HomeMy WebLinkAbout08-2182Form CP 7 (Money Judgment)
w
r
T vxl: rurrrta.ealth of 1j.ennsiaIfxania
COUNTY OF PHILADELPHIA
PR Plymouth Meeting, LLC t/a
PR Plymouth Meeting Limited
Partnership
vs.
Kevin C. Hodges and
C. H. Hodges II
COURT OF COMMON PLEAS
2-60 e-2q?- (/
May TERM, 20 07
NO
01139
Writ of Execution
TO THE SHERIFF OF Cum j,? ,rl?.rnd COUNTY; pursuant to Rude 3103 (b)
To satisfy the judgment, interest and costs against: Kevin C. Hodges and C. H. Hodges II
defendant(s)
(1) You are directed to levy upon the property of the defendant(s) and to sell defendant's(s') interest
therein:
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
Americhoice Federal Credit Union
2175 Bumblebee Hollow Road
Mechanicsburg, PA 17055
(717) 697-3474
as garnishee(s)
(specifically describe property)
10-225(Rev . 10100)
and to notify the garnishee(s) that
(a) an attachment has been issued:
(b) the garnishee(s) is (are) enjoined from paying any debt to or for the account of the defendant(s)
and from delivering any property of the defendant(s) or otherwise disposing thereof.
(3) If property of the defendant(s) not levied upon and subject to attachment is found in the possession of
anyone other than a named garnishee(s), you are directed to notify him (them) that he (they) has
(have) been added as garnishee(s) and is (are) enjoined as above stated.
AMOUNT DUE $ -Ar, Cmi 69
INTEREST 21, 954.10
from $
(Costs to be added)
JOs
By
Date
10-225(Rev .10100)
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' r SHERIFF'S RETURN - GARNISHEE
CASE NO: 2008-00296 T/ 08 - 10 I `? Ob' ;? /pL
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PR PLYMOUTH MEETING LLC ET AL
VS
HODGES KEVIN C ET AL
And now NOAH CLINE
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:55 Hours, on the 11th day of April 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
HODGES KEVIN C
hands, possession, or control of the within named Garnishee
AMERICHOICE FEDERAL CREDIT UNION
2175 BUMBLE BEE HOLLOW ROAD
MECHANICSBURG, PA 17055
Cumberland County, Pennsylvania, by handing to
, in the
KARL LARSON (ASST VICE PRESIDENT/BRANCH ADMIN) ,
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to His .
Sheriff's Costs: So answers:
Docketing .00
?
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
00 1N1d4tr '
04/14/2008
Sworn and Subscribed to
before me this day of By Deputy Sheriff
/1. a? t?C?d )A . D
A _ I n /
CLAUDIA A. BREWBAKER, NOTARY PUBLIC
Carlisle Bom. Cumberland County
My Commission Expires ApdI 4, 2009
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2008-00296 T / uB- tol-}
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PR PLYMOUTH MEETING LLC ET AL
VS
HODGES KEVIN C ET AL
And now NOAH CLINE
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:55 Hours, on the 11th day of April , 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
HODGES C H II
hands, possession, or control of the within named Garnishee
AMERICANCHOICE FEDERAL CREDIT UNION
2175 BUMBLE BEE HOLLOW ROAD
MECHANICSBURG, PA 17055
Cumberland County, Pennsylvania, by handing to
in the
KARL LARSON (ASST VICE PRESIDENT/BRANCH ADMIN) ,
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to His
Sheriff's Costs: So answers:
Docketing .00
Service .00 ? 010*4c'e?-..o
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
.00 ? yfi a/nlT
04/14/2008
Sworn and Subscribed to
before me this day of BY
l Deputy Sheriff
CLAUDIA A. BREWBAKER, NOTARY PUBLIC
Carlisle Boro. Cumberland County
My Commission Expires April 4, 2009
r
PR PLYMOUTH MEETING LIMITED : IN THE COURT OF COMMON PLEAS OF
PARTNERSHIP : CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
V.
KEVIN C. HODGES AND
CH HODGES II9
DEFENDANTS
6*
WRIT NO- 2182 CIVIL TERM
NOTICE TO PLEAD
You have been sued in court. If you wish to defend against the claims set forth in the
New Matter in the following pages, you must take prompt action. You are warned that if you
fail to do so, the case may proceed without you and a Judgment may be entered against you by
the Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Garnishee. You may lose money or property or other rights important to you
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberland County Court House
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
JOt(?RQA 1. KOPECKY, ESQUtRE
Supreme Court ID #53147
120 South Street
Harrisburg, PA 17101
717-221-1111
Attorney for Garnishee
Y
PR PLYMOUTH MEETING LIMITED : IN THE COURT OF COMMON PLEAS OF
PARTNERSHIP : CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
V.
: WRIT NO- 2182 CIVIL TERM
KEVIN C. HODGES AND
CH HODGES II,
DEFENDANTS
ANSWERS TO INTERROGATORIES IN ATTACHMENT WITH NEW MATTER
AND NOW, comes the Garnishee, AmeriChoice Federal Credit Union, by and through its
attorneys, The Shagin Law Group LLC, and respectfully answers as follows:
1. No.
2. Yes; at the time of the service of these Interrogatories in Attachment, the Garnishee was
holding a Savings Account, a Checking Account, Johnson & Johnson capital stock, and IBM
Corporation capital stock for Defendant Kevin C. Hodges.
3. Yes; legal title as Joint Tenants in the Johnson & Johnson capital stock and the IBM
Corporation capital stock with Kevin C. Hodges, vehicle title for 2004 BMW X5.
4. No.
5. No.
6. No.
7. No.
8. No.
NEW MATTER
9. Paragraphs one through eight are incorporated herein by reference.
10. At the time of the service of the Interrogatories in Attachment, the Defendant Kevin C.
Hodges owed to Garnishee an outstanding loan which has an approximate principal loan balance
4
of $131,539.49.
11. In addition, at the time of the service of the Interrogatories in Attachment, the Defendant
Kevin C. Hodges owed to Garnishee an outstanding vehicle loan with an approximate balance of
$4115.47.
12. Both of the above-mentioned loan agreements contain a right of setoff against any of the
accounts held by Garnishee. To the extent there are any funds existing in the accounts as held by
Defendant Kevin C. Hodges, said funds are subject to the right of setoff and are therefore exempt
from attachment.
13. In addition, Garnishee is a joint owner of the above-named capital stock accounts, and claim
one-half of value of said stock, if any.
WHEREFORE, Garnishee respectfully requests Your Honorable Court to allow the
Garnishee to assert its right of set off against any property or accounts as held by Defendant
Kevin C. Hodges.
Respectfully submitted;
Jo Kopec , squire
Supreme Court ID #53147
120 South Street
Harrisburg, PA 17101
(717)221-1111
Attorney for Garnishee
VERIFICATION
I verify that the statements made in this Answers to Interrogatories am true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa_ C.S. Section
4904 relating to unsworn falsification to authorities.
AmeriChoice Federal Credit Union, Plaintiff
p? BY: ,
DATED: DO -
Dallas Zu11i
i7
R. Thomas Kline, Sheriff, who being duly sworn according to law, states r ,
this writ is returned STAYED, DUE TO BANKRUPTCY.
Sheriff s Costs: Advance Costs: 150.00
Sheriff s Costs 147.90
Docketing $ 18.00 2.10
Poundage 2.90
Advertising
Law Library
Prothonotary 38.00 Refunded to Atty on 11/14/08
Milage 11.00
Surcharge 40.00
Levy 20.00
Post Pone Sale
Garnishee 18.00
Postage
TOTAL $ 147.90 So Answers;
R. Tho Kline, S ,
By ? P/7 /Jl?
0
N
Form CP 7
h? o/`_ a i.Y'z e.,
(Money Judgment)
(IT
V_I ommonfuealt4 of ]Jenne-q1 br nia
COUNTY OF PHILADELPHIA
PR Plymouth Meeting, LLC t/a
PR Plymouth Meeting Limited COURT OF COMMON PLEAS
Partnership /
May TERM, 20 07
vs.
NO
01139
Kevin C. Hodges and
C. H. Hodges II
Writ E ecuti
TO THE SHERIFF OF CumbPVian(d COUNTY;
pursuant to Rule 3103 (b) -?
-
p
To satisfy the judgment, interest and costs against: Kevin C. Hodges and C. H. Hodges II
defendant(s)
(1) You are directed to levy upon the property of the. defendant(s) and to sell. defendant's(s') interest
therein:
(2) You are also directed.to attach the property of the defendant(s) not levied upon in the possession of
Americhoice Federal Credit Union
2175 Bumblebee Hollow Road
Mechanicsburg, PA 17055
(717) 697-3474
as garnishee(s)
(specifically describe property)
10-225 (Rev. 10/00)
.. -
and tom, np'0fy**,ie garnishee(s) that
(a) an attachment has been issued:
(b) the garnishee(s) is (are) enjoined from paying any debt to or for the account of the defendant(s)
and from delivering any property of the defendant(s) or otherwise disposing thereof.
(3) If property of the defendant(s) not levied upon and subject to attachment is found in the possession of
anyone other than a named garnishee(s), you are directed to notify him (them) that he (they) has
(have) been added as garnishee(s) and is (are) enjoined as above stated.
AMOUNT DUE $ 34__F.,-40? 69
INTEREST 21, 954.10
from $
(Costs to be added) $
JO5
By
10-225 (Rev. 10(00)
Date
rRUE COPY FROM REGORU
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