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Home My WebLink About11-3027w "J" Jackson Shrum ARCHER & GREINER, P.C. PA Bar No. 92265 One Liberty Place, 32nd Floor 1650 Market Street Philadelphia, PA 19103-7393 Mailing Address: 300 Delaware Avenue, Suite 1370 Wilmington, DE 19801 302-777-4350 1' 11 l ED-OFFICE 01- THE PROTHONOTARY 2011 JUN 24 PM 1: 53 CUMBERLAND COUNTY PENNSYLVANIA GROWMARK FS LLC 308 N.E. Front Street Milford, DE 19963 Plaintiff V. TROY A. WAGGONER 440 Mount Rock Road Newville, PA 17241 Attorneys for Plaintiff Growmark FS LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Action No. 11-3027 AFFIDAVIT OF SERVICE Defendant I hereby certify that on March 16, 2011, Defendant Troy A. Waggoner was served with the Court's Notice of Filing Judgment pursuant to the attached certified mail return receipt card which was returned from the United States Postal Service. Dated: June 15, 2011 Sworn to and subscri ed before me on the 15 day of , 20 .A / /,o 0 DAWN M.-, BR11Y NOTARY PUBLIC STATE OF DELAWARE MY COMMISSION EXPIRES OCTOBER 15, 2012 ?imimc?iriirisriwirrrzriarii?ieisisiosrr ARCHER & REINER, P.C. By: "J" Jackson Shrum (No. 92265) Attorney for Plaintiffs • C.orrrpNets Items 1, 2, and 3. Also complete Item 4 if feted Delivery is desired, t print your name and addrssa.on the reverse so that we can return the card to you. ¦ AtV,.h this card to the back of the mailpfet:e, or on the front If space Permits. 1. Article Addressed to: Troy A. Waggoner 440 Mount Rock Road Newville, PA 17241 2. Article Number (Transfer from Service PS A. ?aque ?, n f] Agent ? ? Addr?. B.SecGW by ( ) C. Date D*my D. Is dellmy address dlRerent from Item 1? O Yes If YES, enter delivery address below: ? No 3. Service Type IN CerMW Mall 13 Express Mai 0 Registered ? Return Reoeipt for Merd wsug" ? Insured Mail 13 C.O.D. 4. Restricted Deihrery? (Extra Fee) O rtes 7010 1670 0000 2745 2932 102W5-0244-150 "J" Jackson Shrum ARCHER & GREINER, P.C. PA Bar No. 92265 One Liberty Place, 32nd Floor 1650 Market Street Philadelphia, PA 19103-7393 Mailing Address: 300 Delaware Avenue, Suite 1370 Wilmington, DE 19801 302-777-4350 GROWMARK FS LLC 308 N.E. Front Street Milford, DE 19963 Plaintiff Attorneys for Plaintiff Growmark 2 LIg -11 Zrrnn c -- ?? - z;0 r -<> N v r:1 oQ <C? ,- cD C-3 =3: c?- C) i, C- .. r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Action No. 11-3027 V. TROY A. WAGGONER 440 Mount Rock Road Newville, PA 17241 PRAECIPE FOR WRIT OF EXECUTION Defendant TO THE PROTHONOTARY: Please issue summons for Writ of Execution (Money Judgment) in the above case and forward to the Sheriff of Cumberland County to serve Defendant. Please index this writ against Q Defendant as a lis pendens against the real and personal property of the Defendant. $ay pp ATey Principal: $ 8,305.47 Delaware Court Costs: $ 40.50 Awarded Attorney's Fees: $ 1,661.09 Interest accruing from 10/12/2010 at $1.43 per diem: $ 402.79 S.Ow Plus costs and endorsement hereon. . x4.00 CSP' 01. SO -55.50 - PO A W plus $1.43 per diem from 7/20/11 ARCHER?,GREINER, P.C. a.00 DveC> By: • Sa LL Dated: July 20, 2011 "J" Jackson Shrum (No. 92265) Attorney for Plaintiffs ejr 50.6ral 0q&4W" o WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-3027 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GROWMARK FS, LLC, Plaintiff (s) From TROY A. WAGGONER, 440 Mount Rock Road, Newville, PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell any real and 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: 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 $8,305.47 L.L. $.50 Interest from 10/12/10 @ $1.43 per diem - $402.79 plus $1.43 per diem from 7/20/11 plus costs and endorsement hereon Atty's Comm % Due Prothy $2.00 Atty Paid $55.50 Other Costs: Delaware Court Costs: - $40.50 Awarded Attorney's Fees: - $1,661.09 Plaintiff Paid Date: 7/21/11 David D-Bfrell, Prothonot (Seal) By: Deputy REQUESTING PARTY: Name '71 JACKSON SHRUM, ESQUIRE Address: ARCHER & GREINER, P.C. ONE LIBERTY PLACE, 32ND FLOOR 1650 MARKET STREET PHILADELPHIA, PA 19103-7393 Attorney for: PLAINTIFF Telephone: 302-777-4350 Supreme Court ID No. 92265 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY BRANCH, PENNSYLVANIA Growmark FS LLC Civil Division ,. 4 30 III ?1 ;_!J N3ERLAtQ COUNT { vs_ : ENNSYLYANIA No. 2011-3027 Troy A. Waggoner SUGGESTION OF BANKRUPTCY To: David D. Buell, Prothonotary Please note upon the record that Troy A. Waggoner, the defendant in the above- captioned action, filed a Voluntary Petition in Bankruptcy with the United States Bankruptcy Court for the Middle District of Pennsylvania at Harrisburg, PA, on August 25, 2011, at 8:58 o'clock A.M., which petition was docketed to 1-11-05863. PURSUANT TO THE PROVISIONS OF 11 U.S.C. §362(A), AN AUTOMATIC STAY IS IN EFFECT FOR ALL PROCEEDINGS INVOLVING THE ABOVE-NAMED DEFENDANT. CERTIFICATE OF SERVICE I, Richard L. Bushman, Esquire, attorney for the above captioned defendant in the bankruptcy proceeding before the United States Bankruptcy Court for the Middle District of Pennsylvania, do hereby certify that on the date set forth below I served the within "Suggestion of Bankruptcy" by depositing a copy of the same in the United States Mail, postage prepaid, at Spring Run, Pennsylvania, addressed to the parties or attorney's of record as follows: Growmark FS, LLC Archer & Greiner, P.C. 309 N.E. Front Street "J" Jackson Shrum, Esquire Milford, DE 19963 One Liberty Place, 32nd Floor 1650 Market Street Philadelphia, PA 19103-7393 Date: August 25, 2011 AL Richard L. Bushman, Esquire 16767 Path Valley Road P.O. Box 51 Spring Run, PA 17262-0051 [717] 349-7657 SHERIFF'S OFFICE OF CUMBERLAND COUNTY A Anderson dy S Smith ,hief Deputy Richard W Stewart Solicitor 00,1i' f' ILELI r i H:RCT?1,,'l'' 2912 JAN 19 AM 8: 34 CUMBERLAND COUNT PENNSYLVANIA Growmark FS LLC vs. Case Number . Troy A. Waggoner 2011-3027 SHERIFF'S RETURN OF SERVICE 07/27/2011 02:53 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Writ of Execution and Claim for Exemption Form to a person representing themselves to be CANDACE WAGGONER, WIFE, who accepted as "Adult Person in Charge" for the within named Defendant, to wit: Troy A. Waggoner at 440 Mount Rock Road, West Pennsboro Township, Newville, PA 17241, informed person of contents of same and levied upon personal property as directed. The writ of execution and notice to defendant was mailed on August 8, 2011 to Troy A. Waggoner at 440 Mount Rock Road, Newville, PA 17241. 08/16/2011 03:17 PM -Sale bill posted by Deputy Bitner on August 16, 2011. 08/17/2011 Sheriffs sale scheduled for August 25, 2011 at 3:00 p.m. 08/25/2011 Sheriff Sale scheduled for Aguust 25, 2011 cancelled. Defendant filed bankruptcy on this date. 01/18/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as STAYED. Defendant entered into bankruptcy. SHERIFF COST: $113.49 SO ANSWERS, January 18, 2012 RON R ANDERSON, SHERIFF ?? ,DD a ? Can 14.E 5?-s293 &C g?SJ (C (?OuntyJiLle Shen{, ieimsort, In( r-n M IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA -< -4 IN RE: CHAPTER 7 p Troy A. Waggoner Candace L. Waggoner Debtor - Troy A. Waggoner CASE NO. 1-11-bk-05863-MDF Movant vs. GROWMARK FS LLC Judicial Judgment Lien Avoidance Respondent ORDER OF COURT GRANTING JUDICIAL JUDGMENT LIEN AVOIDANCE Motion for Judicial Judgment Lien Avoidance having been made on December 13, 2011, said Motion being served that date, with Notice of opportunity to Object, and a certificate of service having been filed with the Clerk of this court, and no answer having been filed by the Respondent within the period allowed for Objection, now, therefore, IT IS ORDERED that Respondent's judicial lien filed in the office of the Prothonotary of the Court of Common Pleas of Cumberland County Pennsylvania to No. 11-3027 Civil, and in the Justice of the Peace Court of the State of Delaware in and for New Castle County [Court No. 131 to JP 13-10-011954 upon the household goods and furnishings of Movant is declared invalid under §522(f)(1) of the United States Bankruptcy Code. IT IS FURTHER ORDERED that the Respondent execute any releases necessary to clear such liens from any public record and the filing of a copy of this Order with the Prothonotary of Cumberland County and with the Clerk of the Justice of the Peace Court of the State of Delaware in and for New Castle County shall serve as a release of the lien of said judgment upon the real and personal property of Movant above described. This order shall not impair anyjudgment lien that Respondent has with respect to the Robert and Troy Waggoner Partnership and to the extent that Respondent's judicial lien attached to such partnership property as opposed to Movant's real or personal property, the judgment lien and shall remain in place not impaired by this order. 13v the Court, -?J 41-? go 4LL Chief Bankruptcy Judge Ctc4- 16$ 2- WK1 Dated: January 9, 2012 Case 1:11 ..bk-05863-MDF Doc 26 Filed 01/11/12 Entered 01/12/12 01:19:52 Desc Imaged Certificate of Notice Page 3 of 3