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
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JOHN DAVIDSON d/b/a JOHN'S Interest $ 18.63 =?Q -0
REFRIGERATION Payments $0.00 c
Defendant(s)
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F & M TRUST ,
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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).
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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
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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
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ERIE INSURANCE EXCHANGE
intiff No. 11-6508
Pl ?
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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-+
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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
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and if so what was the consideration therefor? 1-1 Pt
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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.
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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
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CIVIL ACTION
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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,
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May 09, 2012 RON R ANDERSON, SHERIFF
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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