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Home My WebLink About09-7621 Jeffrey A. Ernico, Esquire METTE, EVANS & WOODSIDE 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Facsimile jaernico@mette.com KATHERINE H. STEWART, P.T., Plaintiff V. KATHIE GRUCZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0q - rRA21 Ci"Irre -m PRAECIPE FOR ENTRY OF JUDGMENT FROM MAGISTERIAL DISTRICT COURT TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff, Katherine H. Stewart, P.T., and against the Defendant Kathie Grucz pursuant to Rule 402(D) of the Pennsylvania Rules of Civil Procedure for Magisterial District Judges. A true and correct copy of the record of the proceedings containing the judgment is attached. 520878v1 i Respectfully submitted, METTE, EVANS & WOODSIDE By: J y A. Ernico, Esquire up. Ct. I.D. No. 07981 3401 North Front Street P. O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Fax Attorneys for Plaintiff Date: October 29, 2009 Jeffrey A. Ernico, Esquire METTE, EVANS & WOODSIDE 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Facsimile jaemico@mette.com KATHERINE H. STEWART, P.T., Plaintiff V. KATHIE GRUCZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Oq - 0'1V-'1 Terw CERTIFICATE OF RESIDENCE I hereby certify that the name and address of the proper person(s) to receive this notice is: Kathie Grucz 425 Independence Court Mechanicsburg, PA 17050 Respectfully submitted, METTE, EVANS & WOODSIDE By: ey A. Ernico, Esquire Sup. Ct. I.D. No. 07981 Date: October 29, 2009 Attorneys for Plaintiff Jeffrey A. Ernico, Esquire METTE, EVANS & WOODSIDE 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Facsimile jaernico@mette.com KATHERINE H. STEWART, P.T., Plaintiff V. KATHIE GRUCZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. AFFIDAVIT OF NON-MILITARY SERVICE The undersigned, being duly sworn according to law, deposes and says that to the best of my knowledge, information and belief, the Defendant is not in the military or Naval service of the United States or its allies, or otherwise within the provisions of the Service Members Civil Relief Act f/k/a the Soldiers and Sailors Relief Act of 1940, 50 U.S.C. App. §501, et. seq. Respectfully submitted, METTE, EVANS & WOODSIDE By: , Esquire o4.r?i co Sup. Ct. I.D. No. 07981 Date: October 29, 2009 Attorneys for Plaintiff 2009 NOV -t} PH 12:48 a?.a5 PD Amf CK,-r? 88555 a33ooo Nohee tilaA.laQ Jeffrey A. Ernico, Esquire METTE, EVANS & WOODSIDE 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Facsimile jaernico@mette.com KATHERINE H. STEWART, P.T., Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIS - l.?ty i l TAN KATHIE GRUCZ, Defendant NOTICE OF ENTRY OF JUDGMENT TO: Kathie Grucz 425 Independence Court Mechanicsburg, PA 17050 You are hereby notified that on, Nov q?` , 2009, the following judgment was entered against you in the above-captioned case in the amount of $2,772.50 A copy of the judgment is attached. e 4,4., D.. 11 Date k6thonotary FlLE~-0t-~I'~E c~F ?NE PPO~!-!0~401'ARY 201Q ~9~R -3 P~1 { ~ 25 ~i~P'~NSYI,.VnI'~~R Jeffrey A. Ernico, Esquire METTE, EVANS & WOODSIDE 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 -Phone (717) 236-1816 -Facsimile jaernico@mette.com KATHERINE H. STEWART, P.T., Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7621 KATHIE GRUCZ, CIVIL ACTION -LAW 425 Independence Ct. Mechanicsburg, PA 17050 Defendant INTERROGATORIES TO GARNISHEE, METRO BAND To: Metro Bank 64 Ashland Avenue Carlisle, PA 17013 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 judgment against you: 1 524155v1 At the time you were served or at any subsequent time did you owe the Defendant(s) any money or were you liable to the Defendant(s) on any negotiable or other written instrument, or did the Defendant(s) claim that you owed the Defendant(s) any money or were liable to the Defendant(s) for any reason? ANSWER: Defendant has account 538078742 held individually wih a balance of $.37 Account is direct deposit (ssi). Defendant did not receive $300 exemption. 2. At the time you were served or 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 owned solely or in part by the Defendant(s)? ANSWER: ~ answex to question 1 2 At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant(s) or in which the Defendant(s) had or claimed any interest? ANSWER: ~ ar~wer to question 1 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which Defendant(s) had an interest? ANSWER: ~ 3 At any time before or after you were served did the Defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? ANSWER: no 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant(s) or to any person or place pursuant to the Defendant(s)'s direction or otherwise discharge any claim of the Defendant(s) against you? ANSWER: no 4 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. ANSWER: See answer to question 1 If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa. C.S. § 8123? If so, identify each account. ANSWER: See answer to question 1] Respectfully submitted, METTE, EVANS & WOODSIDE By: _ ey A Ernico Esquire Sup. Ct. I.D. No. 07981 3401 North Front Street P. O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 Attorneys for Plaintiff Date: ~ ~ aO/U 6 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Lem Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ' ~. 1 ~ ~' (IGN TURF r1~ T~-;~ ~ ,.~ ~ ,~,l~~'T;PZ~Y 2010.l1~! -8 Pt1 ~~ Jeffrey A. Ernico, Esquire Sup. Ct. I.D. # 07981 METTE, EVANS & WOODSIDE 3401 N. Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 -Telephone (717) 236-1816 -Facsimile jaernico@mette.com Attorneys for Plaintiff KATHERINE H. STEWART, P.T., Plaintiff v. KATHIE GRUCZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.09-7621 CIVIL ACTION -LAW PRAECIPE TO DISSOLVE ATTACHMENT AGAINST GARNISHEE, METRO BANK (FORMERLY COMMERCE BANK) TO THE PROTHONOTARY: Please dissolve the Writ of Execution in the above-captioned matter against Garnishee, Metro Bank (formerly Commerce Bank) as said garnishee has satisfied its obligations as a garnishee. Respectfully submitted, METTE, EVANS & WOODSIDE By: ~. Jef .Ernico, Esquire . Ct. I.D. # 07981 3401 N. Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 ~~~~ ~~ ~~~ Attorneys for Plaintiff Date: June 3, 2010 CIS q~'(,/~~ 527579v1 b,~//~} a(,~3 37~ ~N7Yir0