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Home My WebLink About03-5078BLANK ROME LLP Michael D. Shepard, Esquire Atty. No. 50342 One Logan Square Philadelphia, PA 19103-6998 (215) 569-5500 Commerce Bank/Pennsylvania, N.A. 2005 Market Street Philadelphia, Pennsylvania 19103 Plaintiff, McDonald & DeRosa, P.C., formerly named McDonald & Snyder PC Suite 526, Two Penn Center Plaza Philadelphia, Pennsylvania 19102 Defendant. Attorneys for Plaintiff, Commerce Bank/Pennsylvania, N.A. Court of Common Pleas Philadelphia County June Term, 2003 No: 002211 CONFESSION OF JUDGMENT FOR MONEY WRIT OF EXECUTION (Money Judgment) Commonwealth of Pennsylvania ) County of Philadelphia ) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against Defendant, McDonald & DeRosa, P.C., formerly named McDonald & Snyder PC, in the above captioned action, (1) you are directed to levy upon the property of Defendant, McDonald & DeRosa, P.C., formerly named McDonald & Snyder PC, and to sell its interest therein; (2) you are also directed to attach the property of Defendant not levied upon in the possession of ProNational Insurance Company, 401 East Louther Street, Suite 106, Carlisle, Pennsylvania 10713-2625, as garnishee and to notify the garnishee that, (a) an attachment has been issued; and (b) the garnishee is enjoined from paying any debt to or for the account of Defendant and from delivering any property of Defendant or otherwise disposing thereof; (3) The judgment amount due, and interest thereon, and costs are as follows: Judgment amount Less payments on account Interest from 6/17/03 to 9/18/03 Costs to 9/18/03 TOTAL $337,602.11 ($ 34,048.54) $ 6,440.48 $ 76.50 $310,070.55 plus additional costs and interest. Dated: September 19, 2003 Seal of the Court Prothonotary of Philadelphia County By: ~..~ ~..~ Deputy BLANK ROME LLP Michael D. Shepard, Esquire Atty. No. 50342 One Logan Square Philadelphia, PA 19103-6998 (215) 569-5500 Commerce Bank/Pennsylvania, N.A. 2005 Market Street Philadelphia, Pennsylvania 19103 Plaintiff, McDonald & DeRosa, P.C., formerly named McDonald & Snyder PC Suite 526, Two Penn Center Plaza Philadelphia, Pennsylvania 19102 Defendant. Attorneys for Plaintiff, Commerce Bank/Pennsylvania, N.A. Court of Common Pleas Philadelphia County June Term, 2003 No: 002211 WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal tights to prevent your property from being taken. A lawyer can advise you more specifically of these tights. If you wish to exercise your tights, you must act promptly. The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of $300. There are other exemptions which may be applicable to you. Attachedisasummaryofsomeofthemajorexemptions. Youmayhave other exemptions or other rights. If you have an exemption, you should do the following promptly: (1) Fill out the attached claim form and demand for a prompt hearing. (2) Deliver the form or mail it to the Sheriff's Office at the address noted. You should come to court ready to explain your exemption. If you do not come to court and prove your exemption, you may lose some of your property. 108274.00688/I 1251146vl YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGiBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 717-249-3166 3. 4. 5. 6. 7. 8. ATTACHED SUMMARY OF MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW $300 statutory exemption Bibles, school books, sewing machines, uniforms and equipment Most wages and unemployment compensation Social Security benefits Certain retirement funds and accounts Certain veteran and armed fumes benefits Certain insurance proceeds Such other exemptions as may be provided by law 108274,00688/11251146v I 2 BLANK ROME LLP Michael D. Shepard, Esquire Atty. No. 50342 One Logan Square Philadelphia, PA 19103-6998 (215) 569-5500 Commerce Bank/Pennsylvania, N.A. 2005 Market Street Philadelphia, Pennsylvania 19103 Plaintiff, McDonald & DeRosa, P.C., formerly named McDonald & Snyder PC Suite 526, Two Penn Center Plaza Philadelphia, Pennsylvania 19102 Defendant. Attorneys for Plaintiff, Commerce Bank/Pennsylvania, N.A. Court of Common Pleas Philadelphia County June Term, 2003 No: 002211 CLAIM FOR EXEMPTION To the Sheriff: I, the above-named defendant, claim exemption of property from levy or attachment: (I) From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be [] (i) set aside in kind (specify property to be set aside in kind): [] (ii) paid in cash following sale of the property levied upon; or (b) I claim the following exemption (specify property and basis of exemption): 108274,00688/I 1251146vl (2) From my property which is in the possession of a third party, I claim the following exemptions: (a) my $300 statutory exemption: [] in cash; [] in kind (specify property): (b) Social Security benefits on deposit in the amount of $ (c) other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: (Defendant) THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: Courthouse, 3rd Floor I Courthouse Square Carlisle, PA 17013 (717) 240-6390 2 108274 00688/11251146vl SHERIFF' S RETURN - GARNISHEE E NO: 2003-00604 T COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND COMMERCE BANK/PENNSYLVANIA NA VS MCDONALD & DEROSA PC ET AL And now RONALD E. HOOVER Cumberland County of Pennsylvania, to law, at 0014:37 Hours, on the 25th day of September, __ as herein commanded all goods, chattels, rights, debts, moneys of the within named DEFENDANT , MCDONALD & DEROSA, P C hands, possession, or control of the within named Garnishee PRONATIONAL INSURANCE CO 401 E. LOUTHER ST SUITE 106 CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to MICHELLE DANNER (RECEPTIONIST personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 ,Sheriff or Deputy Sheriff of who being duly sworn according 2003, attached credits, and , in the true and made R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo · / Notary By Deputy Sb{ari f f R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing 18.00 Poundage 2.12 Advertising Law Library Prothonotary 25.50 Mileage 3.45 Sumharge 30.00 Levy 20.00 Post Pone Sale Garnishee 9.00 TOTAL $ 108.07 Advance Costs: 150.00 SherifFs Costs: 108.07 $ 41.93 Refunded to Arty on 11/20/03 Sworn and Subscribed to before me Thislo~' flayof /tJ~-t~/~-/ R. Thomas Kline, Sheriff By Claudia A. Brewbaker