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Home My WebLink About07-6371r ?A BALDWIN SECURITY A, L.P., Plaintiff vs. M.P.A. PROPERTIES, LLC a/k/a M.P.A. PROPERTIES, L.L.C., Defendant PRAECIPE TO FILE AND INDEX FOREIGN JUDGMENT AND ASSESS DAMAGES Pursuant to the Uniform Enforcement of Foreign Judgments Act, 42 Pa. C.S.A. § 4306, kindly file and index the attached, authenticated docket entries and judgment entered in the Court of Common Pleas of Dauphin County, Pennsylvania, in an action captioned Baldwin Security A, L.P., vs. M.P.A. Properties, LLC a/k/a M.P.A. Properties, L.L.C., Number 2007-CV-10743-NT, and assess damages in favor of the Plaintiff, Baldwin Security A, L.P. and against the Defendant, M.P.A. Properties, LLC a/k/a M.P.A. Properties, L.L.C., as follows: Amount of Foreign Judgment: $61,927.68 Costs due on Foreign Judgment: Interest from October 12, 2007 (date of entry of judgment) At the rate of $23.46 per diem until paid Total: $61,927.68 Plus cost and interest Date: October ?, 2007 Respectfully submitted, Gates, Halbruner & Hatch, P.C. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. & 6'71 Ten+ CIVIL ACTION -LAW Uniform Enforcement of Foreign Judgments Act Cl' n R. Guise, Esq. ID 493537 13 Mumma Road, Suite 100 moyne, PA 17043 Attorneys for Plaintiff, Baldwin Security A, LP Damages and judgment entered as above: P. L?ue /rthonotary /0/30/07 y ¢ W v, P?p I '-'V Ev?,-F a F' S g s.. 0 .r lit Up Court of Common VCeao of Maupljitt Countp, Vet iglbattia Baldwin Security A, LP VS. No. 2007-CV-10743-NT MPA Properties, LLC CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that judgment was entered in favor of Baldwin Security A, LP, Plaintiff and against MPA Properties, Defendant on 10/12/2007 in said case in the amount of $61,927.68 3n Teotimonp Wbereot, I have hereunto set my hand and affixed the seal of the Court, on Thursday, October 25, 2007. Deputy JUDGMENT $61,927.68 Interest from 5/18/2007 Attorney Due $3.00 Plaintiff Paid $33.00 Prothy. Due $10.00 This record $20.00 Date: 10U*5/2007 Dauphin County User: LBECHTEL Time: 112:23 PM Complete Case History Page 1 of 2 Case: 2007-CV-10743-NT Baldwin Security Avs.MPA Properties Filed: 10/12/2007 Subtype: Notes Physical File: Y Appealed: N Comment: Status History Pending 10/12/2007 Pending / Judgment 10/12/2007 Judge History Date Judge Reason for Removal 10/12/2007 No Judge, Current Payments Receipt Date Type Amount Gates Halbruner & Hatch 143153 10/12/2007 Civil Filing 33.00 Voided 143539 10/18/2007 Civil Filing 33.00 Gates, Halbruner & Hatch, P.C. 144027 10/25/2007 Miscellaneous 20.00 Exemplified Record 20.00 Total 53.00 Miscellaneous Receipts Receipt Date 144027 10/25/2007 Exemplified Record 20.00 Sum: 20.00 Plaintiff Name: Baldwin Security A Address: Phone: Home: Work: Employer: Litigant Type: Comment: Attorneys Guise, Clifton R Defendant SSN: DOB: Sex: Send notices: Y (Primary attorney) Send Notices Name: MPA Properties Address: 950 Walnut Bottom Road Suite Carlisle PA 17015 Phone: Home: Work: Employer: Litigant Type: Comment: Attorneys Guise, Clifton R Register of Actions 10/12/2007 New Civil Case Filed This Date. SSN: DOB: Sex: Send notices: Y (Primary attorney) Send Notices No Judge, Datfl: ' 10,/15/2007 Dauphin County Time: 12:23 PM Complete Case History Page 2 of 2 Case: 2007-CV-10743-NT Baldwin Security Avs.MPA Properties Register of Actions 10/12/2007 Filing: Complaint with Confession of No Judge, Judgment Paid by: Gates Halbruner & Hatch Receipt number: 0143153 Dated: 10/12/2007 Amount: $33.00 (Check) VOIDED Defendant: MPA Properties Attorney of No Judge, Record: Clifton R Guise On Complaint filed Judgment in No Judge, favor of Plaintiff and against Defendant in the sum of Sixty-One Thousand Nine Hundred Twenty-Seven and 68/100 Dollars ($61927.68) by virtue of authority contained in the Warrant of Attorney filed dated 5/18/07 payable See Note with interest, costs, etc. ----- for colt'n. Inquisition and Exemption Waived. Entered At 3:08 p.m. Stephen E. Farina, Prothonotary Copies of all documents mailed. Plaintiff: Baldwin Security A Attorney of No Judge, Record: Clifton R Guise 10/18/2007 Filing: Complaint with Confession of No Judge, Judgment Paid by: Gates Halbruner & Hatch Receipt number: 0143539 Dated: 10/18/2007 Amount: $33.00 (Check) Judgment Order date In Favor Of Disposition Judgment 10112/2007 Plaintiff 10/12/2007 Open Judgment Comment: 61927.68 Plaintiff: Baldwin Security A Defendant: MPA Properties OCT 2 5 20 1 hereby certify that the foregoing is a true and correct col the original filed. 1 aytL? Prothon7otta'ry/Clerk of Courts User: LBECHTEL '? t ? rya OF D Q r D Fn t v Clifton R. Guise, Esq. ID No. 93537 GATES, HALBRUNER & HATCH, P.C. 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 Telephone: (717) 731-9600 Facsimile: (717) 731-9627 E-mail: c.guise@gateslawfirm.com COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BALDWIN SECURITY A, L.P. Plaintiff vs. M.P.A. PROPERTIES, LLC a/k/a M.P.A. PROPERTIES, L.L.C., Defendant DOCKET NO: : CIVIL ACTION To: M.P.A. Properties, LLC a/k/a M.P.A. Properties, L.L.C., Defendant, You are hereby notified that on 00-4 30, 2007, the following Judgment has been Entered against you in the above-captioned case. Judgment has been entered against you in the amount of $61,927.68 plus additional interest and costs from October 12, 2007. DATE: g 3.a? P. " Prothonotary deco I hereby certify that the name and address of the proper person(s) to receive this notice is: M.P.A. Properties, LLC c/o Mikail Ocean, Member 950 Walnut Bottom Road Suite 15-114 Carlisle, PA 17015 Respectfully submitted, Gates, Halbruner & Hatch, P.C. Date: October ?f , 2007 B C on R. Guise, Esq. ID #93537 013 Mumma Road, Suite 100 Lemoyne, PA 17043 Attorneys for Plaintiff, Baldwin Security A, LP A: M.P.A. Properties, LLC a/k/a M.P.A. Properties, L.L.C., Defendido/a Defendidos/as Por este medio se le esta notificando que el de del el/la siguiente Fallo ha sido anotado en contra suya en el caso mencionado en el epigrafe. Judgment has been entered against you in the amount of $61,927.68 plus additional interest and costs from October 12, 2007. FECHA: Prothonotario Certifico que la siguiente direccion es la del defendido/a sigun indicada en el certificado de residencia: M.P.A. Properties, LLC c/o Mikail Ocean, Member 950 Walnut Bottom Road Suite 15-114 Carlisle, PA 17015 Respectfully submitted, Gates, Halbruner & Hatch, P.C. Date: October ?l , 2007 By: Guise, Esq. ID #93537 10 Mumma Road, Suite 100 Lemoyne, PA 17043 Attorneys for Plaintiff, Baldwin Security A, LP Abogado del Demandante r-` "+ Clifton R. Guise, Esq. ID No. 93537 GATES, HALBRUNER & HATCH, P.C. 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 Telephone: (717) 731-9600 Facsimile: (717) 731-9627 E-mail: c.guise@gateslawfirm.com COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION BALDWIN SECURITY A, L.P. Plaintiff vs. M.P.A. PROPERTIES, LLC a/k/a M.P.A. PROPERTIES, L.L.C., Defendant 450 Watlnu.t Boi4cm R0DJ, Sie IS-114 Qarlisle , PA 17015 DOCKET NO: 07-6371 Civil Term Confession of Judgment Amount Due: $61,927.68 Interest: $ 750.72* Attorney's Commission $ 75.07 Cost/Fees: $ *Interest from 10/9/07 through 11/9/07 at $23.46 per diem PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: 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. Issue Writ of Execution in the above matter, 1. directed to the Sheriff of Cumberland County, for debt, interest and costs; 2. against M.P.A. Properties, LLC a/k/a M.P.A. Properties, L.L.C., defendant, including specifically its membership interests in (i) Baldwin/MPA JV1, LLC, (ii) Baldwin/MPA JV2, LLC, (iii) Baldwin/MPA JV4, LLC, (iv) Baldwin/MPA JV5, LLC, (v) Baldwin/MPA JV6, and Baldwin/MPA JV8, LLC; and 3. against Citizens Bank of Pennsylvania, as garnishee, at 665 North East Street, Carlisle, Pennsylvania 17013, as garnishee for all accounts held by garnishee including all savings, checking and other accounts, certificates of deposit, notes receivable, collateral, pledges, documents of title, securities, coupons and safe deposit boxes, especially account no. 6212087230; 4. against Graystone Bank, garnishee; 3599 Gettysburg Road, Camp Hill, Pennsylvania, as garnishee for all accounts held by garnishee including all savings, checking and other accounts, certificates of deposit, notes receivable, collateral, pledges, documents of title, securities, coupons and safe deposit boxes, especially account no. 1880000255; 5. and index this writ a. against M.P.A. Properties, LLC a/k/a M.P.A. Properties, L.L.C, defendant, and b. against Citizens Bank of Pennsylvania, as garnshiee as a lis pendens against property of the defendant held by garnishee. c. against Graystone Bank, as garnishee as a lis pendens against property of the defendant held by garnishee Respectfully Submitted, GATES, HALBRUNER & HATCH, P.C. Dated: November 2007 By: n R. Guise, Esquire omeys for Plaintiff p R t It C5 0 F? v ¦ a ,V 0 l* c A., 9.31 -0 4-? -s S U1 O CJt ?. .b P1.0 N 1? " S ? Y--r w.- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6371 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BALDWIN SECURITY A, L.P., Plaintiff (s) From M.P.A. PROPERTIES, LLC a/k/a M.P.A. PROPERTIES, L.L.C., 950 Walnut Bottom Rd., Suite 15-114, Carlisle, PA 17015 (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(S) as follows: CITIZENS BANK OF PA, 665 North East Street, Carlisle, PA 17013 all accounts held by garnishee including all savings, checking and other accounts, certificates of deposit, notes receivable, collateral, pledges, documents of title, securities, coupons and safe deposit boxes, especially account no. 6212087230 GRAYSTONE BANK, 3599 Gettysburg Road, Camp Hill, PA all accounts held by garnishee including all savings, checking and other accounts, certificates of deposit, notes receivable, collateral, pledges, documents of title, securities, coupons and safe deposit boxes, especially account no. 1880000255 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 $61,927.68 L.L. $.50 Interest from 10/09/07 through 11/09/07 at $23.46 per diem -- $750.72 Atty's Comm % Atty Paid $56.00 Plaintiff Paid Date: 11/21/07 (Seal) Due Prothy $2.00 Other Costs Curt' . Lon *nary By: Deputy REQUESTING PARTY: Name CLIFTON R. GUISE, ESQUIRE Address: GATES, HALBRUNER & HATCH, P.C. 1013 Mumma Road, Sutie 100 LEMOYNE, PA 17043 Attorney for: PLAINTIFF Telephone: 717731-9600 Supreme Court ID No. 93537 SHERIFF'S RETURN - GARNISHEE CAE NO: 2007-06371 P COMMONWEALTH OF PENNSLYVANIA 'OUNTY OF CUMBERLAND L3ALDWIN SECURITY A LP VS MPA PROPERTIES LLC And now TIM BLACK Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0012:00 Hours, on the 12th day of December 2007, 'attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , MPA PROPERTIES LLC AKA M.P.A. PROPERTIES L.L.C. in the hands, possession, or control of the within named Garnishee GRAYSTONE BANK 3599 GETTYSBURG ROAD CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to ,TTTT.Th' PTLGER (TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION a the contents there of known to Her Sheriff's Costs: So answers: i true nd made Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 0 0 x/l7/07 ?-. 12/13/2007 Sworn and Subscribed to i before me this day of By Deput She ff A.D I SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-06371 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BALDWIN SECURITY A LP VS MPA PROPERTIES LLC And now DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:35 Hours, on the 5th day of December , 2007, attached as herein commanded all goods, chattels, rights, debts, credi s, and moneys of the within named DEFENDANT , in the MPA PROPERTIES LLC AKA M.P.A. PROPERTIES L.L.C. hands, possession, or control of the within named Garnishee rT1rT7VrTq RANK 665 NORTH EAST ST -i CARLISLE, PA 17015 Cumberland County, Pennsylvania, by handing to KAREN DIETZ (TELLER) ' i atories together with 3 f intero true e personally three cop g s o and attested copies of the within WRIT OF EXECUTION a nd made the contents there of known to Her Sheriff's Costs: So an /C P Docketing .00 00 Service . 00 Thomas Kline R Affidavit . . 00 Sheriff of Cumberland C unty Surcharge . .00 .00 12/13/2007 Sworn and Subscribed to before me this day of By eputy Sheriff A.D .? Carl D. Lundblad, Esquire Attorney I.D. No. 80059 GRAYSTONE BANK 112 Market Street Harrisburg, Pennsylvania 17101 Attorney for Graystone Bank BALDWIN SECURITY A, L.P.: Plaintiff V. M.P.A PROPERTIES, LLC a/k/a M.P.A PROPERTIES, L.L.C., COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Defendant NO.: 07-6371 CIVIL TERM and GRAYSTONE BANK, Garnishee ANSWERS AND NEW MATTER TO INTERROGATORIES IN ATTACHMENT ADDRESSED TO GARNISHEE, GRAYSTONE BANK By: Carl D. Lundblad, Esq. General Counsel Graystone Bank 112 Market Street Harrisburg, PA 17101 (717) 724-4655 Attorney for Garnishee, Graystone Bank GARNISHEE'S ANSWERS TO INTERROGATORIES I a. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to defendant[s] on any negotiable or other written instrument, or did defendant[s] claim that you owed him any money or were liable to defendant[s] for any reason? ANSWER: No. However, Graystone Bank (the "Bank") maintains the following account for the party indicated: MPA Properties LLC 950 Walnut Bottom Rd, SO 5-114 Carlisle, PA 17015 Checking Account #1810000255 Balance as of December 12, 2007 - ($110.93) Balance as of December 20, 2007 - ($140.93) The additional negative balance consists entirely of bank fees. 1 b. To the extend that your above answer depends in whole or part on documents, account records, other papers, or electronic data, describe each in exact detail (or attach a copy of the same). ANSWER: Bank signature card of MPA Properties LLC. 2a. 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 or more other persons any property of any nature owned solely or in part by the defendant[s]? ANSWER: No. However, the Bank maintains the following account for the party indicated: MPA Properties LLC 950 Walnut Bottom Rd, St15-114 Carlisle, PA 17015 -2- Checking Account #1810000255 Balance as of December 12, 2007 - ($110.93) Balance as of December 20, 2007 - ($140.93) The additional negative balance consists entirely of bank fees. 2b. To the extend that your above answer depends in whole or part on documents, account records, other papers, or electronic data, describe each in exact detail (or attach a copy of the same). ANSWER: Bank signature card of MPA Properties LLC. 3a. 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[s] held or claimed any interest? ANSWER: No. 3b. To the extend that your above answer depends in whole or part on documents, account records, other papers, or electronic data, describe each in exact detail (or attach a copy of the same). ANSWER: Not applicable. 4a. At any time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant[s] had an interest? ANSWER: No. 4b. To the extent that your above answer depends in whole or part on documents, account records, other papers, or electronic data, describe each in exact detail (or attach a copy of the same). ANSWER: Not applicable. 5a. At any time before or after you were served, did the defendant[s] transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? ANSWER: The defendant has made payments to the Bank pursuant to (i) a commercial term loan, account # 4000003366, which loan is secured by certain mortgages and assignments of rents and the assignment of a certain -3- life insurance policy all dated as of June 29, 2007, and (ii) a business line of credit, account # 4000003369, secured by the assignment of a certain life insurance policy, June 29, 2007. 5b. To the extent that your above answer depends in whole or part on documents, account records, other papers, or electronic data, describe each in exact detail (or attach a copy of the same). ANSWER: See Answer to 5.a. above. 6a. At any time after you were served or at any subsequent time did you pay, transfer or deliver any money or property of any nature to the defendant[s]? ANSWER: No. 6b. To the extent that your above answer depends in whole or part on documents, account records, other papers, or electronic data, describe each in exact detail (or attach a copy of the same). ANSWER: Not applicable. 7a At any time after you were served or at any subsequent time did you pay, transfer or deliver any money or property of any nature to any person, entity, or place pursuant to the direction of, or undertaking for, the defendant[s], e.g., lease payments, loan payments? ANSWER: No. 7b. To the extent that your above answer depends in whole or part on documents, account records, other papers, or electronic data, describe each in exact detail (or attach a copy of the same). ANSWER: Not applicable. 8a At any time after you were served or at any subsequent time did you have, share, or utilize any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivable, license, or collateral in which there was an interest claimed by the defendant[s]? ANSWER: The defendant is obligated to the Bank pursuant to (i) a commercial term loan, account # 4000003366, which loan is secured by certain mortgages -4- and assignments of rents and the assignment of a certain life insurance policy all dated as of June 29, 2007, and (ii) a business line of credit, account # 4000003369, secured by a certain life insurance policy, dated June 29, 2007. 8b. To the extend that your above answer depends in whole or part on documents, account records, other papers, or electronic data, describe each in exact detail (or attach a copy of the same). ANSWER: See Answer to 8. a. above. 9a Identify every account (not previously noted) titled in the name of defendant[s] in which you believe defendant[s] have an interest in whole or part, whether or not styled as a payroll account, individual account, individual retirement account, tax account, lottery account, partnership account, joint or tenants by entirety account, insurance account, trust or escrow account, attorney's account, or otherwise. ANSWER: None. 9b. To the extend that your above answer depends in whole or part on documents, account records, other papers, or electronic data, describe each in exact detail (or attach a copy of the same). ANSWER: Not applicable. -5- a NEW MATTER 1. Pursuant to the Bank's Consumer Fee Schedule relating to the account(s) referred to in the Bank's Answers to Interrogatories above, defendant is obligated to the Bank for a "Writ of Execution" fee of $250.00, plus attorney fees, relating to this matter. The Bank hereby claims its right to set-off such amounts owed by Defendants to the Bank from any amount claimed by Plaintiff. 2. The Bank has incurred and will incur attorney fees in the amount of $200.00 in preparation and investigation of the Answers to Interrogatories and in the general handling of this matter. 3. Pursuant to 42 Pa. Con. Stat. Ann. §2503(3), Bank, as Garnishee, is entitled to reasonable counsel fees as a matter of law. WHEREFORE, Bank, Garnishee in this matter, prays that the Court authorize the set-off of the $250.00 writ of execution fee and assess and award reasonable counsel fees as permitted by law in the amount of $200.00 to be set-off from the amounts claimed by Plaintiff. Respectfully submitted, GRAYSTONE BANK By: Carl D. undblad Attorney I.D. No. 80059 112 Market Street Harrisburg, PA 17101 (717) 724-4655 Attorney for Garnishee, Graystone Bank Date: December 21, 2007 -6- VERIFICATION Understanding that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, Unworn Falsification to Authorities, I verify that I am a defendant in the above matter and that after that, after inquiry, the facts set forth in the foregoing answers to postjudgment interrogatories are true, correct, and complete to the best of my knowledge, information, and beliefe. ?L 17 Date: Name: Howard Stein, Senior Vice President -7- CERTIFICATE OF SERVICE I hereby certify that on December,,?I, 2007, a copy of the foregoing Answers to Interrogatories in Attachment Addressed to Garnishee, Graystone Bank, was served upon the persons and in the manner listed below: Service by U. S. first class mail as follows: Gates Halbruner & Hatch PC Clifton R Guise, Esq 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 MPA Properties, LLC 950 Walnut Bottom Road, Suite 15-114 Carlisle, PA 17015 -8- C 'T2 s';- C_'7 II rJ " iV r Q i CO t j Ul i 07 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION BALDWIN SECURITY A, L.P., Plaintiff(s), vs. MPA PROPERTIES, LLC, Defendant(s), vs. Citizens Bank of Pennsylvania, Garnishee. 07-6371 Answers to Interrogatories Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA I.D. No. 62378 2600 One Commerce Square Philadelphia, PA 19103 - 7098 (215)-564-8142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION Baldwin Security A, L.P. Plaintiff(s), VS. MPA Properties, LLC Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. 07-6371 ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1 to 9) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the Defendant, MPA Properties, LLC, with a balance of -$274.10, however at the present time the balance is not sufficient enough to cover the Bank's processing fee. Accordingly there are no funds being held. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Perryn Epps who being duly sworn according to the law deposes and says that she is the Clerk, Operations Services, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. erryn Epps Sworn and subscribed before me this day of AYA .2008. Tawca Vow N ary P lic ? 118t L'M OF MNW YLVANA WOMBed A*' W4,#1jef Certificate of Service I, Perryn Epps, hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this day of , 2008. Clifton R Guise, Esq Gates Halbruner & Hatch, P.C. 1013 Mumma Road Lemoyne, PA 17043 M.P.A. Properties, LLC aka M.P.A. Properties, LLC ct Cyr 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: 250.00 Sheriff's Costs 151.47 Docketing 18.00 98.53 Poundage 2.97 Advertising Law Library .50 Prothonotary 2.00 Refunded on 07/29/08 Mileage 20.00 Misc. Surcharge 50.00 Levy 40.00 Post Pone Sale Certified Mail Postage Garnishee 18.00 TOTAL 151.47 ?? $??Q?C? So Ans s /?• lz? v R. Thomas Kline, Sheriff By? 9.7. go ?4 Cr?+ ?s?s3 k? .21 317/6 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-6371 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BALDWIN SECURITY A, L.P., Plaintiff (s) From M.P.A. PROPERTIES, LLC a/k/a M.P.A. PROPERTIES, L.L.C., 950 Walnut Bottom Rd., Suite 15-114, Carlisle, PA 17015 (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(S) as follows: CITIZENS BANK OF PA, 665 North East Street, Carlisle, PA 17013 all accounts held by garnishee including all savings, checking and other accounts, certificates of deposit, notes receivable, collateral, pledges, documents of title, securities, coupons and safe deposit boxes, especially account no. 6212087230 GRAYSTONE BANK, 3599 Gettysburg Road, Camp Hill, PA all accounts held by garnishee including all savings, check ni and other accounts, certificates of deposit, notes receivable, collateral, pledges, documents of,title, securities, coupons and safe deposit boxes, especially account no. 1880000255 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 $61,927.68 L.L. $.50 Interest from 10/09/07 through 11/09/07 at $23.46 per diem -- $750.72 Atty's Comm % Atty Paid $56.00 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 11/21/07 (Seal) Cu . Long, P otary 11 1 By: Deputy REQUESTING PARTY: Name CLIFTON R. GUISE, ESQUIRE