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HomeMy WebLinkAbout08-3811J & S CALIFORNIA ENTERPRISES, Plaintiff V. IVAN ADAMS and SHENEQUA TAYLOR, Defendants IN THE COURT OF COMMON PLEA CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. el Y, CIVIL TERM JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. 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 without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. 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. LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, Pennsylvania 17013-3302 1-800-990-9108 Telephone: (717) 249-3166 J & S CALIFORNIA ENTERPRISES, Plaintiff V. IVAN ADAMS AND SHENEQUA TAYLOR, Defendants : IN THE COURT OF : COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION . NO. COMPLAINT COUNT 1 J&S CALIFORNIA ENTERPRISES V. IVAN ADAMS Plaintiff files this complaint against Defendant Ivan Adams alleging the following: Plaintiff is J&S California Enterprises a Pennsylvania Partnership. LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 2. Defendant is Ivan Adams, an adult male residing at 410 N. West Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is the owner of real estate at 17 S. Hanover Street, Carlisle, Cumberland County, Pennsylvania which includes a three bedroom apartment identified as Second Floor. 4. Defendant entered into a lease with Plaintiff for the rental of the aforementioned Second Floor on or about February 2, 2007 for the rental sum of $750.00 per month. 5. On or about October 23, 2007 Plaintiff filed a complaint in Magisterial District 09-2-02 requesting possession of the premises for non payment of rent. 6. On or about November.8, 2007 Judgment was issued for Plaintiff and against Defendant for past due rent of $1,755.78 and possession of the premises. 7. Defendant left the premises and turned over possession to Plaintiff on or about December 1, 2007. 8. Plaintiff alleges that Defendant caused significant damage to the premises including but not limited to the following damages with the cost of repair: a. Broken locks and door knobs $223.43 b. Broken window in bathroom $300.00 c. Patching holes in walls in bathroom, hallway and bedroom closet $375.00 d. New tissue holder and towel bar with installation $35.00 e. Broken window in bedroom $125.00 f. Broken sash cord in bedroom $95.00 g. Remove and replace all closet doors and tracks $1,050.00 h. Repair drawer in kitchen $145.00 i. Replace door on sink cabinet in kitchen $125.00 j. Replace missing drip pans in stove $75.00 k. Replace missing range hood filter $75.00 1. Install new missing strike plates on three doors $195.00 m. Replace missing door stop in bathroom $25.00 n. Re-mount bifold door knob $25.00 o. Removing multiple crayon marks and wall damage in hallway, bedroom number 1, bedroom number 2, bedroom number 3, bathroom and living room $1,700.00 p. Replacing two year old carpet damages beyond repair $2,398.50 9. Plaintiff also alleges twenty six (26) hours of cleaning time for removal of debris at $20.00 an hour for 26 hours $520.00 and twenty two (22) Boro trash bags at $4.00 a piece for $88.00. 10. Plaintiff alleges that the total cost of repairing damages and cleanup to restore the premises to a condition it was in on or about February 2, 2007 is $9,330.71. 11. Plaintiff seeks judgment against Defendant Ivan Adams in the amount of $9,330.71. LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 COUNT II J&S CALIFORNIA ENTERPRISES V. SHENEQUA TAYLOR LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 12. Defendant is Shenequa Taylor, an adult female residing at 410 N. West Street, Carlisle, Cumberland County, Pennsylvania. 13. Plaintiff is the owner of real estate at 17 S. Hanover Street, Carlisle, Cumberland County, Pennsylvania which includes a three bedroom apartment identified as Second Floor. 14. Defendant entered into a lease with Plaintiff for the rental of the aforementioned Second Floor on or about February 2, 2007 for the rental sum of $750.00 per month. 15. On or about October 23, 2007 Plaintiff filed a complaint in Magisterial District 09-2-02 requesting possession of the premises for non payment of rent. 16. On or about November 8, 2007 Judgment was issued for Plaintiff and against Defendant for past due rent of $1,755.78 and possession of the premises. 17. Defendant left the premises and turned over possession to Plaintiff on or about December 1, 2007. 18. Plaintiff alleges that Defendant caused significant damage to the premises including but not limited to the following damages with the cost of repair: a. Broken locks and door knobs $223.43 b. Broken window in bathroom $300.00 c. Patching holes in walls in bathroom, hallway and bedroom closet $375.00 d. New tissue holder and towel bar with installation $35.00 e. Broken window in bedroom $125.00 f. Broken sash cord in bedroom $95.00 g. Remove and replace all closet doors and tracks $1,050.00 h. Repair drawer in kitchen $145.00 i. Replace door on sink cabinet in kitchen $125.00 j. Replace missing drip pans in stove $75.00 k. Replace missing range hood filter $75.00 1. Install new missing strike plates on three doors $195.00 m. Replace missing door stop in bathroom $25.00 n. Re-mount bifold door knob $25.00 o. Removing multiple crayon marks and wall damage in hallway, bedroom number 1, bedroom number 2, bedroom number 3, bathroom and living room $1,700.00 p. Replacing two year old carpet damages beyond repair $2,398.50. 19. Plaintiff also alleges twenty six (26) hours of cleaning time for removal of debris at $20.00 an hour for 26 hours $520.00 and twenty two (22) Boro trash bags at $4.00 a piece for $88.00. 20. Plaintiff alleges that the total cost of repairing damages and cleanup to restore the premises to a condition it was in on or about February 2, 2007 is $9,330.71. 21. Plaintiff seeks judgment against Defendant Shenequa Taylor in the amount of $9,330.71. Wherefore, Plaintiff requests judgment in its favor and against Defendants Shenequa Taylor and Ivan Adams jointly and severally in the amount of $9,330.71 such judgment to in lude attorney fees, cost of suit and int rest. Date: ZS d Stephen J. Ho g, squire Attorney for Plaint LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 VERIFICATION I verify that the statements made in this Complaint to the Court of Common Pleas of Cumberland County, Pennsylvania, are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904, relating to unsworn falsifications to authorities. Date: S Y Stephen J. Hog wire LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 I? `I' -..,.. ,. [_3 ?l ?-' .y? ? - .. N'- ?? J G ? ? ?. `?,? `?- ?, ?1 h3 c? L 1 -? e `; ?? a . ? - T'1 Si{ _ ...,.t t _ ??? .. .?, i'. ?v?? c::?, ?`? R CASE NO: 2008-03811 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND J & S CALIFORNIA ENTERPRISES VS ADAMS IVAN ET AL WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ADAMS IVAN the DEFENDANT , at 1414:00 HOURS, on the 2nd day of July , 2008 at 410 N WEST STREET CARLISLE, PA 17013 IVAN ADAMS by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge ?,_ ??/Sj0r 18.00 5.00 .59 10.00 .00 33.59 Sworn and Subscibed to before me this day So Answers: •- R. Thomas Kline 07/09/2008 STEPHEN HOGG By: Deputy Sheriff of A. D. at , SHERIFF'S RETURN - REGULAR CASE NO: 2008-03811 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND J & S CALIFORNIA ENTERPRISES VS ADAMS IVAN ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TAYLOR SHENEQUA the DEFENDANT , at 2113:00 HOURS, on the 7th day of July 2008 at 410 N WEST STREET CARLISLE. PA 17013 by handing to SHENEQUA TAYLOR a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 711,5'10.f ?^ 07/09/2008 So Answers: Affidavit h Surcharge R. Thomas Kline HOGG Sworn and Subscibed to By: before me this day of A.D. . 0 0 5.00 6 Service - c ??,, / ,?„n•.,,,,p .00 10.00 R .00 21.00 STEPHEN J & S CALIFORNIA ENTERPRISES, Plaintiff V. IVAN ADAMS and SHENEQUA TAYLOR, Defendants TO: SHENEQUA TAYLOR 410 N. WEST STREET CARLISLE, PA 17013 DATE: l : IN THE COURT : OF COMMON PLEA : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION-LAW : NO. 08-3811 : CIVIL TERM : JURY TRIAL DEMANDED IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. 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 32 S. Bedford Street Carlisle, Pennsylvania 17013-3302 1-800-990-9108 Telephone: (717) 249-3166 LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 C K 't) t x ca tr r,: c M23 c r •, J & S CALIFORNIA ENTERPRISES, Plaintiff V. IVAN ADAMS and SHENEQUA TAYLOR, Defendants TO: IVAN ADAMS 410 N. WEST STREET CARLISLE, P 17013 DATE: : IN THE COURT : OF COMMON PLEA : CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION-LAW : NO. 08-3811 : CIVIL TERM : JURY TRIAL DEMANDED IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. 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 32 S. Bedford Street Carlisle, Pennsylvania 17013-3302 1-800-990-9108 Telephone: (717) 249-3166 LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 r--3 ca q- G °as x. r'l VA ` -+4 _ sr -% CASE NO: 2008-03811 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND J & S CALIFORNIA ENTERPRISES VS ADAMS IVAN ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon ADAMS IVAN the DEFENDANT , at 2120:00 HOURS, on the 27th day of October , 2008 at 410 N WEST STRRFT CARLISLE, PA 17013 IVAN ADAMS by handing to a true and attested copy of NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.00 Postage .59 Surcharge 10.00 .00 lD?3e?e? 33.59 Sworn and Subscibed to before me this of So Answers: 10- R. Thomas Kline 10/28/2008 J&S CALIFORNIA ENTERPRISES By. day Deputy Sh ff D'a A.D. I ..,R CASE NO: 2008-03811 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND J & S CALIFORNIA ENTERPRISES VS ADAMS IVAN ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon TAYLOR SHENEQUA the DEFENDANT at 2120:00 HOURS, on the 27th day of October 2008 at 410 N WEST STREET CARLISLE, PA 17013 by handing to SHENEQUA TAYLOR a true and attested copy of NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 Io 3(b/ap (?, .00 16.00 So Answers: 1 R. Thomas Kline 10/28/2008 J&S CALIFORNIA ENTERPRISES Sworn and Subscibed to By: before me this day Deputy Sh ff of A.D. J & S CALIFORNIA ENTERPRISES, Plaintiff V. IVAN ADAMS and SHENEQUA TAYLOR, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION-LAW : NO. 08-3811 : CIVIL TERM : JURY TRIAL DEMANDED PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY OF SAID COURT: Enter judgment in favor of the plaintiff and against the defendants above named for want of an answer, and assess the plaintiffs damages as follows: Amount claimed in plaintiffs complaint ......... $9,330.71 Interest .................................. $466.00 Attorney fee .............................. $800.00 Total ......................... $9,797.51 LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 Date: 0 It is certified that a written notice of intention to file this praecipe was mailed to the defendants against whom judgment is to be entered after the default occurred and at least ?d prior to the date of the filing of this praecipe. 451 Stephen J. Hog uire Attorney for Pla' tiff Judgment entered and damages assessed as above. Prothonotary /,?L LAW OFFICES OF TEPHEN J. HOGG 9 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 J & S CALIFORNIA ENTERPRISES, Plaintiff V. IVAN ADAMS and SHENEQUA TAYLOR, Defendants TO: IVAN ADAMS 410 N. WEST STREET : IN THE COURT : OF COMMON PLEA : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION-LAW : NO. 08-3811 : CIVIL TERM : JURY TRIAL DEMANDED CARLISLE, P 17013 0 q p DATE: C.. IMPORTANT NOTICE 1 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR cO DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. 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 32 S. Bedford Street Carlisle, Pennsylvania 17013-3302 1-800-990-9108 Telephone: (717) 249-3166 a f77- --c CASE NO: 2008-03811 P / COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND J & S CALIFORNIA ENTERPRISES VS ADAMS IVAN ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE- was served upon ADAMS IVAN the DEFENDANT , at 2120:00 HOURS, on the 27th day of October , 2008 at 410 N WEST STREET CARLISLE, PA 17013 by handing to IVAN ADAMS a true and attested copy of NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.00 Postage .59 Surcharge 10.00 Sworn and Subscibed to. before me this day of So Answers: R. Thomas Kline 10/28/2008 J&S CALIFORNIA ENTERPRISES By: Deputy Sh ff A.D. J & S CALIFORNIA ENTERPRISES, Plaintiff V. IVAN ADAMS and SHENEQUA TAYLOR, Defendants TO: SHENEQUA TAYLOR 410 N: WEST STREET CAR/LISLE, PA 17013 1--7 Z DATE: / D : IN THE COURT : OF COMMON PLEA : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION-LAW : NO. 08-3811 0 a : CIVIL TERM- m : JURY TRIAL DEM EQ ? (D c:? c.? jrn cn co IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. 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 32 S. Bedford Street Carlisle, Pennsylvania 17013-3302 1-800-990-9108 - Telephone: (717) 249-3166 - LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 ? U NO: 2008-03811 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND J & S CALIFORNIA ENTERPRISES VS ADAMS IVAN ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon TAYLOR SHENEQUA the DEFENDANT at 2120:00 HOURS, on the 27th day of October 2008 at 410 N WEST STREET CARLISLE, PA 17013 SHENEQUA TAYLOR a true and attested copy of NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of 6.00 .00 .00 10.00 .00 16.00 by handing to So Answers: R. Thomas Kline 10/28/2008 J&S CALIFORNIA ENTERPRISES By: day Deputy Sh ff A.D. r-0 r IS> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: J&S California Enterprises V. Ivan Adams and Shenequa Taylor : ? Confessed Judgment ? Other File No. 2008-03811 Amount Due $9,797-531 Interest Atty's Comrn I dO t, Costs TO THE PROTHONOTARY OF THE SAID COURT: 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 mutter to the sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) _ All personal property, furniture, appliances, televisions, computer equipment and the like as well as motor vehicles at 410 N. West Street, Carlisle, PA 17013 license number FW68053 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, dhwting attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ? (Indicate) Index this writ against the garnishee (s) as a l7pet t estate of the defendant(s) described in the attached exhibit. Date 03/03/09 Signature: PrintNarne: Stephen Hogg, Esquire Address: 19 S. Hanover Street, Ste.101 Carlisle, PA 17013 Attorney for: Telephone: 717-245-2698 Supreme Court ID No: 36812 O'K ICI?A CD I ? ?? X1..5 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N02008-3811 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due J&S California Enterprises Plaintiff (s) From Ivan Adams and Shenequa Taylor (1) You are directed to levy upon the property of the defendant (s)and to sell All personal property, furniture, appliances, televisions, computer equipment and the like as well as motor vehicles at 410 N. West Street, Carlisle, PA 17013 license number FW68053. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 $9797.51 Interest Atty's Comm % $800.00 Arty Paid $223.18 Plaintiff Paid Date: March 4, 2009 (Seal) L.L.$.50 Due Prothy $2.00 Other Costs Ada Ctirt's R. Long, oth notary By: Deputy REQUESTING PARTY: Name Stephen J. Hogg, Esq. Address: 19 S. Hanover Street, Ste 101 Carlisle, PA 17013 Attorney for: Telephone: 717-245-2698 .W a.MM .cIPiW Supreme Court ID No. 36812 i A, R. THOMAS KLINE Sheriff EDWARD L.SCHORPP Solicitor OtV of CUJUbpr ja © 44 OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 June 5, 2009 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Sergeant J & S California Enterprises vs Ivan Adams and Shenequa Taylor Writ No. 2008-3811 Civil Term / Property Claim Determination Dear Sir, Reference is made to Property Claim dated May 26, 2009, entered by Jeanne Peay, Writ of Execution No. 2008-3811 Civil Term, J & S California Enterprises vs Ivan Adams and Shenequa Taylor. R. Thomas Kline, Sheriff, has determined that the claimant, Jeanne Peay in the above mentioned property claim, is the owner of the property set forth in the claim. cc Stephen J. Hogg, Atty for Pltff Ivan Adams, Defendant Shenequa Taylor, Defendant Jeanne Peay, Claimant So Answers: .p 9A Thomas R Kline, She ' ff, r On v B -o r- ? NOTICE OF PROPERTY CLAIM J&S California Enterprises VS Ivan Adams and Shenequa Taylor In the Court of Common Pleas Cumberland County, Pennsylvania No. 2008-3811 Civil Term Writ of Execution TO THE DEFENDANTS AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Jeanne Peay claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 05-26-09 Sheriff of Cumberland ounty By Cc Stephen J. Hogg, Atty for Pltff Ivan Adams, Defendant Shenequa Taylor, Defendant Jeanne Peay, Claimant ? f PROItRTY CLAIM ')?S (YAA rr xtk j i-ty,YDYi n ZYC yl lA?l,YY1S f Shs! C?VXA TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA In the Court of Common Pleas of Cumberland County, Pennsylvania writ No. VAT ?j9 U The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE Date S- Z -6q State. of Pennsylvania: County of Cumberland M + }tpme ?(f being duly sworn according to law, deposes and says that the above list in the property cla' are correct and true. . /-1-D S orn and subs y IMLAWOLEW I A- My Comr *WM WM W 4, 2019 r ? C aNOrth cny?iU Qk ?106 e of R. THOMAS KLINE Sheriff EDWARD L.SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 June 5, 2009 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Sergeant J & S California Enterprises vs Ivan Adams and Shenequa Taylor Writ No. 2008-3811 Civil Term Property Claim Determination / Dear Sir, Reference is made to Property Claim dated May 19, 2009, entered by Earl R. Moyer Jr., Writ of Execution No. 2008-3811 Civil Term, J & S California Enterprises vs Ivan Adams and Shenequa Taylor. R. Thomas Kline, Sheriff, has determined that the claimant, Earl R. Moyer Jr., in the above mentioned property claim, is the owner of the property set forth in the claim. cc Stephen J. Hogg, Atty for Pltff Ivan Adams, Defendant Shenequa Taylor, Defendant Earl R. Moyer, Jr., Claimant x cn w q AM So Answers: w. NOTICE OF PROPERTY CLAIM J&S California Enterprises VS Ivan Adams and Shenequa Taylor In the Court of Common Pleas Cumberland County, Pennsylvania No. 2008-3811 Civil Term Writ of Execution TO THE DEFENDANTS AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Earl R. Moyer Jr. claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 05-19-09 Cc Stephen J. Hogg, Atty for Pltff Ivan Adams, Defendant Shenequa Taylor, Defendant Earl R. Moyer, Jr., Claimant -- ' ?.- ?; e? - ? - Sheriff of Cumberland ounty "?A e dale s?'i'I( s?f - os/a7/c?9 - r?e?si?u,;? , , ferns a.u letl PROPERTY CLAIM -T q S C q f,'1'p,'1;?; ',?-4TPIZ PKl e l V ?7?A.v f? r, T d S?e ?J P cc. A Tay /a 2 TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: THE C'LA?MAly??OBT TITLE TO TAE PROPERTY AS /Q LLQQ . G,. ?eej Date Claimant ryl State. of Pennsylvania: County of Cumberland being duly sworn according to law, deposes and says that the above list in the property claim are correct and true. - /J // Sworn and subscribed TbAsLq_ day?f! W QL4A I OTARK r Claimant EINBAItER, NOTAH1f'PUBLir Carlisle Bo% Cwb& MW Co" to Commission Expires Aprfl 4,20' ; 3 yS G S T Ca^ /? I /-e 1-20-13 S ? :01 V b I ? dFj boot il, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ??y??LS?' ctt 4tt'tttGtr/,,,??s?I L)_(jr1 VVS.. OF 'T Fi F 291q MAR 24 x'11 2: 28 , J & S California Enterprises vs. Shenequa Taylor (et al.) Case Number 2008-3811 SHERIFF'S RETURN OF SERVICE 03/24/2009 09:30 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on March 24, 2009 at 0930 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Ivan Adams, by making known unto Ivan Adams at 267 Lincoln Street Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard mailed to attorney and letter mailed to defendant on 03-17-09. 03/24/2009 09:30 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on March 24, 2009 at 0930 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Shenequa Taylor, by making known unto Shenequa Taylor, at 267 Lincoln Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and 1 correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard mailed to attorney and letter mailed to defendant on 03-27-09. 5/01/2009 03:05 PM -Sale bill posted on 05-01-09 at 1506 hours by Deputy Harrison. Sale date set for Wednesday 05-27-09 at 1500 hours. Copy of sale bill mailed to Attorney Hogg. 5/01/2009 Sale bill posted on 05-01-09 at 1506 hours by Deputy Harrison. Sale date set for Wednesday, 05-27-09 at 1500 hours. Copy of sale bill mailed to Attorney Hogg. 5/1 912 0 0 9 On Tuesday, May 19, 2009, at 1045 hours, a property claim was filed by Earl R. Moyer, Jr., who is the property owner where the defendants live. Moyer claimed several items that were furnished to the defendants by him or that were left there by previous tenants for the defendants to use. All parties notified by mail this date. NOTE: Sale date still set for 05-27-09 for remaining items on levy. 5/22/2009 Per request of Attorney Hogg, this sale is continued generally. No further action to be taken unless directed by Attorney Hogg. 5/26/2009 On Tuesday, May 26, 2009, at 1045 hours, a property claim was filed by Jeanne Maranda Peay. Peay claimed several items from the sale bill that she claims are hers and she stored them at the defendant's residence. All parties notified by mail this date /05/2009 Reference is made to Property Claim dated May 19, 2009, entered by Earl R. Moyer, Jr., Writ of Executior No. 2008-3811 Civil Term, J & S Califoronia Enterprises vs Ivan Adams and ShenequaTaylor. R. Thomas Kline, Sheriff, has determined that the claimant, Earl R. Moyer, Jr., in the above mentioned property claim, is the owner of the property set forth in the claim. Reference is made to Property Claim dated May 26, 2009, entered by Jeanne Peay, Writ of Execution No. 2008-3811 Civil Term, J & S California Enterprises vs Ivan Adams and Shenequa Taylor. R. Thomas Kline, Sheriff, has determined that the claimant, Jeanne Peay, in the above mentioned property claim, is the owner of the property set forth in the claim. 0 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. r,) Doom 5y jite Sheriff. ie?eosoff. loc. A, IFF COST. 12.42 ch 24, 2010 SO wsv\epS, FtERiFF F:ANDeRSON, S RON Lantz B Slza=oa R. 4A 7q _3gtt33 ??? Coun,ySutte Sher.. jeleasofl. I,'c. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N02008-3811 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due J&S California Enterprises Plaintiff (s) From Ivan Adams and Shenequa Taylor (1) You are directed to levy upon the property of the defendant (s)and to sell All personal property, furniture, appliances, televisions, computer equipment and the like as well as motor vehicles at 410 N. West Street, Carlisle, PA 17013 license number FW68053. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 $9797.51 Interest Atty's Comm % $800.00 Atty Paid $223.18 Plaintiff Paid Date: March 4, 2009 (Seal) L.1-3.50 Due Prothy $2.00 Other Costs . A.'J." -- C is R. Lo , r thonot By: Deputy REQUESTING PARTY: Name Stephen J. Hogg, Esq. Address: 19 S. Hanover Street, Ste 101 Carlisle, PA 17013 Attorney for: Telephone: 717-245-2698 Supreme Court ID No. 36812 Fk., 0 ? I "?, s bn]z