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HomeMy WebLinkAbout10-7781 KEEPER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 RACHEL SEIBEL, ~~. IN THE COURT OF COMMON PLEAS OF 506 Bard Drive CUMBERLAND COUNTY, PENNSYLVANIA Shippensburg, PA 17257 CIVIL ACTION -LAW Plaintiff NO. CV-0000217-10 v ~ ~d 77$~ C ~Y~' ASHLEY WILSON 316 Elwood Street ~ .~ Easton, PA 18045 -~~ ~ --, cv ~m ~ ~~ Defendant ~ ~ -~~ ~ ~~ .~ ~ ~' ~ ~~ ~ c~ ~ ~~ ~~ ~~„ ~ w _---~ __.~ PRAECIPE FOR ENTRY OF JUDGMENT .. ~ ,~~-, ~> ;.~ TO THE PROTHONOTARY: Pursuant to Pennsylvania District Justice R. Civ. P. 402(D) and Pa. R. Civ. P. 227.4, please enter judgment in favor of Plaintiff and against Defendant in the amount of Two Thousand Three Hundred Sixty Dollar ($2,360.00), together with interest and costs of suit. The Judgment entered by District Justice Harold E. Bender, on November 3, 2010, is attached as Exhibit "A". KEEPER WOOD ALLEN & RAHAL, LLP 1 B V~ Date: December 6, 20 0 y Eugene E. epmsky, Jr. 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff ~~ a~'a~'9~~~ ~, ~' COMMONWEALTH OF PENNSYLVANIA BOUNTY OF: C1D~g>Itr.ANn ~~a NOT CiE OF JUDGMENT/TRANSCRIPT CIVIL CASE Mag. Dist. Ne.: 09-3-01 MDJ Name: Hon. HAROLD 8. BENDER Address: 35 ~ ORANGl3 ST SHIPPENSBDRG, PA Telephone: (717 ~ 532 - 7676 17257 - 0361 RACHEL SLIB$L 506 BARD DR SHIPPffi1SBIIRG, PLAIN'"IF~: NAME and ADDRESS rSEIBEL, RACHEL, ST AL. ~ 506 BARD DR SHIPPS'NSBIIRG, PA 17257 L -~ VS. ~EI'EN~ANT: NAME and ADDRESS ~1~ILSON, ASHLEY ~ 316 ELalOOD ST SASTON, PA 18045 L J Docket No.: CV- 0000217 -10 _ PA 17257 Date Filed: 9/01/10 - THIS IS TO NOTIFY YOU THAT: Judgment: FOR PLAINTIFF (Date of Judgment) 9/30/10 ® Judgment was entered for: (Name) SSIBEL, RACHEL, BT AL. ® Judgment was entered against: (Name WILSON, ASHLEY in the amount of $ 2.360. Defendants are jointly and severally liable. Damages will be assessed on Date & Time This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 2.250.00 Judgment Costs $ 1 Interest on Judgment $ - Attorney Fees $ -~ Total $ 2.360.00 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, 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 MAGISTERIAL DISTRICT JUDGE . 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 MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. %~'L' l ~ Date ~7`Q.c.o-~c/ ~ ~c~~-- ,Magisterial District Judge ~~ I certify that this is a true and correct copy of the record of the proceedings containing the judgment. ~/-3- /d Date ~~ ~~" ,Magisterial Dtsirict Judge My commission expires first Monday of January, cola SEAL AOPC 315-07 DATE PRINTED: 10/O1/10 9:33:00 AM i (B) and against (A) against ASHLEY WILSON Defendants(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RACHEL SEIBEL, ET AL. Plaintiffs vs. ASHLEY WILSON `31(0 >? WO*a &? Defendant : Pas?"t'o 196,45 vs. 1 NO. 2010-7781-CIVIL K1 DANK I"1 r%%/C0C1f- &Lr1i31ci ewIV(S 0 PRAECIPE FOR WRIT OF EXECUTION - MONEY JUDGMENTS M TO THE PROTHONOTARY: a- o o -? ISSUE WRIT OF EXECUTOIN IN THE ABOVE MATTER. 3 2 "ra Z - ?w j -4m (1) Direct to the Sheriff of CUMBERLAND County, PA; ' ? (2) against ASHLEY WILSON Defendant(s); (3) and against SOVEREIGN BANK Garnishee(s); (4) And index this writ SOVEREIGN BANK Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of the garnishee(s). Specifically describe the property per attached property description. Any deposit account(s) maintained by Defendant with Sovereign Bank, including Defendant's interest in deposit account #231372691. Keefer, Wood, Allen, & Rahal, LLP (5) Amount Due: $ 2,360.00 g I I.D. #23702 Signature AD Number Interest From: $ Total: $ 2,360.00 Eugene E. Pepinsky, Jr., Esquire Print Name 210 Walnut Street Address P. O. Box 11963 Harrisburg, PA 17108-1963 so T6 0'? CBF so > ?a*?? (6/02) bb bule Co. . s!6 u Date: December 31, 2010 c?#a?3Y9S Q kJ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-7781 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due RACHEL SEIBEL, ET AL Plaintiff (s) From ASHLEY WILSON, 316 Elwood Street, Easton, PA 18045 (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: SOVEREIGN BANK, 17 West High Street, Carlisle, PA 17013 Any deposit account(s) maintained by Defendant with Sovereign Bank, including Defendant's interest in deposit account #231372691 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 $2,360.00 L.L. $.50 Interest -- Atty's Comm % Due Prothy $2.00 Atty Paid $54.25 Other Costs Plaintiff Paid Date: 01/11/2011 David D. Buell, Pr thonotary (Seal) By: Deputy REQUESTING PARTY: Name EUGENE E. PEPINSKY, JR. ESQUIRE Address: KEEFER, WOOD, ALLEN & RAHAL, LLP 210 WALNUT STREET P.O. BOX 11963 HARRISBURG, PA 17108-1963 Attorney for: PLANTIFF Telephone: 717-255-8051 Supreme Court ID No. 23702 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?,,1ir of 4irurGrrf??,d OF THE PROTHONOTARY Jody S Smith o w Chief Deputy 2011 JAN 20 AN 10: 10 Richard W Stewart CUMBERLAND COUNTY Solicitor ?'?` `? T"` "`R;r PENNSYLVANIA Rachel Seibel Case Number vs. Ashley Wilson 2010-7781 SHERIFF'S RETURN OF SERVICE 01/18/2011 01:31 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 18, 2011 at 1331 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Ashley Wilson, in the hands, possession, or control of the within named garnishee, Sovereign Bank, at 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Julie Myers, Branch Operations 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 January 18, 2011 to Ashley Wilson, 316 Elwood Street, Easton, PA 18045. SO ANSWERS, January 19, 2011 RON R ANDERSON, SHERIFF ,Shkwn ha 1, ci coun'ySuite Shertl'. ieleosft. Inc. KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 RACHAEL SEIBEL, ET AL. IN THE COURT OF COMMON PLEAS OF 506 BARD DRIVE CUMBERLAND COUNTY, PENNSYLVANIA SHIPPENS BURG, PA 17257 CIVIL ACTION - LAW Plaintiff NO. 2010-7781-CIVIL V. ASHLEY WILSON 316 ELWOOD STREET EASTON, PA 18045 C Defendant ~o rncu +" 7r: M = - i V. nr SOVEREIGN BANK < r. , 17 WEST HIGH STREET ? ~j CARLISLE, PA 17013 Garnishee Interrogatories to Garnishee Sovereign Bank (Garnishee): You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? NO 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? YES SEE ATTACHED 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? NO 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? NO KEEFER WOOD ALLEN & RAHAL, LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? NO 6. At anytime after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? NO KEEFER WOOD ALLEN & RAHAL, LLP Date: December 31, 2010 By: Eugene ky, Jr. Attorney I.D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-•8051 Attorneys for Plaintiff ANSWERS TO INTERROGATORIES Account # 0081085702 Balance: $2,888.75 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $2,588.75. Account Holder: ASHLEY E WILSON 316 ELWOOD ST EASTON, PA 18045-3719 VERIFICATION I, John S. Gomes, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank By: John S. Gomes C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: RACHAEL SEIBEL, ET AL VS. ASHLEY E WILSON CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: EUGENE E. PEPINSKY, JR. ESQUIRE KEEFER,WOOD,ALLEN & RAHAL,LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108-1963 Service by certified mail addressed as follows: ASHLEY E WILSON 316 ELWOOD ST EASTON, PA 18045-37'19 John S. Gomes C.O.P. Lead Specialist Sovereign Bank MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 January 27, 2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: RACHAEL SEIBEL, ET AL VS. ASHLEY E WILSON CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: EUGENE E. PEPINSKY, JR. ESQUIRE KEEFER,WOOD,ALLEN & RAHAL,LLP 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108--1963 Service by certified mail addressed as follows: ASHLEY E WILSON 316 ELWOOD ST EASTON, PA 18045-37119 John S. Gomes C.O.P. Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 January 27, 2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Loll 'V"' THE PROTHONOTARY 2011 SEP -2 PM 2: 37 Richard W Stewart Solicitor CUMBERLAND COUNT,/ PENNSYLVANIA Rachel Seibel Case Number vs. Ashley Wilson 2010-7781 SHERIFF'S RETURN OF SERVICE 01/18/2011 01:31 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 18, 2011 at 1331 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Ashley Wilson, in the hands, possession, or control of the within named garnishee, Sovereign Bank, at 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Julie Myers, Branch Operations 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 January 18, 2011 to Ashley Wilson, 316 Elwood Street, Easton, PA 18045. 09/01/2011 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: $87.50 SO ANSWERS, September 01, 2011 RON R ANDERSON, SHERIFF r) re) f/ . l'e?. 46f 53.E a ?& y,.-Li? C Counry3uite hentf. feecs:;tt. In;:.