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HomeMy WebLinkAbout11-2581WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-2581 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK, N.A. Plaintiff (s) From MICHAEL J. TROTTER, 8 HUMMEL AVENUE, APT. B, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: METRO BANK, 65 ASHLAND AVENUE, CARLISLE, PA 17013 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$6,045.56 Interest from April 29, 2011 - - $36.92 Atty's Comm % Atty Paid $176.00 Other Costs Plaintiff Paid Date: 6/27/11 (Seal) , REQUESTING PARTY: Name BARRY A. ROSEN, ESQUIRE Address: GOLDMAN & WARSHAW, P.C. 312 WEST BROAD STREET QUAKERTOWN, PA 18951 Attorney for: PLAINTIFF Telephone: 267-373-9730 L.L. $.50 Due Prothy $2.00 David D. Buell, Prothonotary Deputy Supreme Court ID No. 42951 Goldman & Warshaw, P.C. BY: Barry A. Rosen, Esquire PA Identification No: 42951 312 W. Broad Street Quakertown, PA 18951 267-373-9730 Counsel for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY JPMORGAN CHASE BANK, N.A. 1111 Polaris Parkway Columbus, OH 43240 VS. MICHAEL J TROTTER 8 HUMMEL AVE APT# B CAMP HILL PA 17011 and METRO BANK 65 ASHLAND AVE CARLISLE PA 17013 GARNISHEE DOCKET NO. : 11-2581 PRAECIPE FOR WRIT OF EXECUTION CAF05AV7 FiCE. „ THE FROTHONOTAR? 201 ! SUN 21 AM 9*- 38 CU PENNSYLVICOUNTY TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against MICHAEL J TROTTER defendant (s) and (2) against METRO BANK garnishee(s) (3) AMOUNT DUE INTEREST from April 29, 2011 COSTS Prothonotary fee Sheriff fee TOTAL &mk %aH. SO pd 0. 4 3.oo CKf 9a.W u<< tkA.w11" a. ? §Okj. $6,045.56 36.92 .00 .00 $6,082.48 BARRY A. R N, ESQUIRE Attorney for Plaintiff ? . ?U ,eta- r jL to C N `2 /3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED-OFI=1C? Ronny RAnderson `P THE PROTHONOTARY Sheriff rr Jody S Smith 2011 JUL 14 PM 2: 2+ Chief Deputy CUMBERLAND O[3?J°?TY Richard W Stewart Solicitor PENNSYLVANIA JP Morgan Chase Bank, NA vs. Michael J. Trotter Case Number 2011-2581 SHERIFF'S RETURN OF SERVICE 07/01/2011 02:57 PM - Shawn Harrison, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank at 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to CAROL WALTER - SENIOR CUSTOMER SERVICE REPRESENTATIVE, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. 07/11/2011 08:59 PM - Tim Black, Deputy , being duly sworn according to law, states that on July 11, 2011 at 8:59 PN hours, served the requested Writ of Execution and Claim for Exemption Form by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Michael J. Trotter at 8 Hummel Avenue, Apartment B, Lower Allen Township, tamp Hill, PA 17011, informed Defendant of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on 7-12-11. July 12, 2011 Ti of y Black Deputy foj Cow.:ySu le Sheriff T©:eosoft. Inc_ SO ANSWERS, CAF05457 Goldman & Warshaw, P.C. BY: Barry A. Rosen, Esquire PA Identification No: 42951 312 W. Broad Street Quakertown, PA 18951 267-373-9730 Counsel for Plaintiff JPMORGAN CHASE BANK, N.A. 1111 Polaris Parkway Columbus, OH 43240 vs. MICHAEL J TROTTER 8 HUMMEL AVE APT# B CAMP HILL PA 17011 and METRO BANK 65 ASHLAND AVE CARLISLE PA 17013 GARNISHEE Cl) --n rYit3o ` --r z _ ;C Mr-- r rv ... an r' COURT OF COMMON PLI? CQ c-n CUMBERLAND COUNTY; C. c DOCKET NO.: 11-2581 Answr,m INTERROGATORIES IN ATTACHMENT TO: METRO BANK - GARNISHEE You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so my result in judgment against you. At the time you were served or at any subsequent time did you owe the defendant(s) 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? Defendant has account xxxxxx3595 with a negative balance 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. no 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(s) had an interest? no 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and what was the consideration thereof? no 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to his(her, their) direction or otherwise discharge any claim of the defendant(s) against you? no 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. Not to the knowledge of Metro Bank 8. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. §8123? If so, identify each account. See answwer to question 1 9. How much is the value of any property in your possession belonging to the defendant(s)? DATE: BARRY ROSEN, ESQUIRE Attorney for Plaintiff METRO BANK - GARNISHEE: Date: By: Name/Title: VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIG AT RE) ou?ti? of ?unt?Pr?? RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 RICHARD W. STEWART Solicitor rn W a• m C ; f=- - o-) n? cn r 1 -'6 -< Cn •,' ? -? , ;- August 5, 2011 JP Morgan Chase Bank, NA - vs Michael J. Trotter Writ No. 2011-2581 Property Claim Determination To Whom It May Concern: Reference is made to Property Claim dated July 26, 2011, entered by Kerry Miller, Writ of Execution No. 2011-2581 Civil Term, JP Morgan Chase Bank, NA vs Michael J. Trotter. Ronny R. Anderson, Sheriff, has determined that the claimant, Kerry Miller, in the above mentioned property claim, is the owner of the property set forth in the claim. So Answers: Ronny R. Anders , Sheriff B- cc Barry A. Rosen, Atty for Plaintiff Michael J. Trotter Brought, Defendant Kerry Miller, Claimant NOTICE OF PROPERTY CLAIM JP Morgan Chase Bank, NA In the Court of Common Pleas Cumberland County, Pennsylvania VS Michael J. Trotter No. 2010-2581 Civil Term Writ of Execution TO THE DEFENDANT .AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Kerry Miller, claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 07-26-11 Cc Barry A. Rosen, Atty for Plaintiff Michael Trotter, Defendants Kerry Miller, Claimant S 'ff of Cumberl nd County B PROPERTY CLAIM ? ?p 1 0 lcXaC?..n ? o ? 1 VS TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. ? ?- a S?? The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: VALUE ltC•O0 ' 00 a 1 ?r'3Y4-oL? T7c-JQv1a(- \ ???w 1 `Jyc'? c7L) r ! c?c 1? L/I clor?i ) laid cisem ?THE PROPERTY AS FOLLOWS: Date ? ?E?? ?? Claimant K4rr- ?-/` r" State of P ylvama: County of Cumberland being duly sworn according to law, deposes and says that the above list in the property claim are correct and true. Swo d subscribe to b N sQ p day of o2 N TARK SEAL KER, NOTARY PUBLIC ro, Cumberland County My Commission Expires April 4, 2018 Clamant Cps ( P4 l-lvl l SHERIFF'S OFFICE OF CUMBERLAND COUNTY Anderson ay S Smith ,hief Deputy Richard W Stewart Solicitor ?t3its, t5i ?ttttah?., t L IN l;s- ? FEB 22 PPl 3: B3 UUMBERLA`0 cotjN o PENNSYLVANIA JP Morgan Chase Bank, NA vs. Michael J. Trotter Case Number 2011-2581 SHERIFF'S RETURN OF SERVICE 07/01/2011 02:57 PM - Shawn Harrison, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee„Metro Bank at 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to CAROL WALTER - SENIOR CUSTOMER SERVICE REPRESENTATIVE, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. 07/11/2011 08:59 PM - Tim Black, Deputy , being duly sworn according to law, states that on July 11, 2011 at 8:59 PN hours, served the requested Writ of Execution and Claim for Exemption Form by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Michael J. Trotter at 8 Hummel Avenue, Apartment B, Lower Allen Township, Camp Hill, PA 17011, informed Defendant of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on 7-12-11. 07/26/2011 On July 26, 2011, at 1445 hours, a property claim was filed by Kerry Miller. All parties notified by mail this date. 02/22/2012 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: $164.67 SO ANSWERS, February 22, 2012 RON R ANDERSON, SHERIFF , S`C' Z L1,6 a . 4" S.?