HomeMy WebLinkAbout11-3519VALLEY QUARRIES, INC., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNS YLVANIA
vs. CIVIL ACTION NO.
AMOS BYLER and C -
BYLER CONTRACTORS
Defendants. a?
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PRAECIPE TO ENTER JUDGMENT
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TO THE PROTHONOTARY:
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Please enter on the Judgment Docket of the Court of Common Pleas of
Cumberland County, Pennsylvania, judgment in favor of Valley Quarries, Inc. and against Amos
Byler and Byler Contractors in the amount of $7,363.92, plus continuing interest and costs,
pursuant to the judgment entered by Magisterial District Judge Harold E. Bender on August 27,
2008. Defendant has made one payment of $200.00 on the judgment.
Respectfully submitted,
Date: April 6, 2011
A/ / ,P ) ? A /y tt,42?v
Pepper Hamilton LLP
100 Market Street, Suite 200
P.O. Box 1181
Harrisburg, PA 17108-1181
(717) 255-1155 - phone
(717) 238-0575 - fax
andersont(a)pepperlaw. com
weber]g_a pepperlaw.com
M THY B. ANDERSON (54034)
IN G. WEBER (89266)
Attorneys for Plaintiff
Valley Quarries, Inc.
COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil
COUFFTY OF CUMBERLAND Case
Mag. Dist. No: MDJ-09-3-01
MDJ Name: Honorable Harold E. Bender
Address: 35 West Orange Street
Shippensburg, PA 17257
Telephone: 717-532-7676
Byler Contractors
11173 Stonewall Rd
Shippensburg, PA 17257
Disposition Summary
Docket No
MJ-09301 -CV-00001 88-2008
Valley Quarries Inc
V.
Byler Contractors, Amos Byler
Docket No: MJ-09301-CV-0000188-2008
Case Filed: 7/28/2008 c'?
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Plaintiff Defendant Disposition
Valley Quarries Inc Byler Contractors Default Judgment for Plaintiff
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00ion Date
-08/27/2008
MJ-09301-CV-0000188-2008 Valley Quarries Inc Amos Byler Default Judgment for Plaintiff 08/27/2008
Judgment Summary Joint/Several Liability Individual Liability Amount
Participant
Amos Byler $7,363.92 $0.00 $7,363.92
Byler Contractors $7,363.92 $0.00 $7,363.92
Judgment Detail (*Post Judgment)
In the matter of Valley Quarries Inc vs. Byler Contractors; Amos Byler on 8/27/2008 the disposition is Default Judgment for Plaintiff and
judgment was awarded as follows:
Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount
Civil Judgment $7,223.92 $0.00
$7,223.92
Costs $140.00 $0.00 $140.00
Grand Total: $7,363.92
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 COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF
JUDGMENT/TRANSCRIPT 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.
lxla'? sr
Date Magisterial District Judge Harold E. Bender
?"JNI Dir???
?I
I certify that this is a true and correct copy of t e ecord f the proceedings contaipi the judgmen
Date Magisterial District Judge Harold E. Bender
MDJS 315 Page 1 of 1 Printed: 03/30/2011 3:20:33PM
COMMONWEALTH OF PENNSYLVANIA
COUItTY OF CUMBERLAND
Notice of Judgment/Transcript Civil
Case
Mag. Dist. No: MDJ-09-3-01
MDJ Name: Honorable Harold E. Bender
Address: 35 West Orange Street
Shippensburg, PA 17257
Telephone: 717-532-7676
Amos Byler
11173 Stonewall Rd
Shippensburg, PA 17257
Disposition Summary
Docket No
MJ-09301 -CV-00001 88-2008
MJ-09301 -CV-00001 88-2008
Judgment Summary
Participant
Amos Byler
Byler Contractors
Plaintiff Defendant
Valley Quarries Inc Byler Contractors
Valley Quarries Inc Amos Byler
Joint/Several Liability Individual Liability
$7,363.92 $0.00
$7,363.92 $0.00
Valley Quarries Inc
V.
Byler Contractors, Amos Byler
Docket No:
Case Filed:
MJ-09301-CIM00088-!q08
7/28/2008 =
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Disposition Disposition Date
Default Judgment for Plaintiff 08/27/2008
Default Judgment for Plaintiff 08/27/2008
Amount
$7,363.92
$7,363.92
Judgment Detail ('Post Judgment)
In the matter of Valley Quarries Inc vs. Byler Contractors; Amos Byler on 8/27/2008 the disposition is Default Judgment for Plaintiff and
judgment was awarded as follows:
Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount
Civil Judgment $7,223.92 $0.00 $7,223.92
Costs $140.00 $0.00 $140.00
Grand Total: $7,363.92
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 COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF
JUDGMENT/TRANSCRIPT 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.
14191-? 015 9011?
Date Magisterial District Judge Harold E. Bender
r
I certify that this is a true and correct copy of the record of the proceedings contajgi g the judgmen
/ .l
Date Magisterial District Judge Harold E. Bender
MDJS 315 Page 1 of 1 Printed: 03/30/2011 3:20:33PM
CERTIFICATE OF SERVICE
I hereby certify that on April 6, 2011,1 served a copy of the foregoing by placing
a copy of same in the United States mail, first class postage prepaid, addressed as follows:
Amos Byler
11173 Stonewall Rd.
Shippensburg, PA 17257
Byler Contractors
11173 Stonewall Rd.
Shippensburg, PA 17257
Q?'t ?Z' _
J st' . Weber (89266)
VALLEY QUARRIES, INC.,
Plaintiff
VS.
AMOS BYLER and
BYLER CONTRACTORS
Defendants.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION NO.
NOTICE OF ENTRY OF JUDGMENT
TO: Amos Byler
11173 Stonewall Rd.
Shippensburg, PA 17257
Byler Contractors
11173 Stonewall Rd.
Shippensburg, PA 17257
Pursuant to the requirements of Pa. R.C.P. No. 236, you are hereby notified that
on /? 7 , 2011, judgment in the amount of $7,363.92, together with
interest and costs, has been entered against you.
Date: W--7111
VALLEY QUARRIES, INC.,
Plaintiff
vs.
AMOS BYLER and
BYLER CONTRACTORS
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION NO.
NOTICE OF ENTRY OF JUDGMENT
TO: Amos Byler
11173 Stonewall Rd.
Shippensburg, PA 17257
Byler Contractors
11173 Stonewall Rd.
Shippensburg, PA 17257
Pursuant to the requirements of Pa. R.C.P. No. 236, you are hereby notified that
on Atiy . 7 , 2011, judgment in the amount of $7,363.92, together with
interest and costs, has been entered against you.
Date: L//7/i /
00,-%
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VALLEY QUARRIES, INC. IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
NO. 11-3519 Civil
VS.
AMOS BYLER and CIVIL ACTION - LAW
BYLER CONTRACTORS
I11-7 S 5.6 ?kk ga Defendants.
g1'?w2P?, ?W 1-79S7
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Please issue the writ of execution upon the judgment entered in the above matter:
(1) directed to the Sheriff of Cumberland County;
(2) against Amos Byler and Byler Contractors, Defendants; and
(3) against Orrstown Bank
22 South Hanover Street
Carlisle, PA 17013
(4) and index this writ:
(a) against Amos Byler and Byler Contractors, Defendants, and
(b) against , as garnishee,
as a lis pendens against real property of the Defendants in the name of the garnishee as
follows: None.
(5) attach the following property of the Defendants in the possession of Orrstown Bank as
garnishee:
S Any and all funds or other obligations owed to Amos Byler and Byler Contractors by or
in the custody or control of Orrstown Bank, or its agents.
?7 a s ter
#CL14Lf 5 ?? $a'go?L $oga
?".( Ck.? 189ao ? as
Dated: April 13, 2011
Amount Due
Interest of 6% per annum from August 27,
2008 through April 13, 2011
Attorney's Commission
Costs
$7,363,92
$959.75 ($1,159.75-$200 payment)
(;? ?'l ?
Ti othy B. Anderson (54034)
Justin G. Weber (PA 89266)
PEPPER HAMILTON LLP
100 Market Street, Suite 200
P.O. Box 1181
Harrisburg, PA 17108-1181
717.255.1155
717.238.0575 fax
weberj g@pepperlaw.com
Attorneys for Plaintiff
Valley Quarries, Inc.
#14132625 v1
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-3519 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due VALLEY QUARRIES, INC. Plaintiff (s)
From AMOS BYLER AND BYLER CONTRACTORS, 11173 STONEWALL ROAD,
SHIPPENSBURG, PA 17257
(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:
ORRSTOWN BANK, 22 SOUTH HANOVER STREET, 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 $7,363.92
L.L.$.50
Interest of 6% per annum from August 27, 2008 through April 13, 2011 - $959.75
Atty's Comm % Due Prothy $2.00
Atty Paid $54.25
Plaintiff Paid
Date: 4/14/11
Other Costs
David D. Buell, Prothonotary
(Seal) By:
REQUESTING PARTY:
Name JUSTIN G. WEBER, ESQUIRE
Address: PEPPER HAMILTON LLP
100 MARKET STREET, SUITE 200
P.O. BOX 1181
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-255-1155
Supreme Court ID No. 89266
Deputy
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
FILED-OFFIC-"
1 F THE PROTHONOTAR'
2011 APR 25 AM 10: 1 e
Richard W Stewart
Solicitor
fif
CUMBERLAND COU
;PENNSYLVANIA
Valley Quarries Inc. Case Number
vs. 2011-3519
Amos Byler (et al.)
SHERIFF'S RETURN OF SERVICE
04/20/2011 11:15 AM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on April
20, 2011 at 1114 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Amos Byler and Byler Contractors, in the hands, possession,
or control of the within named garnishee, Orrstown Bank, 22 S Hanover Street, Carlisle, Cumberland
County, Pennsylvania 17013, by handing to Ellen Strawmyre, Teller, 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 April 21, 2011 to Amos Byler at 11173
Stonewall Road, Shippensburg, PA 17257 and Byler Contractors, 11173 Stonewall Road, Shippensburg,
PA 17257.
SO ANSWERS,
April 21, 2011 RON R ANDERSON, SHERIFF
tc; our`y u!! ShEo qf, Teleaso`t, nt.
Gerald Worthi on, Deputy
LE Ji HONO W"
Timothy B. Anderson (PA 54034)
Justin G. Weber (PA 89266)
PEPPER HAMILTON LLP
100 Market Street, Suite 200
Post Office Box 1 181
Harrisburg, PA 17108-1181
717.255.1155
717.238.0575 Fax
1" 0! C S E P 16 A 9: 59
rfUMBERLANa COUNT
PENNSYLVANIA
Attorneys for Plaintiff
Valley Quarries, Inc.
VALLEY QUARRIES, INC. IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff.
NO. 11-3519 Civil
vs.
AMOS BYLER and CIVIL ACTION - LAW
BYLER CONTRACTORS
11113 s?l? 94d Defendants.
SWVP M51 IPp llath
X. I
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Please issue the writ of execution upon the judgment entered in the above matter:
(1) directed to the Sheriff of Cumberland County;
(2) against Amos Byler and Byler Contractors, Defendants; and
(3) against Orrstown Bank
22 South Hanover Street
Carlisle, PA 17013
(4) and index this writ:
(a) against Amos Byler and Byler Contractors, Defendants, and
(b) against Orrstown Bank, as garnishee,
Q as a lis pendens against real property of the Defendants in the name of the garnishee as
S follows: None.
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(5) attach the following property of the Defendants in the possession of Orrstown Bank as
garnishee:
Any and all funds or other obligations owed to Amos Byler and Byler Contractors by or
in the custody or control of Orrstown Bank, or its agents.
Amount Due $7,363.92
Interest of 6% per annum from August 27, $1,342.54
2008 through September 13, 2011
Minus payment ($200.00)
Minus garnishment payment ($1,677.08)
Attorney's Commission $
Costs $
Dated: September 14, 2011
C?'L (?.,, U-,
Ti y B. Anderson (54034)
Justin G. Weber (PA 89266)
PEPPER HAMILTON LLP
100 Market Street, Suite 200
P.O. Box 1181
Harrisburg, PA 17108-1181
717.255.1155
717.238.0575 fax
weberj g@pepperlaw.com
Attorneys for Plaintiff
Valley Quarries, Inc.
414846094 vl
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-3519 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due VALLEY QUARRIES, INC. Plaintiff (s)
From AMOS BYLER AND BYLER CONTRACTORS, 11173 STONEWALL ROAD,
SHIPPENSBURG, PA 17257
(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:
ORRSTOWN BANK, 22 SOUTH HANOVER STREET, 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 $5,486.84
L.L.
Interest of 6% per annum from August 27, 2008 through September 13, 2011 - $1,342.54
Atty's Comm %
Arty Paid $98.25
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: SEPTEMBER 16, 2011
(Seal
REQUESTING PARTY:
"lame JU4TIN G. WEBER, ESQUIRE
Address; PEPPER HAMILTON LLP
100 MARKET STREET, SUITE 200
P.O. BOX 1181
HARRISBURG, PA 17108-1181
Attorney for: PLAINTIFF
Telephone: 717-255-1155
Supreme Court ID No. 89266
David D. Buell, Prothonotary
B:
Deputy
SHERIFF'S OFFICE OF CUMBERLANQ,C'?PJ?TY
Ronny R Anderson
Sheriff
? F? ?? `, .
Jody S Smith 2 Chief Deputy C IU M B E R L A 1 i3 u" R ti
Richard W Stewart PENNSYI V` 'i flA
Solicitor
Valley Quarries Inc.
vs.
Amos Byler (et al.)
Case Number
2011-3519
SHERIFF'S RETURN OF SERVICE
09/23/2011 10:59 AM - William Cline, 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, Orrstown Bank at 22 S Hanover Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to Ellen Strawmyer, Teller, 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 September 23, 2011 to Amos Byler & Byler
Contractors at 11173 Stonewall Road, Shippensburg, PA 17257.
SO ANSWERS,
September 23, 2011 RONO R ANDERSON, SHERIFF
it iam Cline, Deputy
jel Gou"'ySuite Sne r,-E i elec;: e't. In;;
Timothy B. Anderson (PA 54034)
Justin G. Weber (PA 89266)
PEPPER HAMILTON LLP
100 Market Street, Suite 200
Post Office Box 1 181
Harrisburg. PA 17108-1 181
717255.1155
717.238.05 Ti Fax
VALLEY QUARRIES, INC.
Vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. I1-3519 Civil
AMOS BYLER and CIVIL ACTION - LAW
BYLER CONTRACTORS
Defendants.
GARNISHEE ORRSTOWN BANK'S ANSWERS TO
INTERROGATORIES IN ATTACHMENT
PURSUANT TO Pa. R. Civ. P. 3144 and 3253
TO: Orrstown Bank
22 South Hanover Street
Carlisle, PA 17013
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.
Definitions and Instructions
1. When used in these interrogatories, the tenn "Defendants" shall mean the
above-named Defendants, Amos Byler and/or Byler Contractors.
2. '\ TThen used in these interrogatories, the term "you" shall mean Orrsto\\ n
Bank.
3. When used in these Definitions and Instructions and interrogatories. the
conjunetiorts "and" and "or" shall be interpreted to mead "and/or."
JlP r7 ?. a, J
Attornevs for Plaintiff
Valle)' Quarries, Inc..
Plaintiff.
7&1609.1 vl
4. These interrogatories shall be deemed continuing and supplemental
answers shall be required if you directly or indirectly obtain further information of the nature
sought herein.
INTERROGATORIES
At the time you were served, or at any subsequent time, or at anytime
within one (1) year prior to the date you were served, did you owe either of the Defendants any
money or were you liable to Defendants on any negotiable or other written instrument. or did
Defendants claim that you owed them any money or were liable to them for any reason? 11-so.
specify the nature and amount of such liability or claim and, if applicable, the negotiable or other
written instrument on which such liability or claim is based.
ANSWER:
No.
1,9,601), VI
At the time you were served, or at any subsequent time, or at anytime
within one (l) year prior to the date you were served, was there in your possession, custody or
control or in the joint possession, custody or control of yourself and one or more persons any
property of any nature owned solely or in part by either of the Defendants? If so, describe the
property and specify the ownership, location and fair market value of such property.
AWNTER:
Yes. Free business checking Acct. # 103900271
"14846094 vl
At the time you were served, or at any subsequent time, or at anytime
within one (1) year prior to the date you were served, did you hold legal title to any property of
any nature owned solely or in part by Defendants or in which Defendants held or claimed any
interest? If so, describe the property and specify the ownership, location and fair market value ()f
such property, together with the extent of Defendants' ownership interest therein and the val ue
thereof.
ANSWER:
No.
4148,16094 vi
4. At the time you were served, or at any subsequent time, or at anytime
within one (I) year prior to the date you were served, did you hold as fiduciary any property in
which Defendants had any interest`? If so, describe the property and specify the ownership.
location and fair market value of such property, together with the extent of Defendants'
ownership interest therein and the value thereof.
ANSWER:
Yes. Free business checking Acct. #
103900271 with a balance of $32.58.
X14646094 vi
At any time before or after you were served did Defendants transfer or
deliver any property to you or to any person or place pursuant to your direction or consent? ] f
so, describe the property, when and to whom it was transferred or delivered and the
consideration thereof.
ANSWER:
Deposits to free business checking
Acct # 103900271 prior to service.
%14846094 vI
6. At any time after you were served, did you pay, transfer or deliver anv
?noney or property to Defendants or to any person or place pursuant to their direction or
otherwise discharge any claim of Defendants against you? If so, describe the property or amount
of money. ?,vhen and to whom the money or property was transferred or delivered.
ANSWER:
No.
r14846091? 1
At the time you were served, or at any subsequent time, or at anytime
within one (1) year prior to the date you were served, did either of the Defendants maintain with
you at your main office or any of your branch offices, any bank accounts or safe deposit boxes,
or did vouu hold any money of either of the Defendants in any capacity whatsoever? If so,
specify the account names, account numbers, safe deposit box numbers, account types. balances
on the date you were served and current balances.
ANSWER:
Yes. The answer to this interrogatory
No. 4 is incorporated herein by reference
as though set forth at length.
At the time you were served, or at any subsequent time, or at anytime
within on (1) year prior to the date you were served, did either of the Defendants own jointly
with any other person or entity any bank accounts or safe deposit boxes held by you? If so,
specify the account names, account numbers, safe deposit box numbers, account types, balances
on the date you were served and current balances.
ANSWER:
Yes. The answer to interrogatory no. 4
is incorporated herein by reference as
though set forth at length.
I4846U9=1 vt
9. At the time you were served, or at any subsequent time, or at anytime
within one (1) year prior to the date you were served, was any money on deposit for Delcndants
in any bank account in a name other than those previously listed? If so, specify the account.
names, account numbers, account types, balances on the date you were served and current
balances.
ANSWER:
Objection. This interrogatory is unduly
burdensome and not reasonably likely to
lead to the discovery of admissible evidence.
Dated: September 14, 2011 L
C?
Ti y B. Anderson (PA 54034)
.Justin G. Weber (PA 89266)
PEPPER HAMILTON LLP
100 Market Street, Suite 200
P.O. Box 1181
Harrisburg, PA 17108-1181
717,255.1 155
717.238.0575 fax
weberig?it)pepperlaw.com
Attorneys lur Plaintifl-
Valley Quarries, Inc.
rI:S :"I, )J 0
I 'David A. Baric
VERIFICATION
state that I am the attorney for
NX Orrstown Bank, a garnishee in this matter, that I am authorized to make this verification on
its behalf. and that the averments of fact in the foregoing document are true and correct to the
best ofmv k owledge, information and belief. This statement is made subject to the penalties of
18 Pa. C.S. § 4904 (unsworn falsification to authorities).
Gc
---- pk? 1.---
SiPlature David A. Baric, Esquire
Dated: October 4
, 2011
?14846094 vi
AS TO OBJECTIONS
BARI CHERER LLC
Date: October 4, 2011 4t -
David A. Baric, Esquire
I.D. 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
CERTIFICATE OF SERVICE
I hereby certify that on October 4, 2011, I, David A. Baric, Esquire of Baric Scherer LLC,
did serve a copy of the Garnishee Orrstown Bank's Answers To Interrogatories In Attachment
Pursuant To Pa.R.C.P. 3144 and 3253, by first class U.S. mail, postage prepaid, to the party listed
below, as follows:
Timothy B. Anderson, Esquire
Pepper Hamilton LLP
100 Market Street, Suite 200
P.O. Box 1181
Harrisburg, Pennsylvania 17108
David A. Baric, Esquire
VALLEY QUARRIES, INC.,
Plaintiff
vs.
AMOS BYLER and
BYLER CONTRACTORS
Defendants.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION NO. 11-3519 Civil
PRAECIPE TO SATISFY JUDGMENT
Please mark the judgment against Amos Byler and Byler Contractors in the
above-captioned matter satisfied.
Respectfully submitted,
T Y B. ANDERSON (54034)
C:) kjqJ'H
JUSTIN G. WEBER (89266)
Pepper Hamilton LLP
100 Market Street, Suite 200
C'J
P.O. Box 1181
_tw Harrisburg, PA 17108-1181
_. `-4 (717) 255-1155 - phone
(717) 238-0575 - fax
andersontL&pepperlaw.com
weberi ( ,pepperlaw.com
Date: January 23, 2012 Attorneys for Plaintiff
Valley Quarries, Inc.
CERTIFICATE OF SERVICE
I hereby certify that on January 23, 2012, I served a copy of the foregoing by
placing a copy of same in the United States mail, first class postage prepaid, addressed as
follows:
Amos Byler
11173 Stonewall Rd.
Shippensburg, PA 17257
Byler Contractors
11173 Stonewall Rd.
Shippensburg, PA 17257
J t' G. Weber (89266)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Jerson
smith
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lard W Stewart
elicitor
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Valley Quarries Inc.
vs. Case Number
Amos Byler (et al.) 2011-3519
SHERIFF'S RETURN OF SERVICE
09/22/2011 10:58 AM - William Cline, 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, 22 S Hanover Street, Carlisle Borough, Carlisle, PA 17013,
Cumberland County, by handing to ELLEN STRAWMYER, TELLER, personally two (2) true and attested
copies of the Writ of Execution and made the contents there of known to him/her.
09/23/2011 10:59 AM - William Cline, 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, Orrstown Bank at 22 S Hanover Street, Carlisle Borough, Carlisle,
PA 17013, Cumberland County, by handing to Ellen Strawmyer, Teller, personally three copies of
interrogatories together with three true and attested copies of the Writ of Execution and made the content:
there of known to her.
The writ of execution and notice to defendant was mailed on September 23, 2011 to Amos Byler & Byler
Contractors at 11173 Stonewall Road, Shippensburg, PA 17257.
03/22/2012 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: $96.90 SO ANSWERS,
March 22, 2012 RON R ANDERSON, SHERIFF
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
derson
smith
)eputy
,lard W Stewart
elicitor
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2012 MAP 23 PPI 2: 3 r.,
CUMBERLAND CUUNI-V
PENNSYLVANIA
Case Number
Valley Quarries Inc. 2011-3519
vs.
Amos Byler (et al.)
SHERIFF'S RETURN OF SERVICE
04/20/2011 ril - Gerald Worthington, Deputy Sheriff, who being
attached as herein commanded all goods, chattels,trriiglaw, states h s, debts that on
April credits,
April 200, , 2011 at 1114 hous att name dendant, to wit: Amos
BanBk,l22 SoHanovoer Street Carlisle,
hands, and monies of the within f the within named garnishee, Byler and
possession, or control sonally
three Cumberland County, Pennsylvania
with three true and Ellen Strawmyre, Teller,
of the wr it of executionrand made the copies
of interrogatories es together
contents there of known to her. 1 to Amos
at 11
173 The writ of execution an notice to defendant was 17257 and mailed on Contractors, 111731Stone al Roald, Shippe sburg,
Stonewall Road, Shippensbur9 PA
PA 17257.
03/22/2012 Ronny R. Anderson, Sheriff, No who action don writ uly sworn in over 6 riling to law, states this writ of execution is
returned as ABANDONEri
SO ANSWERS,
SHERIFF COST: $98.79
4RON ANDERSON, SHERIFF
March 22, 2012
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