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Home My WebLink About10-5967 HUNTER'S RIDGE HOMEOWNERS THE COURT OF COMMON PLEAS ASSOCIATION, CUMBERLAND COUNTY PLAINTIFF PENNSYLVANIA V. CIVIL ACTION - LAW SHERIE ARIAS, DEFENDANT NO. .S 94-7 01 V L 1 L NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR 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. 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. Use c, CL Lt- LL. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY BAR CENTER c 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 170 (717) 249-3166 Oct 9 1-0 n- W f0a Date: izl Q? By: 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 HUNTER'S RIDGE HOMEOWNERS THE COURT OF COMMON PLEAS ASSOCIATION, CUMBERLAND COUNTY PLAINTIFF PENNSYLVANIA V. CIVIL ACTION - LAW SHERIE ARIAS, DEFENDANT NO. COMPLAINT Plaintiff Hunter's Ridge Homeowner's Association (hereinafter "Plaintiff) is a non-profit Pennsylvania Corporation with a mailing address of P.O. Box 454, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant Sherie Arias (hereinafter "Defendant") is an adult individual residing at 1729 Weatherburn Drive, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Defendant resides within a development subject to the Declaration of Covenants, Conditions, Restrictions and Easements for Hunter's Ridge which was recorded on May 14, 1989 in the Office of Recorder of Deeds for Cumberland County, Pennsylvania in Miscellaneous Book 380, Page 519. 4. Defendant resides within a development subject to the Bylaws of the Association of Hunter's Ridge Homeowners' Association. 5. The governing documents of the Association require the Defendant to pay a monthly homeowners' association fee which has been established by the Association to be One Hundred Twenty Eight and 00/100 ($128.00) Dollars to cover such items as exterior maintenance, snow removal, fees, and landscaping. 6. Since April 11, 2010 the Defendant has failed to timely pay her monthly homeowners' association dues. 7. Defendant failed to appear at a hearing before the Plaintiff's Board on July 13, 2010 despite receiving written notice via certified and regular United States Mail. Attached as Exhibit "A" is a true and correct copy of a Statement dated September 7, 2010 shows the outstanding amount due as of that date to be One Thousand Six Hundred Eighteen and 62/100 ($1,618.62) Dollars. 9. Defendant is aware of the governing documents which are available for review at www.hrhoal707O.com 10. The Declaration of the Association expressly permits the Association to recover all costs and attorney's fees incurred in enforcing the governing documents for the Association. See Article VI, Section 6.8.6. 11. The Bylaws of the Association expressly permit the Association to recover interest at the rate of eighteen (18%) percent per annum on any assessments not paid within five (5) days after its due date. See Paragraph 6.3. 12. The Declaration of Covenants expressly provides for the acceleration of all unpaid assessments due for the fiscal year to be immediately due and payable. See Article VI, Section 6.12 of the Declaration of Covenants. 13. Plaintiff seeks to recover accelerate the three (3) months of assessments due for 2010 or Three Hundred Eighty Four 00/100 ($384.00) Dollars pursuant to Article VI, Section 6.12 of the Declaration of Covenants. 14. Plaintiff has incurred legal fees of Three Hundred and 00/100 ($300.00) Dollars in filing this complaint. WHEREFORE, Plaintiff seeks an award of Two Thousand Three Hundred Two and 62/100 ($2,302.62) Dollars against the Defendant as well as an award of costs and future legal fees in excess of $300.00 and interest at Fifteen Cents ($0.15) per diem in interest from September 7, 2010. Respectfully submitted, BY: Steve oweIl' Esquire Ho ell Law Firm 6119 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Plaintiff Date: q //y/I o VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. BY: resident of the Hunters Ridge Homeowners' Association Date: Hunter's Ridge Homeowners Assn. PO Box 454 New Cumberland, PA 17070 I TO Sherie Arias 1729 Weatherburn Drive New Cumberland, Pa. 17070 Statement DATE 9/7/2010 AMOUNT DUE AMOUNT ENC. $1,618.62 DATE DESCRIPTION AMOUNT BALANCE 12/31/2009 Balance forward 600.80 01/01/2010 Monthly Fee 128.00 728.80 01/06/2010 PMT #2224. -128.00 600.80 02/01/2010 Monthly Fee 128.00 728.80 02/06/2010 PMT #2234. -128.00 600.80 03/01/2010 Monthly Fee 128.00 728.80 03/08/2010 PMT #2245. -128.00 600.80 04/01/2010 Monthly Fee 128.00 728.80 04/11/2010 PMT #2257. -128.00 600.80 04/15/2010 Special Assessment-Snow Removal 300.00 900.80 05/01/2010 Monthly Fee 128.00 1,028.80 05/09/2010 Late Fee 10.00 1,038.80 06/01/2010 Monthly Fee 128.00 1,166.80 06/08/2010 Late Fee 10.00 1,176.80 06/12/2010 Fee for monthly installment plan 20.00 1,196.80 07/01/2010 Monthly Fee 128.00 1,324.80 07/08/2010 Late Fee 10.00 1,334.80 08/01/2010 Monthly Fee 128.00 1,462.80 08/11/2010 Late Fee 10.00 1,472.80 08/31/2010 interest charged on delinquent payments or delinquency to the 7.82 1,480.62 Assn. 09/01/2010 Monthly Fee 128.00 1,608.62 09/07/2010 Late Fee 10.00 1,618.62 AMOUNT DUE wor I $1,618.62 ,4" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~o~sr of ~auut,r~~~~3 Jody S Smith Chief Deputy $~~ ' s_ _ Richard W Stewart Solicitor ~rr;,;G ~ -~- ~:rae~ Hunter's Ridge Homeowners Association I ys Case Number Sherie Arias 2010-5967 SHERIFF'S RETURN OF SERVICE 09/24/2010 04:30 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on September 24, 2010 at 1630 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sherie Arias, by making known unto herself personally, at 1729 Weatherburn Drive, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.74 September 28, 2010 STE HEN BENDER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF ~ o `~ -°~ rs --t m ~ ~ `~'~ ~~ ~ ~h ~ o~y .~- ~~ ~ o ---s ca :~ -~ (e~ Co+.+n±, Suido 5herifY, T21PG9uR. Lir.. HUNTER'S RIDGE HOMEOWNERS THE COURT OF COMMON PLEAS ASSOCIATION, CUMBERLAND COUNTY PLAINTIFF PENNSYLVANIA CIVIL ACTION - LAW Q SHERIE ARIAS, : Z? ?f- DEFENDANT NO. 10-5967 5jD = r-o tj o TO: Sherie Arias i o a o n 1729 Weatherburn Drive ?? •• 5 " New Cumberland PA 17070 , DATE OF NOTICE: June 17, 2011 IMPORTANT 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 (10) 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. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY BAR CENTER 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 AVISO IMPORTANTE A: Sherie Arias 1729 Weatherburn Drive New Cumberland PA 17070 ECHA DEL AVISO: June 17, 2011 USTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESETADO CONTRA USTED. A MEMOS QUE USTED ACTUE DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS IMPORTANTES. USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE. INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY BAR CENTER 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 Respectfully submitted, By: rio ell Law Firm 9 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Date: June 17, 2011 Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first class United States Mail addressed as follows: Sherie Arias 1729 Weatherburn Drive New Cumberland PA 17070 By: Date: June 17, 2011 N i rnm zm r- -v HUNTER' RIDGE HOMEOWNERS THE COURT OF COMMON P S wo r1 o° ASSOCIA ION, CUMBERLAND COUNTY ?C3 -? z-n PL AINTIFF PENNSYLVANIA za z°c V. CIVIL ACTION - LAW SHERIE A RIAS, DEF ENDANT NO. 10-5967 PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a DEFAULT JUDGMENT against SHERIE ARIAS, for her failure to file an Answer tot e Complaint served September 24, 2010 on Sherie Arias by the Office of the Sheriff of Cumberl d County as shown on Exhibit "A-1" in accordance with PA R.C.P. 404 and 403. A Notice of Intention to Take a Default Judgment was filed on June 20, 2011 and served using a U.S. Postal Certificate of Mailing by first class prepaid postage on June 17, 2011 as shown on Exhibit "A- " (Certificate of Mailing USPS Form 3817 is attached showing service). No answer or response having been filed with the Prothonotary as of June 29, 2011 please enter a Default Judgment i the following amount of $2,646.85 plus all costs: Count I Interest Fees $2,302.62 I $ 44.25 ($0.15 Per Diem from September 7, 2010) 300.00 (Attorney Fees) $2,646.85 plus all costs Respectfully submitted, By: ell Lav6 Firm 19 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Plaintiff Date: J 29, 2011 am ? 14.66 Fd a C 4aco 1N dh& %(ej SHERIFF'S OFFICE OF CUMBERLAND COUNTY R y R Anderson heriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 000 OFFICE OF THE SHERIFF Hunter's Ridge Ho eowners Association vs. Sherie Arias Case Number 2010-5967 SHERIFF'S RETURN OF SERVICE 09/24/2010 04:30 M - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on Septe ber 24, 2010 at 1630 hours, he served a true copy of the within Complaint and Notice, upon the within amed defendant, to wit: Sherie Arias, by making known unto herself personally, at 1729 Weath rburn Drive, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same tine handing to her personally the said true and correct copy of the same. STE HEN BENDER, DEPUTY SHERIFF COST: $4174 September 28, 2010 SO ANSWERS, 4RONRTANDERSON, SHERIFF (c GountySuite SnentT. 1eleosort. Inc. HUNTER RIDGE HOMEOWNERS ASSOCIATION, V. SHERIE ARIAS, TO: Sh ie Arias 17 9 Weatherburn Drive Ne Cumberland PA 17070 DATE OF NOTICE: June 17, 2011 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. 10-5967 IMPORTANT NOTICE cn c .- co ?- Mrn C-- r' N ,.? o .mod ?a• v c? ? 2a 5c I N) a o rte, YOU A IN DEFAULT BECAUSE YOU HAVE FAILED E O ENWRITING TER WWRITTE APPEA NCE PERSONALLY OR BY ATTORNEY AND COURT OUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UN ESS YOU ACT WITHIN TEN (10) DAYS WITHOUT A HEARING AND YOU A JUDG ENT MAY BE ENTERED AGAINST MAY LO $E 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 AN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU TO PR( OFFER FEE. LA ',NOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE E YOU WITH INFORMATION ABOUT AGENCM' THAT MAY AL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY BAR CENTER 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 x AVISO IMPORTANTE Shclr )-. /k 'i S? ' 72(i?Wc.a! lf: i, u New Cural er hei ?.? PA ;e 7070 ECHA DEL AVISO J i_ t w _ 2011 USTED STA, E,IN i COMPARENCENCIA.. LSE. Y SOMETER CO LA - i > l I QUE SE HAN PRES' L` h:' DENTRO DE DIEZ I:'11 VISTA Y USTED Pt: I= i IMPORTANTES. "TA :LDIA PORQUE HA 'Ml DE" ' RITA POR SI MISMO 0 A TRAVES DE UN ABOGADO SUS DEFENSAS U OBJECCIONES A LOS CARGOS )0 CONTRA USTED. A MEMOS QUE USTED ACTUE CONTRA SUYA SIN TENER DERECHOS A UNA E PERDER SU PROPIEDAD U OTRO S DERECHOS USTED DEBE 1_I ?VAR EST DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI ISTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LAW SIGUIENTE, ( FICINA. ESTA OFICINA PUEDE PROVEERLE. INFORMACION A CE:Er CYO )E COMO CONSEGUIR UN ABOGADO. SI USTED NO PUE',D1 ? ?AGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA ? FICINA LE PUEDE PROVEER INFORMACION SOBRE AGENCIAS QUE OFR -Z(. AN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CALII= "AN. LAWYER REFERRAL. SEIk VICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION Cl . VIBERLAND COUNTY BAR `CETIER 2 LIBERTY AVENUE +' 'ARLISLE, PENNSYLVANIA 17013 (717) 249-3166 Respectfully submitted, By: . a- -V, Law Firm 09 Bridge Street New Cumberland, PA 17070 (7.17) 770-1277 Supreme Court ID 62063 Date: June 17, 2011 Certificate of Service I hereby certify thai ( a the date set forth below a true and correct copy of the foregoing document was ser, ed upon the party/parties set forth below by postage prepaid, first class United St, rtes Mail addressed as follows: Sherie Arias 1729 Weatherburn Drive New Cumberland PA 17070 By: Date: June 17, 2011 Respectfully submitted, By: Ho ell Law Firm 9 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Date: June 17` 2011 Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first lass United States Mail addressed as follows: Sherie Arias 1729 Weath New Cumbe i Drive PA 17070 ell uNrr;fv 7W Inc RVKE Certificate Of Wiling This Certificate of Mailing owtleevi?e evidence that.mail h has been presented to USPSm for mailing Thus formes+?no?,cad._r? _-J From A•yp' 1(1t .._T ?. Steven Howell ,/'• v%,,? ?^, Attorney At Law 619 Bridge Street ti' N Cumberland, PA 1.7070 f j Z s _ TO: ? --I •CiZD 1 I1761 ,l f / 1 +_ {4 w I`H GV V N V O I a PS Form 3817, Apr 12007 PSN 7530-02-000-9065 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5967 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUNTER'S RIDGE HOMEOWNERS ASSOCIATION Plaintiff (s) From SHERIE ARIAS - 1729 WEATHERBURN DRIVE, NEW CUMBERLAND, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property including but not limited to firearms, applicances, electronic equipment, computers, dvd platers, television, tools, collectibles and vehicle located at 1729 Weatherburn Drive, New Cumberland, Cumberland County, PA 17070. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of' GARNISHEE(S) as follows: PNC BANK - 105 NOBLE BOULEVARD, CARLISLE, PA 17011 All bank accounts, savings accounts, money market accounts or other financial accounts in which the defendant/s has/have any legal or equitable interest including but not limited to her accounts at Garnishee Bank. 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 - Count I - $2, 646.85 L.L. S.50 Interest -Count I - $91.52 ($0.44 Per Diem from 6/29/11) Arty's Comm % Due Prothy $2.25 Arty Pad $181.24 Other Costs Plaintiff Paid Date: 1/24,112 David D. Buell, Prothonotary C (Seal) G? Deputy REQUESTING PARTY: Name STEVEN HOWELL, ESQUIRE Address: HOWELL LAW FIRM 619 BRIDGE STREET NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 717-770-1277 Supreme Court ID No. 62063 HUNTER'S RIDGE HOMEOWNERS ASSOCIATION, PLAINTIFF V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PFNNCVI VANIA CIVIL ACTION - LAW SHERIE ALRIAS, -/7.2? DEFENDANT,NjPw C'vrr?6e/lc?/ NO. 10-5967 p /?- /70 0 PRAECIPE FOR WRIT OF EXECUTION PURSUANT TO PA. R.C.P. 3101 TO 3149 TO THE PROTHONOTARY: Please issue writ of execution in the above matter, (I Directed to the Sheriff of Cumberland County. Pennsylvania r..W M :.r r-J r?.s c_ '-r7 r? (2) Against Garnishee PNC BANK, 105 NOBLE BOULEVARD, CARLISLE, CUMBERLAND COUNTY, PA 17011. (3) and against DEFENDANT SHERIE ARIAS f-+ rfi 7: -4.= ALL PERSONAL PROPERTY INCLUDING BUT NOT LIMITED TO FIREARMS, APPLIANCES, ELECTRONIC EQUIPMENT, COMPUTERS, DVD PLAYERS, TELEVISIONS, TOOLS, COLLECTIBLES AND VEHICLES LOCATED AT 1729 WEATHERBURN DRIVE, NEW CUMBERLAND, CUMBERLAND COUNTY, PA 17070. (4) and index this writ (a) against DEFENDANT SHERIE ARIAS (b) against Garnishee PNC BANK, 105 NOBLE BOULEVARD, CARLISLE, CUMBERLAND COUNTY, PA 17011. as a lis pendens against the property of the defendant in the name of the Garnishee as follows: ALL BANK ACCOUNTS, SAVINGS ACCOUNTS, MONEY MARKET ACCOUNTS OR OTHER FINANCIAL ACCOUNTS IN WHICH THE DEFENDANT/S HAS/HAVE ANY LEGAL OR EQUITABLE INTEREST INCLUDING BUT NOT LIMITED TO HER ACCOUNTS AT GARNISHEE BANK. (5 Count I Count I Interest TOTAL Date: $2,646.85 91.52 ($0.44 Per Diem from 6/29/11) $2,738.37 plus all costs Respectfully submitted, S D PW" By: C8 V3. 7y q;2. 00 /11.00 C-# 10 305- ,?2 7 o 123 1, FAuire 7 Ho ell Law Firm 01 9 Bridge Street New Cumberland, PA 17070 (717)770-1277 Supreme Court ID 62063 a .Z -C; 0/ae (7° 0 50 LL )XIII n7Z ?X /ssuecl SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff a' 1LED-iii 'fit eiE p OTHONOTAP? Jody S Smith Chief Deputy FEB -I PM 1 49 Richard W Stewart Solicitor T- `-'iRIfF t-UMBERLANO COUNT r EN"SYLVA'NI A Hunter's Ridge Homeowners Association vs. Sherie Arias SHERIFF'S RETURN OF SERVICE Case Number 2010-5967 01/26/2012 11:09 AM - Ronald E. Hoover, Deputy Sheriff, who being duly sworn according to law, states that on January 26, 2012 at 1107 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Sherie Arias, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Beth Ann Eppley, 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. SO ANSWERS, January 27, 2012 RONK'S R ANDERSON, SHERIFF Ronald F, Hoover, Deputy GounfySWO Sherift. Teiecsaft Inc HUNTER'S RIDGE HOMEOWNERS IN THI, COURT OF COMMON PLEAS ASSOCIATION, OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA C""j NO. 2010-5967 VS Tv C:°1 . w ' ern SHERRIE ARIAS, ??s M rxr -< Defendant CIVIL ACTION - LAW < Z) <C=1 3>? --4 A ° =C o c PRAECIPE TO STAY WRIT OF EXECUTION c,.y r AND DISSOLVE GARNISHMENT OF PNC BANK ACCOUNT AGAIN' o SHERRIE ARIAS To: Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 Sheriff of Cumberland County (Via Fax 240-6397) Attn: Sherry Lantz One Courthouse Square Carlisle, PA 17013 PNC Bank (Via Fax 412-762-0248) c/o Redena Williams, Garnishment Processor 105 Noble Blvd. Carlisle, PA 17013 Upon motion of Plaintiff's counsel please stay the writ of execution and dissolve the garnishment action against PNC Bank. Any levy and garnishment of the accounts is no longer necessary. Respectfully submitted, By: Steve owell, Esquire I ell Law Firm 619 Bridge Street New Cumberland, PA 17070 Supreme Court ID 62063 Attorney for Plaintiff Date: January 31, 2012 Certificate of Service I :hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first class United States Mail addressed as follows (unless otherwise noted): Sheriff of Cumberland County (Via Fax 240-6397) Attn: Sherry Lantz One Courthouse Square Carlisle, PA 17013 PNC Bank (Via Fax 412-762-0248) c/o Redena Williams, Garnishment Processor 105 Noble Blvd. Carlisle, PA 17013 Sherrie Arias 1729 Weatherbum Drive New Cumberland, PA 17070 By: Ste n Howell, Esquire Rowell Law Firm 619 Bridge Street New Cumberland, PA 17070 Supreme Court ID 62063 Attorney for Plaintiff Date: January 31, 2012