HomeMy WebLinkAbout08-4373s "6
STEPHEN G. KREBS, M.D., AND JANE
R. KREBS, his wife,
plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
19. JCK, hjs wife,
CARETS
4&& /1,9)2j A /`7??70''_--II--Defendants
IN THE COURT OF COMMON
PLEAS, CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 0& ?J2 13
el, ? L `
Cl:4. ACTION
PRAECIPE FOR WRIT OF REVIVAL
TO THE PROTHONOTARY:
Please issue Writ of Revival of the lien of judgment entered at Number 01-7030 and enter it in
the judgment index against G. Ronald Krajack, D.M.D, and Careth E. Krajack, his wife, in the amount
of $50,149.50 with interest from December 1, 2001.
P.C.
Jam . Hughes, Esquire
rney I.D. No. 58884
Susann B. Morrison, Esquire
Attorney I.D. No. 77041
354 Alexander Spring Road
Carlisle, PA 17013
(717) 249-6333
Attorneys for Plaintiff
Date: TU Z I -&& ?.3
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C..... .C" _
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STEPHEN G. KREBS, M.D., AND JANE
R. KREBS, his wife,
plaintiffs
V.
G. RONALD KRAJACK, DALD, AND
CARETH E. KRAJACK, his wife,
Defendants
. IN THE COURT OF COMMON
. PLEAS, CUMBERLAND COUNTY,
. PENNSYLVANIA
NO. 08- -Y3 73 C-r"
. CIVIL ACTION
WRIT OF REVIVAL
TO: G. RONALD KRAJACK D.M.D. and CARETH E. KRAJACK
42 SOUTH PITT STREET
CARLISLE, PA 17013
You are hereby notified that the above-named Plaintiffs have commenced a proceeding to revive the
lien of judgment entered against you at Number 01-7030.
The Plaintiffs claim that the amount due and unpaid is $50,149.50 with interest from December 1,
2001.
You are required within twenty (20) days after service of this writ to file an answer or otherwise
plead to the writ. If you fail to do so, judgment of revival in the amount claimed by the Plaintiffs may
be entered without a heating 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
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 South Bedford Street
a? Carlisle, PA 17013
Telephone No. (717) 249-31
qL _
Pro notary
Date: ?" a 2 05g7- By:
Deputy
STEPHEN G. KREBS, M.D., AND JANE
R. KREBS, his wife,
Plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
Defendants
. IN THE COURT OF COMMON
. PLEAS, CUMBERLAND COUNTY,
. PENNSYLVANIA
NO. 084373 Civil Term
. CIVIL ACTION
PRAECIPE TO REISSUE
TO THE PROTHONOTARY:
Kindly reissue the Writ of Revival filed by Plaintiffs in the above captioned matter.
Respectfully submitted,
SALZMANN HUGHES, P.C.
By:
James D. Hughes, E uire
Supreme Court No.58884
Susann B. Morrison, Esquire
Supreme Court No. 77041
354 Alexander Spring Road, Ste 1
Carlisle, PA 17013
(717) 249-6333
Attorney for Plaintiffs
Date O r
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SHERIFF'S RETURN - REGULAR
4 1 1 1.
CASE NO: 2008-04373 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KREBS STEPHEN G MD ET AL
VS
KRAJACK G RONALD DMD ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF REVIVAL was served upon
KRAJACK G RONALD DMD the
DEFENDANT
at 42 S PITT ST
, at 1450:00 HOURS, on the 22nd day of August , 2008
CARLISLE, PA 17013
by handing to
JOHN KRAJACK, SON
a true and attested copy of WRIT OF REVIVAL
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 10.00
Postage .59
Surcharge 10.00
00
9?bz?og ?^ 38.59
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
08/25/2008
SALZMANN HUGHES
By:
Deputy Sheriff
of A. D.
SHERIFF'S RETURN - REGULAR
A ?
CASE NO: 2008-04373 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KREBS STEPHEN G MD ET AL
VS
KRAJACK G RONALD DMD ET AL
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF REVIVAL was served upon
KRAJACK CARETH E the
DEFENDANT
at 42 S PITT ST
at 1450:00 HOURS, on the 22nd day of August , 2008
CARLISLE, PA 17013
by handing to
JOHN KRAJACK, SON
a true and attested copy of WRIT OF REVIVAL
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
Rlps?UB ?-- 16.00
Sworn and Subscibed to
before me this day
of
So Answers:
Q
R. Thomas Kline
08/25/2008
SALZMANN HUGHES
By:
Deputy Sher ff
A. D.
M
STEPHEN G. KREBS, M.D., AND JANE
R. KREBS, his wife,
plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
Defendants
: IN THE COURT OF COMMON
: PLEAS, CUMBERLAND COUNTY,
: PENNSYLVANIA
NO. 08-4373 Civil Term
CIVIL ACTION
PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAULT
TO THE PROTHONOTARY:
Kindly enter judgment of default in favor of the Plaintiffs, STEPHEN G. KREBS, M.D.,
AND JANE R. KREBS, his wife, and against the Defendants, G. RONALD KRAJACK, D.M.D,
AND CARETH E. KRAJACK, his wife, for Defendants' failure to plead to the Writ in this action
within the required time. The Writ contains a notice to defend within twenty (20) days from the date
of service thereof. Defendant was served with the complaint on or about August 22, 2008, and
Defendant's answer was due to be filed on or about September 11, 2008.
Attached hereto as Exhibit "A" and Exhibit "B" are copies of Plaintiffs written Notice of
Intention to File a Praecipe for Entry of Default Judgment, which I certify was mailed by regular
mail to the Defendants at their last known address on or about September 12, 2008, which is at least
ten (10) days prior to the filing of this Praecipe.
Please enter judgment against the Defendants and assess damages in the amount of
$50,149.50, being the amount demanded in the Writ, including lawful interest from the date of filing
and costs.
SALZMANN HUGHES, P.C.
By ,
Ja? J1911- - A i4g?L? -
mes D. H es, squire
Attorney I.D. No. 58884
Susann B. Morrison, Esquire
Attorney I.D. No. 77041
354 Alexander Spring Road, Suite 1
Carlisle, PA 17015
(717) 249-6333
Attorneys for Plaintiff
Date: ?Z 2 zo ?"
STEPHEN G. KREBS, M.D., AND JANE
R. KREBS, his wife,
plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
Defendants
To: G. RONALD KRAJACK, D.M.D.
Date of Notice: September 12, 2008
IMPORTANT NOTICE
Y
4z'rCOp
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, 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 South Bedford Street
Carlisle, PA 17013
Telephone No. (717) 249-3166
By: k "'?- ,
Susan B. M
Salzmann Hughes, P.C.
354 Alexander Spring Road, Suite 1
Carlisle, PA 17015
(717) 249-6333
Attorney for Plaintiffs
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY,
. PENNSYLVANIA
NO. 084373 Civil Term
: CIVIL ACTION
Exhibit A
A
STEPHEN G. KREBS, M.D., AND JANE
R. KREBS, his wife,
Plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY,
. PENNSYLVANIA
. NO.08 4373 Civil Term
. CIVIL ACTION
Defendants
?y
To: CARETH E. KRA7ACK
Date of Notice: September 12, 2008
IWORTANT 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, 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 South Bedford Street
Carlisle, PA 17013
Telephone No. (717) 249-3166
'?.
By:Ijo
Susan B. M n, Eiquire
Salzmann Hughes, P.C.
354 Alexander Spring Road, Suite 1
Carlisle, PA 17015
(717) 249-6333
Attorney for Plaintiffs
Exhibit R
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,P.C.
Attorneys at Lana
-ER SPRING ROAD, SUITE 1
PENNSYLVANIA 17015
'Ronald Krajack,. D.M.D
.42 South Pitt Street
Carlisle, PA 17013
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02 I P $ 000.424
0002678218 SEP 12 2008
MAILED FROM ZIP CODE 17015
MANN
UGHESYCO
Attorneys at Law
)ER SPRING ROAD, SUITE 1
:, PENNSYLVANIA 17015
Gareth Krajack
42 South Pitt Street
Carlisle, PA 17013
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02 1P $ 000.42;
0002678218 SEP 12 2008
MAILED FROM ZIP CODE 17015
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STEPHEN J. KREBS, M.D., AND JANE
R. KREBS, his wife,
Plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
Defendants
IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 084373 Civil Term
CIVIL ACTION
PETITION IN AID OF EXECUTION
Plaintiffs, Stephen J. Krebs, M.D. and Jane R. Krebs, his wife, by and through their attorneys,
Salzmann Hughes, PC, respectfully represent the following in support of this Petition in Aid of
Execution:
In 2001, Plaintiffs recorded a Judgment Note against Defendants on December 14, 2001
in the amount of $60,000.00 (Civil Action No. 01-7030). Attached hereto as Exhibit A.
2. Defendants have failed to satisfy the debt.
4. The Judgment Note recorded at Civil Action No. 01-7030 was revived on September 23,
2008 in Civil Action No. 08-4373 with a judgment against Defendants in the amount of the remaining
balance of $50,149.50.
5. Plaintiffs filed a Writ of Execution against Defendants on October 30, 2008.
6. The only known asset of substantial value owned by Defendants is the Land Lease with
the Commonwealth of Pennsylvania, Department of Community and Natural Resources (DCNR) located
in Pine Grove Furnace State Park, DCNR Lease Number 1-C-267 and Parcel ID Number 07-42-3299-
267.-001 C267, the purchase of which from Plaintiffs is the source of Defendants' debt.
7. Pennsylvania case law considers a lease of land as personal property as opposed to real
property for purposes of a writ of execution. (Kile v. Giebner, 114 Pa. 381, 7 A. 154 (1886); County o
Allegheny v. Three Rivers Management Corlwration, 16 Pa.Cmwlth.361, 328 A.2d 567 (1974)).
8. Plaintiffs have requested the Sheriff to levy upon the Land Lease as well as the
improvements thereon, in addition to other items of personal property owned by the Defendants.
9. The Department of Conservation and Natural Resources (DCNR) is the agency that
administers the leases on land in Pennsylvania's state parks.
10. DCNR requires that, in order for any rights to confer to a purchaser of a land lease, the
lease must be assigned from the current owner to the purchaser through DCNR.
11. Accordingly, in the event the Land Lease owned by Defendants is sold at a Sheriff's sale,
DCNR would not recognize any rights of the Purchaser without Defendants assigning the Land Lease to
the Purchaser.
WHEREFORE, Plaintiffs respectfully request the following:
1. That a hearing on this petition be set and due notice thereof be given according to
law.
2. That at said hearing, the Court make and enter an Order directing the following:
a. Defendants are enjoined from assigning, transferring or selling their
interest in the Land Lease with the Commonwealth of Pennsylvania,
Department of Community and Natural Resources (DCNR) located in
Pine Grove Furnace State Park, DCNR Lease Number 1-C-267 and
Parcel ID Number 07-42-3299-267.-001 C267.
b. In the event the Land Lease is sold at a Sheriff's sale pursuant to
Plaintiffs' Writ of Execution, Defendants are required to assign the
Land Lease to the purchaser and fulfill all of the requirements of the
Commonwealth of Pennsylvania, Department of Community and
Natural Resources (DCNR) to effectuate such assignment.
c. Defendants are directed to disclose to the Sheriff the whereabouts of
property of the Defendants.
3. That the Court grant such further relief as may deem necessary and appropriate.
SALZMANN HUGHES, P.C.
Date /4 o the
IM-)X)dVu6&
Susann B. orri n, Esq.
Supreme Court ID 77041
354 Alexander Spring Road, Suite
Carlisle, PA 17015
(717) 249-6333
Attorney for Plaintiffs
VERIFICATION
The foregoing document is based upon information that has been gathered by our
counsel and ourselves in the preparation of this action. We have read the statements
made in this document and they are true and correct to the best of our knowledge,
information and belief. We understand that false statements herein made are subject to
the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities.
Ci/?ytL _ r
Date: /C / '2 0
?- Stephen J. Krebs, M.D., Plaintiff
Jane R. Krebs, P aintiff,;
u4/=ci_cwc lil:yc rna L'k i?l u•;? .,na.iuau-u,., ..... ..?... ., ............
D Co Py
Datc:,??? ? . ? z.ecs 1 s60,000.00
JUDGMENT NOTE
G. RONALD KILUACK, D.M.D and CARETS E- KRAJAM husband and wife, jointly and
individually (mown as "Obligor", promises to pay to STEPHEN G. KREBS, M .M. and JANE R.
KREBS, husband and wife, as "Obligee", their heirs and/or assigns, SIXTY THOUSAND AND
00/100'Dollars ($60.000.00) with interest at 6.5% per annum, in SIXTY (60) equal monthly
payments in the amount of FOUR HUNDRED FORTY-SEVEN AND 34/100 Dollars ($447.34)
due the first day of the month beginning Deg 1 zoo I and ending JJ DV
without deWcartion value received. In the event that Obligors are more than fifteen (IS) days late
on any monthly payment, then the entire balance of the principal of this Note and the accrued
interest thereon shall become immediately payable, without notice, demand, presentment, or
protest, all of which are expressly waived by Obligors. Obligors shall have the right to prepay all
or any part of the principal amount of this Note at any time or from time to time without premium
or penalty, provided that Obligors pay at the same time all interest accrued thereon to the date of
payment. In addition, Obligors do hereby authorize and empower the Prothonotary or any
Attorney of any Court of Record of Pennsylvania or elsewhere to appear for and enter judgment
agairnst them for the above sum, with or without declaration, with costs of suit, release of errors,
without stay of execution, and with 15 percent added for collection fees; and Obligors hereby
agree not to make any motion or any application whatsoever to any Court for an inquisition on
any real estate that may be levied upon to collect the aforesaid sum, and Obligors voluntarily
condemn same, and authorizes the Prothonotary to enter said voluntary condemnation upon the
Writ of Execution. Obligors further agree that any property, real personal or mixed may be sold
through a Writ of Execution and "er hereby waives. and releases all relief from any and all
appraisemeats, stay or exemption of any State now in force or which are passed hereafter. NO
SINGLE EXERCISE OF THE FOREGOING POWER TO CONFESS JUDGMENT SHALL BE
DEEMED TO EXHAUST THE POWER WHETHER OR NOT ANY SUCH EXERCISE
SMALL BE HELD BY ANY COURT TO BE VALID, VOIDABLE, OR VOID, 13W rem
POWER SHALL CONTINLIE UNDRAI.NISIED AND IT MAY BE EXERCiSPYFROM
TIME TO TIME AS OFTEN AS THE HOLDER HI?:RBOF SHALL ELECT, SUCH
TIME AS THE HOLDER HBREOF SHALL HAVE RECEIVED PAYMENT ?RXL =OF
ALL AMOUNTS OWING HEREUNDER, TOGETHER WITH COSTS.
WAIVER - r -;
IN EXECUTING THIS NOTE, WE UNDERSTAND THE TRAL ACjIOTZ
AMID KNOWINGLY AND VOLUNTARILY WAIVE OUR RIGHT TO CO $TdM ,.
ENTRY OF THIS JUDGMENT AGAINST US IN COURT AND DO ?i;C04ENT TO
THE ENTRY OF THE RMGIVMNT BY CONFESSION. WE, HEREBY GE 'YTHAT-WE
HAVE EARNINGS OF $10,000.00 OR MORE PER YEAR. ? s
- - , si: --
EXHIBIT A
U4iZZ/ZUUZ 15:4'. rAA Z4b(JJ4 OALAIALW:r VQKILlJLaa rlaauan c,?w?.. v
Witness our hands and seals the day and year first above written,
sealed-and delivered in the
1o
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sPRAL)
(SEAL)
4"" Careth E. Krajack, Obligor
STEPHEN J. KREBS, M.D., AND JANE
R. KREBS, his wife,
Plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
Defendants
IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 084373 Civil Term
CIVIL ACTION
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that on this 30th day of October, 2008, a copy of
Plaintiffs' Petition in Aid of Execution was served by First Class Mail upon the
following:
G. Ronald Krajack
42 South Pitt Street
Carlisle, PA 17013
Careth E. Krajack
42 South Pitt Street
Carlisle, PA 17013
A14LA /47/?
Susann B. Mo 'son, 'Efsquire
Salzmann Hughes, P.C.
Supreme Court I.D. # 77041
354 Alexander Spring Road, Suite 1
Carlisle, PA 17015
(717) 249-6333
Attorney for Plaintiffs
Date: October 30, 2008
"3 7
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
STEPHEN J. KREBS, M.D., AND JANE R.
KREBS, his wife,
Plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
Defendants
_ Confessed Judgment
X Other
File No. OS-4373
Amount Due 50$•149.50
Interest
Atty's Comm
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 matter to the Sheriff of Cumberland County, for debt,
interest and costs, upon the following described property of the defendant(s):
1. Land Lease with the Commonwealth of Pennsylvania, Department of Community and Natural
Resources (DCNR) with regard to a certain tract of land known and numbered as 40 Bepdersville Road,
Cooke Township, Cumberland County, located in Pine Grove Furnace State Park, DCNR Lease Number
1-C-267 and Parcel ID Number 07-42-3299-267.-OO1C267.
2. Any and all improvements on that certain tract of land known and numbered as 40
Bendersville Road, Cooke Township, Cumberland County, located in Pine Grove Furnace State Park,
DCNR Lease Number 1-C-267 and Parcel ID Number 07-42-3299-267.-001 C267.
3. Any and all other property or vehicles owned by the Defendants whether or not located at
their residence at 42 South Pitt Street, Carlisle, PA 17013.
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as
above, directing 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).
_ Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date
A"LSusann B. mso Esq., Attorney for Plaintiffs
SALZMANN HUGHES, P.C.
Supreme Court ID 77041
354 Alexander Spring Road, Suite 1
Carlisle, PA 17015
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-4373 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due STEPHEN J. KREBS, M.D. AND JANE R. KREBS, HIS
WIFE, Plaintiff (s)
From G. RONALD KRAJACK, D.M.D. AND CARETH E. KRAJACK, HIS WIFE, 42 SOUTH
PITT STREET, CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell 1. LAND LEASE
WITH THE COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF
COMMUNITY AND NATURAL RESOURCES (DCNR) WITH REGARD TO A CERTAIN
TRACT OF LAND KNOWN AND NUMBERED AS 40 BENDERSVILLE ROAD, COOKE
TOWNSHIP, CUMBERLAND COUNTY, LOCATED IN THE PINE GROVE FURNACE
STATE PARK, DCNR LEASE NUMBER 1-C-267 AND PARCEL ID NUMBER 0742-3299-
267.-001C267. 2. ANY AND ALL IMPROVEMENTS ON THAT CERTAIN TRACT OF
LAND KNOWN AND NUMBERED AS 40 BENDERSVILLE ROAD, COOKE TOWNSHIP,
CUMBERLAND COUNTY, LOCATED IN PINE GROVE FURNACE STATE PARK,
DCNR LEASE NUMBER 1-C-267 AND PARCEL ID NUMBER 0742-3299-267: OO1C267.
3. ANY AND ALL OTHER PROPERTY OR VEHICLES OWNED BY THE DEFTS
WHETHER OR NOT LOCATED AT THEIR RESIDENCE AT 42 SOUTH PITT STREET,
CARLISLE, PA 17013.
(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 $50,149.50
Interest
Atty's Comm %
Atty Paid $148.59
L.L. $.50
Due Prothy $4.00
Other Costs
Plaintiff Paid
Date: 10/30/08
(-?/' A b ?# - -&..do
s R. Lo onotary
or
?. (Seal)
REQUESTING PARTY:
Name SUSANN B. MORRISON, ESQ.
Address: SALZMANN HUGHES, P.C.
By:
354 ALEXANDER SPRING ROAD, SUITE 1
CARLISLE, PA 17015
Attorney for: PLAINTIFFS
Telephone: (717) 263-2121
Supreme Court ID No. 77041
Deputy
NOV n "D ?nnq 67
STEPHEN J. KREBS, M.D., AND JANE
R. KREBS, his wife,
plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
Defendants
IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-4373 Civil Term
CIVII. ACTION
ORDER
? 0
AND NOW, this 6'?' day of 008, upon consideration of the foregoing petition,
the Court does hereby ORDER that a hearing on the attached Petition is scheduled for
'KM4JWrt_ atP , 2008, at ?5 A " m in Courtroom No. , located in the Cumberland County
Courthouse in Carlisle, Pennsylvania. ?-]Q?J
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STEPHEN J. KREBS, M.D., AND
JANE R. KREBS, HIS WIFE,
Plaintiffs
V.
G. RONALD KRAJACK, D.M.D. AND
CARETH E. KRAJACK, HIS WIFE,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-4373 CIVIL TERM
CIVIL ACTION
MOTION FOR CONTINUANCE
I am a dentist working in locum tenens, meaning that I fill in for other dentists in
Central Pennsylvania when they need to be out of their office. I have been served with
an Order from the Honorable Edgar B. Bayley, P.J., scheduling a hearing for November
26, 2008. A copy of that Order is attached and marked Exhibit "A."
On November 26, 2008, 1 have committed to work in the Office of Dr. Wayne
Silverman in Hanover, PA from 8-5. During that time, I will attend to the patients of Dr.
Silverman, including the examination and treatment of scheduled patients, new
patients, and emergency patients.
This commitment was made long before I was made aware there would be a
hearing on November 26, 2008.
If I were not able to work as scheduled in the Office of Dr. Silverman, numerous
patients would have to be rescheduled as there is a full day already scheduled and
canceling would be a hardship for all concerned.
I do have dates already on my schedule for other dental offices in Central
Pennsylvania through December 15, 2008, as well as occasional dates thereafter.
I have called the attorney for Plaintiffs and left a message explaining these
circumstances and requested a concurrence for continuance of the hearing scheduled
for November 26, 2008; however, my message has not been returned and so I do not
know the Plaintiffs' position.
I am ready and willing to work with Plaintiffs' counsel, as well as your office, for
scheduling a date at a mutually convenient time after December 15, 2008.
WHEREFORE, I, G. Ronald Krajack, D.M.D., Defendant, request that the
hearing scheduled for November 26, 2008, be continued and the parties directed to
work together to find the next available date that is open on the Court's schedule.
Respectfully submitted,
al aia , [,.I4.D., Defendant
CERTIFICATE OF SERVICE
I, the undersigned, certify that a copy of the foregoing Motion for Continuance was
served this date by depositing same in the Post Office at Carlisle, PA, first class mail,
postage prepaid, addressed as follows:
Susann B. Morrison, Esquire
SALZMANN HUGHES
354 Alexander Spring Road, Suite 1
Carlisle, PA 17015
Date: -e f
J,
11
STEPHEN J. KREBS, M.D., AND JANE IN THE COURT OF COMMON PLEAS,
R. KREBS, his wife, CUMBERLAND COUNTY,
Plaintiffs PENNSYLVANIA
V.
NO. 08-4373 Civil Term
G. RONALD KRAJACK, D.M.D, AND .
CARETH E. KRAJACK, his wife, CIVIL ACTION
Defendants
ORDER
AND NOW, this ??-day of 2008, upon consideration of the foregoing petition,
the Court does hereby ORDER that a hearing on the attached Petition is scheduled for
£? , 2008, atS, ? in Courtroom No. -; ,,_, located in the Cumberland County
Courthouse in Carlisle, Pennsylvania.
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STEPHEN J. KREBS, M.D., AND, JANE R. ; IN THE COURT OF COMMON PLEAS OF
KREBS, HIS WIFE,
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs,
vs.
NO. 08-4373 CIVIL TERM
G. RONALD KRAJACK, D.M.D. AND, CARETH E. ; CIVIL ACTION
KRAJACK, HIS WIFE,
Defendants
MOTION FOR CONTINUANCE
NOW COMES the Defendants, G. Ronald Krajack, and Careth E. Krajack, his wife, pro se, and moves for
a continuance as follows:
1. The above captioned matter is scheduled for Hearing on November 26, 2008, at 8:45 am in
Courtroom No. 2, located in the Cumberland County Courthouse in Carlisle, Pennsylvania before
the Honorable Edgar B. Bayley.
2. The moving parties for said proceeding are the Plaintiffs, Stephen J. Krebs, M.D., and, Jane R.
Krebs, his wife.
3. The Plaintiffs are represented by Salzmann Hughes, PC.
4. The proceeding was scheduled by Order dated November 6, 2008. A copy of the said Order is
attached hereto and marked as "Exhibit A."
5. The proceeding has not been previously continued.
6. A continuance is requested because the Defendant is a dentist in locum tenes, meaning that he
fills in for other dentists working in the Central Pennsylvania area when they need to be out of the
office. At the current time, the defendant has made scheduling commitments to these dentists
that he is contractually obligated to fulfill until January 15, 2009.
-1-
7. The Plaintiffs, through their attorneys, Salzmann Hughes, PC, have been notified of this request
by phone, but have not responded.
8. 1 hereby certify that if a continuance is granted I will serve a copy of the order granting the
continuance on all parties forthwith and that I will notify all witnesses who would be appearing at
my request.
9. 1 specifically request a continuance of not less than thirty (30) days or to the next available date.
Defendant
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Careth E. Krajack,
NOV. ?jU8(
STEPHEN J. KREBS, M.D., AND JANE IN THE COURT OF COMMON PLEAS,
R. KREBS, his wife, CUMBERLAND COUNTY,
Plaintiffs PENNSYLVANIA
V.
NO. 084373 Civil Term
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife, CIVIL ACTION
Defendants
ORDER
AND NOW, this &Y%r ay of &.&.Ln,,2008, upon consideration of the foregoing petition,
the Court does hereby ORDER that a hearing on the attached Petition is scheduled for
A aga"gg2L_, 2008, ate;ySA , in Courtroom No. Q, , located in the Cumberland County
Courthouse in Carlisle, Pennsylvania
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STEPHEN J. KREBS, M.D., AND, JANE R.
KREBS, HIS WIFE,
Plaintiffs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 08-4373 CIVIL TERM
G. RONALD KRAJACK, D.M.D. AND, CARETH E. ; CIVIL ACTION
KRAJACK, HIS WIFE,
Defendants
ORDER
AND NOW, this day of llad'yn= 20 d $ , upon
consideration of the attached motion of G. Ronald Krajack, and Careth E. Krajack, his wife
requesting a continuance:
The motion is granted and the matter scheduled for hearing on November 26,
2008, at 8:45 am in Courtroom No. 2, located in the Cumberland County Courthouse in Carlisle,
Pennsylvania before the Honorable Edgar B. Bayley is hereby continued until /b( ??(Vk
at 10, C.m. The moving party shall promptly notify all interested parties of this Order
and shall serve a copy of this Order upon them.
E COURT:
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STEPHEN J. KREBS, M.D., AND, JANE R.
KREBS, HIS WIFE,
Plaintiffs,
vs.
G. RONALD KRAJACK, D.M.D. AND, CARETH E.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-4373 CIVIL TERM
CIVIL ACTION
KRAJACK, HIS WIFE,
Defendants
MOTION FOR CONTINUANCE
NOW COMES the Defendants, G. Ronald Krajack, and Careth E. Krajack, his wife, pro se, and moves for
a continuance as follows:
1. The above captioned matter is scheduled for Hearing on December 10, 2008, at 10:30 am in
Courtroom No. 2, located in the Cumberland County Courthouse in Carlisle, Pennsylvania before
the Honorable Edgar B. Bayley.
2. The moving parties for said proceeding are the Plaintiffs, Stephen J. Krebs, M.D., and, Jane R.
Krebs, his wife.
3. The Plaintiffs are represented by Salzmann Hughes, PC.
4. The proceeding was scheduled by Order dated November 24, 2008. A copy of the said Order is
attached hereto and marked as "Exhibit A."
5. The proceeding has been previously continued.
6. A continuance is requested because the Defendant is a dentist in locum tenes, meaning that he
fills in for other dentists working in the Central Pennsylvania area when they need to be out of the
office. At the current time, the defendant has made scheduling commitments to these dentists
-1-
that he is contractually obligated to fulfill until January 15, 2009. One of these commitments
requires the Defendant to be out of town on December 10th
7. The Plaintiffs, through their attorneys, Salzmann Hughes, PC, have been notified of this request
by phone, but have not responded.
8. 1 hereby certify that if a continuance is granted I will serve a copy of the order granting the
continuance on all parties forthwith and that I will notify all witnesses who would be appearing at
my request.
9. 1 specifically request a continuance of not less than thirty (30) days or to the next available date.
Careth E. Krajack,
Defendant
-2-
ljov 21 2008 k
STEPHEN J. KREBS, M.D., AND, JANE R.
KREBS, HIS WIFE,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs,
VS.
G. RONALD KRAJACK, D.M.D. AND, CARETH E
NO. 08-4373 CIVIL TERM
CIVIL ACTION
KRAJACK, HIS WIFE,
Defendants
ORDER
AND NOW, this 2 y day of , 200 1 , upon
consideration of the attached motion of G. Ronald Krajack, and Careth E. Krajack, his wife
requesting a continuance:
The motion is granted and the matter scheduled for hearing on November 26,
2008, at 8:45 am in Courtroom No. 2, located in the Cumberland County Courthouse in Carlisle,
Pennsylvania before the Honorable Edgar B. Bayley is hereby continued until k4'4,,j JO r?Oct
at /v ; 34 ct-m. The moving party shall promptly notify all interested parties of this Order
and shall serve a copy of this Order upon them.
BY THE COURT:
?T
ME COPY FROM RECORU
Testimony whereof. i Dare canto set my hang
a the sell of said Court at Carlisle. FL
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
AMENDED PRAECIPE FOR WRIT OF EXECUTION
STEPHEN J. KREBS, M.D., AND JANE R.
KREBS, his wife,
Plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
Defendants
_ Confessed Judgment
X Other
File No. 084373
Amount Due $50,149.50
Interest from 10/1/08 at $270/month
Atty's Comm $5,900 as of 12/1/08
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 matter to the Sheriff of Cumberland County, for debt,
interest and costs, upon the following described property of the defendant(s):
1. Land Lease with the Commonwealth of Pennsylvania, Department of Community and Natural
Resources (DCNR) with regard to a certain tract of land known and numbered as 40 Bendersville Road,
Cooke Township, Cumberland County, located in Pine Grove Furnace State Park, DCNR Lease Number
1-C-267 and Parcel ID Number 07-42-3299-267.-001 C267.
2. Any and all improvements on that certain tract of land known and numbered as 40
Bendersville Road, Cooke Township, Cumberland County, located in Pine Grove Furnace State Park,
DCNR Lease Number 1-C-267 and Parcel ID Number 07-42-3299-267.=OO I C267.
3. Any and all other property or vehicles owned by the Defendants whether or not located at
their residence at 42 South Pitt Street, Carlisle, PA 17013.
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as
above, directing 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).
Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s)-described in the attached exhibit.
Date c? Z AVLL ,
tZ Q
Susann B. Monjison, E s4., Attorney for Plaintiffs
SALZMANN IIJ[JGHES, P.C.
Supreme Court ID 77041
354 Alexander Spring Road, Suite 1
Carlisle, PA 17015
(717) 749-6131
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AMENDED WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 084373 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due STEPHEN J. KREBS, M.D. AND JANE R. IMBS, HIS
WIFE, Plaintiff (s)
From G. RONALD KRAJACK, D.M.D. AND CARETH E. KRAJACK, HIS WIFE, 42 SOUTH
PITT STREET, CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell 1. LAND LEASE
WITH THE COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF
COMMUNITY AND NATURAL RESOURCES (DCNR) WITH REGARD TO A CERTAIN
TRACT OF LAND KNOWN AND NUMBERED AS 40 BENDERSVILLE ROAD, COOKE
TOWNSHIP, CUMBERLAND COUNTY, LOCATED IN THE PINE GROVE FURNACE
STATE PARK, DCNR LEASE NUMBER 1-C-267 AND PARCEL ID NUMBER 0742-3299-
267.-001C267. 2. ANY AND ALL IMPROVEMENTS ON THAT CERTAIN TRACT OF
LAND KNOWN AND NUMBERED AS 40 BENDERSVILLE ROAD, COOKE TOWNSHIP,
CUMBERLAND COUNTY, LOCATED IN PINE GROVE FURNACE STATE PARK,
DCNR LEASE NUMBER 1-C-267 AND PARCEL ID NUMBER 0742-3299-267: OO1C267.
3. ANY AND ALL OTHER PROPERTY OR VEHICLES OWNED BY THE DEFTS
WHETHER OR NOT LOCATED AT THEIR RESIDENCE AT 42 SOUTH PITT STREET,
CARLISLE, PA 17013.
(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 $50,149.50
Interest from 10/1/08 at $270/month
Atty'sComm % $5,900 as of 12/1/08
Atty Paid $148.59
Plaintiff Paid
L.L. $.50
Due Prothy $4.00
Other Costs
Date: 10/30/08
e?artis R. Lo onotary
or
(Seal)
By:
Deputy
REQUESTING PARTY:
Name SUSANN B. MORRISON, ESQ.
Address: SALZMANN HUGHES, P.C.
354 ALEXANDER SPRING ROAD, SUITE 1
CARLISLE, PA 17015
Attorney for: PLAINTIFFS
Telephone: (717) 263-2121
Supreme Court ID No. 77041
F C 0 ? 2000
STEPHEN J. KREBS, M.D., AND, JANE R.
KREBS, HIS WIFE,
Plaintiffs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 084373 CIVIL TERM
G. RONALD KRAJACK, D.M.D. AND, CARETH E. ; CIVIL ACTION
KRAJACK, HIS WIFE,
Defendants
ORDER
AND NOW, this da f oooo- , 20 , upon
consideration of the attached mo ' of G. Ronald Kr ' ck, and Careth E. Kra' is wife
requesting a continuance:
The otion is grante nd the matter sch ed for hearing on D er 10,
2008, at 10:3 am in Courtro No. 2, located ' e Cumberland C Courthouse in Car'
Pennsyl nia before t Honorable E r B. Bayley is here continued until
at _ m. The ing party shall pro by notify all in sted parties of this Order
and shall s rve a copy is Order upon th
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STEPHEN J. KREBS, M.D., AND JANE IN THE COURT OF COMMON PLEAS,
R. KREBS, his wife, CUMBERLAND COUNTY,
Plaintiffs PENNSYLVANIA
V.
NO. 084373 Civil Term
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife, CIVIL ACTION
Defendants
ORDER
AND NOW, this _ day of December, 2008, upon consideration of the foregoing petition, the
Court does hereby ORDER the following:
1. The hearing on Plaintiffs' Petition in Aid of Execution scheduled for December 10, 2008
is canceled.
2. That Plaintiffs Writ of Execution is stayed for thirty (30) days pending Defendants
attempts to obtain financing to satisfy the debt owed to Plaintiffs.
3. Defendants are enjoined from assigning, transferring or selling their interest in the cabin
and Land Lease with the Commonwealth of Pennsylvania, Department of Community and Natural
Resources (DCNR) located in Pine Grove Furnace State Park, DCNR Lease Number 1-C-267 and Parcel
ID Number 07-42-3299-267.-001 C267 until the debt owed to Plaintiffs is satisfied.
4. If the cabin and Land Lease are sold at a Sheriff's sale pursuant to Plaintiffs' Writ of
Execution, Defendants are required to assign the Land Lease to the purchaser and fulfill all of the
requirements of the Commonwealth of Pennsylvania
(DCNR) to effectuate such assignment.
urces
C P-13
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STEPHEN J. KREBS, M.D., AND JANE
R. KREBS, his wife,
Plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
Defendants
IN THE COURT OF COMMON PLEAS,
. CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 08-4373 Civil Term
. CIVIL ACTION
STIPULATION
Plaintiffs, Stephen J. Krebs, M.D. and Jane R. Krebs, his wife, by and through their attorneys,
Salzmann Hughes, PC, and Defendants G. Ronald Krajack, D.M.D., and Careth E. Krajack, his wife, by
and through their attorneys, Saidis Flower & Lindsay, respectfully represent the following in support of
this Stipulation:
WHEREAS, in November 2001, Plaintiffs sold a cabin in Pine Grove Furnace State Park to
Defendants via agreement of sale secured by a Judgment Note in the amount of $60,000 which was
recorded on December 14, 2001; and
WHEREAS, in April 2007 the Agreement was amended to give Defendants 18 more months to
satisfy the debt, which to this date has not been satisfied; and
WHEREAS, the Judgment was revived on September 23, 2008 in Civil Action No. 08-4373 with
a judgment against Defendants in the amount of the remaining balance on the debt of $50,149.50; and
WHEREAS, Plaintiffs filed a Writ of Execution against Defendants on October 30, 2008 and an
Amended Writ of Execution was filed on December 2, 2008; and
WHEREAS, Plaintiffs filed a Petition in Aid of Execution to requesting the Court to prohibit
Defendants from assigning, transferring or selling their interest in the cabin and land lease in Pine Grove
Furnace and to order the Defendants to complete the necessary paperwork with the Department of
Conservation and Natural Resources to assign the land lease in Pine Grove Furnace to the purchaser at a
Sheriff's Sale; and
WHEREAS, a hearing on the Petition in Aid of Execution was scheduled before the Honorable
Judge Bayley on December 10, 2008; and
WHEREAS, Defendants have represented that they are in the process of obtaining financing to
satisfy the debt owed to Plaintiffs; and
WHEREAS, the parties have come to an agreement to stay the execution of the judgment
pending Defendants efforts to obtain financing provided Defendants agree to the matters requested in
Plaintiffs Petition in Aid of Execution.
NOW THEREFORE, in consideration of the mutual promises and covenants contained herein,
the parties to this action by and through their respective counsel hereby agree to the following:
Plaintiffs will stay execution of the judgment against Defendants for thirty (30) days to
allow Defendants time to obtain financing to satisfy the debt owed to Plaintiffs.
2. Defendants agree not to assign, transfer or sell their interest in the cabin/land lease with
Department of Conservation and Natural Resources located in Pine Grove Furnace State Park, DCNR
Lease # 1-C-267 and Parcel ID # 07-42-3299-267.-001 C267 until the debt is satisfied.
3. Defendants agree that, if the cabin and land lease are sold at a Sheriff s sale pursuant to
Plaintiffs' Writ of Execution, Defendants shall assign the land lease to the purchaser and fulfill all of the
requirements of the Commonwealth of Pennsylvania, Department of Community and Natural Resources
(DCNR) to effectuate such assignment.
SAIDAS FLOWER & LINDSAY
J mes D. Flower, Jr., Esq.
Attorney for Defendants
SALZMANN HUGHES, P.C.
A eOZ,
Susann B. orriso , Esq.
Attorney for Plaintiffs
Date 1 - 9 -- 0 %?(
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff's Costs: Advance Costs: 150.00
Sheriff's Costs: 95.17
Docketing 18.00 54.83
Poundage 1.87
Advertising
Law Library .50
Prothonotary 4.00 Refunded to Atty on 12/16/08
Mileage 10.80
Surcharge 40.00
Levy 20.00
Certified Mail
Post Pone Sale
Garnishee
Postage jj
TOTAL $ 95.17 Jd),' Dg So Answers;
Y
rThomas Kline, Sheriff
N,j2j? 4UI-Jod-L1
By Claudia A. Brewbaker
8E =E d h - 030 0001
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1 331?3HS 1111
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(Seal)
By:
Deputy
REQUESTING PARTY:
Name SUSANN B. MORRISON, ESQ.
Address: SALZMANN HUGHES, P.C.
354 ALEXANDER SPRING ROAD, SUITE 1
CARLISLE, PA 17015
Attorney for: PLAINTIFFS
Telephone: (717) 263-2121
Supreme Court ID No. 77041
pmiENDED WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 08-4373 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due STEPHEN J. KREBS, M.D. AND JANE R. KREBS, HIS
WIFE, Plaintiff (s)
From G. RONALD KRAJACK, D.M.D. AND CARETH E. KRAJACK, HIS WIFE, 42 SOUTH
PITT STREET, CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell 1. LAND LEASE
WITH THE COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF
COMMUNITY AND NATURAL RESOURCES (DCNR) WITH REGARD TO A CERTAIN
TRACT OF LAND KNOWN AND NUMBERED AS 40 BENDERSVILLE ROAD, COOKE
TOWNSHIP, CUMBERLAND COUNTY, LOCATED IN THE PINE GROVE FURNACE
STATE PARK, DCNR LEASE NUMBER 1-C-267 AND PARCEL ID NUMBER 07-42-3299-
267: OO1C267. 2. ANY AND ALL IMPROVEMENTS ON THAT CERTAIN TRACT OF
LAND KNOWN AND NUMBERED AS 40 BENDERSVILLE ROAD, COOKE TOWNSHIP,
CUMBERLAND COUNTY, LOCATED IN PINE GROVE FURNACE STATE PARK,
DCNR LEASE NUMBER 1-C-267 AND PARCEL ID NUMBER 07-42-3299-267: OO1C267.
3. ANY AND ALL OTHER PROPERTY OR VEHICLES OWNED BY THE DEFTS
WHETHER OR NOT LOCATED AT THEIR RESIDENCE AT 42 SOUTH PITT STREET,
CARLISLE, PA 17013.
(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 $50,149.50 L.L. $30
Interest from 10/1/08 at $270/month
Atty's Comm % $5,900 as of 12/1/08 Due Prothy $4.00
Atty Paid $148.59 Other Costs
Plaintiff Paid
Date: 10/30/08
C is R. L r onota
STEPHEN J. KREBS, M.D., AND JANE
R. KREBS, his wife,
Plaintiffs
V.
G. RONALD KRAJACK, D.M.D, AND
CARETH E. KRAJACK, his wife,
Defendants
. IN THE COURT OF COMMON PLEAS,
. CUMBERLAND COUNTY,
. PENNSYLVANIA
. NO. 084373 Civil Term
. CIVIL ACTION
PRAECIPE TO SETTLE AND DISCONTINUE ACTION
AND NOW, this 12a` day of August 2010, Plaintiffs Stephen J. Krebs, M.D., and Jane R.
Krebs, his wife, hereby request the Prothonotary of Cumberland County to settle and discontinue the
above-captioned matter against all defendants and mark the judgment satisfied.
SALZMANN HUGHES, P.C.
Susann B/Morribon, Esq.
Supreme Court ID 77041
354 Alexander Spring Road, Suite 1
Carlisle, PA 17015
(717) 249-6333
Attorney for Plaintiffs
Date 12, 20/0