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HomeMy WebLinkAbout11-6716 Jji PROTHONOTk 2011 SEP 14 Pm 2; 4 9 CUMBERLAND COUNTY -PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION NO. 86-5586 /1 - 6716 vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING SERVICES, Defendants. CERTIFICATE OF SERVICE OF WRIT OF REVIVAL Filed on behalf of Plaintiff, PNC Bank, National Association Code: Counsel of Record for This Party: Donna M. Donaher, Esquire Pa. I . D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff, CIVIL DIVISION NO. 06-5586 vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING SERVICES, Defendants CERTIFICATE OF SERVICE OF WRIT OF REVIVAL The undersigned hereby certifies that she did serve a true and correct copy of the Writ of Revival upon Sally Harper dba Asap Typing Services, at her last known address of 914 Indiana Avenue, Lemoyne, PA 17043, by certified mail on September 2, 2011. A true and correct copy of a certified mail receipt is attached hereto. Respectfully submitted, TUCKER ARENSBERG, P.C. Donna M. Donaher, Esquire 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 Attorneys for Plaintiff BANK FIN:416269-1 000011-129927 0 m a m 0 m a 0 0 a N 0 rl P-q a N s t is r r? 9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION NO. 06-6"6 11 Plaintiff PRAECIPE FOR DEFAULT JUDGMENT ON WRIT OF REVIVAL Filed on behalf of Plaintiff, vs. PNC Bank, National Association C- - M ° y=r;1- JERRY HARPER and SALLY HARPER " , ?CD dba ASAP TYPING SERVICES Defendant «r c, - _ Counsel of Record for This Party: `, C' Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 4'1 y,U ?j A5k a4? 5,5-6 K4 n I A e At4) 14 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff CIVIL DIVISION NO. 08=5586 C W vs. JERRY HARPER and SALLY HARPER dba ASAP TYPING SERVICES Defendant PRAECIPE FOR JUDGMENT ON WRIT OF REVIVAL To: Prothonotary, Cumberland Kindly revive the judgment by default filed in the above-referenced matter for the Plaintiff and against the Defendant, Sally Harper dba ASAP Typing Services, for failure to file a responsive pleading, in the amount of $5,318.77 plus costs of suit. Respectfully submitted, TUCKER ARENSBERG, P.C. By ?; JCL ??0•?_? Donna--M. Donaher, Esquire 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 Attorneys for Plaintiff CERTIFICATION The undersigned hereby certifies that a true and correct notice of intention to enter a default judgment, said notice conforming to Pa. R.C.P. No. 237.1, was sent to defendant(s), by U.S. mail, postage prepaid on the 23rd day of September, 2011. A true and correct copy of the notice is attached hereto Attorney for PNC Bank, N.A. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff CIVIL DIVISION NO.09ZZ86 (- I 61 G vs. JERRY HARPER and SALLY HARPER dba ASAP TYPING SERVICES Defendant TO: Sally Harper dba ASAP Typing Services 914 Indiana Avenue Lemoyne, PA 17043 NOTICE OF ENTRY OF JUDGMENT Please take notice that on 6 &-,t Cam- 7 , 2011, a Judgment by Default was entered against you in the court and at docket term and number set forth above. The amount of the Judgment is $5,318.77, cost 0 ounty BANK-FIN: 417833-1: 000011-129927 ? ? 1 gyn..! 1 ?? V E??(f+ ,l Y ??AI Y z ILg I NI2':4 Fr r' Ir`?SYI_VANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION. CIVIL DIVISION Plaintiff vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING SERVICES, Defendants NO. 11-6716 PRAECIPE TO REISSUE WRIT OF REVIVAL Filed on behalf of Plaintiff, PNC Bank, National Association Code: Counsel of Record for This Party: Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 0-fA 1%b•o0F1 1 ck,b. 3 su -? 9 0-a 6 (09A3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION Plaintiff ) NO. 11-6716 VS. ) JERRY HARPER AND ) SALLY HARPER DBA ) ASAP TYPING SERVICES, ) Defendants ) PRAECIPE TO REISSUE WRTT OF REVIVAL To: Prothonotary, Cumberland County Kindly reissue the Writ of Revival in the above-captioned case against Jerry Harper and Sally Harper dba ASAP Typing Services, in the amount of $5,318.77. Respectfully submitted, TUC R ENSBERG, P.C By Donna M. Donaher, Esquire 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 Attorneys for Plaintiff BANK_FIN:419066-1 000011-129927 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ? ititp at 414+nor',4114 F+LED-OFFICE lic THE P 01 HON0TARY 20 i I NOY 18 AM 10: 56 CUMBERLAND COUNTY PENNSYLVANIA PNC Bank National Association vs. Jerry S. Harper Case Number 2011-6716 SHERIFF'S RETURN OF SERVICE 11/15/2011 07:32 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on November 15, 2011 at 1932 hours, he served a true copy of the within Writ of Revival, upon the within named defendant, to wit: Jerry S. Harper, by making known unto Nick Harper, Son of Defendant at 206 Bosler Avenue D, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $44.00 November 16, 2011 Alatzi, LltL?& GERALD WORTHINGT , DEPUTY SO ANSWERS, RON ~ R ANDERSON, SHERIFF icy CowitySuite Sheri+f. Teleosoft. Inc. ~ IN THE COURT OF OMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff vs. NO. 11-6716 PRAECIPE FOR DEFAULT JUDGMENT ON WRIT OF REVIVAL Filed on behalf of Plaintiff, PNC Bank, National Association JERRY HARPER AND Sf LLY HARPER DBA ASAP TYPING SERVICES, Defenda Counsel of Record for This Party: Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 20 4d A ^C v ? /11.00 pd, 4 464 53 1..5--3 ,3?-* // 5, 93;?- ` ete, n4a,.4? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL SSOCIATION, ) CIVIL DIVISION Plaintiff ) NO. 11-6716 vs. JERRY HARPER AND HARPER DBA ASAP I Defend, P To: Prothonotary, Cur Kindly revive the j and against the Defendar $5,318.77, plus costs of s _LY NG SERVICES, PE NT Berland County dgment by default filed in the above-referenced matter for the Plaintiff , Jerry Harper, for failure to file a responsive pleading, in the amount of Respectfully submitted, TUCKER ARENSBERG, P.C. B Alv? Don a M. Donaher, Esquire 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 Attorneys for Plaintiff The undersigned default judgment, said nc U.S. mail, postage prepa notice is attached hereto CERTIFICATION hereby certifies that a true and correct notice of intention to enter a a conforming to Pa. R.C.P. No. 237.1, was sent to defendant(s), by on the 7t' day of December, 2011. A true and correct copy of the Attorney for PNC Bank, N.A. ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 7'f 1CI?LI?j' @?IA Mt t o r n e Ws ON Division PNC BANK, NATIONAL ASSOCIATION, ) Plaintiff, ) vs. ) JERRY HARPER AND ) SALLY HARPER DBA ) ASAP TYPING SERVICES, ) } Defe dants. } TO: Jerry Harper 206 Bosier Avenue Lemoyne, PA 17043 DATE OF NOTICE: Dece ber 7, 2011 No. 11-6716 IMPORTANT NOTICE YOU ARE IN DEFA LT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. U LESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGM NT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOU PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, G TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LE AL HELP: LAWYER REFERRAL SERVICE Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 TUCKER ARENSBERG, P.C. By:.v?C??` 1. Donna M. Donaher, Esquire Ati•omey for Plaintiff 1500 One PPG Place Pittsburgh, Pa 15222 BANK-FIN-.421824-1 000011-129927 (412) 566-1212 Tucker Arensberg, P.C. 1500 One PPI Place Pittsburgh, PA 15222 p. 412.566.1212 f. 412.594.5619 www.tuckerlaw.com 2 Lemonyne suite 200 Harrisburg, PA 17043 p. 717.234.4121 f. 717.232.6802 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL Plaintiff vs. JERRY HARPER AND HARPER DBA ASAP 1 Defendc, TO: Jerry Harper 206 Bosler Ave Lemoyne, PA 1 Please take notice entered against you in the The amount of the IATION, LLY ING SERVICES, D CIVIL DIVISION NO. 11-6716 NOTICE OF ENTRY OF JUDGMENT that on 12 z 2011, a Judgment by Default was ourt and at docket term and number set forth above. udgment is $5,:34aft: uProthonotary, Cumberland County BANK FIN:422864-1 000011-1 it IN THE COURT OF C MMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL AS OCIATION, CIVIL DIVISION Plainti NO. 11-6716 Vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPIN SERVICES, Defen AFFIDAVIT OF NON-MILITARY SERVICE Filed on behalf of Plaintiff, PNC Bank, National Association Counsel of Record for This Party: Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 IN THE COURT OF C PNC BANK, NATIONAL A; Plair IMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA )CIATION, ) CIVIL DIVISION } NO. 11-6716 vs. JERRY HARPER AND SAL IY HARPER DBA ASAP TYPIN SERVICES, ants. FIDAVIT OF NON-MILITARY COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF ALLEGHENY ) I, Donna M. Donahe , being duly sworn according to law, hereby depose and say that the Defendant, Jerry Harpe , is not a member of the military service of the United States of America to the best of my k owledge, information and belief. Donna M. Donaher, Counsel for PNC Bank, National Association Sworn to and s befor a this of OCC rl\ bed day r 2011:, IC COMMONEWEALTH OF PENNSYLVANIA ^btariat OF cif Mizak, Notary Public My Commisabn ?h Allegheny county Member, Penns E?iros' 23, 2013 ylvanta Association or Notaries BANK FIN:422863-1 000011-129927 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-6716 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK, NATIONAL ASSOCIATION Plaintiff (s) From JERRY HARPER - 206 Bosler Avenue D, Lemoyne, PA 17043 and SALLY HARPER DBA ASAP TYPING SERVICES - 914 Indiana Avenue, Lemoyne, PA 17043 (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: METRO BANK - 20 Noble Blvd., Building #1, Carlisle, PA 17013 FULTON BANK - 599 North 121h Street, Lemoyne, PA 17043 SUSQUEHANNA BANK - 201 St. Johns Church Road, Camp Hill, PA 17011 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 $5318.77 L.L.$.50 Interest Atty's Comm % Due Prothy $.1/.25 Atty Paid $206,00 Other Costs Plaintiff Paid Date: 1/17112 David D. Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name Donna M. Donaher, Esquire Address: TUCKER ARENSBERG, P.C. 1500 One PPG Place Pittsburgh, PA 15222 Attorney for: PLAINTIFF Telephone: (412) 566-1212 Supreme Court ID No. 53165 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION NO. 11-6716 Plaintiff, PRAECIPE FOR WRIT OF EXECUTION (CONFESSED JUDGMENT) Filed on behalf of Plaintiff, PNC Bank, National Association vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING SERVICES, Defendants, METRO BANK, FULTON BANK AND SUSQUEHANNA BANK, Garnishees. CODE: Counsel of Record for This Party Donna M. Donaher, Esquire Pa. I . D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 IN THE COURT OF COMMONS PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PNC BANK, NATIONAL ASSOCIATION ) CASE NO. 11-6716 Plaintiff, ) vs. ) JERRY HARPER AND - 106 ^$osG?? Y9+nve l Pwroy0ell Pq /7013 SALLY HARPER DBA 7 Qry hvPnue, tewolltl ASAP TYPING SERVICES, Defendants. ) Pl* i70V3 METRO BANK, FULTON BAN X20 104e $L ?v? ???? 1# 1, AND SUSQUEHANNA BANK, S9 14?(A 1 Z s °?fl l ekooyNC, Z> 201 51- -P-0?7n.S ChL1fCkQoacfi (ame Garnishees. ) PRAECIPE FOR WRIT OF EXECUTION (CONFESSED JUDGMENT) To the Prothonotary: Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; C'arlis lP i'f/ r70r3 PA X70 V3 (2) against, Jerry Harper and Sally Harper dba ASAP Typing Services, Defendants; (3) and against Metro Bank, Fulton Bank and Susquehanna Bank, Garnishees; (4) and index this writ (a) against N/A, Defendants; 3 rn m =M (b) and against N/A, Garnishee; z z= (5) Amount due 40M.00 pd q tt Total (cf. 0 CAS yy. 00 1411. 00 -/?- 10. Oti-1- Ic(. p0 ?. Jp -fl ,2ob.? pd )"P Co 7, gb LL a.353787 F# 26f7cf 2? "'V/r, f 0-P Ex. ? $ 5,318.77 x> $ 5,318.77 Donna M. Donaher, Esquire Attorney for PNC Bank, National Association TUCKER ARENSBERG, P.C. 1500 One PPG Place Pittsburgh, PA 15222 3-u,?e d d ti v rv w v• q c? ra-n CERTIFICATION I certify that: (a) This Praecipe is based upon a judgment entered by confession, and notice was served upon the Defendants pursuant to Rule 2958.1 on October 6, 2006. Donna M. Donaher, Esquire Attorney for PNC Bank, National Association TUCKER ARENSBERG, P.C. 1500 One PPG Place Pittsburgh, PA 15222 -2- D NOTE Under paragraph (1) when the writ is directed to the sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph (3) above should be completed only if a name garnishee is to be included in the writ. Paragraph (4) (a) should be completed only if indexing of the execution in the county of issuance, is desired as authorized by Rule 3104(a). Where the writ issues to another county indexing is required as of course in that county by the Prothonotary. See Rule 3104(b). Paragraph 4 (b) should be completed only if real property in the name of a garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). Certification as to waiver of exemption may be included in the Praecipe. Specific directions to the sheriff as to property to be levied upon may be included in the Praecipe or by separate direction at the option to Plaintiff. BANK_FIN:424623-1 000011-129927 =!; 0r'-'F I CIE' kE P OTIIONOTARR I'd €2- FEB - I FM I: 41 CUMBERLAND COUNP( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT':I YAA L 4NIA PNC BANK, National Association, Plaintiff vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING, Defendants and CIVIL DIVISION NO. 11NNX,-erC INTERROGATORIES OF ATTACHMENT Filed on behalf of PNC Bank, National Association, Garnishee CODE: Counsel of Record for This Party: METRO BANK, FULTON BANK AND SUSQUEHANNA BANK, Garnishees Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 !' THE COURT OF COMMONS PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION ) CASE NO. 11-6716 Plaintiff, vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING SERVICES, Defendants METRO BANK, FULTON BANK AND SUSQUEHANNA BANK, Garnishees To: Metro Bank 20 Noble Blvd, Building #1 Carlisle, PA 17013 IMPORTANT NOTICES TO GARNISHEE A. 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. B. Herein, the word "Defendant" means any one or more of the defendants against whom the Writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the Garnishee, it also attaches all property of the Defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against tl-e Garnishee. 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 lease, mortgage or 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. lie. 2. If the answer to Interrogatory 1 is in the affirmative, state the following: (a) the amount of money you owe or owed to Defendant; (b) if such money is in the form of a fund, the present location thereof; (c) the amount or amounts that Defendant claims or claimed that you owe or owed to him; (d) the nature and amount of each of such liabilities. TWA 3. At the time you were served or at any subsequent time was there in your 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. NO. 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value and present location of each of such properties. MIA 5. 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 part by the Defendant or in which Defendant held or claimed any interest? 140. 6. If the answer to Interrogatory 5 is in the affirmative, described the nature, fair market value and present location of each of said properties. TWA 7. 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. 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value and present location of each of such properties. WA 9. 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? Na, 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value and present location of each of such properties. N/A 11. 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? NO. 12. If you are a bank or other financial institution, at the time you were served or 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 a federal law? If so, identify each account and state the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 13. 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 or 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. Nft T KER ARENSBERG, P.C. Donna M. Donaher, Esquire 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 BANK FIN:424625-1 000011-129927 VERIFICATION I, Catherine M. Bush, verify that the facts set forth in these Garnishee's Answers to Interrogatories are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. § 4904) related to unsworn falsification to authorities. Dated: January 31, 2012 Catherine M. Bush, Assistant Secretary and Legal Counsel Susquehanna Bank 26 North Cedar Street Lititz, Pa 17543 (717) 625-6273 C' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYI IAN) ?v -a 6 -1 _C:) National Association, CIVIL DIVISION PNC BANK , Plaintiff vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING, Defendants and METRO BANK, FULTON BANK AND SUSQUEHANNA BANK, Garnishees NO. 11-6716 INTERRO ATORIES OF ATTACHMENT Filed on behalf of PNC Bank, National Association, Garnishee CODE: Counsel of Record for This Party: Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 IN THE COURT OF COMMONS PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION CASE NO. 11-6716 Plaintiff, vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING SERVICES, Defendants METRO BANK, FULTON BANK AND SUSQUEHANNA BANK, Garnishees To: Susquehanna Bank 201 St. Johns Church Road Camp Hill, PA 17011 IMPORTANT NOTICES TO GARNISHEE A. 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. B. Herein, the word "Defendant" means any one or more of the defendants against whom the Writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the Garnishee, it also attaches all property of the Defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. 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 lease, mortgage or 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. Defendants have no accounts with Metro Bank. 2. If the answer to Interrogatory 1 is in the affirmative, state the following: (a) the amount of money you owe or owed to Defendant; (b) if such money is in the form of a fund, the present location thereof; (c) the amount or amounts that Defendant claims or claimed that you owe or owed to him; (d) the nature and amount of each of such liabilities. 3. At the time you were served or at any subsequent time was there in your 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. 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value and present location of each of such properties. 5. 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 part by the Defendant or in which Defendant held or claimed any interest? 6. If the answer to Interrogatory 5 is in the affirmative, described the nature, fair market value and present location of each of said properties. -2- 7. 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? 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value and present location of each of such properties. 9. 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? 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value and present location of each of such properties. -3- 11. 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? 12. If you are a bank or other financial institution, at the time you were served or 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 a federal law? If so, identify each account and state the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 13. 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 or 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. TUCKER ARENSBERG, PA r- J. J_ t Donna M. Donaher, Esquire 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 BANK_FI N:424625-1 000011-129927 -4- 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 Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, National Association, Plaintiff vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING, Defendants and METRO BANK, FULTON BANK AND SUSQUEHANNA BANK, Garnishees CIVIL DIVISION NO. 11-6716 Answea 4o INTERROGATORIES OF ATTACHMENT Filed on behalf of PNC Bank, -? ^? - National Association, Garnishee .:'crrol r 7:' ca r , CODE: -o Counsel of Record for This Party: Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 IN THE COURT OF COMMONS PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION CASE NO. 11-6716 Plaintiff, vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING SERVICES, Defendants METRO BANK, FULTON BANK AND SUSQUEHANNA BANK, Garnishees. To: Fulton Bank 599 North 12th Street Lemoyne, PA 17043 IMPORTANT NOTICES TO GARNISHEE A. 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. B. Herein, the word "Defendant" means any one or more of the defendants against whom the Writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the Garnishee, it also attaches all property of the Defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. 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 lease, mortgage or 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. i 2. If the answer to Interrogatory 1 is in the affirmative, state the following: (a) the amount of money you owe or owed to Defendant; (b) if such money is in the form of a fund, the present location thereof; (c) the amount or amounts that Defendant claims or claimed that you owe or owed to him; (d) the nature and amount of each of such liabilities. 1 At the time you were served or at any subsequent time was there in your 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. AA) 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value and present location of each of such properties. 5. 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 part by the Defendant or in which Defendant held or claimed any interest? 14A) 6. If the answer to Interrogatory 5 is in the affirmative, described the nature, fair market value and present location of each of said properties. 7. 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? /LAI 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value and present location of each of such properties. 9. 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? r?j 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value and present location of each of such properties. It 11. 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 12. If you are a bank or other financial institution, at the time you were served or 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 a federal law? If so, identify each account and state the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. AAD 13. 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 or 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. /?o " LAA? TUCKER ARENSBERG, P.C. r_. _. Donna M. Donaher, Esquire 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 BANK_FIN:424625-1 000011-129927 VERIFICATION The undersigned does hereby verify, unde nalty of perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities, that he/ a is (Name) (Title) of (Company) L Garnishee herein, that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. Date l Signature Present Address: Fulton Bank 4429 Bonney Road Virginia Beach, VA 23462 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?xtr of Climb F ILEU-OFFICE G`7F PROTI{t3N0 f'` Jody S Smith Chief Deputy ti 20 12 FEB 15 PM 3= 44 Richard W Stewart Solicitor OFFICE OF THE S-ERIFF C RLANO COUNTY % ?NSYLVANIA PNC Bank National Association vs. Case Number Jerry S. Harper (et al.) 2011-6716 SHERIFF'S RETURN OF SERVICE 01/26/2012 11:04 AM - Ronald E. Hoover, Deputy Sheriff, who being duly sworn according to law, states that on January 26, 2012 at 1100 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Jerry Harper and Sally Harper DBA ASAP Typing Services, in the hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania, 17013, by handing to Kristen Gasbarre, Assistant 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. 01/30/2012 11:30 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 30, 2012 at 1130 hours, 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, Fulton Financial Advisors, 599 N 12th Street, Lemoyne, Cumberland County, Pennsylvania, 17043, by handing to Brad Statnick, Branch 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 him. 01/30/2012 12:56 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 30, 2012 at 1256 hours, 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, Susquehanna Bank, 201 St. Johns Church Road, Camp Hill, Cumberland County, Pennsylvania, 17011, by handing to Ana T. Yost, Branch 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 January 31, 2012 to Jerry Harper at 206 Bosler Avenue D, Lemoyne, PA 17043 and to Sally Harper dba ASAP Typing Services, 914 Indiana Avenue, Lemoyne, PA 17043. SO ANSWERS, January 31, 2012 RON R ANDERSON, SHERIFF Ronald E. Hoover, D uty Noah Cline, Deputy c COLIMYSuite Sherrt. Telec= o`t h-, r" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION Plaintiff, Vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING SERVICES, Defendants. METRO BANK, FULTON BANK AND SUSQUEHANNA BANK, Garnishees CIVIL DIVISION -` NO. 11-6716 MM r- -< N --m C3 "4C) PRAECIPE TO DISCONTINUE4 TOX GARNISHEES 5; C: w Filed on behalf of PNC Bank, National Association. Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 *456 pA ATT`/ al3sg981 p4t a?i 583 Code: Counsel for PNC Bank, National Association IN THE COURT OF COMMONS PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION CASE NO. 11-6716 Plaintiff, vs. JERRY HARPER AND SALLY HARPER DBA ASAP TYPING SERVICES, Defendants METRO BANK, FULTON BANK AND SUSQUEHANNA BANK, Garnishees PRAECIPE TO DISCONTINUE AS TO GARNISHEES TO: Cumberland County Prothonotary: Kindly mark the above-referenced matter as discontinued as to the Garnishees, Metro Bank, Fulton Bank and Susquehanna Bank. Respectfully submitted, ARENSBERG, P.C. Donna M. Donaher, Esquire Attorney for PNC Bank, National Association TUCKER ARENSBERG, P.C. 1501.1 vi.e PP.1 Place Pittsburgh, PA 15222 Sworn to and subscribed before me this if day of 2012. COMMONWEALTH OF PENNSYLVANIA 1 '; _ _-'Aotarz l Sea] "7 Amy 6, Hdocn,,ootary Public Notary Public City of Pit'_sburgh, AliNheny County ?7y ? mmissian Expires Aug. 28, 2013 M-'m}?c . Pen isv'va:,!a %kssck-jation of Notaries BANK FIN:426390-1 000011-129927