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HomeMy WebLinkAbout11-6508IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ERIE INSURANCE EXCHANGE Plaintiff CIVIL ACTI ON NO. 1 1-6508 VS. Amount Due $ 5,786.39 cc - , JOHN DAVIDSON d/b/a JOHN'S Interest $ 18.63 =?Q -0 REFRIGERATION Payments $0.00 c Defendant(s) ?tY10.r1 ?d ?1 S?1? Q ?Qng Costs e Pounda $ CZ) Q . - ` g - , F & M TRUST , ? --g Garnishee c 19b ?t 2r : Total $ 5,805.02 To the Prothonotary - Cumberland County: ISSUE A WRIT OF EXECUTION AND ATTACHMENT IN THE ABOVE MATTER. PRAECIPE WRIT OF EXECUTION Issue a 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) All cash on hand or in the possession of the defendant(s), accounts receivables, furniture, furnishinqs, equipment inventory, tools, electronic equipment, vehicles, any and all other personal property belonging to the above-named defendant(s). PRAECIPE FOR WRIT OF 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: All property of the above-named defendant(s), including, without limitation, all savings and checking accounts, certificates of deposit, money market accounts, deposits and all debts and other property and/or obligations owing from the above-named garnishee to the above named defendant(s), including but not limited to account #10 75063, and any account owned solely or in part by the above-named defendant(s), which are in the possession, custody and/or control of said garnishee(s). S? • o? ? Q.?`'l TQ.cv ?uQ C? ,%. <,b L__ CW4 le?-)111y ? aWeat> Attorney File#: 2103326 AMATO AND LESSA, P.C. By: 1 /J Ronald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Anthony J. Giaramita, Esq.,Atty ID #205587 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-6508 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ERIE INSURANCE EXCHANGE Plaintiff (s) From JOHN DAVIDSON d/b/a JOHN'S REFRIGERATION, 6 DYKEMAN ROAD, SHIPPENSBURG, PA 17257 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CASH ON HAND OR IN THE POSSESSION OF THE DEFENDANTS, ACCOUNTS RECEIVABLES, FURNITURE, FURNISHINGS, EQUIPMENT, INVENTORY, TOOLS, ELECTRONIC EQUIPMENT, VEHICLES, ANY AND ALL PERSONAL PROPERTY BELONGING TO THE ABOVE-NAMED DEFENDANTS. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: F&M TRUST, 1901 RITNER HIGHWAY, CARLISLE, PA 17013, ALL PROPERTY OF THE ABOVE-NAMED DEFENDANTS, INCLUDING, WITHOUT LIMITATION, ALL SAVINGS AND CHECKING ACCOUNTS, CERTIFICATES OF DEPOSIT, MONEY MARKET ACCOUNTS, DEPOSITS AND ALL DEBTS AND OTHER PROPERTY AND/OR OBLIGATIONS OWING FROM THE ABOVE-NAMED GARNISHEE TO THE ABOVE NAMED DEFENDANTS INCLUDING BUT NOT LIMITED TO ACCOUNT #10 75063, AND ANY ACCOUNT OWNED SOLEY OR IN PART BY THE ABOVE.-NAMED DEFENDANTS, WHICH ARE IN THE POSSESSION, CUSTODY AND/OR CONTROL OF SAID GARNISHEE. 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 $5,786.39 Interest $18.63 Atty's Comm % Atty Paid $54.25 Plaintiff Paid Date: SEPTEMBER 16, 2011 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs -- -r --J REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND LESSA, P.C. 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 CUMBERLAND COUNTY, MMON PLEAS PENNSYLVANIA IN THE COURT OF CO CI LAW VIL ACTION r 3 ERIE INSURANCE EXCHANGE intiff No. 11-6508 Pl ? o a - vs. JOHN DAVIDSON d/b/a JOHN'S ` REFRIGERATION CIVIL ACTION F&MTRUST Defendant(s) Garnishee INTERROGATORIES TO GARNISHEE To: F & M TRUST, Garnishee 1901 RITNER HIGHWAY, CARLISLE PA 17013 You are required to submit answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a judgment being entered 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? y S, ?Jl ? &I ?1 G1 S G1 ki h r-+ Vf!(1-h0),s11(? oit- -) Fes' M TYoS+ 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 owned solely or in part by the defendant? N 3. At the time you served at whichdd defentitle part byb he defendant did you dant any susequent time to any property of any nature owned solely or held or claimed any interest? t? 0 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 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 ? i'Vl S S I and if so what was the consideration therefor? 1-1 Pt -?)') e GilmuUn-? S??b? ct 1v VJ It 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? N u 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 entity electronically depositing those funds on a recurring basis. N u . 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.A. § 81 237 If so, identify each account. ? ((0UL'(f VN o ? 9. At any time before or after you were served, did the defendant, either solely or in part, have any account (savings, checking, certificate of deposit, money market, deposits or any other debt and/or property) [including but not limited to 10 750631 with your office? N?. J?iS1' C1(.10V14??' XX-1??" 10. If your answer to interrogatory #9 is in the affirmative, state: A) the account number of each account; 1 U ?? cj ?l? 3 B) the amount of money in each account. ` , 016) AMATO AND LESSA, P.C. By vlo? Ronald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Anthony J. Giaramita, Esq.,Atty ID #205587 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File#: 2103326 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ERIE INSURANCE EXCHANGE Plaintiff vs. JOHN DAVIDSON d/b/a JOHN'S REFRIGERATION Defendant(s) F & M TRUST Garnishee No. 11-6508 W. rnto rn c:: C") s' ) . CIVIL ACTION =C) C) =.. wh'? PRAECIPE TO DISCONTINUE AGAINST GARNISHEE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please discontinue the above-captioned matter against F & M TRUST, Garnishee, ONLY, without prejudice. AMATO AND LESSA, P.C. By: RonM Amato, sq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM aKvA '%$.cb P? a I ?A ox Is SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ay R Anderson ariff Jody S Smith Chief Deputy Richard W Stewart Solicitor ("T THE P T iCNC? F?-012 MAY 10 AM 8: 59 CUMBERLAND COUNTly PENNSYLVANIA Erie Insurance Exchange vs. John Davidson d/b/a John's Refrigeration Case Number 2011-6508 SHERIFF'S RETURN OF SERVICE 09/22/2011 11:15 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, F&M Trust at 1901 Ritner Highway, Carlisle Borough Annex, Carlisle, PA 17013, Cumberland County, by handing to Curt Lashune, 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 him. 05/09/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as STAYED per request of plaintiffs attorney. SHERIFF COST: $211.23 SO ANSWERS, w May 09, 2012 RON R ANDERSON, SHERIFF ? --? 7Wfi fl t,c. GeifntvSufte ShenfP. T&eosoft, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ERIE INSURANCE EXCHANGE Plaintiff vs. JOHN DAVIDSON d/b/a JOHN'S REFRIGERATION Defendant(s) No. 11-6508 CIVIL ACTION PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please satisfy the judgment entered in the above-captioned case. AMATO AND LESSA, P.C. By: R ald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM