E. Lebo, Clerk of Court Date: July 18, 2003 ENTRY OF JUDGMENT AND NOW, this J Z' t, day of (, 2 3 judgment is entered in favor of the Plaintiff and against the Defendant in thl amount set forth above. Curtis R Attachment cc: Defendant Probation Clerk of Court 11 134723070903 CCS746 Case No. 2002-02571 SHOEMAKER JOHN V V 2 ANN STREET DUNCANNON, PA 17020 --------------------------- Date Transaction 12/09/02 CONT SER SURG Totals 02/24/03 SHERIFFS COST Totals 03/05/03 COURT COSTS Totals 03/05/03 SHERIFFS COST Totals 03/05/03 OFF F.E. ACT158 Totals 03/05/03 CCC ACT 139 Totals 03/05/03 CVC ACT 139 Totals 03/05/03 DVC - ACT 44 Totals 03/05/03 STATE COST A Totals 03/05/03 STATE COST B Totals 03/05/03 JCP FEE Totals 03/05/03 DISTRICT ATTY ******************** Pa e 7 *STATEMENT OF COSTS* 709/2003 ******************** To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 Courthouse Square Carlisle, Pa 17013 Debit 5.00 5.00 18.00 18.00 24.90 24.90 1.50 1.50 5.00 5.00 25.00 25.00 35.00 35.00 10.00 10.00 8.94 8.94 7.66 7.66 10.00 10.00 15.00 Credit Balance 5.00 5.00 18.00 18.00 24.90 24.90 1.50 1.50 5.00 5.00 25.00 25.00 35.00 35.00 10.00 10.00 8.94 8.94 7.66 7.66 10.00 10.00 15.00 134783070903 ******************** Pa e 8 CC9746 *STATEMENT OF COSTS* 7709/2003 ******************** Case No. 2002-02571 SHOEMAKER JOHN V V 2 ANN STREET DUNCANNON, PA 17020 Totals 03/05/03 PLEA Totals 03/05/03 AUTOMATION FEE Totals 03/05/03 NON-DUI CP COST Totals 03/06/03 SHERIFFS COST Totals 06/17/03 ADMIN. FEE Totals 06/17/03 COUNTY FINES Totals 06/25/03 RESTITUTION Totals 07/07/03 SHERIFFS COST Totals Case Totals To: Dennis E. Lebo Cumberland County - Clerk of Courts 1 Courthouse Square Carlisle, Pa 17013 A TRUE COPY FROM RECORD In and the seal of said Court at Came, PA. this . 4 "ot ? ?-?- 4 filerk of the Cod 1 15.00 15.00 125.00 125.00 125.00 125.00 5.00 5.00 5.00 5.00 200.00 200.00 200.00 200.00 6.90 6.90 6.90 6.90 40.00 40.00 40,00 40.00 100.00 100.00 100.00 100.00 750.00 750.00 750.00 750.00 18.00 18.00 18.00 18.00 1410.90 .00 1410.90 You are liable for the above costs ---------------------------------------------------------------------- Pursuant to Title 42 of Judiciary and Judicial procedure, 42 PA CSA 9728, the Prothonotary is authorized to confess -judgment on all unpaid costs and issue an execution and place same in the hands of the Sheriff for the collection. We trust you will give the above account your prompt attention. 1 C fem. 4 - 4b 1 17 r CUMBERLAND COUNTY ADULT : IN THE COURT OF COMMON PLEAS OF PROBATION : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. JOHN V. SHOEMAKER V, ESTATE OF : JOHN V. SHOEMAKER III AND : CIVIL ACTION - LAW AND ROBERT FISHER, EXECUTOR :NO. 03-03426 OF THE ESTATE Defendants PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: 1. Issue writ of execution in the above matter; 2. against John V. Shoemaker, V, defendant; and 3. Robert Fisher, executor of the estate of John V. Shoemaker III, garnishee; 4. and enter this writ in the judgment index (a) against John V. Shoemaker, V, defendant in name of garnishee as follows: Including but not limited to a 1999 Dodge Van described as follows: VIN #I B4GP44G6X881761 Titled in the name of John V. Shoemaker III Pennsylvania license plate #DV1235 Held by Robert Fisher, executor of the estate of John V. Shoemaker III, 6 Johns Drive, Mechanicsburg, PA 17050 5. Amount due: Interest from July 18, 2003 to June 20, 2007: Plus costs to be added Plus interest at the rate of $ .24/day until paid in full: 2d%D7 Da e $ 1,410.90 $ 343.92 Edward L. Schorp' Esquire Attorney for Plaintiff =F- "^1 - ? CO Cl o , c1 = ? w {N 1 ?? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CUMBERLAND COUNTY ADULT PROBATION, Plaintiff (s) From JOHN V. SHOEMAKER V, ESTATE OF JOHN V. SHOEMAKER III AND ROBERT FISHER, EXECUTOR OF THE ESTATE (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 VIN #IB4GP44G6X881761 - TITLED IN THE NAME OF JOHN V. SHOEMAKER III - PENNSYLVANIA LICENSE PLATE #DV1235 - HELD BY ROBERT FISHER, EXECUTOR OF THE ESTATE OF JOHN V. SHOEMAKER III, 6 JOHNS DRIVE, MECHANICSBURG, PA 17050 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 $1,410.90 L.L. $.50 Interest FROM 7/18/03 TO 6/20/07 - $343.92 - PLUS COSTS TO BE ADDED - PLUS INTEREST AT THE RATE OF $.24/DAY UNTIL PAID IN FULL Atty's Comm % Due Prothy $2.00 Atty Paid $27.00 Plaintiff Paid Date: JUNE 28, 2007 Other Costs $19.50 DUE COUNTY (Seal) NO 03-3426 Civil CIVIL ACTION - LAW Deputy REQUESTING PARTY: Name EDWARD L. SCHORPP, ESQUIRE Address: 35 THRUSH DRIVE CARLISLE, PA 17013 Attorney for: PLAINTIFF Telephone: 717-486-8386 Supreme Court ID No. CUMBERLAND COUNTY ADULT : IN THE COURT OF COMMON PLEAS OF PROBATION : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. JOHN V. SHOEMAKER V, ESTATE OF : JOHN V. SHOEMAKER III AND : CIVIL ACTION - LAW AND ROBERT FISHER, EXECUTOR :NO. 03-03426 OF THE ESTATE Defendants PRAECIPE FOR AMENDED WRIT OF EXECUTION To the Prothonotary: 1. Issue writ of execution in the above matter; 2. against John V. Shoemaker, V, defendant; and 3. Robert Fisher, executor of the estate of John V. Shoemaker III, garnishee; 4. and enter this writ in the judgment index (a) against John V. Shoemaker, V, defendant in name of garnishee as follows: Garnish all property in the possession of the Garnishee including all testamentary bequests to the defendant, tangible, intangible or pecuniary, and specifically to include, but not limited to a 1999 Dodge Van described as follows: VIN #1B4GP44G6X881761 Titled in the name of John V. Shoemaker III Pennsylvania license plate #DV1235 Held by Robert Fisher, executor of the estate of John V. Shoemaker III, 6 Johns Drive, Mechanicsburg, PA 17050 5. Amount due: Interest from July 18, 2003 to June 20, 2007: Plus costs to be added Plus interest at the rate of $ .24/day until paid in full: vGY /.Z Date $ 1,410.90 $ 343.92 Edward L. Schorpp, Es ire Attorney for Plaintiff a Fm - CD b .r ..AdPI CUMBERLAND COUNTY ADULT : IN THE COURT OF COMMON PLEAS OF PROBATION : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. JOHN V. SHOEMAKER V, ESTATE OF : JOHN V. SHOEMAKER III AND : CIVIL ACTION - LAW AND ROBERT FISHER, EXECUTOR :NO. 03-03426 OF THE ESTATE Defendants ANSWER bF ROBERT FISHER TO INTERROGATORIES To: Robert Fisher, Executor of the Estate of John V. Shoemaker, III, Garnishee: 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 at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instruct, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? Answer: No. My only relationship with Defendant John V. Shoemaker, V, is as Executor of the Estate of John V. Shoemaker, III,of which said Defendant is a beneficiary. By way of further response, the answer to interrogatory X64 below is incorporated herein by reference thereto. 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: No. My only relationship with Defendant John.V. Shoemaker, V, is as Executor.of the Estate of John V. Shoemaker, III, of which said Defendant is a beneficiary. By way of further response, the answer to interrogatory #4 below is incorporated herein by reference thereto. 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: No. My only relationship with Defendant John V. Shoemaker, V, is as Executor of the Estate of John V. Shoemaker, III, of which said Defendant is a beneficiary. By way of further response, the answer to interrogatory #4 below is incorporated herein by reference thereto. 4. At the time you were served or at any subsequent time did you hold as fiduciary and property in which the defendant had an interest? Answer: Yes. Defendant John V. Shoemaker, V, is a beneficiary of the Estate of John V. Shoemaker, III, of which I am Executor. Said Defendant may be entitled to a distributive share of the Estate as determined by the Orphans' Court Division of the Court of Common Pleas of Cumberland County, Pennsylvania. According to Deced'ent's Last Will and Testament, said Defendant is to-receive $10,000 "and the motor vehicle owned by me at the time of my death." The vehicle described in the Writ-of Execution appears to be the vehicle bequeathed via the Will. 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. By way of further response, the answer to interrogatory #4 below is incorporated herein by reference thereto. 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 lace pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? Answer: No• By way of further response, the answer to interrogatory #4 below is incorporated herein by-reference thereto. SIGNED this 31st day of July, 2007. Robert Fisher Executor of Estate of John V. Shoemaker, III 7-17- Date r? Edward L. Schorpp, Es wire Attorney for Plaintiff VERIFICATION I, Robert- Fisher, Executor of the Estate and under the Last Will and Testament of John V. Shoemaker, III, Deceased, do hereby certify,that the facts set forth in the foregoing answers to Interrogatoriesare true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. r Robert fisher, Executor of the Estate of John V. Shoemaker, Dated: July 31 , 2007 III CERTIFICATE OF SERVICE I hereby certify that I am this day serving a true copy of the foregoing document upon the and in the manner indicated below: Service by first-class mail addressed as follows: Edward L. Schorpp, Esquire 35 Thrust Drive Carlisle, PA 17013 (Attorney for Plaintiff) Service by first-class mail, certified, return receipt requested, addressed as follows: John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 (Defendant) Richard C. Snelbaker, Esquire Snelbaker & Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055 Attorneys for Estate of John V. Shoemaker, III : August 1 , 2007 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. ca " w CUMBERLAND COUNTY ADULT PROBATION Plaintiff V. JOHN V. SHOEMAKER V, ESTATE OF JOHN V. SHOEMAKER III AND AND ROBERT FISHER, EXECUTOR OF THE ESTATE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO. 03-03426 Defendants ANSWER :OF KAREN STAFFORD TO INTERROGATORIES To: Karen Stafford, Garnishee: 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 at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instruct, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? Answer: No. See attached Addendum for further response. 2. At the time you were served of 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: No. See attached Addendum for further response. 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: No. See attached Addendum for further response. 4. At the time you were served or at any subsequent time did you hold as fiduciary and property in which the defendant had an interest? Answer: No. See attached Addendum for further response. 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. See attached Addendum for further response. 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 lace pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? Answer: No. See attached Addendum for further.response. SIGNED this 'O? day of ?tJ?r 2007 Date Karen Staf rd Edward L. Schorpp, Es uire Attorney for Plaintiff ADDENDUM TO ANSWERS OF KAREN STAFFORD TO PLAINTIFF'S INTERROGATORIES % I am Karen Stafford, the co-owner with my husband, Roland D. Stafford, of the real estate known as 1 Shoemaker Lane in Silver Spring Township, Cumberland County, Pennsylvania. My husband and I purchased said real estate on June 15, 2007, from the Estate of John V. Shoemaker, III (Robert Fisher, Executor). As an accommodation to said Estate, we permitted the Executor to park a Dodge van style motor vehicle, believed to be the vehicle identified in the pending Writ of Execution, on a portion of our property during the further administration of the above cited Estate. I assume I was named as a garnishee because said vehicle is stored on our property. I/we claim no interest in said vehicle and have no relationship whatsoever with John V. Shoemaker, V. ---------------- Karen Stafford VERIFICATION I, Karen Stafford, do hereby certify that the facts set forth in the foregoing answers to Interrogatories are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to the penalties of 18 Pa. C.S § 4904 relating to unsworn falsification to authorities. Dated: JtJ (? 3 ( , 2007 ?' Karen St ord / CERTIFICATE OF SERVICE I hereby certify that I am this day serving a true copy of the foregoing document upon the and in the manner indicated below: Service by first-class mail addressed as follows: Edward L. Schorpp, Esquire 35 Thrust Drive Carlisle, PA 17013 (Attorney for Plaintiff) Service by first-class mail, certified, return receipt requested, addressed as follows: John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 (Defendant) and C. Snelbaker, Esquire Snelbaker & Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055 Attorneys for Estate of John V. Shoemaker, III August 1 , 2007 LAW OFFICES SNELBAKER 8C BRENNEMAN, P.C. o M z.. G7 Ti F Tip- Y.i `__ Q m C ) p A COUNTY ADULT OBATION, Plaintiff VS. OHN V. SHOEMAKER, V, ESTATE OF OHN V. SHOEMAKER, III AND :OBERT FISHER, EXECUTOR OF THE ;STATE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 03-03426 AFFIDAVIT OF SERVICE OMMONWEALTH OF PENNSYLVANIA OUNTY OF CUMBERLAND : SS. RICHARD C. SNELBAKER, Esquire, being duly sworn according to law deposes and 1. That he is a principal in the law firm of Snelbaker & Brenneman, P.C., which firm the attorney for the Estate of John V. Shoemaker, III, deceased, of which Robert Fisher is the 2. That the Sheriff of Cumberland County served a Writ of Execution and rrogatories for the above mentioned Plaintiff on the above referenced Estate and its Executor on Karen Stafford, as garnishee; LAW OFFICES SNELBAKER & BRENNEMAN, P.C 3. That on behalf of the above named recipients of the Writ and Interrogatories, your Deponent did duly serve copies of the Writ by certified mail, return receipt requested to Defendant John V. Shoemaker,V, as evidenced by copies of letters dated July 26, 2007, having attached thereto certified mail receipts for mailing and delivery as follows: (a) No. 7004 1350 0004 1256 2978 with regard to Estate of John V. Shoemaker, III, and Robert Fisher, Executor, and (b) No. 7004 1350 0004 1256 2992 with regard to Karen Stafford, indicating receipt of delivery on August 1, 2007 as to (a) and on July 28, 2007 as to (b); 4. That on behalf of the above named recipients of Writ and Interrogatories, your Deponent did duly file with the Prothonotary of Cumberland County on August 1, 2007, Answers to Interrogatories and served copies thereof on the same date as follows: (a) on the Attorney for Plaintiff (Edward L. Schorpp, Esquire) by regular first-class mail, and (b) on Defendant John V. Shoemaker, V, by certified mail, return receipt requested, as evidenced by es of letters dated August 1, 2007, having attached thereto certified mail receipts for mailing delivery as follows: (i) No. 7004 1350 0004 1256 3005 with regard to the Estate of John V. emaker, III, and Robert Fisher, Executor, and (ii) No. 70004 1350 0004 1256 3012 with rd to Karen Stafford, indicating receipt of delivery of both articles on August 3, 2007; and That the foregoing facts are true and correct to the best of your deponent's information and belief. Richard C. Snelbaker to and subscribed before me 71?4 day of '4d9wso4 , 2007. Notary OEAI-TH OF PENNSYLVANIA Susan NokwW Sea! L Area Nov ,-A 2007 Member, Pennsylvania Association of Notaries LAW OFFICES SNELBAKER & BRENNEMAN, P.C. 2 ESTATE OF JOHN V. SHOEMAKER, III ROBERT FISHER, EXECUTOR 6 JOHNS DRIVE MECHANICSBURG, PA 17050 July 26, 2007 VIA CERTIFIED MAIL NO: 7004 1350 0004 1256 2978 RETURN RECEIPT REQUESTED John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 Re: Cumberland County Adult Probation, Plaintiff VS. John V. Shoemaker, V, Estate of John V. Shoemaker, III and Robert Fisher, Executor of the Estate In the Court of Common Pleas of Cumberland County, Pennsylvania No: 03-03426 Dear Sir: As a Garnishee recently served with a Writ of Execution in the above captioned case, I hereby forward to you two (2) copies of said Writ pursuant to Pennsylvania Rule of Civil Procedure No. 3140. You are further notified that the Estate does not intend to resist the attachment or defend the action against you. Very truly yours, X?? Robert Fisher, Executor Enclosures ESTATE OF JOHN V. SHOEMAKER, III ROBERT FISHER, EXECUTOR 6 JOHNS DRIVE MECHANICSBURG, PA 17050 July 26, 2007 VIA CERTIFIED MAIL NO: 7004 1350 0004 1256 2978 RETURN RECEIPT REQUESTED John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 Re: Cumberland County Adult Probation, Plaintiff vs. John V. Shoemaker, V, Estate of John V. Shoemaker, III and Robert Fisher, Executor of the Estate In the Court of Common Pleas of Cumberland County, Pennsylvania No: 03-03426 Dear Sir: As a Garnishee recently served with a Writ of Execution in the above captioned case, I hereby forward to you two (2) copies of said Writ pursuant to Pennsylvania Rule of Civil Procedure No. 3140. You are further notified that the Estate does not intend to resist the attachment or defend the action against you. Very truly yours, ro - rM1 A Ir ru . • -0 . Ln ti 7 0 + Postage $ o C3 Certlfled Fee 2.65 Re 4W Fee Required) 2 15 0 m uirFed) r_j . , ¦ Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. ¦ print your name and address on the reverse the card to you. so th can return ?--y' ¦ A to the back of the maiipiece, ' or odEEBW if space permits. 1. ArdcldfoWessed to: John V. Shoemaker, V 1741 Lehman Street X Total $5.38 Hershey, PA 17033 Postage & Fees 0 6IIt TO Nt John V. Shoemaker V _ orpoaoxlVo. 1754 Lehman Street b47 Srete, 2%P+4 --' --- ^- Hershey, PA 17033 2. Article Number PS Form 3800, See Rever? (Transw from service far z A. Sign m 0 Agent x r ? Addressee B? Receiv by nted Name) (: Date of Delivery . ? -. D. Is delivery address difterk from item 17 C3 Yes If YES, enter delivery address below: ? No 3. Service Type .= Certified Mail 13 Express Mail ? Registered ? Return Receipt for Merchandise O Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) O Yes 7004 1350 0004 1256 2978 KAREN STAFFORD 1 SHOEMAKER LANE MECHANICSBURG, PA 17050 July 26, 2007 VIA CERTIFIED MAIL NO: 7004 1350 0004 1256 2992 RETURN RECEIPT REQUESTED John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 Re: Cumberland County Adult Probation, Plaintiff vs. John V. Shoemaker, V, Estate of John V. Shoemaker, III and Robert Fisher, Executor of the Estate In the Court of Common Pleas of Cumberland County, Pennsylvania No: 03-03426 Dear Sir: As a Garnishee recently served with a Writ of Execution in the above captioned case, I hereby forward to you a copy of said Writ pursuant to Pennsylvania Rule of Civil Procedure No. 3140. Very t my Karen St f r Enclosure KAREN STAFFORD 1 SHOEMAKER LANE MECHANICSBURG, PA 17050 July 26, 2007 VIA CERTIFIED MAIL NO: 7004 1350 0004 1256 2992 RETURN RECEIPT REQUESTED John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 Re: Cumberland County Adult Probation, Plaintiff VS. John V. Shoemaker, V, Estate of John V. Shoemaker, III and Robert Fisher, Executor of the Estate In the Court of Common Pleas of Cumberland County, Permsylvania No: 03-03426 Dear Sir: As a Garnishee recently served with a Writ of Execution in the above captioned case, I hereby forward to you a copy of said Writ pursuant to Pennsylvania Rule of Civil Procedure No. 3140. Very t my Total Postage & Fees and to the back of the mailplece, „f if ansCG ruwmitS- y, PA 17033 Date B. Re eivedpy ( Printed Name) C. 1 - of Delivery Shoemaker, V ?hman Street D. is delivery address differentfrom item I? ? Yes if YES, enter delivery address below: ? No 3. Service Type ;aCertifled Mail O Registered ? Express Mail ? Return Receipt for Merchandise n rnn nnnu ,_?cn nnn SNELBAKER 8 BRENNEMAN, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 RICHARD C. SNELBAKER KEITH O. BRENNEMAN 717697-8528 P. O. BOX 318 FACSIMILE (717) 697-7681 August 1, 2007 VIA CERTIFIED MAIL NO: 7004 1350 0004 1256 3005 RETURN RECEIPT REQUESTED John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 Re: Cumberland County Adult Probation, Plaintiff vs. John V. Shoemaker, V, Estate of John V. Shoemaker, III and Robert Fisher, Executor of the Estate In the Court of Common Pleas of Cumberland County, Pennsylvania No: 03-03426 Dear Sir: On behalf of Estate of John V. Shoemaker, 111, and Robert Fisher, Executor thereof, we hereby serve you with Answers of Robert Fisher to Interrogatories pursuant to Pennsylvania Rule of Civil Procedure No. 3140. er truly o s, Richard C. Snelbaker RCS:jjc Enclosure SNELBAKER 8 BRENNEMAN, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW RICHARD C. SNELBAKER KEITH O. BRENNEMAN 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 717697-8528 P. O. BOX 318 FACSIMILE (717) 697-7681 August 1, 2007 VIA CERTIFIED MAIL NO: 7004 1350 0004 1256 3005 RETURN RECEIPT REQUESTED John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 Re: Cumberland County Adult Probation, Plaintiff VS. John V. Shoemaker, V, Estate of John V. Shoemaker, III and Robert Fisher, Executor of the Estate In the Court of Common Pleas of Cumberland County, Pennsylvania No: 03-03426 Dear Sir: On behalf of Estate of John V. Shoemaker, III, and Robert Fisher, Executor thereof, we hereby serve you with Answers of Robert Fisher to Interrogatories pursuant to Pennsylvania Rule of Civil Procedure No. 3140. V y truly yo , Ln C3 C3 M Ln ti a -'I- POete9E E3 Certlfled Fee L C3 R C3 f8ement Required) Ln M ResMcted Delivery Fee (Endorsement Required) C3 C3 r? Mechanicsburg, PA 0 Express Mail 0 Return Receipt for Merchandise nr,nn 17( 2. ARicleNumber 7004 1350 0004 1256 3005 (rrwaw from Serv) 1o2595-02-M-1540 i U. IS oanray auu,? ••.. If YES, enter delivery address below: RICHARD C. SNELBAKER KEITH O. BRENNEMAN SNELBAKER & BRENNEMAN, P.C. A PROFE55IONAL CORPORATION ATTORNEYS AT LAW 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 717-697-8528 August 1, 2007 P. O. BOX 318 FACSIMILE (717) 697-7681 VIA CERTIFIED MAIL NO: 7004 1350 0004 1256 3012 RETURN RECEIPT REQUESTED John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 Re: Cumberland County Adult Probation, Plaintiff vs. John V. Shoemaker, V, Estate of John V. Shoemaker, III and Robert Fisher, Executor of the Estate In the Court of Common Pleas of Cumberland County, Pennsylvania No: 03-03426 Dear Sir: On behalf of Karen Stafford, we hereby serve you with Answers of Karen Stafford to Interrogatories pursuant to Pennsylvania Rule of Civil Procedure No. 3140. V r truly yo , Richard C. Snelbaker RCS:jjc Enclosure SNELBAKER 8 BRENNEMAN, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW RICHARD C. SNELBAKER KEITH O. BRENNEMAN 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 717-697-8528 August 1, 2007 P. O. BOX 318 FACSIMILE (717) 697-7681 VIA CERTIFIED MAIL NO: 7004 1350 0004 1256 3012 RETURN RECEIPT REQUESTED John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 Re: Cumberland County Adult Probation, Plaintiff VS. John V. Shoemaker, V, Estate of John V. Shoemaker, III and Robert Fisher, Executor of the Estate In the Court of Common Pleas of Cumberland County, Pennsylvania No: 03-03426 Dear Sir: On behalf of Karen Stafford, we hereby serve you with Answers of Karen Stafford to Interrogatories pursuant to Pennsylvania Rule of Civil Procedure No. 3140. er tru rs, dam`' rU - - - r-9 O M '? • JI L ?- Postage $ . SS C3 ?'•td a F- ° 4R=- Medept Fee ( rx Req uired) 2 " C3 . Lrl M Restr icted Delivery Fee (Endorsement Required) E ra Total Postage & Fees C3 ent o ° John V. Shoemaker s ti: 01 No.,-T75t ef or liriari St"reef ?tM PO Box No. C/ry; Stets. Z/P+4'------'-°----------- - a item4HReesstrictied Deli and is Also GOMPIGte • ¦ Print your ram and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of he mailpiece, or on the front If space permits Rudow Hershey, PA 170 1. Article Addressed to: John V. emaker, V 754 Le `,Street Hershey,'., 17033 A Sign ure `J' v `rte %B.Iv2ed , Addr?eee by Name) C. Date of Delivery different from Item 1? O Yes address [3 No If YES. enter delivery address below: 3. Service TYPe Mail = Certified Mail C3 Express ? Registered ? Return Receipt for Merchandise n Insured Mail ? C.O.D. 4. Restricted Delivery? (Exha Fee) ? Yes ----------------- 2. Article Number (Transfer from service -- - ._ ___-, nnnA 7004 1350 0004 1256 3012 Domestic Return Receipt 10259"2-M-1640 CERTIFICATE OF SERVICE I hereby certify that I am this day serving a true copy of the foregoing document upon the and in the manner indicated below: Service by first-class mail addressed as follows: Edward L. Schorpp, Esquire 35 Thrush Drive Carlisle, PA 17013 (Attorney for Plaintiff) John V. Shoemaker, V 1754 Lehman Street Hershey, PA 17033 (Defendant) Ric and C. Snelbaker, Esquire Snelbaker & Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055 Attorneys for Estate of John V. Shoemaker, III August 1 , 2007 LAW OFFICES SNELBAKER & BRENNEMAN, P.G. ' -n ? w? ?. -r? ' y ; t? . till T .+ r . . ,? _ .,,. . . ?, . % -('7 . . . _ r{? ? ? . ,' h? .-? r ? ?? ? .'.7 +- +. j . CUMBERLAND COUNTY ADULT : IN THE COURT OF COMMON PLEAS OF PROBATION : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. JOHN V. SHOEMAKER V, ESTATE OF : JOHN V. SHOEMAKER III AND : CIVIL ACTION - LAW AND ROBERT FISHER, EXECUTOR :NO. 03-03426 OF THE ESTATE Defendants PRAECIPE To the Prothonotary: Pursuant to Pa.R.C.P. No. 3146(b), please enter judgment against the Garnishee, Robert Fisher, Executor of the Estate of John V. Shoemaker, III, for the portion of the pro rata testate share of the Defendant admitted to be in the Garnishee's possession in the amount of $1,410.90, plus accrued interest of $368.88, plus interest at the rate of $ .24 per diem from the date of entry of judgment, plus costs. Edward L. Schorpp, Esquir County Solicitor Date: /O -13- 0 7 L7 ?n? ("?. P ???. d i -? ?-,, <- :? '` t ?"3 G•„ [,s,J _:j? --? -"f' __.. fi:?;-. ` ?... c,? -„'. W. 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 90.89 Docketing 18.00 59.11 Poundage 1.79 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 04/30/08 Mileage 9.60 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 90.89 ? S?bslO. So Answers R. Thomas Kline, Sheriff ?^ W By zc eA- 5 Ck- 4 3 '2 j,aT53`l WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-3426 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CUMBERLAND COUNTY ADULT PROBATION, Plaintiff (s) From JOHN V. SHOEMAKERV, ESTATE OF JOHN V. SHOEMAKER III AND ROBERT FISHER, EXECUTOR OF THE ESTATE (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 GARNISHEE ALL PROPERTY IN THE POSSESSION OF THE GARNISHEE INCLUDING ALL TESTAMENTARY BEQUESTS TO THE DEFENDANT, TANGIBLE, INTANGIBLE OR PECUNIARY, AND SPECIFICALLY TO INCLUDE, BUT NOT LIMITED TO A 1999 DODGE VAN DESCRIBED AS FOLLOWS: VIN #1B4GP44G6X881761 - TITLED IN THE NAME OF JOHN V. SHOEMAKER III - PENNSYLVANIA LICENSE PLATE #DV1235 - HELD BY ROBERT FISHER, EXECUTOR OF THE ESTATE OF JOHN V. SHOEMAKER III, 6 JOHNS DRIVE, MECHANICSBURG, PA 17050 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 $1,410.90 L.L. $.50 Interest FROM 7/18/04 TO 6/20107 - $343.92 - PLUS COSTS TO BE ADDED - PLUS INTEREST AT THE RATE OF $.24/DAY UNTIL PAID IN FULL Atty's Comm % Due Prothy $2.00 Atty Paid $27.00 Other Costs $19.50 DUE COUNTY Plaintiff Paid Date: JUNE 28, 2007 (Seal) REQUESTING PARTY: Name EDWARD L. SCHORPP, ESQUIRE Address: 35 THRUSH DRIVE L"PULY CARLISLE, PA 17013