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Home My WebLink About04-4392J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 NBA CREDIT UNION 3807 Otter Street, P.O. Box 2206 Tullytown, PA 19007 v. LAIRD YOUNG 304 Pennsylvania Avenue Camp Hill, PA 17011 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CXl - Y39a, e~w~~~~''''1 PRAECIPE Kindly docket the attached Judgment in the amount of$11,132.10in favor ofPlaintiff, NBA Credit Union, and against the Defendant, Laird Young, for execution purposes only. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 NBA CREDIT UNION 3807 Otter Street, P.O. Box 2206 Tullytown, PA 19007 v. LAIRD YOUNG 304 Pennsylvania Avenue Camp Hill, PA 17011 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military orNaval Service ofthe United States or its Allies, orotherwise withinthe provisions ofthe Soldiers' and Sailors' Civil ReliefAct ofCongress of 1940 as amended; that Defendant, Laird Young, is over eighteen (18) years of age, and resides at 304 Pennsylvania Avenue, Camp Hill, PA 17011. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS j 3~l DAY OF ~ yt151. 20nq, COMMONWEAL7y~ OF PENNSYLVANIA NO7AR~AL SEAL BRYAN W, SCHUL72, Ndary Public I MY Canm(ssfd ^ O~aware Countyty Expires Jwie 10, 2006 NOTARY J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 NBA CREDIT UNION 3807 Otter Street, P.O. Box 2206 Tullytown, PA 19007 v. LAIRD YOUNG 304 Pennsylvania Avenue Camp Hill, PA 17011 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT I, J. Scott Watson, Esquire, hereby certifies thatthe debt inthe above matter is valid, enforceable and unsatisfied to date. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS ~,~t DAY OF NOTARY COMMONYVGLTN OP PENNSYLVANIA NOTARIAL SEAL BRYAN W. SCHULTZ, Notary Public Concad Trrp.. Debware County G1y Commission Eapnes Jwte 70, 2!106 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 NBA CREDIT UNION 3807 Otter Street, P.O. Box 2206 Tullytown, PA 19007 v. LAIRD YOUNG 304 Pennsylvania Avenue Camp Hill, PA 17011 AFFIDAVIT Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS I, J. Scott Watson, Esquire hereby certifies that the name and the last known address ofPlaintiff and Defendant are as stated below: Plaintiff: NBA Credit Union 3807 Otter Street, P.O. Box 2206 Tullytown, PA 19007 Defendant: Laird Young 304 Pennsylvania Avenue Camp Hill, PA 17011 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS ~3Th DAY OF NOTARY COMMONWEALTH OF PENNSY WANIA NOTARIAL SEAL j BRYAN W. SCHULT2, Na1ary PuClit I Calcad Twp., Delaware Caul My Cmm~dsabn Exproa Jule 10.2(106 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 NBA CREDIT UNION Attorney for Plaintiff CUMBERLAND COUNTY 3807 Otter Street, P.O. Box 2206 COURT OF COMMON PLEAS Tullytown, PA 19007 v. LAIRD YOUNG 304 Pennsylvania Avenue Camp Hill, PA 17011 AFFIDAVIT OF NO APPEAL I, J. Scott Watson, Esquire, hereby certifies that the District Court judgement in the above matter was not appealed into a higher court to date. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS ~3 TM DAY OF NOTARY AUgUSG 2004 ~~///////yyy~ //I VV N COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL BRYAN W. SCHULTZ. Notary Pudic Concord Twp., Delaware County MY Commission Expires June 10, 2008 PAGE 1 REPORT ZDRDOCT First Judicial District RUN DATE 08/05/04 USER ID: COS CIVIL DOCKET REPORT RUN TIME 01:48 PM CASE ID 981200887 -------------------------------------------------------------------------------- CASE NUMBER CASE CAPTION 981200887 NBA CREDIT UNION VS YOUNG FILING DATE COURT LOCATION JURY 14-DEC-1998 AR AC N CASE TYPE: CONTRACTS OTHER STATUS: JUDGMENT BY DEFAULT/FINAL DISP Seq # Assoc Expn Date Type ID 1 APLF A410E0 2 1 3 4 PLF I10852 DFT X3899847 20-MAY-04 DGR X236494 Party Name / Address & Phone No. WATSON, J. SCOTT 30 REGENCY PLAZA GLEN MILL$ PA 19342 (610)358-9600 NBA CREDIT UNION 3807 OTTER ST P.O. BOX 2206 TULLYTOWN PA 19007 YOUNG, LAIRD 9453 FAIRGREEN LANE #A PHILADELPHIA PA 19114 FREEDOM CREDIT UNION 25 JACKSON RD. WARMINSTER PA 18974 Filing Date / Time Docket Entry Date Entered 14-DEC-98 10: 03:00 COMMENCEMENT OF CIVIL ACTION 15-DEC-98 WATSON, J. SCOTT 14-DEC-98 10: 03:00 COhPLAINT FILED NOTICE GIVEN 10,631.58 15-DEC-98 WATSON, J. SCOTT COMPLAINT WITH NOTICE TO DEFEND WITHIN TWENTY (20) DAYS AFTER SERVICE IN ACCORDANCE WITH RULE 1018.1 FILED . 14-DEC-98 10: 03:00 SHERIFF'S SURCHARGE 1 DEFT 15-DEC-98 WATSON, J. SCOTT 14-DEC-98 10:08:35 ACTIVE CASE 14-DEC-98 15-DEC-98 16:29:17 ARBITRATION HEARING SCHEDULED 15-DEC-98 PAGE 2 REPORT ZDRDOCT First Judicial District RUN DATE 08/05/04 USER ID: COS CIVIL DOCKET REPORT RUN TIME 01:48 PM CASE ID 981200887 Filing Date / Time Docket Entry Date Entered 07-JAN-99 20:02:00 AFFIDAVIT OF SERVICE FILED 14-JAN-99 OF COMPLAINT BY PERSONAL SERVICE UPON DFT. LAIRD YOUND. 19-FEB-99 14:28:00 JUDGMENT BY DEFAULT/FINAL DISP 11,132.10 19-FEH-99 PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT FILED. JUDGMENT FOR PLAINTIFF(S) AGAINST DEFENDANT(S) FOR FAILURE TO FILE ANSWER WITHIN REQUIRED TIME. PRO-PROTHONOTARY NOTICE UNDER RULE 236. NOTICE UNDER 237.5. AFFIDAVIT OF NON-MILITARY SERVICE FILED DAMAGES ASSESSED $ 11,132.10 20-APR-04 10:48:00 PRAECIPE TO ISSUE WRIT FILED 20-APR-04 PRAECIPE FOR WRIT OF ATTACHMENT AGAINST FREEDOM C.U. FILED. WRIT OF EXECUTION IN ATTACHMENT AND SUMMONS ISSUED UPON GARNISHEE. 30-APR-04 10:19:08 SHERIFF'S SERVICE 30-APR-04 SHERIFF'S RETURN OF SERVICE OF WRIT OF ATTACHMENT/INTERROGATORIES UPON GARNISHEE, FREEDOM F.C.U. ON APRIL 22, 2004. 19-MAY-04 09:08:23 ATTACHMENT DISSOLVED 20-MAY-04 WRIT OF ATTACHMENT DISCONTINUED/DISSOLVED AGAINST GARNISHEE FREEDOM CREDIT UNION BY PLAINTIFF(S)ATTORNEY. * * * End of Docket * * Judgment certified in the amount of $11,132.10 CERTIFIEDFRDMTHERECDRDDN AUG 6 2004 JOSEPH H. EV S PROT OTARY OF PHILAD HIA COUNTY BY: (~ '~- ~ ~}~ O ~ ~ ~/~ T ~) p C' -n c~`. rii ~; _nc~ r,~ ~ ;~ K ~ ~~ < •' vl 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ( )Confessed Judgment NBA CRIDIT UNION 3807 Otter Street ( )Other P.O. Box 2206 04-4392 Tullytown, PA 19007 File No. vs. Amount Due 11,132.10 ~~ YOUNG Interest 8/30/04 304 Pennsylvania Avenue Atty's Comm Camp Hill, PA 17011 Costs 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 gland County, for debt, interest and costs, upon the following described property of the defendant(s) All contents of Defendant's residence including but not limited to all furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, televisions, tools and any other property which may be subject to levy. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of_ Counry, 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) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date / ~s/~ `C Signature: Print Name: J. Scott Watson, Esquire Address: 24 Regency Plaza Glen Mills, PA, 19342 Attorney for: Plaintiff Telephone: 610-358-9600 Supreme Court ID No.: 41060 (over) r _. -~- :~ n ~~ ~\ 1 o' '~. :w ~ s 9., 0 p o c a °a ~ ~ ~ ~ -v 1`~ ;:~~ . ~~ .. ~: ,-,, ~, C.1 t _;, --~ -{ T i ~ 1 l~. "~ ~. I L.. N t,) .L , i~ t'= : . ~~ AF r~ , - 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-4392 Civil CIVIL ACTION -LAW - „~ TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NBA CREDIT UNION, Plaintiff (s) From LAD2D YOUNG, 304 PENNSYLVANIA AVENUE, CAMP HILL, PA 17011 (1) You aze duetted to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, IQTCHEN UTENSILS, SILVERWARE, TELEVISIONS, TOOLS AND ANY OTHER PROPERTY WHICH MAY BE SUBJECT TO LEVY. (2) You are also duetted to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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 aze directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $11,132.10 L.L. $.50 Interest 8/30/04 Atty's Comm % Due Prothy $1.00 Atty Paid $37.50 Other Costs PlaintiffPaid Date: OCTOBER 22, 2004 CURTIS R. LONG Prothonota ~/~ (Seal) .I1y: ~jf~ Deputy REQUESTING PARTY: Name J. SCOTT WATSON, ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone:610-358-9600 Supreme Court ID No. 41060 NOV 1 6 ?004 p~ Gates, Halbruner & Hatch, P.C. By: Albert N. Peterlin, Esquire PA Attorney ID No. 84180 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 (717) 731-9600 (717) 731-9627 facsimile a.peterlin @ gateslawfirm.com Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -- - ------ - -- ---------------- --------------- -X NBA CREDIT UNION, Plaintiff, v. LAIRD YOUNG, Defendant. --------------- -- ~ - ----...--------...---------X CIVIL ACTION -LAW N0.04-4392 CLAIM FOR EXEMPTION TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: Defendant, Laird M. I. Bruno, formerly known as Laird Young, by and through her attorneys, Gates, Halbruner & Hatch, P.C., claim exemption of property from levy or attachment as follows: 1. Personal property of the Defendant, identified as a stereo system and household furniture, is exempted in kind pursuant to 42 Pa.C.S.A. § 8123(x). 2. Wearing apparel of the Defendant is exempted in kind pursuant to 42 Pa.C,S.A. § 8124(x). 3. Any and all tangible personal property, including any and all furniture, equipment, electronics, jewelry, electrical appliances, kitchen utensils, televisions, tools, photographs, pictures, books, magazines, and all other personal property, located in Defendant's residence is exempted due to the ownership of such property by Defendant and her husband as joint tenants by the entireties. 4. A prompt court hearing is requested to determine the exemptions. 5. Notice of the hearing should be given to Defendant's attorneys at the above-referenced address. WHEREFORE, the Defendant, Laird M. I. Bruno, formerly known as Laird Young, suggests the property attached pursuant to the Writ of Execution is exempt. Respectfully submitted, GATES, HALBRUNER & HATCH, P.C. Date: November 15, 2004 By: ~ /' ~~ Alb N. eterlin, E quir Attorneys for Defendant 2 VERIFICATION I, Laird M. I. Bruno, formerly known as Laird Young, state that I have reviewed the foregoing Claim for Exemption and verify that the facts contained therein are true and correct to the best of my knowledge, information and belief. I further verify that these statements made by me are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Date: November 15, 2004 Laird M. 1. Bruno CERTIFICATE OF SERVICE I, Albert N. Peterlin, Esquire, hereby certify that a true and correct copy of the foregoing Claim for Exemption has been served this day upon the following interested parties by United States first class mail, postage prepaid, addressed as follows: J. Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Attorney for Plaintiff GATES, HALBRUNER & HATCH, P.C. Date: November 15, 2004 By: Albe . Pe rli s uire Attorneys for Defendant ~~~~~! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ------------------------------------------------------X NBA CREDiT UNION, Plaintiff, v. LA{RD YOUNG, Defendant. ---------------------------------------------------- -X CIVIL ACTION -LAW NO. 04-4392 ORDER AND NOW, this day of 2004, upon consideration of Petition to intervene, Stay and Set Aside Writ of Execution as to Exempt Property (the "Petition"), it is hereby ORDERED and DECREED that: 1. The Petition is Granted in toto; and 2. The Writ of Execution is stayed and set aside as to any and all personal property located at the personal residence of Defendant commonly identified as 305 Pennsylvania Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. BY THE COURT: J. Distribution List: Albert N. Peterlin, Esquire Gates, Halbruner & Hatch, P.C. 1013 Mumma Road, Suite 100, Lemoyne, PA 17043 J. Scatt Watson, Esquire 24 Regency Piaza, Glen Mills, PA 19342 Gates, Halbruner & Hatch, P.C. By: Albert N. Peterlin, Esquire PA Attorney ID No. 84180 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 (717} 731-9600 (717} 731-9627 facsimile a.peterlin @ gatesiawfirm.com Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ---------------------------------------------------- -X NBA CREDIT UNION, Plaintiff, CIVIL ACTION -LAW v. NO. 04-4392 LAIRD YOUNG, Defendant. ---------------------------------------------------- -X PETITION TO INTERVENE, STAY AND SET ASIDE WRiT OF EXECUTION AS TO EXEMPT PROPERTY Defendant, Laird M. I. Young, formerly known as Laird Young ("Petitioner" or "Mrs. Bruno"}, by and through her attorneys, Gates, Halbruner & Hatch, P.C., hereby moves the Court pursuant to Pa.R.C.P. No. 3121(a)(4) to stay and set aside the Writ of Execution as to the personal property owned by Mrs. Bruno and her husband, John L. Bruno ("Mr. Bruno") as joint tenants by the entireties, and in support thereof, avers as follows: 1. Mrs. Bruno and Mr. Bruno have been married for several years. 2. All of the persona! property Mr. Bruno and Mrs. Bruno own and that is contained in their residence (the "Residence") located at 304 Pennsylvania Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 is owned as joint tenants by the entireties. 3. The personal property includes household goods, furnishings, fixtures, appliances, electronic equipment, and all other contents located at Mrs. Bruno's personal residence. WHEREFORE, Defendant, Laird M. I. Bruno, formerly known as Laird Young, respectfully requests this Court enter an Order staying and setting aside the Writ of Execution as to any and all contents of the Defendant's personal residence and for such other relief as is just and proper. Respectfully submitted, GATES, HALBRUNER & HATCH, P.C. ~ lr Date: November 15, 2004 By: (/'w ,/~ Alb rt N. Peterlin, Esquire Attorneys for Defendant 2 of 2 VERIFICATION I, Laird M. I. Bruno, formerly known as Laird Young, state that I have reviewed the foregoing Petition to Intervene, Stay and Set Aside Writ of Execution as to Exempt Property and verify that the facts contained therein are true and correct to the best of my knowledge, information and belief. ! further verify that these statements made by me are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Date: November 15, 2004 ,='" ~` c~ "{V Z ~. Y _ __~.~~ ~.._.~-Laird M. i. Bruno CERTIFICATE OF SERVICE I, A{bert N. Peterlin, Esquire, hereby certify that a true and correct copy of the foregoing Petition to Intervene, Stay and Set Aside Writ of Execution as to Exempt Property has been served this day upon the following interested parties by United States first class mail, postage prepaid, addressed as follows: J. Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Attorney for Plaintiff Office of the Sheriff of Cumberland County 1 Courthouse Square Carlisle, PA 17013-3387 GATES, HALBRUNER & HATCH, P.C. Date: November 15, 2004 By: ~ ~ `, ~ ~/' ~~ A~ e ~ Pe lin, s u4 `f'' ~ Attorneys for Defendant ~ NBA CREDIT UNION, PLAINTIFF V. LAIRD YOUNG, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 04-4392 CIVIL TERM ORDER OF COURT AND NOW, this (~i day of November, 2004, IT IS ORDERED that a hearing on the within claim for exemption shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 2:34 p.m., Thursday, December 2, 2004. By the Court, ,~ ,~ ..~~' / . ~~ %' ~ EdgarB. Bayley ~-'Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 For Plaintiff Ebert N. Peterlin, Esquire 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 For Defendant Sheriff l > ~~ ~.,1 it-l9-a :sal - .-,~ ~ii~ •~i l4,1 4~I f1~t~~iL~C~ :tics .. ,1~ '~,1.... ~r._ Gates, Halbruner & Hatch, P.C. By: Albert N. Peterlin, Esquire PA Attorney ID No. 84180 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 (717) 731-9600 (717) 731-9627 facsimile a. peterlin @ gateslawfirm.com Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ---------------------------------------------------- -X NBA CREDIT UNION, Plaintiff, v. LAIRD YOUNG, Defendant. -------- _ _ ------- - -- _ ---------- -X CIVIL ACTION -LAW NO.04-4392 PETITION TO INTERVENE, STAY AND SET ASIDE WRIT OF EXECUTION AS TO EXEMPT PROPERTY Defendant, Laird M. I. Young, formerly known as Laird Young ("Petitioner" or "Mrs. Bruno"), by and through her attorneys, Gates, Halbruner & Hatch, P.C., hereby moves the Court pursuant to Pa. R.C.P. No. 3121(a)(4) to stay and set aside the Writ of Execution as to the personal property owned by Mrs. Bruno and her husband, John L. Bruno ("Mr. Bruno") as joint tenants by the entireties, and in support thereof, avers as follows: 1. Mrs. Bruno and Mr. Bruno have been married for several years. 2. All of the personal property Mr. Bruno and Mrs. Bruno own and that is contained in their residence (the "Residence") located at 304 Pennsylvania Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 is owned as joint tenants by the entireties. 3. The personal property includes household goods, furnishings, fixtures, appliances, electronic equipment, and all other contents located at Mrs. Bruno's personal residence. WHEREFORE, Defendant, Laird M. I. Bruno, formerly known as Laird Young, respectfully requests this Court enter an Order staying and setting aside the Writ of Execution as to any and all contents of the Defendant's personal residence and for such other relief as is just and proper. Respectfully submitted, GATES, HALBRUNER & HATCH, P.C. Date: November 15, 2004 By: Alb rt N. eterlin, Esquire Attorneys for Defendant 2of2 VERIFICATION I, Laird M. I. Bruno, formerly known as Laird Young, state that I have reviewed the foregoing Petition to Intervene, Stay and Set Aside Writ of Execution as to Exempt Property and verify that the facts contained therein are true and correct to the best of my knowledge, information and belief. I further verify that these statements made by me are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Date: November 15, 2004 _ ~ _ Laird M. I. Bruno CERTIFICATE OF SERVICE I, Albert N. Peterlin, Esquire, hereby certify that a true and correct copy of the foregoing Petition to Intervene, Stay and Set Aside Writ of Execution as to Exempt Property has been served this day upon the following interested parties by United States first class mail, postage prepaid, addressed as follows: J. Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Attorney for Plaintiff Office of the Sheriff of Cumberland County 1 Courthouse Square Carlisle, PA 17013-3387 GATES, HALBRUNER & HATCH, P.C. Date: November 15, 2004 By: ~' /~ A . Pe lin s ui Attorneys for Defendant ~~ ra - ~ -rt .~ f~,... t... , ~.i_ ~„~ , t.....' ~t ~ ~ ~ .. ~ ~ ~ , { _i ~ `~~ ~~.~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ---------------------------------------------------- -X NBA CREDIT UNION, Plaintiff, CIVIL ACTION -LAW v. NO. 04-4392 LAIRD YOUNG, Defendant. ---------------------------------------------------- -X ORDER iL AND NOW, this ~ day of , 2004, upon consideration of Defendant's Claim for Exemption (th~~ "Claim"), it is hereby ORDERED and DECREED that: 1. The Claim is Granted in toto; 2. Defendant resides at certain real property (thE: "Residence") commonly identified as 305 Pennsylvania Avenue, Camp Hill, Pennsylvania 17011. 3. Any and all tangible personal property located at the Residence is owned as joint tenants by the entireties by Defendant and her husband, John L. Bruno and, as a result, exempt from execution. 4. The Writ of Execution is set aside in toto as to any and all personal property located at the Residence. ~~ ~0`~ la- ~ _ ~1 ~ -~ y, + /~ t.t . ...i .~ ° ; t.~,.. -r' c° a ," ~ ` ~~ . N Distribution List: Albert N. Peterlin, Esquire Gates, Halbruner & Hatch, P.C, 1013 Mumma Road, Suite 100, Lemoyne, PA 17043 J. Scott Watson, Esquire 24 Regency Plaza, Glen Mi!!s, PA 19342 NBA CREDIT UNION, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. LAIRD YOUNG, DEFENDANT 04-4392 CIVIL TERM ORDER OF COURT AND NOW, this t ~ day of November, 2004, IT IS ORDERED that a hearing on the within claim for exemption shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 2:30 p.m., Thursday, December 2, 2004. ~..d~Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 For Plaintiff Ebert N. Peterlin, Esquire 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 For Defendant Sheriff By the C9urt, ~. .~„ .~ ,.~% EdgarB. Bayley~J. ~.1:~ } r,n ,~.90~ . il-i9-o sal -~-. NOV 1 6 ?004 ~ Gates, Halbruner & Hatch, P.C. By: Albert N. Peterlin, Esquire PA Attorney ID No. 84180 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 (717) 731-9600 (717) 731-9627 facsimile a.~eterlin @ gateslawfirm.com Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ---------------------------------------------------- -X NBA CREDIT UNION, Plaintiff, v. LAIRD YOUNG, Defendant. -----------------------------------------------------X CIVIL ACTION -LAW NO.04-4392 CLAIM FOR EXEMPTION TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: Defendant, Laird M. I. Bruno, formerly known as Laird Young, by and through her attorneys, Gates, Halbruner & Hatch, P.C., claim exemption of property from levy or attachment as follows: 1. Personal property of the Defendant, identified as a stereo system and household furniture, is exempted in kind pursuant to 42 Pa.C.S.A. § 8123(a). 2. Wearing apparel of the Defendant is exempted in kind pursuant to 42 Pa.C.S.A. § 8124(a). 3. Any and all tangible personal property, including any and all furniture, equipment, electronics, jewelry, electrical appliances, kitchen utensils, televisions, tools, photographs, pictures, books, magazines, and all other personal property, located in Defendant's residence is exempted due to the ownership of such property by Defendant and her husband as joint tenants by the entireties. 4. A prompt court hearing is requested to determine the exemptions. 5. Notice of the hearing should be given to Defendant's attorneys at the above-referenced address. WHEREFORE, the Defendant, Laird M. I. Bruno, formerly known as Laird Young, suggests the property attached pursuant to the Writ of Execution is exempt. Respectfully submitted, GATES, HALBRUNER & HATCH, P.C. Date: November 15, 2004 By: Alb N. eterlin, E qu~r Attorneys for Defendant 2 VERIFICATION I, Laird M. I. Bruno, formerly known as Laird Young, state that I have reviewed the foregoing Claim for Exemption and verify that the facts contained therein are true and correct to the best of my knowledge, information and belief. I further verify that these statements made by me are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Date: November 15, 2004 .~ _ ,~- f ~`'"-~- Laird M. I. Bruno CERTIFICATE OF SERVICE I, Albert N. Peterlin, Esquire, hereby certify that a true and correct copy of the foregoing Claim for Exemption has been served this day upon the following interested parties by United States first class mail, postage prepaid, addressed as follows: J. Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Attorney for Plaintiff GATES, HALBRUNER & HATCH, P.C. Date: November 15, 2004 By: Albe . Pe rli s uire Attorneys for Defendant L.r~~i~rl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ------------------------------------------------------X NBA CREDIT UNION, Plaintiff, v. LAIRD YOUNG, Defendant. ---------------------------------------------------- -X AND NOW, this CIVIL ACTION -LAW N0. 04-4392 ORDER day of 2004, upon consideration of Petition to intervene, Stay and Set Aside Writ of Execution as to Exempt Property (the "Petition"), it is hereby ORDERED and DECREED that: 1. The Petition is Granted in toto; and 2. The Writ of Execution is stayed and set aside as to any and all personal property located at the personal residence of Defendant commonly identified as 305 Pennsylvania Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. BY THE COURT: J. Distribution List: Albert N. Peterlin, Esquire Gates, Halbruner & Hatch, P.C. 1013 Mumma Road, Suite 100, Lemoyne, PA 17043 J. Scott Watson, Esquire 24 Regency Plaza, Glen Mills, PA 19342 Gates, Halbruner & Hatch, P.C. By: Albert N. Peterlin, Esquire PA Attorney ID No. 84180 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 (717) 731-9600 (717) 731-9627 facsimile a.peterlin @ gateslawfirm.com Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ---------------------------------------------------- -X NBA CREDIT UNION, Plaintiff, CIVIL ACTION -LAW v. N O. 04-4392 LAIRD YOUNG, Defendant. ------------------------------------------------------X PETITION TO INTERVENE, STAY AND SET ASIDE WRIT OF EXECUTION AS TO EXEMPT PROPERTY Defendant, Laird M. I. Young, formerly known as Laird Young ("Petitioner" or "Mrs. Bruno"), by and through her attorneys, Gates, Halbruner & Hatch, P.C., hereby moves the Court pursuant to Pa.R.C.P. No. 3121(a)(4) to stay and set aside the Writ of Execution as to the personal property owned by Mrs. Bruno and her husband, John L. Bruno ("Mr. Bruno") as joint tenants by the entireties, and in support thereof, avers as follows: 1. Mrs. Bruno and Mr. Bruno have been married for several years. 2. A!I of the personal property Mr. Bruno and Mrs. Bruno own and that is contained in their residence (the "Residence") located at 304 Pennsylvania Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 is owned as joint tenants by the entireties. 3. The personal property includes household goods, furnishings, fixtures, appliances, electronic equipment, and all other contents located at Mrs. Bruno's personal residence. WHEREFORE, Defendant, Laird M. I. Bruno, formerly known as Laird Young, respectfully requests this Court enter an Order staying and setting aside the Writ of Execution as to any and all contents of the Defendant's personal residence and for such other relief as is just and proper. Respectfully submitted, GATES, HALBRUNER & HATCH, P.C. Date: November 15, 2004 By: t ~ ' , Alb rt N. Peterlin, Esquire Attorneys for Defendant 2of2 VERIFICATION I, Laird M. I. Bruno, formerly known as Laird Young, state that I have reviewed the foregoing Petition to Intervene, Stay and Set Aside Writ of Execution as to Exempt Property and verify that the facts contained therein are true and correct to the best of my knowledge, information and belief. I further verify that these statements made by me are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. ~- ~~~ ~ -- Date: November 15, 2004 ~.--" ' ~` cj.- <___._-Laird f~1. i. Bruno CERTIFICATE OF SERVICE I, Albert N. Peterlin, Esquire, hereby certify that a true and correct copy of the foregoing Petition to Intervene, Stay and Set Aside Writ of Execution as to Exempt Property has been served this day upon the following interested parties by United States first class mail, postage prepaid, addressed as follows: J. Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Attorney for Plaintiff Office of the Sheriff of Cumberland County 1 Courthouse Square Carlisle, PA 17013-3387 GATES, HALBRUNER & HATCH, P.C. Date: November 15, 2004 By: ~ t ' A~ e l~ . Pe lin ~s ui ~ - % Attorneys for Defendant R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED. no action taken in six months. Sheriff s Costs: Docketing 18.00 Poundage 1.42 Advertising Law Library .50 Prothonotary 1.00 Mileage 11.10 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Postage Garnishee TOTAL 72.02 Advance Costs: 150.00 Sheriff's Costs 72.02 77.98 Refunded to Atfy on 10/18/05 Sworn and Subscribed to before me So Answers; this .24 ~ 2005 A.D -J :_, -,s 't4 =~} ;„ .. ....~ . ~~t^ R. Thomas Kline, Sheriff BY ~ ~~ 2a-- ~r~~~~~ SS III d 8Z 1~0 h001 tlj~1213HS 3N11~0 301 f~;i ~ ~~ rk.,','I Ls ~ Jli<.. /7C'l~9 (/ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-4392 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NBA CREDIT UNION, Plaintiff (s) From LAIRD YOUNG, 304 PENNSYLVANIA AVENUE, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, HITCHEN UTENSILS, SILVERWARE, TELEVISIONS, TOOLS AND ANY OTHER PROPERTY WHICH MAY BE SUBJECT TO LEVY. (2) You are also duected to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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 $11,132.10 L.L. $.50 Interest 8/30/04 Atty's Comm % Due Prothy $1.00 Atty Paid $37.50 Other Costs Plaintiff Paid Date: OCTOBER 22, 2004 CURTIS R. LONG Prothonota ~~~J -- (Seal) ,R~ pti~ _ ~, / ~/~/!D/9 ~ Deputy REQUESTING PARTY: Name J. SCOTT WATSON, ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-358-9600 Supreme Court ID No. 41060 j~~r ~1° ~ vJ'~~,'rs~fAn{~Ily,°~V $%a7 &n,'~~~wY''(-~,n ~~~~ Y ~IJ1. a'(=rht3reDi, ~ ~f~ t{~t~ Jot ~i ~ 'n:F t J ~~~ cs~t ~~ t;t spa CvtIR at arl9s;a, ~~. tni ~L'~:.~.Ca ~~~ ~P_