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Home My WebLink About11-5714WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-5714 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GUARDIAN PROTECTION SERVICES Plaintiff (s) From JAY SCOTT STEWART, 181 WARM SUNDAY WAY, MECHANICSBURG, PA 17050 (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: SOVEREIGN BANK, 798 E. SIMPSON STREET, MECHANICSBURG, PA 17055 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$2,495.12 Interest Atty's Comm % Atty Paid $54.25 Plaintiff Paid Date: AUGUST 15, 2011 (Seal) REQUESTING PARTY: L.L. $.50 Due Prothy $2.00 Other Costs David D. Buell, Prot n By: Deputy Name J. SCOTT WATSON, ESQUIRE Address: J. SCOTT WATSON, P.C. 24 REGENCY PLAZA GLENN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-358-9600 Supreme Court ID No. 41060 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Guardian Protection Services 174 Thorn Hill Road Warrendale, PA 15086 VS. Jay Scott Stewart 181 Warm Sunday Way Mechanicsburg, PA 17050 and Sovereign Bank 798 E. Simpson Stree Mechanicsburg, PA 17055 (Garnishee) 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, 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, 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) All checking accounts, savings accounts, monies on deposit, safM deposit boxes, and any other reapyor personalty which may be subject to levy in the possession of the Garnishee, Sovereign Bank, 798 E. Simpson Street. Mechanicsburg. PA 17055 and belonging to the Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ( ) Confessed Judgment (X) Other Q ? File No. 11-5714 Civil _n Amount Due $2,495.12v Interest to 7/17/11 - $ 62.37 C> ?- C) Atty's Comm ? --t '5 Costs -? - (indicate) Index the writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date 5'// / Signature: Print Name: Address: ?p ! / amn $ 9y SD Pa 0-" a). as ?? t t a.? oA 1 sy. a Attorney for: Telephone: Supreme Ct ID J. Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Plaintiff 610-359-9600 041060 S -TD LL Ck-A 4 1o"Ll 9-1+ MQOO Icq SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED-OFFICE Ronny R Anderson UE THE PRO I HOW 1AR Sheriff Jody S Smith 2011 AUG 19 AM G= 30 Chief Deputy Richard W Stewart CUMBERLAND PSYANIA COUNTY 4 Solicitor Guardian Protection Services I Case Number vs. 2011-5714 Jay Scott Stewart SHERIFF'S RETURN OF SERVICE 08/18/2011 09:45 AM - Stephen Bender, 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, Sovereign Bank at 17 West High Street, Carlisle, PA 17013, Cumberland County, by handing to Julie Myers, Branch Operations Manager, 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 August 18, 2011 to Jay Scott Stewart at 181 Warm Sunday Way, Mechanicsburg, PA 17050. SO ANSWERS, August 18, 2011 RON R ANDERSON, SHERIFF tephe Bender, Deputy iCi Goun'y5uite Shenff. Te'ecs?'t L?;;. J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 li gG 31 P', II =rI renhy Plaintiff DCLAIn%it &JA L... GUARDIAN PROTECTION SERVICES 174 Thorn Hill Road Warrendale, PA 15086 V. JAY SCOTT STEWART 181 Warm Sunday Way Mechanicsburg, PA 17050 S.S.N. XXX-XX-8707 and SOVEREIGN BANK 798 East Simpson Street Mechanicsburg PA 17055 ONMRLAND COUNTY COURT OF COMMON PLEAS NO. 11-5714 Civil SGATO? INTE ORIES IN ATTACHMENT TO: Sovereign Bank 798 E. Simpson Street Mechanicsburg, PA 17055 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. 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 the Defendant any money or were liable to the Defendant for any reason ? NO 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the point 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 ? YES, SEE ATTACHED 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 had an interest ? NO 5. At the time before or after you were served did 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? NO 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? 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 any 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. 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. Section 8123. If so, identify each account and the amount available in each account. NO 9. 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, exceeded the amount of the general monetary exemption under 42 Pa.C.S. Section 8123? If so, identify each account and the amount available in each account. YES J. SCOTT WATgON, ESQUIRE Attorney for Plaintiff ANSWERS TO INTERROGATORIES Account # 3484000181 Balance.- $3,050.89 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $2,750.89. Account Holder- JAY S STEWART 181 WARM SUNDAY WAY MECHANICSBURG, PA 17050-3801 VERIFICATION I, John S. Gomes, C.O. P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank John S. Gomes C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: GUARDIAN PROTECTION SERVICES vs. JAY S STEWART CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s)- Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows. J. Scott Watson, Esquire J. Scott Watson, P.C. 24 Regency Plaza Glen Mills, PA 19342 Service by certified mail addressed as follows: JAY S STEWART 181 WARM SUNDAY WAY MECHANICSBURG, PA 17050-3801 i' ohn S. Gomes C.O.P. Lead Specialist Sovereign Bank MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 August 29, 2011 J. SCOTT WATSON, P.C. BY: GREGORY J. ALLARD, ESQUIRE Identification Number 92218 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 GUARDIAN PROTECTION SERVICES V. JAY SCOTT STEWART 10 C, T /2 4 PH I: 4 'UMBE RLAND COUNT'1, ENNSYLVANIA Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 11-5714 Civil ORDER TO SATISFY JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly mark the judgment against Garnishee, Sovereign Bank, in the above matter as satisfied upon payment of your costs only. G GORY J. ALLARD, ESQUIRE Attorney for Plaintiff as ag wr4 a? ?- 1 U(-aI& J. SCOTT WATSON, P.C. BY: GREGORY J. ALLARD, ESQUIRE Identification Number 92218 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 GUARDIAN PROTECTION SERVICES V. JAY SCOTT STEWART Attorney for Plaintiff tom, `. CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 11-5714 Civil ORDER TO. SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the Money Judgment in the above matter as satisfied upon payment of your costs only. GREGORY J. ALLARD, ESQUIRE Attorney for Plaintiff goo PD KrM C# 5367 SHERIFF'S OFFICE OF CUMBERLAND COUNTY f R Anderson ri?ut,rrF,iIto r THt i ?liydl ,y S Smith lief Deputy ,tichard W Stewart Solicitor ?392 NAR 27 P19 2 ?t CUMBERLAND s?t?CJs PENNSYLVANIIA Guardian Protection Services Case Number vs. 2011-5714 Jay Scott Stewart SHERIFF'S RETURN OF SERVICE 08/18/2011 09:45 AM - Stephen Bender, 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, Sovereign Bank at 17 West High Street, Carlisle, PA 17013, Cumberland County, by handing to Julie Myers, Branch Operations Manager, 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 August 18, 2011 to Jay Scott Stewart at 181 Warm Sunday Way, Mechanicsburg, PA 17050. 03/27/2012 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: $88.13 SO ANSWERS, RON R ANDERSON, SHERIFF March 27, 2012 1A.A <,?, ii7 0,tr a-? 30-2