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
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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-
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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
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.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
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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.
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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
-
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Ir
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ti
7
0
+ Postage $
o
C3 Certlfled Fee
2.65
Re 4W Fee
Required) 2 15
0
m uirFed)
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. , ¦ 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 ,
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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.
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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
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4. Restricted Delivery? (Exha Fee) ? Yes
-----------------
2. Article Number
(Transfer from service
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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.
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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
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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
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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