HomeMy WebLinkAbout12-0091
Robert and Sandra Knawby In the Court of Common Pleas
Plaintiffs Cumberland County, Pennsylvania
V.
Andrew Kohr and No. 101 - 00g1 alvi I Term
Kristen Kohr, :
Defendants
PRAECIPE FOR NOTICE OF INTENT TO ATTACH WAGES
To the Prothonotary:
Issue a Notice of Intent to Attach Wages in the above-noted matter:
1. Against Kristen Kohr, Defendant, and
2. Against Direct Brands, Inc., employer of Defendant.
c
Respectfully submitted, MOD
zr--
CHARLES W. JOHNSTON, P.C. Zor?-- '
101 Erford Road, Suite 302 -<> o
Post Office Box 98
Camp Hill, Pennsylvania 17001-0098 z
Telephone: (717) 975-5500 _
Facsimile,.{ 17 5-S
Pa. I.D. No. 15 21
e-mail: cjohnst @jadlegal.com
Attorney for Plaintiffs/Judgment Creditors
Dated: January 9, 2012
CERTIFICATION BY JUDGMENT-CREDITORS
1. I hereby certify that the Plaintiffs judgment-creditors are as follows:
Robert and Sandra Knawby
5260 Deerfield Avenue
Mechanicsburg, PA 17050
2. I hereby certify that the Defendant judgment-debtor is as follows:
Kristen Kohr
209 First Street
Summerdale, PA 17093-8021
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3. The employer garnishee of Defendant/judgment-debtor Kristen Kohr is as fol-
lows:
Direct Brands, Inc.
1225 South Market Street
Mechanicsburg, PA 17055
4. The Judgment arises out of a residential lease for the premises at 17 High Street,
Enola, Cumberland County, Pennsylvania.
5.
(a) The amount of the judgment is $12,181.00.
(b) A security deposit in the amount of $600.00 is being held by the judgment
creditor-landlord. This security deposit has been applied to payment of rent due on the
same premises for which the judgment has been entered.
(c) The amount of $0.00 has been paid toward satisfaction of the judgment.
6. This Praecipe is filed within five years of the date of the original judgment upon
which execution is sought.
7. The judgment was entered in an action brought before a magisterial district judge.
8. Copies of magisterial district judge records are attached showing that the action
arose from a residential lease and that the defendant appeared or filed papers in the action or that
the complaint was served by handing a copy to the defendant.
I certify that the statements made in this Certification are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to un-
sworn falsification to authorities.
Robert Knawby, Pla' tiff/Judgment Creditor
Sandra Knawby, P aintiff/Ju ment Creditor
Dated: January 9, 2012
COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript
COUNTY OF CUMBERLAND Residential Lease
Mag. Dist. No: MDJ-09-1-03
MDJ Name: Honorable Richard S. Dougherty
Address: 98 South Enola Drive, Suite 1
Enola, PA 17025
Telephone: 717-728-2805
Robert/Sandra Knawby
5260 Deerfield Avenue
Mechanicsburg, PA 17050
Disposition Details
Grant possession.
Grant possession if money judgment is not satisfied by the time of eviction.
Andrew Kohr
Wage attachment is prohibited due to lack of personal service.
Wage attachment is prohibited under Title 42 Section 8127.
Kristen Kohr
Wage attachment is prohibited due to lack of personal service.
Wage attachment is prohibited under Title 42 Section 8127.
Disposition Summary
Docket No Plaintiff Defendant
MJ-09103-LT-0000122-2011 Robert/Sandra Knawby Andrew Kohr
MJ-09103-LT-0000122-2011 Robert/Sandra Knawby Kristen Kohr
Judgment Summary
Participant Joint/Several Liability Individual Liability
Andrew Kohr $12,181.00 $0.00
Kristen Kohr $12,181.00 $0.00
Robert/Sandra Knawby $0.00 $0.00
Robert/Sandra Knawby
V.
Andrew Kohr, Kristen Kohr
Docket No: MJ-09103-LT-0000122-2011
Case Filed: 10/28/2011
No
Yes
No
No
No
No
Disposition Disposition Date
Judgment for Plaintiff 11/10/2011
Judgment for Plaintiff 11/10/2011
Amount
$12,181.00
$12,181.00
$0.00
Judgment Detail ('Post Judgment)
In the matter of Robert/Sandra Knawby vs. Andrew Kohr; Kristen Kohr on 11/10/2011 the disposition is Judgment for Plaintiff and
judgment was awarded as follows.
The amount of rent per month, as established by the Magisterial District Judge, is $800.00
Judament Component Joint/Several Liability Individual Liability Deposit Applied AmguZ
Rent in Arrears $12,000.00 $0.00 $12,000.00
Filing Fees $181.00 $0.00 $181.00
Grand Total: $12,181.00
Portion of judment for physical damages arising out of residential lease: $0.00
Amount of judgment subject to attachment 42 PA C.S. 8127: $0.00
MDJS 315A Page 1 of 3 Printed: 11/10/2011 2:59:43PM
Robert/Sandra Knawby Docket No.: MJ-09103-LT-0000122-2011
V.
Andrew Kohr, Kristen Kohr
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION
WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURT OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF
ANY. IN ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARYICLERK OF COURTS THE
LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. HOWEVER, LOW-INCOME
AND/OR SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J. NO. 1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS
DEPOSIT.
IF A PARTY WISHES ONLY TO APPEAL THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE NOTICE OF
APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME
FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A
REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
NOV 10 2011
Date
! . rial Distri ud Richard S. U rty r
n aimng n . -
nFr: 1 7011
Date
S. Dougherty
MDJS 315A Page 2 of 3 Printed: 11/10/2011 2:59:43PM
Robert/Sandra Knawby
v.
Andrew Kohr, Kristen Kohr
Docket No.: MJ-09103-LT-0000122-2011
Participant List
Plaintiff(s)
Robert/Sandra Knawby
5260 Deerfield Avenue
Mechanicsburg, PA 17050
Defendant(s)
Andrew Kohr
17 High Street
Enola, PA 17025
Kristen Kohr
17 High Steet
Enola, PA 17025
MUJb JIbA Page 3 of 3 Printed: 11/10/2011 2:59:43PM
COMMONWEALTH OF PENNSYLVANIA Recovery of Real Property Hearing
COUNTY OF CUMBERLAND Notice
Mag. Dist. No: MDJ-09-1-03
MDJ Name: Honorable Richard S. Dougherty
Address: 98 South Enola Drive, Suite 1
Enola, PA 17025
Telephone: 717-728-2805
Robert/Sandra Knawby
5260 Deerfield Avenue
Mechanicsburg, PA 17050
Robert/Sandra Knawby
V.
Andrew Kohr, Kristen Kohr
Docket No: MJ-09103-LT-0000122-2011
Case Filed: 10/28/2011
A Recovery of Real Property Hearing has been scheduled for the above captioned case to be held on/at:
Date: Thursday, November 10, 2011 Place: Magisterial District Court 09-1-03
98 South Enola Drive, Suite 1
Time: 1:30 PM Enola, PA 17025
717-728-2805
Notice To Defendant
A landlordttenant complaint has been filed against you for the recovery of possession of real property, and or money and damages
associated with the above captioned case.
If you have a defense to this complaint, you may present it at the hearing.
If you have a claim against the plaintiff arising out of the occupancy of the premises, which is within the jurisidiction of the
magisterial district judge and which you intend to assert at the hearing, you must file it on a complaint form at this office before the
time set for the hearing.
If you do not appear at the hearing, a judgment for possession and costs, and for damages and rent if claimed, may
nevertheless be entered against you. A judgment against you for possession may result in your eviction from the premises.
October 31, 2011
Date Magisterial District Judge Richard S. Dougherty
If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services,
please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation.
MDJS 308 1 Printed: 10/31/2011 11:02:26AM
COMMONWEALTH OF PENNSYLVANIA
d,OUNTY OF: CUMBERLAND
Mag. Dist. No.:
MDJ Name: Hon-
09-1-03
RICHARD S. DOUGHERTY
Address: 9 8 S ENOLA DR STE 1
ENOLA, PA
Telephone: (717) 728-2805
17025
Filing Costs $ AM D Postage $ _
Service Costs $
Total Constable Ed. $ _7_7
Pa.R.C.P.D.J. No. 6 sets forth those costs recoverable by
the prevailing party.
LANDLORD AND
TENANT COMPLAINT
PLAINTIFF: NAME and ADDRESS
F
Robert & Sandra Knawby
5260 Deerfield Avenue
Mechanicsburg, Pa. 17050
L 717-737-7421
VS.
DEF ND NT: y5 NAME and ADDRESS
F N?W ? ! 1kiu
r. & Mrs. n rew K?
ohr
17 High Street
Enola, Pa. 17025
L
Docket No.:4/ _
Date Filed:
7
J
J
TO THE DEFENDANT: The above named plaintiff (s)
asks judgment together with costs against you for
the possession of real property and for:
Lease is RX] Residential FINonresidential.
XX Damages for injury to the real property, to wit: Not sure at this time
in the amount of: $
1-1 Damages for the unjust detention of the real property in the amount of
XK Rent remaining due and unpaid on filing date in the amount-of
Includes water and fuel oil.
® And additional rent remaining due and unpaid on hearing date
Attorney fees in the amount of
THE PLAINTIFF FURTHER ALLEGES THAT:
.$ 9.7-18.66
$
Total: $
800.00
1. The location and the address, if any, of the real property is: 17 High Street Enola, Pa. 17025
2. The plaintiff is the landlord of that property.
3. He leased or rented the property to you or to
4. ® Notice to quit was given in accordance with law, or
No notice is required under the terms of the lease.
5. The term for which the property was leased or rented is fully ended, or
F] A forfeiture has resulted by reason of a breach of the conditions of the lease, to wit:
under whom you claim.
or,
FIRent reserved and due has, upon demand, remained unsatisfied.
6. You retain the real property and refuse to give up its possession.
1, Robert L. Knawby verify that the facts set forth in this complaint
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) relating to unsworn f sification to authorities.
-(Signature o aintiff)
(Plaintiff's Attorney) (Address) (Phone)
IF YOU HAVE A DEFENSE to this complaint you may present it at the hearing. IF YOU HAVE A CLAIM against the plaintiff arising out of the occupancy of the premises,
which is in the magisterial district judge jurisdiction and which you intend to assert at the hearing, YOU MUST FILE it on a complaint torn at this office BEFORE THE TIME set for the
hearing. IF YOU DO NOT APPEAR AT THE HEARING, a judgment for possession and costs, and for damages and rent it claimed, may neverihelesa be entered against you.
A judgment against you for possession may result in your EVICTION from the premises.
If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services,
please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation.
DPC 31 OA-09 Remarks end summary 01 testimony may be recorded on reverse side
COMMONWEALTH OF PENNSYLVANIA Receipt
COUNTY OF CUMBERLAND
Mag. Dist. No: MDJ-09-1-03
MDJ Name: Honorable Richard S. Dougherty
Address: 98 South Enola Drive, Suite 1
Enola, PA 17025
Telephone: 717-728-2805
Payor: Robert/Sandra Knawby
5260 Deerfield Avenue
Mechanicsburg, PA 17050
Payment Source: Window
Receipt Number: 09103-2011-R0004930
Recorded Date: 10131/2011 9:56:03AM
Receipt Date: 10131/2011
Manual Receipt No:
Payment Date Payment Method Check I Money Order Bank Transit Number Void Payment
Number Amount
10/31/2011 Check 4948 No $181.00
Responsible Participant: Knawby, Robert/Sandra
Docket Number: MJ-09103-LT-0000122-2011 Knawby, Robert/Sandra v. Kohr, Andrew, et al
Complaint/Citation Number: Lead Offense:
Total amount owed by responsible participant on all non-archived $0.00
cases in this Court for Participant Account No 2011-0925121:
Nayment Summary:
Total Payment Received: $181.00
Change Amount: $0.00
Retained Unapplied Amount: $0.00
Payments Less Change: $181.00
Comments: ko
RETAIN THIS RECEIPT FOR YOUR RECORDS
You can make case payments online through Pennsylvania's Unified Judicial System web portal. Visit the portal at
httpJ/ujsportal.pacourts.us to make a payment.
MDJS 120 1 Printed: 10/31/2011 9:56:04AM
SHERIFF'S OFFICE OF CUMBERLAND COUNT
r7' cc
n
Ronny R Anderso
Sheriff
Jody S Smith Co ?
Chief Deputy
w
Richard W Stewart :> { a
Solicitor Zr
?n
Sandra & Robert Knawby
vs.
Andrew Kohr (et al.)
Case Number
2012-91
SHERIFF'S RETURN OF SERVICE
01113/2012 02:34 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January
13, 2012 at 1434 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendants, to wit: Andrew Kohr and Kristen Kohr, in the hands, possession, of
control of the within named garnishee, M&T Bank, 1 W High Street, Carlisle, Cumberland County,
Pennsylvania, 17013 by handing to Donna Egolf, Teller, 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 17, 2012 to Andrew Kohr at 209 First
Street, Summerdale, PA 1093 and to Kristen Kohr at 209 First Street, Summerdale, PA 17093.
SO ANSWERS,
January 17, 2012 RON R ANDERSON, SHERIFF
, V?Z; 7
w utsha 1, Deputy heriff
ico C-0uR yJUito, 5hs7r'f. Ie': ,^.50'I. I , , c.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
?txj ut `;itr,l?r?
LID"
F3LE0, _t?x:: ,. .
t?
pkiillt,+E
2012 JAN 23 AM 10: 4«
CUMBERLAND COU14I Y
PENNSYLVANIA
Sandra & Robert Knawby Case Number
vs.
Andrew Kohr (et al.) 2012-91
SHERIFF'S RETURN OF SERVICE
01/13/2012 08:10 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January
13, 2012 at 2010 hours, he served a true copy of the within Notice of Intent to Attach Wages, upon the
within named defendant, to wit: Andrew Kohr, by making known unto Kristen Kohr, Wife of Defendant at
209 First Street, Summerdale, Cumberland County, Pennsylvania 17093 its contents and at the same time
handing to her personally the said true and correct copy of the same.
RYAN BURGETT, DOYOTY"
01/13/2012 08:10 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January
13, 2012 at 2010 hours, he served a true copy of the within Notice of Intent to Attach Wages, upon the
within named defendant, to wit: Kristen Kohr, by making known unto herself personally, at 209 First Street,
Summerdale, Cumberland County, Pennsylvania 17093 its contents and at the same time handing to her
personally the said true and correct copy of the same.
SHERIFF COST: $60.44
January 17, 2012
RYAN BURGETT, DEPUTY---*"
SO ANSWERS,
RON R ANDERSON, SHERIFF
ir'CountySwte ahentf. Feleas, tt In;.
ROBERT AND SANDRA
KNAWBY
VS
ANDREW KOHR
Employee
TO: UPS FREIGHT
6060 CARLISLE PIKE
MECHANICSBURG, PA 17050
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
No. 2012-0091 Civil Term
RE: Residential Lease between Plaintiff and Defendant
WRIT OF ATTACHMENT
The above employer shall attach and deduct from the wages of the above employee a sum not to
exceed ten (10%) of the net wages per pay period of said employee or a sum not to place employees net
income below poverty income guidelines as provided annually by the Federal Office of Management and
Budget, whichever is less. "Net wages" shall mean all wages paid, less only the following items:
1. Federal, State and Local income taxes;
2. F.I.C.A. payments and non-voluntary retirement payments;
3. Union dues; and,
4. Health insurance premiums
The amount wages to be attached shall total $12,181.00 (plus costs)
The employer shall send the attached wages to the Prothonotary, Cumberland County
Courthouse, One Courthouse Square, Carlisle, PA 17013, payable to Plaintiff-Creditor: ROBERT
AND SANDRA KNAWBY within fifteen (15) days from the close of the last pay period in each month.
The employer shall be entitled to deduct from the wages collected from the employee pursuant hereto the
costs incurred from the extra bookkeeping necessary to implement the terms within the Writ of Attachment,
not exceeding $5.00 of the amount of the wages so deducted. If you, the employer, are served with more
than one Writ of Attachment for damages arising out of a residential lease against the same employee, then
the wage attachments shall be satisfied in the order in which said Writs of Attachment were served. Each
prior wage attachment shall be satisfied before any effect is given to a subsequent attachment.
You shall not take any adverse action against the employee solely because his wages, salaries or
commissions have been attached. Violations may result in (i) you being adjudged in contempt and
committed to jail or fined by the court and (ii) an action against you by the employee for damages.
Willful failure to comply with this Writ of Attachment may result in (i) you being adjudged in
contempt of court and committed to jail or fined by the court; (ii) you being held liable for any amount not
withheld, or withheld but not forwarded to the Prothonotary's office; and, (iii) attachment of your funds or
property.
This Writ of Attachment has been entered pursuant to 42 PA. C.S.A. 8127, as amended by House
Bill 908, Act 5 of 1996, effective February 15, 1996. A copy of this Writ of Attachment has been sent by
U.S. Mail, postage prepaid, to the employee's last known address at:
ANDREW KOHR
209 FIRST STREET
SUMMERDALE, PA 17093-8021
Any questions should be directed to the Plaintiff-Creditor:
Charles W. Johnston Esq., 101 Erford Road, Suite 302, Post Office Box 98, Camp Hill, PA 17001
(717)975-5500
Date: 2/14/12
D.2
David D. Buell, Prothonotary
Costs: $177.25 pd atty By Depu
You shall send the following notice to the Prothonotary if the defendant has never been or is on longer an
employee on company letterhead:
Date:
1 have received a Writ of Attachment in the following case:
Plaintiff
No of Year
The following person,
Or is no longer and employee (_)
has never been (_)
Signature of Employer
Print name of Employer
Address
Address
Telephone #
For Prothonotary use only
Date:
David D. Buell, Prothonotary
v. Defendant
Deputy
(Seal of the Court)
' C F 1C
T111 PR0TH0N0TAR'r
28 12 FEB 14 PM 2: 5 4
Robert and Sandra Knawby
Plaintiffs
V.
Andrew Kohr and
Kristen Kohr,
Defendants
In the Court of Copes t$ 1 MQ COUNTY
Cumberland County, PEWNSIY MNIA
: No. 2012-91
PRAECIPE FOR WRIT OF ATTACHMENT OF WAGES
To the Prothonotary:
1. Issue a Writ of Attachment of Wages in the above-noted matter against UPS
Freight, employer of Defendant, Andrew Kohr.
2. The Defendant/Judgment-Debtor is as follows:
Andrew Kohr
209 First Street
Summerdale, PA 17093-8021
3. The employer garnishee of Defendant/Judgment-Debtor Andrew Kohr is as fol-
lows:
UPS Freight
6060 Carlisle Pike
Mechanicsburg, PA 17050
4. The Judgment arises out of a residential lease for the premises at 17 High Street,
Enola, Cumberland County, Pennsylvania.
5.
(a) The amount of the judgment is $12,181.00.
(b) A security deposit in the amount of $600.00 is being held by the judgment
creditor-landlord. This security deposit has been applied to payment of rent due on the
same premises for which the judgment has been entered.
(c) The amount of $0.00 has been paid toward satisfaction of the judgment.
6. Notice of Intent to Attach Wages, Salary or Commissions was personally served
upon Defendant/Judgment-Debtor Andrew Kohr on January 13, 2012, by the Cumberland Coun-
ty Sheriff.
st,b.oo Cat= a'a. So k e,
3i. as « Y . sa w
as. so r < <, 1-1-7, -PS
a8, so ?' k
j
7. Defendant/Judgment-Debtor Andrew Kohr has not filed a claim for exemption
from attachment.
Dated: February 13, 2012
Respectfully submitted,
CHARLES W. JOHNSTON, P.C.
101 Erford Road, Suite 302
Post Office Box 98
Camp Hill, Pennsylvania 17001-0098
Tele e: 7) 975-5500
F csimil (71975-551k
CtfikRfES W. JOHNSy( I
Pa. I.D. No. 15621 U
e-mail: cjohnston@jadlegal.com
Attorney for Plaintiffs/Judgment Creditors
ROBERT AND SANDRA
KNAW BY
VS
KRISTEN KOHR
Employee
TO: DIRECT BRANDS, INC.
1225 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
No. 2012-0091 Civil Term
RE: Residential Lease between Plaintiff and Defendant
WRIT OF ATTACHMENT
The above employer shall attach and deduct from the wages of the above employee a sum not to
exceed ten (10%) of the net wages per pay period of said employee or a sum not to place employees net
income below poverty income guidelines as provided annually by the Federal Office of Management and
Budget, whichever is less. "Net wages" shall mean all wages paid, less only the following items:
1. Federal, State and Local income taxes;
2. F.I.C.A. payments and non-voluntary retirement payments;
3. Union dues; and,
4. Health insurance premiums
The amount wages to be attached shall total $12,181.00 (plus costs)
The employer shall send the attached wages to the Prothonotary, Cumberland County
Courthouse, One Courthouse Square, Carlisle, PA 17013, payable to Plaintiff-Creditor: ROBERT
AND SANDRA KNAWBY within fifteen (15) days from the close of the last pay period in each month.
The employer shall be entitled to deduct from the wages collected from the employee pursuant hereto the
costs incurred from the extra bookkeeping necessary to implement the terms within the Writ of Attachment,
not exceeding $5.00 of the amount of the wages so deducted. If you, the employer, are served with more
than one Writ of Attachment for damages arising out of a residential lease against the same employee, then
the wage attachments shall be satisfied in the order in which said Writs of Attachment were served. Each
prior wage attachment shall be satisfied before any effect is given to a subsequent attachment.
You shall not take any adverse action against the employee solely because his wages, salaries or
commissions have been attached. Violations may result in (i) you being adjudged in contempt and
committed to jail or fined by the court and (ii) an action against you by the employee for damages.
Willful failure to comply with this Writ of Attachment may result in (i) you being adjudged in
contempt of court and committed to jail or fined by the court; (ii) you being held liable for any amount not
withheld, or withheld but not forwarded to the Prothonotary's office; and, (iii) attachment of your funds or
property.
This Writ of Attachment has been entered pursuant to 42 PA. C.S.A. 8127, as amended by House
Bill 908, Act 5 of 1996, effective February 15, 1996. A copy of this Writ of Attachment has been sent by
U.S. Mail, postage prepaid, to the employee's last known address at:
KRISTEN KOHR
209 FIRST STREET
SUMMERDALE, PA 17093-8021
Any questions should be directed to the Plaintiff-Creditor:
Charles W. Johnston Esq., 101 Erford Road, Suite 302, Post Office Box 98, Camp Hill, PA 17001
(717)975-5500
Date: 2l14/12 l? D
David D. Buell, Prothonotary Costs: $177.25 pd atty By Deputes
You shall send the following notice to the Prothonotary if the defendant has never been or is on longer an
employee on company letterhead:
I have received a Writ of Attachment in the following case:
Date:
Plaintiff
No _ of Year.
The following person,
Or is no longer and employee (_)
has never been (__)
Signature of Employer
Print name of Employer
Address
Address
Telephone #
For Prothonotary use only
Date:
David D. Buell, Prothonotary
v. Defendant
Deputy
(Seal of the Court)
p ILED-OFf ICr.
i HE RROTHONOTAR'?
H12 FEB 14 Ply 2: 54
Robert and Sandra Knawby : In the Court of Common Pleas CUMBERLAND COUNTY
Plaintiffs Cumberland County, Pennsylvania PENNSYLVANIA
V. :
Andrew Kohr and No. 2012-91
Kristen Kohr, :
Defendants
PRAECIPE FOR WRIT OF ATTACHMENT OF WAGES
To the Prothonotary:
1. Issue a Writ of Attachment of Wages in the above-noted matter against Direct
Brands, Inc., employer of Defendant, Kristen Kohr.
2. The Defendant/Judgment-Debtor is as follows:
Kristen Kohr
209 First Street
Summerdale, PA 17093-8021
3. The employer garnishee of Defendant/Judgment-Debtor Kristen Kohr is as fol-
lows:
Direct Brands, Inc.
1225 South Market Street
Mechanicsburg, PA 17055
4. The Judgment arises out of a residential lease for the premises at 17 High Street,
Enola, Cumberland County, Pennsylvania.
5.
(a) The amount of the judgment is $12,181.00.
(b) A security deposit in the amount of $600.00 is being held by the judgment
creditor-landlord. This security deposit has been applied to payment of rent due on the
same premises for which the judgment has been entered.
(c) The amount of $0.00 has been paid toward satisfaction of the judgment.
6. Notice of Intent to Attach Wages, Salary or Commissions was personally served
upon Defendant/Judgment-Debtor Kristen Kohr on January 13, 2012, by the Cumberland County
Sheriff.
as• S0
a8, !SO ?' ??. a5 Pd a?
7. Defendant/Judgment-Debtor Kristen Kohr has not filed a claim for exemption
from attachment.
Respectfully submitted,
CHARLES W. JOHNSTON, P.C.
101 Erford Road, Suite 302
Post Office Box 98
Camp Hill, Pennsylvania 17001-0098
17) 975-5500
Telephone
F sim . (717) 975-55J 1 ,,, ,
DES W. JOHNN
Pa. I.D. No. 1562
e-mail: cjohnston@jadlegal.com
Attorney for Plaintiffs/Judgment Creditors
Dated: February 13, 2012