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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 :P, o? 1.? ,.? r yz 4ab-60 PA PGFP 61SH e 01 6956-T e0v ,0 '%M 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