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Home My WebLink About10-3433 i ?:r ^Tp FAY 2010 MAY 24 AM 10. O4 DEWBERRY-GOODKIND, INC., Plaintiff, vs. SGS ARCHITECTS ENGINEERS, INC., Defendant. IN THE COUkV bF tOWO?4:RYEAS OF CUMBERLAND (? f)UNT , `kNNSYLVANIA NOAH- 3y33 CIVIL CIVIL ACTION - LAW PRAECIPE TO TRANSFER VIRGINIA JUDGMENT PURSUANT TO 42 PA.C.S.A. 4 4306 TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Plaintiff Dewberry-Goodkind, Inc. ("Plaintiff'), through its counsel, requests that the judgment against SGS Architects Engineers, Inc. which was entered on May 5, 2010, in the Circuit Court of Fairfax County, Virginia, in the amount of 553,467.62, together with interest thereon at the rate of 10% per annum, from July 1, 2009, until paid, costs, attorneys' fees and collection fees, be transferred and fully domesticated in the Cumberland County Court of Common Pleas pursuant to 42 Pa.C.S.A. § 4306, relating to Enforcement of Foreign Judgments. In support thereof Plaintiff submits the following Exhibits attached to this Praecipe: ??o?Uyebe? aE ,fit P f-r t r - Triple Sealed Copy of the Judgment and Certified Copy of sla Docket Ent of the Confession of Judgment; and, -EithibU-44v Affidavit Pursuant to 42 Pa.C.S.A. § 4306(c). * o-&co P13 A'r't/ Ce raIQq 0 Jga5coo G4?? Respectfully submitted, A Ue7l? ria P. Downey (PA 59891) stin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, Pennsylvania 17108-1181 717.255.1155 717.238.0575 (Fax) downeyb@pepperlaw. com weberj g@pepperlaw.com Attorneys for Plaintiff Date: May 21, 2010 Dewberry-Goodkind, Inc. -2- COMMONWEALTH OF VIRGINIA COUNTY OF FAIRFAX To wit: I, John T. Frey, Clerk of the Circuit Court of Fairfax County, Virginia, the same being a Court of Probate and of Record and having a seal, do hereby certify that the foregoing and hereunto annexed paper is a true and complete copy of. Abstract of Judgment rendered in the FAIRFAX CIRCUIT COURT on the 03/08/2010, in the case DEWBERRY GOODKIND, INC. versus SGS ARCHITECTS, INC. - DELETED 5/5/10 and SGS ARCHITECTS ENGINEERS, INC. - ADDED 5/5/10. Now on file and of record in my office. IN TESTIMONY WHEREOF I have hereunto set my hand and affixed the seal of the said Court hereto, at Fairfax, Virginia this: 18TH DAY OF MAY, 2010 A :z 4 ,? Clerk's WPM= COMMONWEALTH OF VIRGINIA COUNTY OF FAIRFAX To wit: I, Randy 1. Bellows, Judge of the Circuit Court of Fairfax County, Virginia, the same being a Court of Probate and of Record, do hereby certify that John T. Frey, whose genuine signature appears signed to the foregoing and hereunto annexed certificate and thereon written, was, at the date thereof, and is now, the Clerk of said Court, duly elected, qualified and authorized under the laws of said State to give the same, and all his official acts as such Clerk are entitled to full, faith and credit; and that the said certificate is in due form of law and by the proper officer. I further certify that I am well acquainted with the handwriting of said John T. Frey, Clerk. as aforesaid, and that his said signature to the foregoing and hereunto annexed Certificate is his usual and genuine signature. Judge's Signature COMMONWEALTH OF VIRGINIA COUNTY OF FAIRFAX To wit: I, John T. Frey, Clerk of the Circuit Court of Fairfax County, Virginia, the same being a Court of Probate and of Record and having a Seal, do hereby certify that the Honorable Randy I. Bellows, whose genuine signature appears signed to the foregoing certificate and thereon written, was at the date thereof, and is now, the Judge of said Court and County, duly elected, qualified and authorized under the laws of the State of Virginia to give the same, and that all of his official acts as such Judge are entitled to full faith and credit. I further certify that I am well acquainted with the handwriting of the said, Randy I. Bellows, Judge, as aforesaid, and that the signature to the said Certificate is his usual and genuine signature. IN TESTIMONY WHEREOF I have hereunto set my hand and affixed the seal of the said Court hereto, at Fairfax, Virginia this: 'g? !: ,-,z -,- 18TH DAY OF MAY, 2010 Clerk's Signature Abstract of Judgment Case No.: CL20100003192 ................................................... Fairfax Circuit Court Judgment No.: 472361 ................................................... FAIRFAX CIRCUIT COURT ........................................................................................................................................................................ Where Rendered DEWBERRY GOODKIND INC Yes vs SGS ARCHITECTS INC - DELETED 5/5/10 Yes ............................................................................................................................................. ............................................................................................................................................................ Plaintiff Name Firm Defendant Name Firm ............................................................................................................................................................ SSN/ID DOB ONE TYLER COURT CARLISLE PA 17015 ............................................................................................................................................................... Address SGS ARCHITECTS ENGINEERS INC - ADDED 5/5/10 Yes ............................................................................................................................................................ Defendant Name firm 03/08/2010 .................................................. Dais of Judgment [ ] Homestead [ ] Cosed ............................................................................................................................................................ SS11D DOB ONE TYLER COURT CARLISLE PA 17015 ............................................................................................................................................................... Address 03/08/2010 12:00:00 AM ............ ........................................................................... Docket Date/Time Plaintiff Attorney Name .............................................................. Defendant Attorney Narne 53,467.62 WITH 10% INTEREST FROM 07/01/2009 UNTIL PAID AND COSTS OF THIS PROCEEDINGS, INCLUDING ATTORNEY FEES AND COLLECTION FEES; CONFESSION OF JUDGMENT .............................................................................................................................................................................................................................................................................................................................................. Judgment Descri'Jtion Executions None Updates Docketed Description 05/05/2010 11:25:15 AM RECONFESSION OF JUDGMENT TO CORRECT DEFENDANT NAME TO SGS ARCHITECTS ENGINEERS INC, FILED BY CRAIG N THOMAS, ATTORNEY; TE3TE SUSAN WINSTON, DEPUTY CLERK I certify that above to be a true abstract of a judgment docketed in this court. A Date: Deputy b????? Clerk: 472361 VIRGINIA: BK 00173 2323 05/05/2010 IN THE CLERK'S OFFICE OF FAIRFAX CIRCUIT COURT G 'R CONFESSION OF JUDGMENT Civil Action #: CL- 2010 _ 3192 I/we, Craig N. Thomas hereby acknowledge ?K?/Attornev-in Fact SGS Architects Engineers, Inc. to be justly indebted to, and do hereby confess judgment in favor of Dewberry-Goodkind, Inc. In the sum of Fifty-three thousand four hundred sixty-seven and 62/100 Dollars ($-!L,467._62 ) with interest thereon at the rate of io.oo% from the 1St July day of , 2009 until payment, and the costs of this proceeding, including collection costs and ft attorney's fees, hereby waiving the benefit of homestead exemptions as to the same, provided the instrument on which the proceeding is based carries such homestead waiver. Given under hand and seal this ??f4 day of y Signa of bo r / Attorney-in-Fact C N. Thomas Name Printed of r / Attorney-in-Fact 8401 Arlington Boulevard Address Fairfax, VA 22031 703.849.0189 Daytime Phone Number VIRGINIA: IN THE CLERK'S OFFICE OF FAIRFAX CIRCUIT COURT The foregoin judgment was duly confessed before me in my office aforesaid on the 6- day of o io _ at O o'clock and has been duly entered of reco Defendant's Name & Address: SGS Architects En ineers, Inc. One Tyler Court Carlisle, PA 17015 CCR-D-70 Confessed Judgment Form 05/05/2010 RECORDED FAIRFAX CO VA TE;;A- _T CLERK -,/'_? TESTE: HN T. FR Y, Clerk By: Deputy Clerk A COPY TES E, JOHN Te FREY, CL RK March 2009 Depu';y Clark I I DEWBERRY-GOODKIND, INC., Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10- 3433 CIVIL vs. SGS ARCHITECTS ENGINEERS, INC., CIVIL ACTION - LAW Defendant. AFFIDAVIT PURSUANT TO 42 Pa.C.S.A. §4306 (c) Justin G. Weber, an attorney with the law firm Pepper Hamilton LLP, on behalf of Dewberry-Goodkind, Inc. ("Plaintiff"), and in support of its Praecipe to Transfer Virginia Judgment Pursuant to 42 Pa.C.S.A. § 4306, swears and affirms under the penalties of 18 Pa.C.S.A. § 4904 that the following is true and correct to the best of my knowledge, information and belief: 1. The document titled Confession of Judgment/Certificate of Clerk is a true, accurate and certified copy of the judgment that was entered in the above-captioned case in the Circuit Court of Fairfax County, Virginia, on May 5, 2010. 2. The full amount of the judgment remains outstanding. Plaintiff has not received any payment on the judgment from SGS Architects Engineers, Inc. ("Defendant") as of the date set forth below. 3. The last known address of Plaintiff is 8401 Arlington Boulevard, Fairfax, VA 22031. 4. The last known address of Defendant is One Tyler Court, Carlisle, PA 17015. 5. Defendant is a corporation and therefore is not believed to be in the military service of the United States. ?'L- Jtb/G. Weber Sworn and subscribed before me on this 21 st day of May, 2010 NMy commission expires on: (p I j / oQ- o 1 NOW LL SEAL PAWA K SIENO? Notary PubNc i111RKMSiIRC CITY,DA M MI COUNTY MY COM"WIon Expkot Jun d, 2011 CERTIFICATE OF SERVICE I hereby certify that on May 21, 2010, 1 served a copy of the foregoing document by United States mail, first class postage prepaid, addressed as follows: SGS Architects Engineers, Inc. One Tyler Court Carlisle, PA 17015 J s ' G. Weber (PA 89266) DEWBERRY-GOODKIND, INC., Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 3`(.33 CIVIL vs. SGS ARCHITECTS ENGINEERS, INC., CIVIL ACTION - LAW Defendant. NOTICE OF ENTRY OF JUDGMENT TO: SGS Architects Engineers, Inc. One Tyler Court Carlisle, PA 17015 Pursuant to the requirements of Pa. R.C.P. No. 236, you are hereby notified that on Mau a4-4 , 2010, judgment in the amount of $53,467.62, together with interest thereon at the rate of 10% per annum, from July 1, 2009, until paid, costs, attorneys' fees and collection fees, has been entered against you. Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DMSION t'7 PRAECIPE FOR WRIT OF EXECUTION C r~ ~? ~~-i ~ ~~r-,' ~_ ,~ .. Ca tion: ~ ~ . P ^ Confessed Judgment G'? ~- ~ Dewberry-Goodkind, Inc . , ; ^ Other ~.~C `~ a-'~ ._ , I vs. File No. Civil Action No. 10- J$_3 ". SGS Architects Engineers, Inc. ~ ~- Amount Due $ 5 3, 4 6 7. 6 .. ~ dtiQTylesf.~~~ -~ w Interest $4, 901.16 (7/:1/09 - 5/31/10 CarllS~e,PR~7D1S : Atty'sComm $4,674.40 Costs $ 41.4 0 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) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriffof 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) any and all funds or other obligations owed to SGS Architects Engineers, Inc. by or in the Gusto y or contro o t e garnis ees, or t eir agen s, w ose names and addresses appear on the attached Exhibit A. and all other property of the defendant(s) in the possession, custody or control of the said gamishee(s} ~~ t`? :r rr7 ~~~ ~:.> r i ~ ~r-, -, ~~~ f ee 'j. -~ ^ (Indicate) Index this writ against the garnishee (s) as a lis pendens agair~st real estate of the defe dart(s) described in the attached exhibit. Date 2 d Signature: ,tl,,, ~.. Print Name: J stir C? Weber Esq ~~,y.~o ~~ E~7 Address: ~K~ lga~Y Attorney for: Telephone: s~.5.oct ~os~ Q ~~:~~1~~~co Pepper ami ton 100 Market Street Suite 200 P.O. Boy: 1181 Harrisburg, PA 17108 Dewberry-Goodkind, Inc. 717.255.1155 Supreme Court ID No: 8 9 2 E 6 ~ ~ w~ ~ ~xti;b;~ ~ Dewberry-Goodkind, Inc. vs. SGS Architects Engineers, Inc. Civil Action No. 10-3433 Exhibit A to Praecipe for Attachment Execution Fulton Bank, National Association d/b/a Fulton Bank 6520 Carlisle Pike Mechanicsburg, PA 17050 Giant Food Stores, LLC 1149 Harrisburg Pike Carlisle, PA 17013 The Vigilant Hose Company of Shippensburg 129 East King Street Shippensburg, PA 17257-1325 #12693370 v7 DEWBERRY-GOODKIND, INC., Plaintiff, vs. SGS ARCHITECTS ENGINEERS, INC., Defendant CIVIL ACTION -LAW PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue the writ of execution upon the judgment entered in the above matter: (1) directed to the Sheriff of Cumberland County; (2) against SGS Architects Engineers, Inc., Defendant; and (3) against Fulton Bank, National Association, d/b/a Fulton Bank 6520 Carlisle Pike Mechanicsburg, PA 17050; Giant Food Stores, LLC 1149 Harrisburg Pike Carlisle, PA 17013; and The Vigilant Hose Company of Shippensburg 129 East King Street Shippensburg, PA 17257 (4) and index this writ: (a) against SGS Architects Engineers, Inc., Defendant, and IN THE COURT OF COMMON PLEAS OF CUMBERLAND CC-UNTY, PENNSYLVANIA NO. 10-3433 CIVIL #12699086 vl (b) against None , as garnishee, as a lis pendens against real property of the Defendant in the name of the garnishees as follows: None. (5) attach the following property of the Defendant in the possession oI' Fulton Bank, National Association, d/b/a Fulton Bank, Giant Food Stores, LLC and The Vigilant Hose Company of Shippensburg as garnishees: Any and all funds or other obligations owed to SGS Architects Engineers, Inc. by or in the custody or control of Fulton Bank, Giant Food Stores, LLC anti The Vigilant Hose Company of Shippensburg, or their agents. Amount Due $53,467.62 Interest of 10% per annum from 7/1/09 $ 4,901.16 through 5/31/10 Attorney's Commission $ 4,674.40 Costs $ 41.40 Dated: June Z, 2010 ,~. Gtr---` r' n P. Downey (59891) ustin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 P.O. Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 fax weber] g@pepperlaw.com Attorneys for Plaintiff Dewberry-Goodkind, Inc. N12699086 vl WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-3433 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEWBERRY-GOODKIND, INC. Plaintiff (s) From SGS ARCHITECTS ENGINEERS, INC. ,ONE TYLER COURT, CARLISLE, PA 17015 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: FULTON BANK, NATIONAL ASSOCIATION D/B/A FULTON BANK, 6520 CARLISLE PIKE, MECHANICSBURG, PA 17050 GIANT FOOD STORES, LLC, 1149 HARRISBURG PIKE, CARLISLE, PA 17013 THE VIGILANT HOSE COMPANY OF SHIPPENSBURG, 129 EAS KING STREET, SHIPPENSBURG, PA 17257-1325 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 properly 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$53,467.62 Interest $4,901.16 (7/1/09 - 5/31/10 ) Atty's Comm %$4,674.40 Atty Paid $56.00 L.L.$.50 Due Prothy $2.00 Other Costs$41.40 Plaintiff Paid Date: June 3, 2010 (Seal) REQUESTING PARTY: David D. Buell, Prothonotary By: Deputy Name JUSTIN G. WEBER, ESQUIRE Address: PEPPER HAMILTON LLP, 100 MARKET STREET, SUITE 200, P.O. BOX 1181, HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-255-1155 Supreme Court ID No. 89266 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CTVIL DMSION PRAECIPE FOR WRIT OF EXECUTION Caption: ^ Confessed Judgment Dewberry-Goodkind, Inc., ; ^ Other vs. : File No. Civil Action No. 10-3433 SGS Architects Engineers, Inc. $53,467.62 Amount Due Interest $4, 901.16 (7/1/09 - 5/31/10) Atty's Comm $ 4, 6 7 4. 4 0 Costs $ 41.4 0 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 origins] 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 SheriB'of Cumberland County, for debt, interest and costs, upon the following described property of the defendant (s) 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) any and all funds or other obligations owed to SGS Architects Engineers, Inc. by or in the custody or control of Rite Aid Corporation, 30 Hunter Lane, Camp_Hill, PA 17011 and Rite Aid HDQTRS Corp., 30 Hunter Lane, Camp Hill, PA 17011, and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). or their agents . ^ (Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of the / d endant(s) described in the attached exhibit. / Date ~/ J g ~d Signature: (,~. Print Name: stin G. Weber, Esq. Pepper Haml ton Address: 100 Market Street, Suite 200 P.O. BOX 1181 Harrisburg, PA 17108 Attomeyfor: Dewberry-Goodkind, Inc. Telephone: 717.255.1155 Supreme Court 1D No: 8 92 6 6 --, ~~~ - - ~I~ r l/ 4_ I ~ ~y~J 11(~ "~~tar ~J .r~~ i `jY 1 I .... ., Zoo ~v~~~ -~ ~r-~ -~: CUB!:-:_ ._ ;;,:.:'u~~1( -~Lf. Sr~ Ipl~r ~,~ f / ~ ~3 ~~~ .oo ,~ co . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-3433 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Dewberry-Goodkind, Inc. Plaintiff (s) From SGS Architects Engineers, Inc. (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: any and all funds or other obligations owed to SGS Architects Engineers, Inc. by or in the custody or control of Rite Aid Corporation, 30 Hunter Lane, Camp Hill, PA 17011 and Rite Aid HDQTRS Corp. 30 Hunter Lane, Camp Hill , PA 17011 or their agents. 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 $53,467.62 Interest $4,901.16 (7/1/09 - 5/31/10) Atty's Comm $4,674.40 Atty Paid $53.50 Plaintiff Paid Date: June 9, 2010 L.L. Due Prothy $2.00 Other Costs $41.40 David D. Buell, Protho otary (Seal) By: REQUESTING PARTY: Name Justin G. Weber, Esq. Pepper Hamilton LLP Address: 100 Market Street, Suite 200 P. O. Box 1181 Harrisburg, PA 17108 Attorney for: Plaintiff Telephone: 717-255-1155 Supreme Court ID No. 89266 Deputy J Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor &Q~~rn of ~umbpr~~~ ~1a ~t oFfiCg OF THE $Fi¢RIFF Y010 JUN 2 I ~'~! Z: Dewberry-Goodkind, Inc. vs. SGS Architects Engineers, Inc. Case Number 2010-3433 SHERIFF'S RETURN OF SERVICE 06/14/2010 01:00 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 14, 2010 at 1257 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: SGS Architects Engineers, Inc., in the hands, possession, or control of the within named gamishee, Giant Food Stores, LLC at 1149 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Peggy Ashwell, Receptionist, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 16, 2010 to SGS Architects Engineers, Inc. at One Tyler Court, Carlisle, PA 17105. 06/14/2010 03:09 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 14, 2010 at 1509 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: SGS Architects Engineers, Inc., in the hands, possession, or control of the within named gamishee, Fulton Bank at 6520 Carlisle Pike, Suite 600, Mechanicsburg, Cumberland County, Pennsylvania 17050, by handing to Jody Lewis, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 16, 2010 to SGS Architects Engineers Inc. at One Tyler Court, Carlisle, PA 17105. 06/14/2010 02:17 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 14, 2010 at 1413 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: SGS Architects Engineers, Inc., in the hands, possession, or control of the within named gamishee, The Vigilant Hose Company of Shippensburg at 129 East King Street, Shippensburg, Cumberland County, Pennsylvania 17257, by handing to Doug Trahey, Adult in Charge, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to him. The writ of execution and notice to defendant was mailed on June 16, 2010 to SGS Architects Engineers, Inc. at One Tyler Court, Carlisle, PA 17105. SO ANSWERS, June 16, 2010 RON R ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~:~~ . (c) CountySuite Shenft, Teleosoft, Inc. Page 2 Dewberry-Goodkind, Inc. vs. SGS Architects Engineers, Inc. B ~~ _ ~._..____..._. Y MICHELLE GUTSHALL, DEPUTY SHERIFF By ~~ TIMOT Y LACK, DEPUTY SHERIFF . , r. Brian P. Downey (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 Fax F!L Et~' t~~;=, i,, ~ r `~ Y ZOiO ui.'~d i ~ f i'~ 2~ 42 C~J~Y~ r '-: ^•~ - 3 t t ..!r/~i.a~~ f ~: Attorneys for Plaintiff Rite Aid Corporation DEWBERRY-GOODKIND, INC., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, NO. 10-3433 CIVIL vs. SGS ARCHITECTS ENGINEERS, INC., CIVIL ACTION -LAW Defendant. ~~~~ ~ - . . INTERROGATORIES IN ATTACHMENT PURSUANT TO Pa. R. Civ. P. 3144 and 3253 T'O: Fulton Bank, National Association, d/b/a Fulton Bank 6520 Carlisle Pike Mechanicsburg, PA 17050 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. Definitions and Instructions 1. When used in these interrogatories, the term "Defendant'' shall mean the above-named Defendant, SGS Architects Engineers, Inc. 2. When used in these interrogatories, the term "you" shall mean Fulton Bank, National Association, d/b/a Fulton Bank. 3. When used in these Definitions and Instructions and interrogatories, the conjunctions "and" and "or" shall be interpreted to mean "and/or." tt12654765 vl 4. These interrogatories shall be deemed continuing and supplemental answers shall be required if you directly or indirectly obtain further information of the nature sought herein. INTERROGATORIES 1. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, did you owe 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 it for any reason? If so, specify the nature and amount of such liability or claim and, if applicable, the negotiable or other written instrument on which such liability or claim is based. ANSWER: w~~V #12654765 vl 2. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by Defendant? If so, describe the property and specify the ownership, location and fair market value of such property. ANSWER: #12654765 vi 3. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, did you hold legal title to any property of any nature owned solely or in part by Defendant or in which Defendant held or claimed any interest? If so, describe the property and specify the ownership, location and fair market value of such property, together with the extent of Defendant's ownership interest therein and the value thereof. ANSWER: ~ // _ #12654765 vl 4. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, did you hold as fiduciary any property in which Defendant had any interest? If so, describe the property and specify the ownership, location and fair market value of such property, together with the extent of Defendant's ownership interest therein and the value thereof. ANSWER: ~~ #12654765 vl 5. 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? If so, describe the property, when and to whom it was transferred or delivered and the consideration thereof. ANSWER: ~ "' #12654765 vl 6. At any time after you were served, did you pay, transfer or deliver any money or property to Defendant or to any person or place pursuant to their direction or otherwise discharge any claim of Defendant against you? If so, describe the property or amount of money, when and to whom the money or property was transferred or delivered. ANSWER: ~~,/,(~ #12654765 vl 7. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, did Defendant maintain with you at your main office or any of your branch offices, any bank accounts or safe deposit boxes, or did you hold any money of Defendant in any capacity whatsoever? If so, specify the account names, account numbers, safe deposit box numbers, account types, balances on the date you were served and current balances. ANSWER: ~ ~Jz~~~-u~$- JS333.b~ #12654765 vl At the time you were served, or at any subsequent time, or at anytime within one (I) year prior to the date you were served, did Defendant own jointly with any other person or entity any bank accounts or safe deposit boxes held by you? If so, specify the account names, account numbers, safe deposit box numbers, account types, balances on the date you were served and current balances. ANSWER: /f~ atz~sa~6s ~t 9. At the time you were served, or at any subsequent time, or at anytime within one (1) year prior to the date you were served, was any money on deposit for Defendant in any bank account in a name other than those previously listed? If so, specific the account names, account numbers, account types, balances on the date you were served and current balances. ANSWER: /G' v Dated: June Z, 2010 ~ ~J~--_._ Bri .Downey (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 P.O. Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 fax weberjg@pepperlaw.com Attorneys for Plaintiff Dewberry-Goodkind, Inc. 1112654765 vl ,. / _ VERIFICATION I, ~~ ISIS (..~ /1 ,state that I am the ~~~y- of Fulton Bank, National Association, d/b/a Fulton Bank, a garnishee in this matter, that I am authorized to make this verification on its behalf, and that the averments of fact in the foregoing document are true and correct to the best of my knowledge, information and belief. This statement is made subject to the penalties of 18 Pa. C.S. § 4904 (unsworn falsification to authorities). Signati.~re Dated: ZZ , 2010 #12654765 vl vs. Brian P. Downey (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 Fax ~'~ Gi 4 - ~~r ~ ;,.. 'i? . ~ _~ ~~.jl1~ ~t; CFQ ~,!M r~; .. _ Attorneys for Plaintiff Dewberry-Goodkind, Inc. DEWBERRY-GOODKIND, INC., Plaintiff, SGS ARCHITECTS ENGINEERS, INC., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-3433 CIVIL CIVIL ACTION -LAW PRAECIPE TO DISSOLVE ATTACHMENT PROCEEDING TO THE PROTHONOTARY: Please withdraw the attachment proceeding against Fulton Bank, N.A., the garnishee in the above action, without prejudice to execution proceedings against any other entity. Bri n .Downey (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 (Fax) downeyb@pepperlaw.com weber] g@pepperlaw.com Attorneys for Plaintiff Dated: July 6, 2010 Dewberry-Goodkind, Inc. s 8'. oD p ~ ~"`1 ~~ ~~~ss3 ~ ~yy 7 / ~ CERTIFICATE OF SERVICE I hereby certify that on July 6, 2010, I served a copy of the foregoing Praecipe to Dissolve Attachment Proceeding on the following via First Class U.S. Mail, postage prepaid, as follows: Lawrence V. Young, Esquire CGA Law Firm CGA Professional Center 135 N. George Street York, PA 17401 Chris Land, OPS Supervisor Fulton Bank,N.A. 4429 Bonney Road, Suite 300 Virginia Beach, VA 23462 ~.J~-~ Ju G. Weber (PA 89266) ~~ Brian P. Downey (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 Fax i=.', . . BUG ~ Phi ~ : 3y '€ ,. Attorneys for Plaintiff Dewberry-Goodkind, Inc. DEWBERRY-GOODKIND, INC., Plaintiff, vs. SGS ARCHITECTS ENGINEERS, INC., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-3433 CIVIL CIVIL ACTION -LAW PRAECIPE TO DISSOLVE ATTACHMENT PROCEEDING TO THE PROTHONOTARY: Please withdraw the attachment proceeding against Rite Aid HDQTRS. Corp. and Rite Aid Corporation, the garnishees in the above action, without prejudice to execution proceedings against any other entity. Dated: August 5, 2010 Cam.. rian P. Downey (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 (Fax) downeyb@pepperlaw. com weber] g@pepperlaw. com Attorneys for Plaintiff Dewberry-Goodkind, Inc. ~8•0~ po a-n-/ ~~ ra35t~ ~~0~4 ~ 385 i CERTIFICATE OF SERVICE I hereby certify that on August 5, 2010, I served a copy of the foregoing Praecipe to Dissolve Attachment Proceeding on the following via First Class U.S. Mail, postage prepaid, as follows: Rite Aid HDQTRS Corp. 30 Hunter Lane Camp Hill, PA 17011 Rite Aid Corporation 30 Hunter Lane Camp Hill, PA 17011 l_.._~ u G. Weber (PA 89266) lw Y Brian P. Downey (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 Fax ~~i I ! .. ;~, ~v~ t~ ~m ~ .3y L ~ i ~ ri ~.:3 _~ V E' . ~; , _~.... Attorneys for Plaintiff Dewberry-Goodkind, Inc. DEWBERRY-GOODKIND, INC., Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-3433 CIVIL vs. SGS ARCHITECTS ENGINEERS, INC., CIVIL ACTION -LAW Defendant. PRAECIPE TO DISSOLVE ATTACHMENT PROCEEDING TO THE PROTHONOTARY: Please withdraw the attachment proceeding against The Vigilant Hose Company of Shippensburg, the garnishee in the above action, without prejudice to execution proceedings against any other entity ri .Downey (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 (Fax) downeyb@pepperlaw. com weber] g@pepperl aw. com Attorneys for Plaintiff Dated: August 5, 2010 Dewberry-Goodkind, Inc. $8.00 PA a~-'rt'/ e~tg3ss y~3ss CERTIFICATE OF SERVICE I hereby certify that on August 5, 2010, I served a copy of the foregoing Praecipe to Dissolve Attachment Proceeding on the following via First Class U.S. Mail, postage prepaid, as follows: The Vigilant Hose Company of Shippensburg 129 East King Street Shippensburg, PA 17257 s ' G. Weber (PA 89266) Brian P. Downey (PA 59891) Justin G. Weber (P.A 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1 181 Harrisburg, PA 17108-1181 717 255.1155 717.238.0575 Fax rr Y FLED- 14PY -3 F 1:22 Attorne? or Plaintiff Dewberry-Goodkind, Inc. DEWBERRY-GOODKIND, INC., Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-3433 CIVIL vs. SGS ARCHITECTS ENGINEERS, INC., CIVIL ACTION - LAW Defendant. PRAECIPE TO DISSOLVE ATTACHMENT PROCEEDING TO THE PROTHONOTARY: Please withdraw the attachment proceeding against Giant Food Stores, LLC, the garnishee in the above action, without prejudice to execution proceedings against any other entity. (Al? - ria P. Downey (PA 59891) ustin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 (Fax) downeyb@pepperlaw.com weberjg@pepperlaw.com Dated: September 2, 2010 Attorneys for Plaintiff Dewberry-Goodkind, Inc. 8.0o PO A" at !8(30 01 1 u-1 -7 a.3 CERTIFICATE OF SERVICE I hereby certify that on September 2, 2010, I served a copy of the foregoing Praecipe to Dissolve Attachment Proceeding on the following via First Class U.S. Mail, postage prepaid, as follows: Lawrence V. Young, Esquire CGA Law Firm CGA Professional Center 135 N. George Street York, PA 17401 Clayton W. Davidson, Esquire McNees Wallace & Nurick LLC 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 s n G. Weber (PA 89266) Brian P. Downey (PA 59891) Justin G. Weber (1?A 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0375 Fax FIL E R OTN?N ICE TARS OF TVA 201 Attorneys for Plaintiff Dewberry-Goodkind, Inc.. DEWBERRY-GOODKIND, INC., VS. Plaintiff, SGS ARCHITECTS ENGINEERS, INC., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-3433 CIVIL : CIVIL ACTION - LAW PRAECIPE TO MARK JUD. g DENT SAT'ISFIELI TO THE PROTHONOTARY: Please mark the judgment against SGS Architects Engineers, Inc. in the above, CaPtioned matter satisfied. Dated: January 3, 2011 B t P. DQwney (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP 100 Market Street, Suite 200 Past Office Box 1181 Harrisburg, PA 17108-1181 717,255,1155 717.238.0575 (Fax) downeyb@pcpperlaw.com weberjg@pepperlaw.com Attorneys for Plaintiff Dewberry-Goodkind, Inc. Q?? ?$,oc>`t p a&J C?? 185 ?(o ?? a CERT'IFICAT'E OF SELZVICE I hereby certify that on January 3, 2011,1 served a copy of the foregoing Praecipe to Mark Judgment Satisfied on the following via First Class U.S. Mail, postage prepaid, as follows: Lawrence V. Young, Esquire CGA Law Firm CGA Professional Center 135 N. George Street York, PA 17401 (;?g ? (-?' Justin G. Weber (PA 89266)