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HomeMy WebLinkAbout11-4419SALDUTTI, LLC By: ROBERT L. SALDUTTI, ESQUIRE Identification No. 63867 800 N. Kings Highway, Suite 300 Cherry Hill, NJ 08034 Telephone: (856) 779-0300 Attorney for Plaintiff 200 Locust Street Unit 24E, North Philadelphia, PA 19106 PREMIER TRAILER LEASING, INC. Plaintiff V. WRIGHT TRANSPORTATION AND CHARLES WRIGHT, INDIVIDUALLY Defendant(s) COURT OF COMMON PLEAS _ CUMBERLAND COUNTY, PA c DOCKET NO. I- uI I ?+ n .-y PRAECIPE TO FILE AND INDEX FOREIGN JUDGMENT TO THE PROTHONOTARY: Pursuant to the Uniform Enforcement of Judgments Act, 42 PA. C.S.A. §4306 (the "Act"), kindly file and index the attached exemplified and certified copy of the Judgment, _ rr which is attached hereto and incorporated herein as Exhibit "A" entered in favor of plaintiff, Premier Trailer Leasing, Inc. and against Defendants, Wright Transportation and Charles Wright, Individually in the amount of $26,430.96 net of any credits, with interest at the rate of 4.00% per annum from March 18, 2010 until paid, plus costs and attorneys' fees, in an action captioned Premier Trailer Leasing, Inc. v. Wright Transportation and Charles Wright, Individually, No.L-5236-09; J274952-10, In the Superior Court of New Jersey, Law Division, Camden County. Certified docket entries were not available from this foreign 6o l $ a9. oa Pd a Ce. & 7Y31 a o ,25739? W c M04 l1ed court. The Affidavit required by the Act and the Certified of Address are attached hereto and incorporated herein as Exhibits "B" and "C", respectively. The time within which defendants had to appeal the entry of the judgment in the New Jersey courts has long expired. SALDUTTI, LLC Date: May 16, 2011 Robe 'L-'Saldutti, Esquire SALDUTTI, LLC 800 North Kings Highway, Suite 300 Cherry Hill, NJ 08034 Telephone : 856-779-0300 SUPERIOR COURT OF NEW JERSEY I, MITCHEL E. OSTRER, Judge of the Superior Court of New Jersey, do hereby I, Kathleen McCann, Chief, Superior Court Clerk's Office, The same being a Court of Record, do hereby certify That the foregoing is a true copy of the FINAL JUDGMENT BY DEFAULT AND TAXING OF COSTS filed and recorded as a lien October 26, 2010 in the cause wherein PREMIER TRAILER LEASING, INC. is the Plaintiff; and WRIGHT TRANSPORTATION AND CHARLES WRIGHT, Individually are the Defendants, now on file in my office. IN TESTIMONY WHEREOF, I have hereto set my hand and affixed the seal of Said Court, at Trenton, this Z Day of/&-,- two thousand- d ten. Chief certify that Kathleen McCann, whose name is subscribed to the above certificate, was, at that date thereof, and now is, the Chief, Superior Court Clerk's Office, that the foregoing attestation is in proper form, that the seal thereto annexed is the seal of said court, and that the signature of the said Kathleen McCann, is in her own proper handwriting. WITNESS my hand at the City of Trenton, this ,?- Day of Udr`C Two thousand and ten. Judge NOTE--This certificate is made pursuant to an act of Congress (Title 28 U.S. Code, Sec. 1738 effective September 1, 1948) - ? n IF OCT 2 6,2W SALDUTTI, LLC Robert L. Saldutti, Esquire 800 N. Kings Highway, Suite 300 Cherry Hill, NJ 08034 (856) 779-0300 ATTORNEYS FOR PLAINTIFF /D6Ir PREMIER TRAILER LEASING, I Plain SUPERIOR COURT OF NEW JERSEY.: N MEN IVISION COUNTY V. O CT 0 5 2010 DOCKET NO. L-5236;09 WRIGHT TRANSPOR PM)R CO Jff Civil Action CHARLES WRIGHT, I4%)=1RDefendant(s). FINAL JUDGMENT BY DEFAULT AND TAXING OF COSTS tRSa- io THIS MATTER coming before the court by Robert L. Saldutti, Esquire, from the law firm of Saldutti, LLC, appearing on behalf of the plaintiff and it appearing that a Complaint was filed in this matter and that the defendant was served with the Summons and Complaint and it further appearing that no Answer or appearance has been entered on behalf of the defendant and that the time within which to file a responsive pleading having past and default having been entered and proper notice having been given pursuant to R.4:43-2(d) and other good cause having been shown; IT IS on 18 q6 day of h' ar eJ\ , 2010, ORDERED that judgment be and hereby is entered against the defendants, WRIGHT TRANSPORTATION AND CHARLES WRIGHT, INDIVIDUALLY, and in favor of the plaintiff, PREMIER TRAILER LEASING, INC., in the amount of $20,952.77, together with contractual attorney's fees in the amount of $5,238.19, and court costs in the amount of $200.00, and attorney allowance for $40.00, for a total of $26,430.96. A s CLERK SALDUTTI, LLC By: ROBERT L. SALDUTTI, ESQUIRE Identification No. 63867 800 N. Kings Highway, Suite 300 Cherry Hill, NJ 08034 Telephone: (856) 779-0300 Attorney for Plaintiff 200 Locust Street Unit 24E, North Philadelphia, PA 19106 PREMIER TRAILER LEASING, INC. Plaintiff v. WRIGHT TRANSPORTATION AND CHARLES WRIGHT, INDIVIDUALLY Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA DOCKET NO. AFFIDAVIT OF UNAVAILABILITY OF CERTIFIED DOCKET ENTRIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. Robert L. Saldutti, Esquire, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff, that he is authorized to make this Affidavit on its behalf of plaintiff, Premier Trailer Leasing, Inc.; and that certified docket entries from the Superior Court of New Jersey, Law Division, Camden County in the matter of Premier Trailer Leasina, Inc. v. Wriaht Transportation and Charles Wright Individually were not available. Pursuant to the New Jersey Rules of Procedure concerning collection actions, I hereby certify that the time within which Defendants, Wright Transportation and Charles Wright had to appeal the entry of judgment entered against them on March 18, 2010 has expired. No further action was taken by the Defendants, Wright Transportayon and Charles Wright in the Superior Court of New Jersey, Law Division, Camden Coun concernina4his matter. Robert L. S, Sworn to subscre,4- be Fe s Ada(XV ?--? Esquire WWWR8X0FNW SALDUTTI, LLC By: ROBERT L. SALDUTTI, ESQUIRE Identification No. 63867 800 N. Kings Highway, Suite 300 Cherry Hill, NJ 08034 Telephone: (856) 779-0300 Attorney for Plaintiff 200 Locust Street Unit 24E, North Philadelphia, PA 19106 PREMIER TRAILER LEASING, INC Plaintiff V. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA DOCKET NO. WRIGHT TRANSPORTATION AND CHARLES WRIGHT, INDIVIDUALLY CIVIL ACTION Defendant(s) NOTICE OF ENTRY OF FOREIGN JUDGMENT To: WRIGHT TRANSPORTATION AND CHARLES WRIGHT, INDIVIDUALLY Pursuant to 42 Pa.C.S.A. §4306 and Pennsylvania Rule of Civil Procedure 236, notice is hereby given that on May Ig, 2011, a Foreign Judgment in the above-captioned matter has been entered against you in the amount of $26,430.96 plus interest at 4% per annum from March 18, 2010 until paid, and with additional interest, plus costs and attorney's fees. The above-mentioned Foreign Judgment is valid, enforceable and unsatisfied. If you have any questions regarding this notice, please contact Robert L. Saldutti, Esquire, Saldutti, LLC, 800 N. Kings Highway, Suite 300, Cherry Hill, NJ 08034. Dated: May 18, 2011 Prothonotary NOTE FOR DOCKET The above notice was mailed by first class mail to the judgment debtor on Prothonotary ?? SALDUTTI, LLC By: ROBERT L. SALDUTTI, ESQUIRE Identification No. 63867 800 N. Kings Highway, Suite 300 Cherry Hill, NJ 08034 Telephone: (856) 779-0300 Attorney for Plaintiff 200 Locust Street Unit 24E, North Philadelphia, PA 19106 PREMIER TRAILER LEASING, INC. Plaintiff V. WRIGHT TRANSPORTATION AND CHARLES WRIGHT, INDIVIDUALLY Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA DOCKET NO. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA Robert L. Saldutti, Esquire, being duly sworn according to law, deposes and says as follows: I. I am attorney for Plaintiff, Premier Trailer Leasing and, as such, have the authority to make this Affidavit pursuant to the Uniform Enforcement of Foreign Judgments Act, 42 Pa.C.S.A. §4306(c). 2. The judgment creditor is Premier Trailer Leasing, Inc., 991 Route 22 West, Bridgewater, NJ 08807. 3. The judgment debtors ("Defendants") are: Wright Transportation and Charles Wright, Individually. 4. The Defendants last known address is 160 Lamont Street, New Cumberland, PA 17070. The Foreign Judgment being transferred to this Court is valid, enforceable and unsatisfied. SALDUTTI, LLC By: ROBERT L. SALDUTTI, ESQUIRE Identification No. 63867 800 N. Kings Highway, Suite 300 Cherry Hill, NJ 08034 Telephone: (856) 779-0300 Attorney for Plaintiff 200 Locust Street Unit 24E, North Philadelphia, PA 19106 PREMIER TRAILER LEASING, INC. Plaintiff V. WRIGHT TRANSPORTATION AND CHARLES WRIGHT, INDIVIDUALLY Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA DOCKET NO. CERTIFICATE OF ADDRESSES I, Robert L. Saldutti, Esquire, hereby certify that the names and addresses of the proper person to receive this notice are: WRIGHT TRANSPORTATION 160 Lamont Street New Cumberland, PA 17070 CHARLES WRIGHT 160 Lamont Street New Cumberland, PA 17070 SALD Robert L.J SWAtti, Esquire SALDUTTI, LLC By: ROBERT L. SALDUTTI, ESQUIRE Identification No. 63867 800 N. Kings Highway, Suite 300 Cherry Hill, NJ 08034 Telephone: (856) 779-0300 Attorney for Plaintiff 200 Locust Street Unit 24E, North Philadelphia, PA 19106 PREMIER TRAILER LEASING, INC Plaintiff V. WRIGHT TRANSPORTATION AND CHARLES WRIGHT, INDIVIDUALLY Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA DOCKET NO. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADLEPHIA SS. Robert L. Saldutti, Esquire, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiff; that he is authorized to make this Affidavit on its behalf; and that the above named Defendant, Charles Wright, is over 18 years of age; the address of the Defendant is 160 Lamont Street, New Cumberland, PA 17070; the occupation of the Defendant is unknown; and Defendant is not in the Military Service of the United States, nor any State or Territory thereof or its allies in the Soldier' and Sai s' Civil Relief Act of 1940 and the Amendments thereto. See proof of non-military statu ached hereto. These statements are made subject to the penalties of I Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. r Robert L. Saldutti, Esquire 4 r 1 SALDUTTI, LLC By: ROBERT L. SALDUTTI, ESQUIRE Identification No. 63867 800 N. Kings Highway, Suite 300 Cherry Hill, NJ 08034 Telephone: (856) 779-0300 Attorney for Plaintiff 200 Locust Street Unit 24E, North Philadelphia, PA 19106 PREMIER TRAILER LEASING, INC Plaintiff V. WRIGHT TRANSPORTATION AND CHARLES WRIGHT, INDIVIDUALLY Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA DOCKET NO. CERTIFICATE OF SERVICE I, Robert L. Saldutti, hereby certify that on they day of May, 2011, I served the foregoing Praecipe to File and Index Foreign Judgment via United States first class mail, postage prepaid and certified mail, return receipt requested, upon the following: WRIGHT TRANSPORTATION 160 Lamont Street New Cumberland, PA 17070 CHARLES WRIGHT 160 Lamont Street New Cumberland, PA 17070 SALDUTTI°L C t Robert L. S 4td, Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 May-16-2011 05:16:16 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency WRIGHT CHARLES Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). 011 Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL htti)://www.defenselink.niil/fag/l)is/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 5/16/2011 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:HOLSHG09P0 https://www.dmdc.osd.mil/appj/scra/popreport.do 5/16/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Premier Trailer Leasing, Inc. ? Confessed Judgment ° Plaintiff ? Other rrtm x¦ :41 - VS. File No. 11-4419 x r 26,430.96 A t D -<> Wright Transportation, et al. moun ue ? _ -tom 1 Defendant Interest >c-a T Address: Atty's Comm ;> C- © r 160 Lamont Street Costs New Cumberland, PA 17070 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County County, for debt, interest and costs, upon the following described property of the defendant (s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle, PA 17013 f' and all other property of the defendant(s) in the possession, custody or control of the said arnishee(s). ? (Indicate) Index this writ against the garnishee (s) as a lis pendens again real estate of the defendant(s) described in the attached exhibit. f Date 07/29/2011 Signature: Print Name: Rob it L. aldutti, Esquire e? 44 ft 74 7.S Address: 800 N. Kings Highway. Suite 300 S V et ry ??cv . oo Co [V U fCf - Cherry Hill, NJ 08034 Attorney for: Premier Trailer Leasing, Inc. Telephone: 856-779-0300 Supreme Court ID No: 63867 * pew 11,4:, I1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-4419 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Premier Trailer Leasing, Inc. Plaintiff (s) From Wright Transportation Charles Wright 160 Lamont St., New Cumberland, PA 17070 (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 Members 1" Federal Credit Union GARNISHEE(S) as follows: 1711 Spring Road, 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 $26,430.96 Interest Atty's Comm % Atty Paid $56.00 Plaintiff Paid Date: 8/l/2011 (Seal) REQUESTING PARTY: Name Robert L. Saldutti, Esq. Address: 800 N. Kings Highway, Suite 300 Cherry Hill, NJ 08034 Attorney for: Premier Trailer Leasing Inc. Telephone: 856-779-0300 Supreme Court ID No. 63867 L.L. $.50 Due Prothy $2.00 Other Costs: avid D. Buell, Prothonotary Deputy A RECEIVED AUG 08 2011 PREMIER TRAILER LEASING, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. DOCKET NO. 11-4419 ' v WRIGHT TRANSPORTATION CIVIL ACTION-LAW t= d.' + 160 Lamont Street New Cumberland, Pa 17070 --<> c:v L ' z CHARLES WRIGHT ?CD 3> 160 Lamont Street 5; New Cumberland, Pa 17070 -? -' Defendant AND MEMBERS 1" FEDERAL CREDIT UNION Garnishee PLAINTIFF'S INTERROGATORIES IN ATTACHMENT TO: Members 1St Federal Credit Union 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 a default 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 him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? n0 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 owed solely or in part by the defendant? mo 3. At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owed solely or in part by the defendants or in which defendants held or claimed any interest? *s 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? 00 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? VO 6. At any time 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 his direction or otherwise discharge any claim of the defendant against you? W% 7. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax, or other accounts or deposits in which defendant has an interest? rs 1 sil a6t 1, 8. If your answer to any of the foregoing interrogatories was in the affirmative, set forth the approximate value of any such asset(s) and set forth the method of determining same. Respectfully submitted, bert L. Saldutti, Esquire Saldutti, LLC 800 N. Kings Highway Suite 300 Cherry Hill, NJ 08034 Telephone: 856-779-0300 Attorney for Plaintiff Date: July 25, 2011 f*vl"'St MEMBERS 1St FEDERAL CREDIT UNION August 8, 2011 Charles Wright 151 Reno Ave New Cumberland, PA 17070 Review Dates (60 Days): June 9, 2011 - August 8, 2011 Total Writ of Execution: $26,489.46 Cumberland County Docket Number: NO 11-4419 Civil Account Number: XXX413 Name on Account: Savings - 0000: Navarro & Wright Charles E. Wright (Authorized signer) Arlene Callahan (Authorized signer) Paul J. Navarro (Authorized signer) $ 5.00 $ 20.00 (Processing Fee) $ -5.00 (Membership Fee) $0.00 $300.00 Statutory Exemption was not taken out. - dIZ411 Pe llI k, y . Wall po it Operati ns Analyst Rev: 06/11 5000 Louise Drive - P.O. Box 40 - Mechanicsburg, Pennsylvania 17055 - (800) 283-2328 - www.memberslst.org 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 Kelly L Hall (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. SHERIFF'S OFFICE OF CUM13ERLAjQ P14 Ronny R Anderson Sheriff NN pp pp 20 11 AUG 12 HM 8' 0 3 Jody S Smith Chief Deputy C MBERLAND CrJUN I Richard W Stewart PENNSYLVANIA Solicitor I, F Premier Delivery Co. vs. Wright Transporation (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2011-4419 08/05/2011 11:25 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, Members 1st FCU at 1166 WALNUT BOTTOM RD, SOUTH Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to ASHLEY HOKE, TELLER, personally 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 August 8, 2011 to Charles Wright & Wright Transporation at 160 Lamont Street, New Cumberland, PA 17070. SO ANSWERS, August 08, 2011 ROW Y R DERSON, SHERIFF it iam Cline i, t;ourtySuite SFerdf. Tc;'ene o't. Lx; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ?Ke PRAECIPE FOR WRIT OF EXECUTION Premier Trailer Leasing, Inc. Plaintiff vs. Charles Wright Defendant Address: 1560 Robinhood Drive Etters, PA 17319 XXX-XX-9418 ? Confessed Judgment ? Other File No. 11-4419 ; rn En a Amount Due 26,430.96 ? I z Interest ?'Z Atty's Comm 4 n C Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County County, for debt, interest and costs, upon the following described property of the defendant (s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) .Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle, PA 17013 and all other property of the defendant(s) in the possession, custody or control of the said,*mishee(s). ? (Indicate) Index this writ against the garnishee (s) as a lis pendens agai f real estate of the defendant(s) described in the attached exhibit. / Date 8/10/2011 Signature: Print Name: Robert/f. S?utti, Esquire Address: 300 N. Kk<s Highway, Suite 300 Cherry Hill, NJ 08034 Attorney for: Premier Trailer Leasing, Inc. 856-779-0300 Supreme Court ID No: 63867 Telephone: VC-1U- 11 V,?.Va CnVll-JC11UUl11 LLV CJU ( (J VQJJ 1 1101 1 vi"./ vv? t a. v PREMIER TRAILER LEASING, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. DOCKET NO. 11-4419 WRIGHT TRANSPORTATION CIVIL ACTION-LAW t?7 zm. =M c/o Charles Wright -4.rrs c 1560 Robinhood Drive r > Etters, PA 17319-9529 ' CHARLES WRIGHT RECENED > CC 3 7z - 1560 Robinhood Drive AUG 18 2011 :>= E3 c) Etters, PA 17319-9529 _ »s Defendant and MEMBERS 1ST FEDERAL CREDIT UNION Garnishee p,naws PLAIN'TIFF'S INTERROGATORIES IN ATTACHMENT TO: Members 1" Federal Credit Union 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 a default 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 him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason?46 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 owed solely or in part by the defendant? 40 3. At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owed solely or in part by the defendants or in which defendants held or claimed any interest? 00 4. At the time you were served or at any subsequent time, did you hold as fiduciary any YJO-1U- L.1 U0. VO rnUL7-Jd1UULL1 LLl/ t3U0- (! J-Y1JUU 1'-1x11 1 UVJJ/ VVJ...1 t -31 v property in which the defendant had an interest? N 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? 06 6. At any time 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 his direction or otherwise discharge any claim of the defendant against you? Q 7. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tai., or other accounts or deposits in which defendant has an interest? yl?8. If your answer to any of the foregoing interrogatories was in the affirmative, set forth the approximate value of any such asset(s) and set forth the method of determining same. src aj ?ac,krr? Date: August 15, 2011 Rober[ S utti, Esquire Saldutti, C 800 N. Things Highway Suite 300 Cherry Hill, N] 08034 Telephone: 856-779-0300 Attorney for Plaintiff A f4vle MEMBERS 1St FEDERAL CREDIT UNION August 19, 2011 Charles Wright 1560 Robin Hood Drive Etters, PA 17319 Review Dates (60 Days): 6/19/2011 - 8/18/2011 Total Writ of Execution: $26,489.46 Cumberland County Docket Number: No. 11-419 Civil File # No. 11-419 Civil Account Number: XXX123 Name on Account: Savings- 0000: Checking - 0011: Account Number: XXX517 Name on Account: Balance: Account Number: XXX847 Name on Account: Balance: Account Number: XXX001 Name on Account: Balance: Account Number: XXX297 Wright Express Service Co, LLC Charles Wright (Authorized Signer) Palmina Wright (Authorized Signer) $ 1,005.00 $ 33,633.00 -$ 50.00 (Processing Fee) $ 33,583.43 Wright Express Service Co, LLC Charles Wright (Authorized Signer) Palmina Wright (Authorized Signer) $12,981.88 Charles C. Wright $0.00 Palmina Wright Charles Wright $36.43 Name on Account: Valley Greet Mobile Repair Service Charles Wright (Authorized Signer) Balance: $1,211.91 $300.00 Statutory Exemption was not taken out. lly L. al Deposit perations Analyst 5000 LoVUt- Eft - P.O. Box 40 - Mechanicsburg, Pennsylvania 17055 - (800) 283-2328 - www.memberslst.org 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 Kelly L Hall (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. i (SIG A URE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?o,???tr of 4u?gbrr/,r?? OFF CE OF '-MFF OF THE FILED- ROTHO OFFICE Jody S Smith Chief Deputy Richard W Stewart Solicitor Premier Delivery Co. vs. Wright Transporation (et al.) 2011 AUG 22 AM 8: 4 0 CU P?NNSYLYAMIAM7Y Case Number 2011-4419 SHERIFF'S RETURN OF SERVICE 08/05/2011 11:25 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, Members 1 st FCU at 1166 WALNUT BOTTOM RD, SOUTH Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to ASHLEY HOKE, TELLER, personally 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 August 8, 2011 to Charles Wright & Wright Transporation at 160 Lamont Street, New Cumberland, PA 17070. 08/17/2011 02:15 PM - Robert Bitner, Deputy, who being duly sworn according to law, attached as herein commandec all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1 st FCU at 1166 WALNUT BOTTOM RD, SOUTH Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to ASHLEY HOCK-RECP., personally 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 August 18, 2011 to Wright Transportation and Charles Wright at 1560 Robinhood Drive, Etters, PA 17319. SHERIFF COST: $651.06 August 18, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF r it iam Cline, Deputy Robe t Bitner, Deputy (c; GountySwe Sheriff Te:eosoft inc SALDUTTI, LLC , BY: Robert L. Saldutti,'Esquire Identification No. PA-63867 800 N. Kings Highway, Ste 300 Cherry Hill, NJ 08034 (856) 779-0300 )ROTHOHO ARC l 200 Locust Street 2011 SEP - $ PH 2: D Unit 24E, North d „n 8-M WTPhiladelphia, PA 19106 Attorney for Ylalntltt t Ja'1L,I-RLHnu %Jww" - . PREMIER TRAILER LEASING, INC. OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. WRIGHT TRANSPORTATION 160 Lamont Street New Cumberland, Pa 17070 CHARLES WRIGHT 160 Lamont Street New Cumberland, Pa 17070 Defendant AND MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee DOCKET NO. 11-4419 CIVIL ACTION-LAW PRAECIPE FOR ENTRY OF JUDGMENT AGAINST GARNISHEE BASED UPON ADMISSION IN ANSWERS TO INTERROGATORIES IN ATTACHMENT TO THE PROTHONOTARY: Please enter judgment in favor of Premier Trailer Leasing, Inc., and against Garnishee, Members 1" Federal Credit Union, for $26,489.46, being the property of the Defendants, Wright Transportation and Charles Wright, admitted in the Garnishee's Answer to Interrogatories to be in the Garnishee's possession, which amount does not exceed the amount of the judgment of the Plaintiff against the Defendant together with interest and costs. A true and correct copy of Garnishee's Answers to Interrogatories in Attachment (filed with the Court on August 22, 2011) is attached hereto as ExWbit "A". SALDUTTI, ,C Attorney for Plaintiff Dated: August 26, 2011 ROBERT L. ESQUIRE %14.00 allA Cke? ?B Ilp ebhca W SALDUTTI, LLC BY: Robert L. Saldutti; Esquire Identification No. PA-63867 800 N. Kings Highway, Ste 300 Cherry Hill, NJ 08034 (856) 779-0300 200 Locust Street Unit 24E, North Philadelphia, PA 19106 Attorney for Ylaintitt PREMIER TRAILER LEASING, INC V. Plaintiff, WRIGHT TRANSPORTATION 160 Lamont Street New Cumberland, Pa 17070 CHARLES WRIGHT 160 Lamont Street New Cumberland, Pa 17070 Defendant AND MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 11-4419 CIVIL ACTION-LAW NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that judgment has been entered against Garnishee, Members I" Federal Credit Union in the above proceeding as indicated below: Judgment by Default Money Judgment Judgment on Award of Arbitrators Judgment on Verdict X Money Judgment on admitted amount: $26,489.46 Other IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY: Robert L. Saldutti, Esquire at this telephone number: 856-779-0300 A Q iac. i MEMBERS 1St FEDERAL CREDIT UNION August 23, 2011 Robert L. Saldutti, Esq. 800 N. Kings Highway, Suite 300 Cherry Hill, NJ 08034 RE: Writ of Execution for Charles Wright Dear Mr. Robert L. Saldutti, Esq.: A search of our records has revealed two (3) business checking accounts, (3) business savings accounts, one (1) personal checking accounts and two (2) personal savings accounts bearing the name Charles Wright with an address of 1560 Robin Hood Drive, Etters, PA 17319. The checking accounts reflect an available balance of $64,707.75. The savings accounts reflect an available balance of $47,713.51. Pursuant to the writ, $26,489.46 in the aforementioned accounts has been frozen. Pursuant to Rule 3111.1 of Title 231 as promulgated and made effective on April 1, 2007, the total balance of both accounts exceeds the general monetary exemption under 42 Pa. C.S. § 8123 and therefore are attachable. The full amount of the attachable funds is contained in the interrogatories as filed with the Cumberland County Prothonotary. Should you have any questions or need any additional information, feel free to contact me at (800) 283-2328, ext. 6353. Sincerely, LI/ ' j elly . Hall Deposit Operations Analyst Rev: 06/11 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org YJO-1:1- 11 YJJ.l1J C11Vll-JQ1UUlL1 LLV OJU ( f J VJJJ 1 .1W1 1 LpvC / a!- a a i m PREMIER TRAILER LEASING, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. DOCKET NO. 11-4419 WRIGHT TRANSPORTATION CIVIL ACTION-LAW do Charles Wright rTJCO Dn. 1560 Robinhood Drive M _ Etters, PA 17319-9529 U'9 k? rya K) :!30 -.CHARLES WRIGHT 1 1560 Robinhood Drive RECEIVED v c? Etters, PA 17319-9529 AUG 18 200 Defendant and MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee PLAIN'TIFF'S INTERROGATORIES IN ATTACHMENT TO: Members I" Federal Credit Union 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 a default 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 him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason7no ` 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 owed 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 owed solely or in part by the defendants or in which defendants held or claimed any interest? n() ?rt i? -+c7 4. At the time you were served or at any subsequent time, did you hold as fiduciary any V UQ-1:l- 11 UO. VO rnVl'1-JGt1UUL l l LLIJ OHO- 1 ! J-YJ3U? 1 -1VJ1 1 r1Y.1J1 IUIUJ L- -21 property in which the defendant hid an interest? 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? V10 6. At any time 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 his direction or otherwise discharge any claim of the defendant against you? 00 7. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax, or other accounts or deposits in which defendant has an interest? 8. If your answer to any of the foregoing interrogatories was in the affirmative, set forth the approximate value of any such asset(s) and set forth the method of determining same. ?& as +a.(w Respectful Robert 14 S utti, Esquire Saldutti, C 800 N. Kings Highway Suite 300 Cherry Hill, NJ 08034 Telephone: 856-779-0300 Attorney for Plaintiff Date: August 15, 2011 M A MEMBERS 1St FEDERAL CREDIT UNION August 19, 2011 Charles Wright 1560 Robin Hood Drive Etters, PA 17319 Review Dates (60 Days): 6/19/2011 - 8/18/2011 Total Writ of Execution: $26,489.46 Cumberland County Docket Number: No. 11-419 Civil File # No. 11-419 Civil Account Number: XXX123 Name on Account: Savings- 0000: Checking - 0011: Account Number: XXX517 Name on Account: Balance: Account Number: XXX847 Name on Account: Balance: Account Number: XXX001 Name on Account: Balance: Account Number: XXX297 Wright Express Service Co, LLC Charles Wright (Authorized Signer) Palmina Wright (Authorized Signer) $ 1,005.00 $ 33,633.00 -$ 50.00 (Processing Fee) $ 33,583.43 Wright Express Service Co, LLC Charles Wright (Authorized Signer) Palmina Wright (Authorized Signer) $12,981.88 Charles C. Wright $0.00 Palmina Wright Charles Wright $36.43 Name on Account: Valley Greet Mobile Repair Service Charles Wright (Authorized Signer) Balance: $1,211.91 $300.00 Statutory Exemption was not taken out. ;,1A lly L. all Deposit operations Analyst 5000 Lo-Wae:D*?tjt • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org 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 Kelly L Hall (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. l(N/ (SI P ATURE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY .nderson 1 S Smith ,fief Deputy Richard W Stewart Solicitor iii'... ''!2 HP 23 PM 2: u n °?P NSYLVANI Premier Delivery Co. vs. Wright Transporation (et al.) Case Number 2011-4419 SHERIFF'S RETURN OF SERVICE 08/05/2011 11:25 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, Members 1 st FCU at 1166 WALNUT BOTTOM RD, SOUTH Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to ASHLEY HOKE, TELLER, personally 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 August 8, 2011 to Charles Wright & Wright Transporation at 160 Lamont Street, New Cumberland, PA 17070. 08/17/2011 02:15 PM - Robert Bitner, Deputy, who being duly sworn according to law, attached as herein commander all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st FCU at 1166 WALNUT BOTTOM RD, SOUTH Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to ASHLEY HOCK-RECP., personally 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 August 18, 2011 to Wright Transportation and Charles Wright at 1560 Robinhood Drive, Etters, PA 17319. 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: $126.20 SO ANSWERS, March 22, 2012 RON R ANDERSON, SHERIFF so tt loe' _;'.,oll'l+ySull? hE'l TP.IPOsotl Inc,