HomeMy WebLinkAbout11-4495IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
RANDALL LAKEFISH,
Plaintiff
V. :
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SOLUTION INFUSION LLC rn c. -_?
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Defendant --<> rv C-1
NO.: 11-4495 <
and
GRAYSTONE TOWER BANK, : -?
Garnishees
ANSWERS TO INTERROGATORIES
IN ATTACHMENT ADDRESSED TO GARNISHEE,
GRAYSTONE TOWER BANK
By: a
anie L. Vanderau, Esq.
Associate Counsel
Graystone Tower Bank
112 Market Street
Harrisburg, PA 17101
(717) 728-2628
Attorney for Garnishee,
Graystone Tower Bank
1
GARNISHEE'S ANSWERS TO INTERROGATORIES
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 him any money or were liable to him for any reason?
ANSWER: Graystone Tower Bank maintains the following account for
Solution Infusion LLC:
Checking account number XXXXXX4737. The balance in the
account on the day of service was $3.65.
Checking account number XXXXXX8531 is closed.
The open account was not frozen, restricted or otherwise put on
hold by Graystone Tower Bank as the dollar amount in the
account, at the time of service, was less than the $300.00 statutory
exemption.
2. At the time you were served or at any subsequent time was there in your possession,
custody or control of yourself and one more other persons any property of any nature
owned solely or in part by the Defendant?
ANSWER: 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 the
Defendant held or claimed any interest?
ANSWER: No.
4. At the time you were served or at any subsequent time, did you hold as a fiduciary any
property in which Defendant had an interest?
ANSWER: No.
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 directions or consent and if so,
what was the consideration thereof?
ANSWER: No.
2
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 the Defendant's direction or
otherwise discharge any claim of the Defendant against you?
ANSWER: 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 amount of funds in each account,
and the entity electronically depositing those funds on a recurring basis.
ANSWER: No.
8. 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 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.
ANSWER: No.
Respectfully submitted,
GRAYSTONE TOWER BANK
By: A4?Y-6--
9461anie L. Vanderau
Attorney I.D. No. 203167
112 Market Street
Harrisburg, PA 17101
(717) 728-2628
Attorney for Garnishee,
Graystone Tower Bank
Date: June 1, 2011
3
VERIFICATION
Kimberly Taylor deposes and says, subject to the penalties of 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities, that she is the Deposit Operations Manager/AVP of
Graystone Tower Bank, that she makes this verification by its authority and that the facts set
forth in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of
her knowledge, information and belief.
Date: June 1, 2011
me: Ki berl Taylor
itle: Deposit Operations Manager/AVP
4
CERTIFICATE OF SERVICE
I hereby certify that on June 1, 2011, a copy of the foregoing Answers to Interrogatories in
Attachment Addressed to Garnishee, Graystone Tower Bank, was served upon the persons and in
the manner listed below:
Service by U. S. first class mail as follows:
Solution Infusion LLC
415 Fallowfield Road
Camp Hill, PA 17011
Randall Lakefish
2614 NE 32nd Place
Portland, OR 97212
5
WRIT OF EXECUTION and/or ATTACHMENT
10? -
COMMONWEALTH OF PENNSYLVANIA)
COUN'T'Y OF CUMBERLAND)
NO 11-4495 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Randall Lakefish Plaintiff (s)
From Solution Infusion LLC
(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 Graystone Bank, 3599 Gettysburg Road, Camp Hill, PA 17011
GARNISF[EE(S) as follows:
Account Number: 1710008531, Routing Number: 031318907
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$1694.63
L. L.
Interest 9% per year - MOLy V. ao I/
Atty's Cornm %
Attv Paid
Plaintiff Paid 53.50
Date: May 20, 2011
(Seal)
2),
;--?/
B , Prothonota
By: -
Deputy
REQUESTING PARTY:
Name Randall Lakefish
Address: 1.614 NE 32"`' Place
Portland, OR 97212
Attorney for: NA
Telephone: 503-282-1301
Supreme Court ID No.
Due Prothy $2.00
Other Costs $259.10
TRUE COPY FROM RECORD
6 Toonony whereof. I here unto set my head
fed ft MW of seld Court at Caribie. Pa,
Prou?orwlsry
.'j SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
-
Jody S Smith 41t4
Chief Deputy
- L0119 JA 25 P 2: 1
Richard W Stewart
{?}?7 p
Solicitor r t = CUMBERL-k lij ?, u N, ti
PENNSY"! ??41A
Randall Lakefish
Case Number
vs.
Solution Infusion, LLC 2011-4495
SHERIFF'S RETURN OF SERVICE
05/27/2011 11:36 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 27,
2011 at 1136 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Solution Infusion, LLC , in the hands, possession, or control of the
within named garnishee, Graystone Bank, 3359 Gettysburg Road, Camp Hill, Cumberland County,
Pennsylvania 17011, by handing to Connie Fetrow-Ritz, Teller, personally two (2) true and attested copies
of the writ of execution and made the contents there of known to her. No interrogatories were served as
none were received.
01/24/2012 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: $97.'0
January 24, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF