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Home My WebLink About04-3097'Johnson, Duffle, Stewart & Weidner By: Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff SCOTT D. FROCK 3712 LISBURN ROAD MECHANICSBURG, PA 17055, Plaintiff WALTER MORGAN and RHONDA MORGAN 17 Bridge Street New Cumberland, PA 17070, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Please enter judgment according to the Notice of Judgment/Transcript entered by the Honorable Scott J. Gross on April 30, 2004, a true and correct copy of which is attached hereto, the time for appeal having expired as evidenced by the attached Affidavit of No Appeal, and assess damages in favor of the Plaintiff and against Defendants in the amount of.~Li~¢~5. Respectfully submitted, JOHNSON, DUFFLE, STEWART & WEIDNER Date: ~ /I/'~ By: Wade D. Manl~t.y Attorney I.O..No. .87 4;[.~ 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 Attorneys for Plaintiff AND NOW, this ~;:~/~lay of~_ ) b(~ against the Defendants as requested above. :230027 ,2004, judgment is entered in favor of the Plaintiff and Prothonotary THIS COMMONWEALTH OF PENNSYLVANIA COUNTY OF: YORK Mag. DisL NO.: 19-3-09 DJ Name: Hen, ~dr. ss: 686 YORKTOWh'E ROAD OFF OF EXIT 35, 1-83 LEWISBERRY, PA ~'.~,~¢o,~e: (717) 938'2523 17339 ATTORNEY FOR PLAINTIFF : WADE D. MANLEY PO BOX 109 301 MARKET ST. LEMOYNE, PA 17043-0109 NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: RESIDENTIAL LEASE NAME arid ADDRESS r-FROCK, SCOTT D 3712 LISBURN ROAD MECHANICSBURG, PA 17055 VS. DEFENDANT: NAME and ADORE$S ~MORGAN, WALTER, ET AL. 17 BRIDGE ST. NEW CUMBERLAND, PA 17070 Docket No.: LT-0000234-04 [ ~ Date Filed: 4/07/04 IS TO NO'~FY YOU THAT: Judgment: FOR PT,~INTIFF [] Judgment was entered for: (Name) FROCK, SC(Y~ D Judgment was entered against MORGAN, WALTER ] Landlord/Tenant action in the amount of $ 6. 637.25 on 4/30/04 The amount of rent per month, as established by the District Justice, is $ The total amount of the Security Deposit is $ 725.00 Total Amount Established J~. ~)J ,, ~,ess .Security Deposit App, Ji,,ed Adjudica,:Led..AjT/ouJ2L Rent in Arrears $ ::),u::)u.uu--$ .uu = $ Physical Damages Leasehold Property $ 1,470.00 -- $ 725.00 -- $ 745.00 Damages/Unjust Detention $ .00 -- $ . O0$ . O0 Less Amt Due Defendant from Cross Complaint -- $ . O0 Interest (if provided by lease) $ . O0 !.JT Judgment Amount $ 5, '795. O0 E~ Attachment Prohibited/ Judgment Costs $ 142.25 42 Pa.C.S. § 8127 Attorney Fees $ '700. O0 E~] This case dismissed without prejudice. Total Judgment $ 6,637.25 ~] Possession granted. Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ FPossession granted if money judgment is not sat~st~ed Dy t~me ct eviction. Possession not granted. [] Defendants are jointly and severally liable. .J J in a (Date of Judgment) 8 o.oo. IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSEBBION WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. /¢ - ,-¢g)- a ~/ Date _ ~/~~'~ , District Justice II certify that this is a tru(~ and corr~c~-,ep~f t'he~r~J~'f'~l~ proceedings containing the judgment. I ~2~"¢-~ Date ~~~;~,~ - , District Justice AMo~cC¢..mA.0m3 ission expires first Monday of January, 2006. SEAL ,,,,g/COMMONWEALTH OF PENNSYLVANIA. COUNTY OF: ¥OAK Mag. Dist NO: 19-3-09 DJ Name; Hon. ^d~ra.s: 686 ¥ORKTOWJ,T~ ROAD OFF OF EXIT 35, I'83 LEWISBERRY, PA RECEIVED JUN 2 § 2iL': NOTICE OF JUDGMENT/TRANSCRIPT RESIDENTIAL LEASE PLAINTIFF: NAME and APDRESS ~FROCK, SCOTT D -~ 3712 LISBU~N ROAD MECHANICSBURG, PA 17055 0EFENDAN/: ~ NAME ~and ADDRESS 717 ~38-2523 17339 CMoRGAN, WALTZ, ET AL. PO BOX 109 30l MARKET ST. LEMOYRE, PA 17043-0109 TH~S ;S TO NO~¥ YOU THAT: Judgment: FOR PLAINTIFF I'Z~ Judgment was entered for: {Name) [~.OCK, SCO'/"Z' D Judgment wasenteredagainst ~ ~O~, [O~A ~ Landlord~enant action Jn the amount of $ 6,637.25 on 4/30/0~ The amount of rent per month, as established by the District Justice, is $ The totai amount of the Security Deposit is $ 725.00 Docket No.: ~.T' 0000234- Date F ed: zJ/07/0zJ · ina, {Date of Judgment) s o.oo. TotalAmountEstablish~d~;~J..~ess. Security Deposit Api~l[.ed = Adjudic~e,doA~O. ust.. Rent in Arrears $ .,, .... uu--$ .uu = $ :),u:~u u Physical Damages Leasehold Property $ 1,~70,00 ~ 725.00 = $ 7~5.00 Damages/Unjust Detention $ .00 --,~ . O0 = $ .00 Less Amt Due Defendant from Cross Complaint -- $ , ~': '. 00 Interest (if provided by Pease) $ ~; ~ . 00 ~ Att:a~h~nt ~iOhibit~, UT Judgment Amount $ Judgment Costs $ ,~ ,~ :~ 142.25 42 Pa.G,S: § 8~127,:r Attorney Fees ~ $ ~ Th~S case dismiSsed'Without p~ejudice, : :Total Judgment $)~ 6,637,25 , ~'-] Possession Post Judgment Credits $' granted. Post Judgment Cos!s $ Certified Judgment Total Possession granted if money judgment is not sabshe0 by t~me et ewctron. ,. Possession not granted' j~ Defendants are jointly and \ s~3?elly liable. · ~' ~A'R~A~"'TTON'INVOE'~ZlNG'~RESIDENTI~A'L LEA~E, ANY-FARTYflAS THE RIGHT TO A~'PEAL FROM A,.JU. DGJ~ENT FOR POSSES~!~ TEN DAYS AFTER THE DATE OF ENTRY oF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTI-~ON,OT-ARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONE~' JUDGMENT, IF ANY. IN ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTAR~/CLERK'OF COURTS THE LESSER OF THREE MON'i~-IS RENT ORTHE RENT AC~TUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED.;%.. IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RES!DENTIAL LEASE, THE PARTY HAS 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN,THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICE, S, IF THE JUDGMENT HOLDER ELECTS TO ENTER~THE JUDGMENT iNTHE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST C~ME FROM THE COURT OF COMMON pLEAS AND NO,FURTHER pROCESS MAY BE iSSLiEp By THE DiSTRiCT juSTiCE. ',. ; UNLESS T[`~E JU~GME~ ~S ENTERED ~N T~E C(~UFrr ~ C~M~bN P~-EAS~`A~Y~E ~NTE~E~T-ED }~N THE JUD~M~`F~ MAY F~LE A REQU~S~ F0R EN~Y'0F SATisFAcTiON WITH THE DISTRICT jUSTICE IF THE JUDGMENT DEB~'OI~ PAYS i1~~ FULL, sE'TTLES OR OTH~RWiSE~o'I~LIEs ~V~ifHTHE;~DGMENY;' ,, :~ . . : · · , , rl'ce,t/ify that t~S is a tru~nd corr~e,~,,z,-c~py of t~orj;t~"f~j~i proceedings containing the judgment· ~cC:~o. Am.?ssion expires first Monday of Januar,~, 2006. SEAL · "Johnson, Duffle, Stewart & Weidner By: Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff SCOTT D, FROCK 3712 LISBURN ROAD MECHANICSBURG, PA 17055, Plaintiff WALTER MORGAN and RHONDA MORGAN 17 Bridge Street New Cumberland, PA 17070, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW AFFIDAVIT OF NO APPEAL TO THE PROTHONOTARY: As of June 17, 2004 a District Justice Appeal has not been filed in the court of Common Pleas of Respectfully submitted, JOHNSON, DUFFLE, STEWART & WEIDNER Wade D. Manley/ Attorney I,D. No, 8724.4/ 301 Market Street P.O, Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 Attorneys for Plaintiff York County in the above-captioned matter. Date: :230871 AFFIDAVIT OF NO APPEAL District Justice Docket ~"~er= SCOTT D FROCK LT 234 04 Plaintiff VS. WALTER MORGAN ET AL. Defendant Aa of June 11, 2004 A District Justice appeal has not been filed in the Court of Co~on Pleas of York, Pa. County an the above captioned ~u~tter. Plaintiff/Defendant Johnson, Duffle, Stewart & Weidner Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT FROCK, Plaintiff/Petitioner VS. R_HONDA MORGAN, Defendant/Respondent VS. ELECTRIC DATA SYSTEMS CORPORATION, No. No, 0q-3077 Amount Due: Costs: To~l Due: Term, 20.__ Term, 20 04 Garnishee/Respondent : PETITION FOR A RULE TO SHOW CAUSE WHY AN ORDER GRANTING WAGE ATTACHMENT SHOULD NOT ISSUE AND NOW comes the Plaintiff, Scott Frock, by and through his attorneys, Johnson, Duffle, Stewart & Weidner, to hereby petition this Honorable Court to issue a Rule to Show Cause as to why the relief requested in the instant Petition should not be granted, and in :support thereof avers as follows: The Plaintiff, Scott Frock, is an individual residing at 3712 Lisbum Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. The Defendant, Rhonda Morgan, is an individual residing at 17 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070 as ~3presented by the Defendant to the Plaintiff. The Garnishee, Electronic Data Systems Corporation, is a Pennsylvania Corporation with a business address of 4600 Westport Drive, Mechanicsbmg, Cumberland County, Pennsylvania 17055. 4. This matter arises out of a dispute concerning a residential lease. 5. A Judgment was entered against the Defendant by District Justice Scott J. Gross, Magisterial District 19-3-09, on April 30, 2004, in the amount of $6,637.25, to Docket Number LT-234-04. 6. Simultaneous with the filing of this Petition, the Judgment erttered by District Justice Gross was entered with the Cumberland County Prothonotary at the above-captioned docket number. 7. The Defendant is currently employed by the Garnishee. 8. Pursuant to 42 Pa.C.S.A. Section 8127, the Plaintiff is entitled to garnish ten percent of the net wages per paid period of the Defendant. 9. The Plaintiff requests that this Court issue an order attaching the wages of the Defendant to satisfy said judgment, as permitted by 42 Pa.C.S.A. Section 8127. 10. The copy of said Judgment is attached, incorporated herein by reference, and marked as Exhibit A. WHEREFORE, the Plaintiff hereby requests that this Honorable Court issue a rule of show cause directing both the Defendant, Rhonda Morgan, and her employer and the Garnishee, Electronic Data Systems Corporation, to show cause why an order granting wage attacl~ment should not be issued. :230309 Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER Wade D. Manley~ Esq~ti~e ~ tlO~l: rYkI~ tD~ ~eOe.t 872~ P.O. Box 109 Lemoyne, PA 17043 -0109 Telephone (717)761-4540 E-mail: wdm~jdsw.com Attorney for Plaintiff CERI~F~CA TE OF $£RI~¢£ AND NOW, this .!"~ day of July, 2004, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Walter Morgan 17 Bridge Street New Cumberland, PA 17070 Rhonda Morgan 17 Bridge Street New Cumberland, PA 17070 Electronic Data Systems Corporation 4600 Westport Drive Mechanicsburg, PA 17055 JOHNSON, DUFFIF, STEWART & WEIDNER Johnson, Duffle, Stewart & Weidner Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT FROCK, Plaintiff/Petitioner VS. RHONDA MORGAN, DefendanffRespondent VS. ELECTRIC DATA SYSTEMS CORPORATION, Garnishee/Respondent No. Term, 20 No. Term, 20 04 Amount Due: $6,637.~1~,Z~ Costs: ~ Tot~l Due: ~~.~ 4o RULE TO SHOW CAUSE AND NOW, this /~" day of ,<~ ,2004, upon consideration of thc Plaintiff's Petition for a Rule to Show Cause Why an Order Granting Wage Attachmcn! Should Not Issue, it is hereby ORDERED and DECREED that: a rule is issued upon the Defendant, Rhonda Morgan, and the Garnishee, Electronic Data Systems Corporation, as thc Defendant's current employer, to show cause why the petitioner is not entitled to the relief requested; 2. the respondents shall file an answer to the petition within ,~O_ days of service; 3. the petition shall be decided under Pa.R.C.P. No. 206.7; notice of the entry of this order shall be provided to all parties as well as the Garnishee, as the Respondent's current employer. :230309 BYTHECOURT: ,~ Johnson, Duffle, Stewart & Weidner Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT FROCK, Plaintiff/Petitioner VS. RHONDA MORGAN, Defendant/Respondent VS. ELECTRIC DATA SYSTEMS CORPORATION, Garnishee/Respondent No. 04-3~q CIVIL Amount Due: $6,637.25 PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE AND NOW, pursuant to Pa. R.C.P. 206.7, the Plaintiff, Scoa Frock, hereby files this Motion to Make Rule Absolute and in support of the same avers as follows: On July 2, 2004, the Plaintiff, Scott Frock, filed a Petition for a Rule to Show Cause Why an Order Granting Wage Attachment Should Not Issue. On July 13, 2004, this Honorable Court issued a Rule to Show Cause with a return of twenty (20) days. Notice of the entry of the Order issuing a Rule to Show Cause was sent to the Defendant and the Garnishee on July 16, 2004 as evidenced by correspondence to the Defendant and the Garnishee, dated July 16, 2004, copies of which are attached, incorporated herein by reference, and marked as Exhibits "A" and "B", respectively. Neither the Defendant nor the Garnishee have answered the Rule. Pursuant to Pa. R.C.P. 206.7, when a Rule is not answered, the averments of fact may be deemed admitted and the Court shall enter an appropriate Order. WHEREFORE, the Plaintiffrespcctfully requests that this ttonorable Court grant his Motion to Make Rule Absolute and order thc Defendant's current employer, Electronic Data Systems Corporation, and all subsequent employers of the Defendant, to garnish the wages of the Defendant in thc amount of ten percent (10%) of her net wages per pay period until the judgment in the above-captioned matter is marked "Satisfied" and that thc Defendant's current employer and all subsequent ernployers of thc Defendant send checks, for each pay period of the Defendant, in the ~tmount often percent (10%) of her net wages per pay period, and made payable to thc Plaintiff, Scott Frock, 3712 Lisburn Road, Mechanicsburg, Pennsylvania 17055, to the Office of thc Prothonotm3,, who will then forward the checks to thc Plaintiff. Respectfully submitted, JOHNSON, DUFFEE, STEWART & WEIDNER Wade D. Manle]~, EsqUire } Attorney I. ID. No. 87 4~1~/ 301 Market Street P O Box 10!9 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 E-mail: wdm~jdsw,com Attorney roi' Plaintiff csj:233472 13615-1 CERT~FZCATE OF SERVZCE AND NOW, this ~'(~ day of August, 2004, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Rhonda Morgan 17 Bddge Street New Cumbedand, PA 17070 Electronic Data Systems Corporation 4600 Westport Ddve Mechanicsburg, PA 17055 JOHNSON, DUFFLE, STEWART & WEIDNER Carteen S. Oensen~.../ dEI~RY R. DUFFLE RICHARD W. STEWART C. ROY WE1DNER, JR EDMUND G. MYERS DAVID ~K DELUCE JEFFERSON J. SHIPMAN RALPH H WPJGHT, JR. MARK C. DUFFIE JOHN R NINOSKY MICHAEL J. CASSID ¥ MEL1SSA PEEL GREEVY ROBERTM WALKER WADE D. MANLEY LAW OFFICES JOHNSON, DUFFIE, STEWART & WEIDNER A Professional Corporation 301 MARKET STREET P.O. BOX 109 LEMOYNE, PENNSYLVANIA 17043-{1109 WEB$ITE: www.jdsw.com FiLE COPY HORACE A dOHNSON F LEE SHIPMAN BRUCE J. GROSSMAN* OFCOUNSEL TELEPHONE 717-761-4540 FACSIMILE 717-761-3015 E-MAlL: mail~jdsw.tom *Admitted in New York only WRITER'S EXT. NO. 122 E'MAIL wdm@jdsw.com July 16, 2004 Ms. Rhonda Morgan 17 Bridge Street New Cumberland, PA 17070 Re: Frock v. Morgan Cumberland County C.C.P. Docket No.: 04-3097 Dear Ms. Morgan: Enclosed herein please find a Rule to Show Cause entered by the Honorable Kevin A. Hess ordering you to show cause within twenty (20) days of service of this document why the Petitioner, Scott Frock, is not entitled to attach wages to satisfy the judgment against you entered with the Cumberland County Prothonotary. If you have any questions or concerns please feel free to contact me. Very truly yours, JOHNSON, DUFFLE, STEWART & WEIDNER Wade D. Manley [ '~' / djz:232304 13615-1 Enclosure cc: Mr. Scott Frock RECEIVED Johnson, Duffle, Stewart & Weidner Wade D. Manley I.D. No. 87244 30l Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 JUL ! 5 2(10 JUL JOHNSON, a[:~U.E~,JE,= eo,,- Plaintiff STEWART AND'W IlffiI g IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT FROCK, Plaintiff/Petitioner VS. PI-ION-DA MORGAN, Defendant/Respondent VS. ELECTRIC DATA SYSTEMS CORPORATION, Garnishee/Respondent No.. Term, 20 No. Term, 20 04 : Amount Due: $6,637,90 · : Costs: : Total Due: RULE TO SHOW CAUSE AND NOW, this .~ day o~, ,2004, upon consideration of the Plaintiff S Petition for a Rule to Show Cause Why an Order Granting Wage Attachment Should Not Issue, it is hereby ORDERED and DECREED that: a rule is issued upon the Defendant, P.honda Morgan, and the Garnishee, Electronic Data Systems Corporation, as the Defendant's current employer, to show cause why the petitioner is not entitled to the relief requested; 2. the respondents shall file an answer to the petition w/thin ,2,'9 . days of service; 3. the petition shall be decided under Pa.R.C.P. No. 206.7; notice of the entry of this order shall be provided to all parties as well as the Garnishee, as the Respondent's current employer. BY THE COURT: :230309 JERRY R. DUFFIE RICHARD W STEWART C ROY WE1DNER, JR EDMUND G ]flYERS DAVID ~( DELUCE dEFFERSONd. SHIPMAN RALPH H WRJGI~, JR. MARK C DUFFIE JOHN R. NINOSKY MICHAEL J. CASSIDY MELISSA PEEL GREEPT ROBERTM WALKER WADE D. MANLEY LAW OFFICES JOHNSON, DUFFIE, STEWART & WEIDNER A Professional Corporation 301 MARKET STREET P.O. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109 WEBSITE: www.jdsw.com FILE COP r HORACE A. JOHNSON ~ LEE SHIPMAN BRUCE d. GROSSMAN* OF COUNSEL TELEPHONE 71%761-4540 FACSIMILE 717-761-3015 E-MAIL: mail(D~jdsw,com *Admitted tn New York only WRITER'S EXT. NO. 122 E-MAIL wdm@jdsw.com July 16, 2004 Electric Data Systems Corporation 4600 Westport Drive Mechanicsburg, PA 17055 Re: Frock v. Morgan Cumberland County C.C,P. Docket No.: 04-3097 Dear Sir or Madam: Enclosed herein please find a Rule to Show Cause entered by the Honorable Kevin A. Hess ordering you to show cause within twenty (20) days of service of this document why the Petitioner, Scott Frock, is not entitled to attach wages to satisfy the judgment against your employee, Rhonda Morgan, entered with the Cumberland County Prothonotary. If you have any questions or concerns please feel free to contact me. Very truly yours, djz:232304 13615-! Enclosure cc: Mr. Scott Frock ~ad3~:i~i!!~RT & wEIDNER Johnson, Duffle, Stewart & Weidner Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 1704%0109 (717) 7614540 RECEIVED JUL 1 5 200 JLIL JOHNSON,aI~J,J,~.JI~ for Plaintiff STEWART AND~W'~I~NER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT FROCK, Plaintiff/Petitioner VS. RHONDA MORGAN, Defendant/Respondent VS. ELECTRIC DATA SYSTEMS CORPORATION, Garnishee/Respondent Term, 20.__ No. Term, 20 04 AmotmtDue: Cos~: TotalDue: RULE TO SHOW CAUSE AND NOW, this L.i ~ day o~],_.~, 2004, upon consideration of the Plaintiff's Petition for a Rule to Show Cause Why an Order Crnmting Wage Attachment Should Not Issue, it is hereby ORDERED and DECREED that: a rule is issued upon the Defendant, Rhonda Morgan, and the Garnishee, Electronic Data Systems Corporation, as the Defendant's current employer, to show c~;use why the petitioner is not entitled to the relief requested; 2. the respondents shall file an answer to the petition within ,2 0 days of service; 3. the petition shall be decided under Pa.R.C.P. No. 206.7; notice of the entry of this order shall be provided to all parties as well as the Garnishee, as the Respond~t's current emplOyer. BYTHE COURT: :230309 TRUE COP? FROM IN THE coURT OF COMMON PLEAS OF cuMBERLAND coUNTY, PENNSYLVANIA scoTT FROCK, : : Plaintiff/Petitioner : VS. RHoNDA MORGAN, Defendant/Respondent VS. ELECTRONIC DATA sYSTEMS cORPORATION, Garnishee/Respondent No. 04-3097 CIVIL Amount Due: $6,637.25 _ATTAClllVIENT oRDER AND NOW, this _/~ e__ day of AUGUST, 2004, upon consideration of the aforegoing Petition for a Rule to Show Cause Why an Order Granting Wage Attachment Should Not Issue, no response being filed by the Defendant, Rhonda Morgan, and Garnishee, Electronic Data Systems Corporation, it is hereby oRDERED and DECREED as follows: 1. The Defendant's current employer, Electronic Data Systems Corporation, and all subsequent employers of the Defendant, are hereby ORDERED to garnish the wages of the Defendant in the amount of ten percent (10%) of her net wages per pay period until the judgment in this matter is marked "Satisfied". 2. The Defendant's current employer, Electronic Data Systems Corporation, and all subsequent employers of the Defendant are hereby oRDERED to send checks for each pay period of the Defendant, in the amount specified in paragraph 1 above, :and made payable to Scott Frock, 3712 Lisburn Road, Mechanicsburg, pennsylvania 17055 to the Office of the ProthonotarY who will then record the amount paid in the docket of this malXer and then forward the checks to Scott Frock, 3712 Lisbum Road, Mechanicsburg, pennsylvania. 17055. BY THE COUII:T: ~/~/~