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Home My WebLink About08-5400y4,, . a .9. s y a-u IN THE COURT OF COMMON PLEAS, WESTMORELAND COUNTY, PENNA. CIVIL ACTION - LAW / Cas?No. 1863 of 2708/ Hanson Aggregates Pennsylvania, Inc. WRIT OF EXECUTION Plaintiff(s) (Money Judgment) Vs. W & P Excavating, Inc., and William S. Reynolds Defendant(s) COMMONWEALTH OF PENNSYLVANIA } COUNTY OF WESTMORELAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against Defendant(s); W & P Excavating, Inc., and William S. Reynolds (1) you are directed to levy upon the property of the defendant(s) and to sell his interest therein; (2) you are also directed to attach the property of the defendant(s) not levied upon in the possession of Susquehanna Bank PA as Garnishee(s). (Specifically described property) 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 and subject to attachment is found in the possession of anyone other than a named garnishee(s), you are directed to notify him that he has been added as a garnishee(s) and is/are enjoined as above stated. Amount due $ 11,035.86 Interest from 8/1/08 through date of satisfaction $ - - - (Cost to be added): $ 239.66 Date: August 11, 2008 1863 of 2008 Aug t 22, 2 8 Writ Reissuedwith changes. Ro il, ro onotary Plaintiff P 0 Box 360724-M Case No. X 1863 of 2008 Pittsburgh, PA 15251 Defendants W & P Excavating, Inc. COMMON PLEAS William S. Reynolds 170 Cambridge Road Coatesville, PA 19320 Hanson Aggregates Pennsylvania, Inc. Garnishee 271 Market Street Plaintiff(s) Lemoyne, PA 17043 Counsel for Plaintiff Vs. 1004 Ligonier Street P 0 Box 758 W & P Excavating, Inc., and William S. Reynolds Latrobe, PA 15650 Defendant(s) telephone: (724) 539-3511 Vs. Susquehanna Bank PA Garnishee WRIT OF EXECUTION (MONEY JUDGMENT) TO THE SHERIFF OF CUMBERLAND COUNTY Amount due $ 11,035.86 Interest from 8/1/08 through date of satisfaction $ - - - Attorney Com $ Attorney $ 239.66 Rv ry C Plaintiff $ Defendant $ r ? Prothonotary $ lR NO< t'- C. - Other $ Sheriff $ ? tr ? rv d " Deputy Surcharge $ McDonald, Snyder & Lightcap, P.C. Daniel C. Hudock, Esquire Attorney for Plaintiff DATE JUDGMENT ENTERED: August 11, 2008 N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW HANSON AGGREGATES PENNSYLVANIA, INC Plaintiff, VS. No. 0 8. 5_4 &0 C" `r?- W & P EXCAVATING, INC., and WILLIAM S. REYNOLDS, Defendants. NOTICE OF INTERROGATORIES To: Susquehanna Bank 271 Market Street Lemoyne, PA 17043 (717) 763-4577 You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so may result in default judgment being entered against you. 1. (a) At the time you were served or at any subsequent time, did you owe Defendants W & P Excavating, Inc., and William S. Reynolds ("Defendant") any money or were you liable to Defendant on any negotiable or other written instrument, or did Defendant claim that you owed it any money or were liable to Defendant for any reason? Attached as Exhibit "A" is a true and correct copy of a check received by Plaintiff drawn on a Susquehanna Bank account. ANSWER: Yes. (b) If the answer to the foregoing is in the affirmative, state the amount and details. ANSWER: William S. Reynolds has one individual checking account number xxxxxx5292 with no available balance after the general monetary exemption. W & P Excavating, Inc. has two checking account numbers xxxxxx4792 and xxxxxx2400 with a combined available balance of $4,769.70. 2 2. (a) 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 one or more other persons any property of any nature owed solely or in part by Defendant? ANSWER: No. (b) If the answer to the foregoing is in the affirmative, state the amount and details. ANSWER: N / A 3. (a) At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owed solely or in part by Defendant or in which Defendant held or claimed any interest? ANSWER: N o. (b) If the answer to the foregoing is in the affirmative, state the amount and details. ANSWER: N /A 4 4. (a) At the time you were served or at any subsequent time, did you hold as fiduciary any property in which Defendant had an interest? ANSWER: No. details. (b) If the answer to the foregoing is in the affirmative, state the amount and ANSWER: N/A 5. (a) At any time before or after you were served, did Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so, what was the consideration therefor? ANSWER: No . (b) If the answer to the foregoing is in the affirmative, state the amount and details. ANSWER: N / A 6 6. (a) At any time after you were served, did you pay, transfer, or deliver any property to Defendant or to any person or place pursuant to its direction or otherwise discharge any claim of Defendant against you? ANSWER: No. (b) If the answer to the foregoing is in the affirmative, state the amount and details. ANSWER: N / A 7 7. (a) At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? ANSWER: Yes. (b) If the answer to the foregoing is in the affirmative, state the amount and details. ANSWER: Defendant, W & P Excavating, Inc has two loans with Susquehanna. Loan account number xxxxxx0635 which is unsecured and loan account number xxxxxx6653 which is collateralized by account receivable, equipment and inventory. GARNISHEE: Susquehanna Bank Dated: 9/24/08. 0.,- L Name:Catherine M. Bush Title: Vice President & Associate Counsel McDONALD, SNYDER GHTCAP, P.C. Dated: September 5, 2008 iel C. Hudock, Esqui e Pa. I.D. #81146 1004 Ligonier Street P.O. Box 758 Latrobe, Pennsylvania 15650 (724) 539-3511 Attorneys for Plaintiff 8 VERIFICATION I, Catherine M. Bush, verify that the facts set forth in these Answers to Interrogatories are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. § 4904) related to unsworn falsification to authorities. Dated: September 24, 2008 Catherine M. Bush Secretary and Legal Counsel Susquehanna Bank PA 26 North Cedar Street Lititz, Pa 17543 (717) 625-6273 CZ 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: 300.00 Sheriff's Costs: 143.25 Docketing 18.00 156.75 Poundage 2.81 Law Library Refunded on 06/04/09 Prothonotary 38.00 Mileage 15.00 Surcharge 40.00 Levy 20.00 Postage .44 Garnishee 9.00 So Answers, 143.25 4?o?f o 9 I? R. hom Kline, Sheriff B Sharon R. Lantz Cn O '° V. IN THE COURT OF COMMON PLEAS, WESTMORELAND COUNTY, PENNA. Hanson Aggregates Pennsylvania, Inc. WRIT OF EXECUTION Plaintiff(s) (Money Judgment) Vs. CIVIL, ACTION - LAW )-00840? Case No. X1863 of 200 W & P Excavating, Inc., and William S. Reynolds Defendant(s) COMMONWEALTH OF PENNSYLVANIA } COUNTY OF WESTMORELAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against Defendant(s); W & P Excavating, Inc., and William S. Reynolds (1) you are directed to levy upon the property of the defendant(s) and to sell his interest therein; (2) you are also directed to attach the property-of the defendant(s) not levied upon in the possession of Susquehanna Bank PA as Garnishee(s). (Specifically described property) 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 and subject to attachment is found in the possession of anyone other than a named garnishee(s), you are directed to notify him that he has been added as a garnishee(s) and is/are enjoined as above stated. Amount due $11,035.86 Interest from 8/1/08 through date of satisfaction $ - - - (Cost to be added): $ 239.66 Date: August 11, 2008 TRUE COPY FROM RECORD Testimony wtuw, i two unto set my harm i the '10 of said court at c?urifsfe?, AL (_ t lonow J.OVJ Vl LVVO Aug t 22, 2 8 Writ Reissuedwith changes. Ro ehl, ro onotary Plaintiff P 0 Box 360724-M Case No. X 1863 of 2008 Pittsburgh,,PA 15251 Defendants W & P Excavating, Inc. COMMON PLEAS William S. Reynolds 170 Cambridge Road Coatesville, PA 19320 Hanson Aggregates Pennsylvania, Inc. Garnishee 271 Market Street Plaintiff(s) Lemoyne, PA 17043 Counsel for Plaintiff Vs. 1004 Ligonier Street P 0 Box 758 W & P Excavating, Inc., and William S. Reynolds Latrobe, PA 15650 Defendant(s) telephone: (724) 539-3511 Vs. Susquehanna Bank PA Garnishee WRIT OF EXECUTION (MONEY JUDGMENT) TO THE SHERIFF OF CUMBERLAND COUNTY Amount due $11,035.86 Interest from 8/1/08 through date of satisfaction $ - - - Attorney Com $ Attorney $ 239.66 Plaintiff $ Defendant $ Prothonotary $ Other $ Sheriff $ Deputy Surcharge $ McDonald, Snyder & Lightcap, P.C. Daniel C. Hudock, Esquire Attorney for Plaintiff 7 C: * r 1 +? DATE JUDGMENT ENTERED: August 11, 2008