HomeMy WebLinkAbout10-0328fio, 16 - 3 )- Fr c i4 l e fM
PHILADELPHIA MUNICIPAL COURT
FIRST JUDICIAL DISTRICT OF PENNSYLVANIA
ARM 34 South 11th Street, Philadelphia, PA. 19107
Marsha H. Neifield, President Judge Patricia R. McDermott, Deputy Court Administrator
#LT-08-11-12-4759
SHAWN GEE ROBERT ALEXANDER AND ALL OCCS
1818 BREYER COURT 130 EAST WALNUT PARK DRIVE, GARAGE
ELKINS PARK, PA 19027 PHILADELPHIA, PA 19120
RITE AID PHARMACY, 30 HUNTER LANE, CAMP
HILL, PA 17011
GLENN M Ross 566 SOUTH BETHLEHEM PIKE
Address & FORT WASHINGTON, PA 19034 n N 0 t_,
Petitioner/Attorney Phone 215 643-7200 o -n
Attorney # 044537 ? C__ Z
-r r7l
WRIT OF EXECUTION NOTICE rr,
r-j-', N
This paper is a Writ of Execution. It has been issued because there is a judgment against?GLU. It i
may cause your property to be held or taken to pay the judgment. You may have legal ri`to tv r n
prevent your property from being taken. A lawyer can advise you more specifically of the!?
rights. If you wish you exercise your rights, you must act promptly. .
The law provides that certain property cannot be taken. Such property is said to be exempt.
There is a debtor's exemption of $300. There are the following other exemptions which may be
applicable to you: (1) bibles, school books, sewing machines, uniforms and equipment; (2) most
wages and unemployment compensation; (3) social security benefits; (4) certain retirement funds
and accounts; (5) certain veteran and armed forces benefits; and (5) certain insurance proceeds.
You may have other exemptions or other rights.
If you have an exemption, you should do the following promptly: (1) fill out the attached claim
for exemption form and demand for a prompt hearing and (2) deliver the form or mail it to the
Sheriff's Office at the address noted.
You should come to court ready to explain your exemption. If you do not come to court and
prove your exemption, you may lose some of your property.
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 ELEIGIBLE PERSONS AT A REDUCE FEE OR NO
FEE.
Lawyer Referral and Information Service
1101 Market Street, 11'h Floor
Philadelphia, PA 19107-2911
(215) 238-6333
s 3? DU /?
PHILADELPHIA MUNICIPAL COURT
FIRST JUDICIAL DISTRICT OF PENNSYLVANIA
34 South 11th Street, Philadelphia, PA. 19107
Marsha H. Neifield, President Judge Patricia R. McDermott, Deputy Court Administrator
## LT-08-11-12-4759
SHAWN GEE ROBERT ALEXANDER AND ALL OCCS
1818 BREYER COURT 130 EAST WALNUT PARK DRIVE, GARAGE 2
ELKINS PARK, PA 19027 PHILADELPHIA, PA 19120
RITE AID PHARMACY, 30 HUNTER LANE, CAMP HILL, PA
17011
WRIT OF EXECUTION
(Money Judgment)
TO: THE SHERIFF OF CUMBERLAND , COUNTY:
To satisfy the judgment, interest and costs against the above-captioned defendant(s):
ROBERT ALEXANDER
1. You are directed to levy upon property of the defendant(s) and to sell defendant's (s') interest therein:
2. You are also directed to attach the property of the defendants not levied u n in the RITE AID PHARMACY, 30 HUNTER LANE,
po possession of ( more >
(Name of Garnishee)
GARNISH THE WAGES OF DEFENDANT ROBERT ALEXANDER.
as garnishee, and to notify the garnishee of the following:
(specifically describe property)
(a) an attachment has been issued;
(b) except as provided in paragraph (c) the garnishee is enjoined from paying any debt to or for the account of the defendant
and from delivering any property of the defendant or otherwise disposing thereof,,
(c) the attachment shall not include any funds in an account of the defendant with a bank or other financial institution
(i) in which funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are
exempt froth execution, levy or attachment under Pennsylvania or federal law, or
(ii) that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and
attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant's general
exemption provided in 42 Pa. C.S. § 8123.
3. If property of the defendant not levied upon and subject to attachment is found in the possession of anyone other than a .named
garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated.
REAL DEBT $ 790.00
CREDIT $
INTEREST from 12/10/2008 $ 75.00
COSTS PAID:
Prothonotary $ 55.00
Sheriff $ 284.00
Joseph Eve ; Prothonotary
A elphia Munic Court
N?V 4 1001 By.
Date: 1'?
tAb PHILADELPHIA MUNICIPAL COURT
FIRST JUDICIAL DISTRICT OF PENNSYLVANIA
34 South 11 th Street, Philadelphia, PA. 19107
Marsha H. Neifield, President Judge Patricia R. McDermott, Deputy Court Administrator
# LT-08-11-12-4759
SHAWN GEE ROBERT ALEXANDER AND ALL OCCS
1818 BREYER COURT 130 EAST WALNUT PARK DRIVE, GARAGE
ELKINS PARK, PA 19027 PHILADELPHIA, PA 19120
File no.
WRIT OF EXECUTION
THE PHILADELPHIA MUNICIPAL COURT
CLAIM NO. LT-08-11-12-4759 .11/19/2009
SHAWN GEE
1818 BREYER COURT
ELKINS PARK, PA 19027
z
0
ROBERT ALEXANDER AND ALL OCCS
130 EAST WALNUT PARK DRIVE, GARAGE
PHILADELPHIA, PA 19120
Plaintiff
SHAUN GEE _
1818 BREYER COURT
ELKINS PARR, PA 19027
Vs.
Defendant(s) THE PHILADELPHIA COURT OF
T ALEXANDER
130 E. WALNUT PARK DR COURT No. - -
1ST FIX -
TERM No.
CLAIM No. ?-------_._.
LT-08-11-L2-4759
WRIT OF EXECUTION
NOTICE
This paper is a Writ of Execution. It has bcen-issued because there is a =ud
you. It may cause your property to be held or taken to a the judgment. ? gment against
rights to prevent your property from being taken. If you wish to exercise your rights youlega
act promptly.
must
Exempt Property: The law provides that certain property cannot be taken. Such
property is said to be exempt. There is a debtor's exemption for 5300.00. There are other
exemptions, which may be applicable to you. Attached is a summary of some of the major
exemptions. You may have other exemptions or other rights.
If you have an exemption, you should do.the following promptly: (1) Fill out the attached
exemption claim form and demand for a prompt hearing; (2) Deliver the form or mail it to the
Sheriff's Office at the address noted. The fee to file this is S20.60(Attorney check, certified
check, cashiers check or money order only).
You should come to court ready to-explain you exemption. and prove your exemption, you may )ose some of our property. If you do not come to court
Property Belonging to Another Person: If thre i
your bank account) that belongs to another property at your residence (or-in
should notify that person or that you own with another person-, you
person so that he/she can file a Property Claim (fee to file is $40.00, attorney
check, certified check, cashiers check or money order only) or other legal papers with the
Sheriff`s Office to prevent his/her property from being taken or sold at Sheriff's Sale to satisfy
your debt. See enclosed forms.
"YOU SHOULD TAKE THIS PAPER TO "LLEVE EST DEMANDA A UN ABOGADO
YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT IMMEDIATAMENTE. SI NO TIENE
AFFORD ONE, GO TO OR TELEPHONE THE ABOGADO O SO NO TIENE EL DTNEitO
OFFICE SET FORTH BELOW TO FIND OUT VAYAA EN PERSONA O LLAME PPORR CIO
WHERE YOU CAN GET LEGAL HELP" TELEFONO A LA OFICINA CUYA
Philadelphia Bar Association DIRECCION SE ENCUENTRA ESCRITA
Lawyer Referral and ociatmation Service ABAIO PAR.A AERIGUAR DONDE SE PUDE
One Reading Center CONSGUIR ASISTENCIA LEGAL."
Philadelphia, PA 1910?
1701 Telephone: (215) 2313-7 Associancion De Licenciados De Filadelfa
Servicio Da Referencia E Informacion Legal
One Reading Center
Filadelfia, PA 19107
Telefono: (215) 238-1701
EXHIBIT "A"
PLAINTIFF SHAWN GEE
Court & Term No VS. DEFENDANT ROBERT ALEXANDER
CLAIM FOR E Claim No.
TO T SHERIFF: XEMpTION -12-4759
1, the above-named defendant, claim e
(1) From MY personal pro
Perry in c xmPtton of prop"
from levy (]) or attachment
(a) I desire my Possession which has been levied u (2}:
that my S300.00 statutory exemption by
Pon,
() (l) set aside in kind (specify proper, to beset aside in kind):
() (II) paid in cash following the salt of the
(b) I claim the following exemption (specify Property levied upon. Pro s of or
party and basis of exemption
(2) From my pro
Percy which is in the P°SUSSion or a third party,
exemptions: )
1 claim the following
(a) MY S300_00 statutory exemption f ) in cash () in kind
(specify property):
(b) Social Security benefits on deposit in the amount of: S
(c) Other (specify amount and basis of exemption):
I request a prompt court hearing to dctrmr;ne
Notice of the hearing should be the exemption
given to me at: (Nana, Address & Telephone Number)
I verify that the scat
that false state "meats made in this Claim for
meats herein are made subject to the penalties are true and correct. ] ode fs
toad
relapn to unsworn falsification to authorities. Penalties of l8 PA.C.S. Section4904
. Date:
Phone # Defendant(s):
Address:
City, zip:
THIS CLAIM TO-BE
'E MTH= Office of the Sheriff of Philadelphia C . ounty
Land Title Building
100'South Broad Sired, Fifth Floor.
Note: Under Paragraphs (]) and (2) of the Philadelphia, PA 19110 (215) 686-3559/60
attached nay be set forth in t, description of specific property
Under paragraph ) writ or included in a separate direction to the
u
be set forth in the space Provded a wnt, if attachment of a named garnishee is desired, to be lev ied Pon or ff. Under paragraph (3) of the writ. his name should
person not n t, the Sheriff may, as under
For 1" arned in this wri t May be found in prior practice, add as a
uratations on the power to attach Possession of property of the defendant. garnishee any
(b) Each court shall by local rule dcsignVbc the soncall property, sec Rule 3108(a).
See MAJ Rule 311 I (a).
organization or person to be named in the notice.
ORE7CEM]' TIONS UNDER pENNSYLV
(I) 5300.00 statutory exertion A ANb j'EDERAI, LA W
(2) Drbks, school books, scwin
(3) Most wages and un g machines, uniforms and equipment
(4) Social Securi emP1oYt?nt compensation
(5) Certain retirement fund and accounts
(6) Certain veteran and armed forces benefits
(7) Certain insurance proceeds
EXHIBIT "A- I
Plainliff
--SIiAbIIL..?E_.
1818 BREYER COURT
ELKINS PARK, - 9027
Vs.
Defendant(s)
!ALEXANDER THE PHILADELPHIA COURT OF
130 E. WALNUT PARK DR
1 ST FLR COURT No.
TERM No.
CLAIM No. LT-0 - - 2-+7%1-
PROPERTY CLAIM NOTICE TO PERSONS OTHER THAN
ABOVE-NAMED DEFENDANT WINO OVVN PROPERTY LOCATED
All household goods and contents at this address may be scheduled for Sheriffs Sale in the n
future to satisfy a judgment against:
If you are not named above, and you own ro ear
sold unless You inform the Sheriff in writing what p " lOCated at this address, your property
may be
You may protect your prop ? ?' beiongs to you.
named above, by filling out the attached 1Property
person
Claim form' and filing it at the Office of the Sheriff,
cannot afford it. off' Clam is $40.00, but you may not have to pay the fee if you
(Payment must be in the form of Attorney's check, certified check, cashier's check or
money order only.)
If you file a Property Claim, the Sheriffs Sale will not o through
whether you own the property you claim. g until the Sheriff decides
For additional information, you may telephone the Sheriffs Office at (215) 686-3.559/60.
"YOU SHOULD TAKE THIS PAPER TO YOUR
LAWYER AT ONCE: IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP."
Philadelphia Bar Association
Lawyer Referral and Information Service
One Reading Center
Philadelphia, PA 19107
Telephone: (2) 5)238-1701
"LLEVE EST DEMANDA A UN ABOGADO
1MMED'ATAMENTE. SI NO'TIENE ABOGADO
O SO NO TIENE EL DINERO SUFICIFNTE DE
LUME TAL SERVICIO VAYA EN PERSONA 0
LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABA70
PARA AERIGUAR DONDE SE PUDE
CONSGUIR ASISTENCIA LEGAL"
Assoeianeion De Lianciados De Filadelfia
Servicio Da Referencia E Informacion Legal
One Reading Center
Filadelfia, PA 19107
Telefono: (215) 236-1701
EXHIBIT "B"
Plaintiff
SHA.I?i GEE
18 BREYER COURT
ELKINS PARK, 27
Vs.
Defendant(s) THE PHILADELPHIA COURT OF
T ALEXANDER
T130!f. F
WALNUT-`PARR bR COURTNo.
1ST FLR TERM No.
PHILA, CLAIM No.
NOTICE TO CO-OWNER OF ATTAC$MENT OF PROPERTY
Date:
The Bank account or other property that you own with the defendants a
have been attached by plaintiff
to satisfy a jud bove-named,
gment obtained by the plaintiff against the defendant- your money or pro
may soon be taken even though you owe nothing to the plaintiff
If some of the funds in the account or some of the p?h'
garnishee to see if it is defendin°' held by the garnishee,
belongs to you, you should contact the bank or
garnishee is not defending against oamisnds or property against garnishment- a Petition with the S g hment of prop - If-the bank or
heriff.Y? You can prevent garnishment by
To protect your funds or property.
Stay and Set Aside you should complete the attached petition
Writ of Execution as to Non-Judgment Debtor Property of the Sheriff' within fifteen (15) days after the this notice. to Intervene
For additional info PAY and file it in the
Informal- date of
on, you may call the Sheriff's Office at (215) 686-3559/60
..YOU SHOULD TAKE THIS PAPER TO YOUR
LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER
OR T OR CANNOT AFFORD ONE, GO TO
ELEPHONE THE OFFICE SET FORTH
BELOW TO-FIND OUT ARE YOU CAN GET
LEGAL HELP.,-
Philadelphia Bar Association
Lawyer Referral and Infomlation Service
One Reading Center
Philadelphia, PA 19107
't'elephone: (215) 238-170)
"LLEVE EST DEMANDA A UN ABOGADO
IMMEDL4TAMENTE. SI NO TIENE ABOGADO
O SO NO TIMNE EL DINERO SUFICIENTE DE
PAGAR TAI, SERVICIO VAYA EN PERSONA 0
LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUE?tTRA ES
PAR.A AERIGUAR DONDE SE pUD TA ABA]0
CONSGUIR ASISTENCIA LEGAL."
Associancion De Licenciados De Filadelfia
Servicio Da Referencia E 1nfoT111acion Legal
One Reading Center
Filadelfia, PA 19107
Telefono: (21S) 238-1701
EXHIBIT 7"
Plaintiff
SliAhtN GEE
1818 BREYER COURT
ELKINS PARK, pA 1 27
Vs.
Defendant(s)
T-®LEX ER _
130 E. WALNUT PARK DR
1ST FLR
THE PHILADELPHIA COURT OF
COURT No.
TERM No.
CLAIM No.
LT-08-11-12-4759
PETITION TO INTERVENE, STAY AND SET ASIDE
WRIT OF E?CUTION AS TO NON-
(S40.0010 rlc - muse be in form of attorneys checklcashiiee?rME ? EBk OR PROPERTY
money order only.)
This petition respectfully represents:
t. l
the Petitioner, am a
intervene in this garnishment proceedin ?t to pn interest p and hereby move to
3121 and 3126 et seq. g pursuan
Nos.
2. The plaintiff has attached
of the garnishee. Personal property bel?ging to me currently in the possession
3. This attached property consists of.
} money held in a bank account held in common or
other (specify) jointly with the defends
[ ] nt
4. The Writ of Execution must be stayed and Set aside as to m
plaintiff does not have the legal right to attach and/or gain ish property because the
belonging to the judgment debtor in this matter. Prop' other than that
5. 1 verify that the foregoing statements of fact are true and correct to the
knowledge, information and belief. 1 understand that false state best ofre
subject to the penalties of 18 PA. C.S.A. 4904 relating to unsworn nts herein are made
falsifications to authorities.
Date:
(Petitioner)
(Address)
(Telephone)
EXHIBIT °G,.
Plaintiff
S1iATei?i rr, ?
818 B1tEYER OURT
ELRINS PARR PA
19027
7
Vs.
Defendant(s)
1ST F'LR R
PHILA, PA 19120
THE PHILADELPHIA COURT OF
COURT No.
TERM No.
CLAIM No.
LT-08-11-12-4759
APPLICATION TO PRO
(PROPERT CEED IN FORMA PAUPE
CI'AIM RXS
STAY AND /l'ETITION TO INTERVEN
SET ASIDE v? n T E
XECU n6p1,
TO THE SHERIFF:
t MY Personal prope
person. nY is subject to levy or attachment due to a judgment against anot
2 Because of my financial c her
ondition, ] am unable
Property Claim for M to Pay the fees and costs of filling m
Petition to Interv
defend my Property interests. Stay and Set Aside Writ of y
3. I am unable to obtain funds from anyone, includin?ution; and to
the costs of this litigation I understand that I have y -family and
Court of improvement in my financial circumstancescont, associates, to pay
mg obligation to inform the
cost incurred herein_ which would
4. l verify that the ' Permit me to pay the
information disclosed on this application and the attached "
Statement are true and correct to the best of m
I understand that false statements herein are Y knowledge, inform Financial
ation and ral
relating to unswom falsification to autho r emade subject to belief
penalties of 18 PA C.S.A_ 4904
Name:
Address:
Telephone:
EXHIBIT °•H°
PLAINTIFF SHAWN GEE
Court & Term No. VS- DEFENDANT ROBERT ALEXANDER
Claim NO.
FINANCIAL STATEMENT LT-08-1-1--12-4
(a) Name: Address:
Social Security Number: Phone Number
(b) Employment: If you are recently employed, state
Employer:
Address:
Salary or wages per month: Phone Number
Type of work:
(c) Other Income within the past twelve (12) months:
Business or Profession:
Other Self-Employment:
Interest:
Pension and Annuities: Dividends:
Social Security
Brnefits:
Disability Payments: Support Payments:
Unemployment Compensation/Workers Compensation:
Public Assistance:
-d) OAkLContributions to Household Support Other.
(Wife) (Husband) Name.
If Your (WifefHusband) is employed, state:
Employer:
Salary . or wages per rrbnth:
Type of Work:
Contributions from Children:
Contributions from Parents:
Other Contributions:
(e) Property Owned:
Cash:
Checking Account:
Certificates otDeposit: Savings Account:
Real Estate (including home):
Motor Vehicle:-Make-
Stoc]cs/bonds: Cost:
(n Debts and Obligations
Mortgage:
Loans: Rent:
(g) Persons Dependent U Other:
(WifcMusband) Name: You for Support
Children, if any:
Name:
Other Persons:
Name:
Relationship:
_______ Year:
Amount Owed:
Age: _
Age: _
Age:
EXHIBIT 14 - 1
,q :pi `d 8 - Ndf GIOZ
4/?12??3S yt?i a0 ?J1?3?0
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Edward L Schorpp
Solicitor
0 CE:;F'HES-ERiFF
f
r- p' y
2010 FEB -1 III, 11: 07
/?- 3")
Shawn Gee
vs.
Robert Alexander
SHERIFF'S RETURN OF SERVICE
Case Number
LT-08-11-124759
01/27/2010 02:15 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on January 27
2010 at 1520 hours, he served two true copies of the within Writ of Execution and Notice to Withhold
Income, upon the garnishee, to wit: Rite Aid, by making known unto Laura Crum, Paralegal, at 30 Hunter
Lane, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to
her personally the said true and correct copies of the same. Letter mailed to defendant obert lexander
at 130 E Walnut Park Drive, 1st Floor, Philadelphia, PA 19120 on 01-2
MARK CONKLIN, DEPUTY
SO ANSWERS,
January 28, 2010
RO ANDERSON, SHERIFF
u- F --------NOTARIAL SEAT.
Affirmed and subscrib WWI
%Sle Boro,
O f`-- day f
(c) CountySuite Shenff, Teleosoft, Inc,
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson "~~(,~
Sheriff ~F 7I-!E !'P^sF''')Nr3TARY
~,~,tv nt `unrbcr
Jody S Smith ` ~ ~ ~~° 10 AUG 3 I PM b~ 07
Chief Deputy ~%;. `_
~:{ _:;
Richard W Stewart `~ '' <~'~°
Ct~utBE~! ~~~1~ c,~,JNTY
Solicitor ot=~(c~cF ~r sN~R(rF ~~~V~
I0~ 3~
Shawn Gee
vs.
Robert Alexander
SHERIFF'S RETURN OF SERVICE
Case Number
LT-08-11-12-4759
01/27/2010 02:15 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on January
27, 2010 at 1520 hours, he served two true copies of the within Writ of Execution and Notice to Withhold
Income, upon the garnishee, to wit: Rite Aid, by making known unto Laura Crum, Paralegal, at 30 Hunter
Lane, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to
her personally the said true and correct copies of the same. Letter mailed to defendant Robert Alexander
at 130 E Walnut Park Drive, 1st Floor, Philadelphia, PA 19120 on 01-28-10.
08/30/2010 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.
SHERIFF COST: $131.07
August 30, 2010
SO ANSWERS,
(c, CountySuite Sheriff. Teleosoft, Inc.
RON R ANDERSON, SHERIFF