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Home My WebLink About12-3055A. Scott A. Dietterick, Esquire Supreme Court I.D. #55650 Kimberly A. Bonner, Esquire Supreme Court I.D. #89705 James, Smith, Dietterick & Connelly, LLP PO Box 650 Hershey, PA 17033 (717) 533-3280 (717) 533-2795 Attorneys for Plaintiff GIRL SCOUTS IN THE HEART OF PENNSYLVANIA, PLAINTIFF V. JANINE SMITH, DEFENDANT ?t?(rfjil f P11 12, P NN YL7'lE?v'It? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ??-3?J CIVIL ACTION -LAW PRAECIPE TO THE PROTHONOTARY: KINDLY ENTER JUDGMENT in favor of the Plaintiff and against the Defendant, Janine Smith, in the amount of $1,221.51, plus interest at the legal rate of 6% from April 3, 2012, the date of the district justice judgment and costs of suit, pursuant to the judgment granted by District Justice George A. Zozos. I hereby certify that no a appeal has beer made. DATE: May 15, 2012 JAMES, S ITH, IETT RICK & CONNELLY, LLP By: Kimberly A. Bonner, Esquire Ctd 7/3 P ? 7,?L/5' 1q,4 J, 1 A,, JI' d COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF DAUPHIN Case Mag. Dist. No: MDJ-12-1-05 MDJ Name: Honorable George A. Zozos Address: 538 S 29th Street Harrisburg, PA 17104 Telephone: 717-231-3500 Kimberly Ann Bonner, Esq. James, Smith, Dietterick & Connelly, LLP PO Box 650 Hershey, PA 17033 Disposition Summary Docket No MJ-12105-CV-0000044-2012 Judgment Summary Participant Girl Scouts In The Heart Of Pa Janine Smith Plaintiff Defendant Girl Scouts In The Heart Of Pa Janine Smith JoinVSeveral Liability Individual Liability $0.00 $0.00 $0.00 $1,221.51 Girl Scouts In The Heart Of Pa V. Janine Smith Docket No: MJ-12105-CV-0000044-2012 Case Filed: 2/13/2012 Disposition Disposition Date Default Judgment for Plaintiff 04/03/2012 Amount $0.00 $1,221.51 Judgment Detail (*Post Judgment) In the matter of Girl Scouts In The Heart Of Pa vs. Janine Smith on 4/03/2012 the disposition is Default Judgment for Plaintiff and judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Lia bility Deposit Applied Amount Costs $0.00 $97.50 $97.50 Civil Judgment $0.00 $1,124.01 $1,124.01 Grand Total: $1,221.51 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE'OF APPEAL. EXCEPT./AS.OTHERW I$.E_PROVlUP.III-THE.-RU SSJF_OLXIL,_QR DURF ES2F :MAGI&TERIAL DISTRICI.,11 D0iES,1F.THE.JIIJ4MENI 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. n UNLESS THE JUDGMENT' IS ENTERED IN THE: COURY OFtOMMON 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, j OR OTHERWISE COMPLIES WITH•THE JUDGMENT. ilk Date Magisterial District Judge George A. Zozos ? ? •,. ?,;:4??s,?,';?.+,,,, s certify that t is is a true and correct copy o the record o the proceedings containing the judgment. .3?aeMagisteriarDistr udg? •°O•e°e•• Z\`N pc CT COO V` jtPllllttl? MDJS 315 Page 1 of 2 Printed: 04/03/2012 10:33:56AM GIRL SCOUTS IN THE HEART OF PENNSYLVANIA, PLAINTIFF V. JANINE SMITH, DEFENDANT TO: JANINE SMITH, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . NO. : CIVIL ACTION - LAW You are hereby notified that on May 15, 2012, judgment has been entered against you in the above-captioned case in the a unt of $1,221.51, plus interest at the legal rate of six (6%) percent, plus costs of suit. DATE: May 15, 2012 Prothonotary I hereby certify that the following is the address of the Defendant stated in the Certificate of Residence: Janine Smith 1178 Shoreham Road Camp Hill, PA 17011 TO: JANINE SMITH, DEFENDANT Por este medio se le esta notificando que el May 15, 2012, el siguiente Fallo ha sido antode en contra suya en el case mecianado en el epigrafe. FECHA: May 15, 2012 Prothonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: Janine Smith 1178 Shoreham Road Camp Hill, PA 17011 GIRL SCOUTS IN THE HEART OF PENNSYLVANIA, PLAINTIFF V. JANINE SMITH, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 3K) CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE I hereby certify that the addresses of the parties in the above-captioned action are as follows: Girl Scouts in the Heart. of Pennsylvania 350 Hale Avenue Harrisburg, PA 17104 Plaintiff Janine Smith 1178 Shoreham Road Camp Hill, PA 17011 Defendant JAM MITH, DIETTERICK & CONNELLY, LLP BY: ise L. Foster, Paralegal Scott A. Dietterick, Esquire Supreme Court I.D. #55650 Kimberly A. Bonner, Esquire Supreme Court I.D. #897.05 James, Smith, Dietterick & Connelly, LLP PO Box 650 Hershey, PA 17033 (717) 533-3280 (717) 533-2795 Attorneys for Plaintiff GIRL SCOUTS IN THE HEART OF PENNSYLVANIA, PLAINTIFF V. JANINE SMITH, DEFENDANT 1z _ yy : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . NO. : CIVIL ACTION -LAW AFFIDAVIT OF NO APPEAL I, Kimberly A. Bonner, Esquire, on behalf of the Plaintiff hereby affirm that I have not received any appeal from the Defendant, Janine Smith, from the Dauphin County Prothonotary, from the judgment awarded Plaintiff by District Justice George A. Zozos. James, ith,Dietteriick & C nnelly, LLP By: Kimberly A. Bonner, Esquire Attorney for Plaintiff Sworn and scribed e this day of May, 2012 o ary Public COMMONWEALTH OF PENN,YI VANIA NOTARI At. St, At, DENISEL FOSTER. Nt>CARY PUBLIC CITY OF HARRISBURG. DAUPI IIN COUNTY MY COMMISSION EXPIR1iS MARCH O5, 313 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - CIVIL DIVISION Girl Scouts in the Heart of Pennsylvania, Plaintiff V. Janine Smith, Defendant Amount Due $1,221.51 Interest at legal rate of 6% from 4/3/2012 @ $.20 per day • film 7rM Attorney's Comm. ?h Costs ?- 3 by TO THE PROTHONOTARY OF THE SAID COURT: 1---3 C. -I r? rF c.n 1a rya 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. PREACIPE FOR EXECUTION Issue write of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of description; supply four copies of lengthy personalty list) LEVY ON ALL PERSONAL PROPERTY, INCLUDING FURNITURE APPLIANCES TELEVISIONS, VCR'S, DVD PLAYERS, ENTERTAINMENT EQUIPMENT. JEWELRY. COMPUTERS, ETC., LOCATED AT: 1178 SHOREHAM ROAD, CAMP HILL, PA 17011 X and all other property for the defendant(s) in the possession, custody or control of the said garnishee(s). Any and all bank accounts with Metro Bank - 42 Bellaire Avenue, Carlisle, PA 17015 (Indicate) Index this writ against the garnishees a lis pendens against real estate of the defendant(s) described in the attached exhibit. I? DATE: May 15, 2012 Signature: \ ?'- °-?- Print Name: i erl A. Bonner Esquire 2fr d ? James, Smith, Dietterick A Connelly LLP P -.215" U? So ? ?? a7S al 5" Telephone: Box 650, 533-328p Hershey, PA 17033 Address: P ---y? Supreme Court I.D.#89705 BY Attorney for Plaintiff 3 (..1 S" cGzt S? ;? pd a y 7 5 Pct s ? 15 ??c c? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 12-3055 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GIRL SCOUTS IN THE HEART OF PENNSYLVANIA Plaintiff (s) From JANINE SMITH, 1178 SHOREHAM ROAD, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PERSONAL PROPERTY, INCLUDING FURNITURE, APPLIANCES, TELEVISIONS, VCR'S, DVD PLAYERS, ENTERTAINMENT EQUIPMENT, JEWELRY, COMPUTERS, ETC., LOCATED AT: 1178 SHOREHAM ROAD, CAMP HILL, PA 17011 . (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, 42 BELLAIRE AVENUE, CARLISLE, PA 17015 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 DueS1,221.51 L.L. $.50 Interest AT A LEGAL RATE OF 6% FROM 4/3/2012 @ $.20 PER DAY Atty's Comm % Atty Paid $62.75 Plaintiff Paid Date: MAY' 15, 2012 (Seal) Due Prothy $2.25 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : KIMBERLY A. BONNER, ESQ. Address: JAMES, SMITH, DIETTERICK & CONNELLY, LLP, PO BOX 650, HERSHEY, PA 17033 Attorney for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No. 89705 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 6 ?urt6r lJ i Jody S Smith - F Chief Deputy - Richard W Stewart MMMAY 18 FM 1: # Solicitor,.. - _-: 03B:RL.e3t1,N`,' PEMSYLVANIA Girl Scouts in the Heart of Pennsylvania Case Number vs. 2012-3055 Janine Smith SHERIFF'S RETURN OF SERVICE 05/17/2012 02:02 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 17, 2012 at 1402 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Janine Smith, in the hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Greg Apgar, Cusstomer Service Representative 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. SO ANSWERS, May 18, 2012 RON R ANDERSON, SHERIFF Noah Cline Deputy Scott A. Dietterick, Esquire Supreme Court I.D. #55650 Kimberly A Bonner. Esquire Supreme Court I.D. #89705 James. Smith. Dietterick & Connelly, LLP PO Box 650 Hershey, PA 170'1- (717) 533-3280 (717) 533-2795 Attorneys for Plaintiff GIRL SCOUTS IN THE HEART OF PENNSYLVANIA, PLAINTIFF V. JANINE SMITH, DEFENDANT V. METRO BANK, GARNISHEE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 'J NO. 30 5 CIVIL ACTION - LAW PLAINTIF 'S INTERROGATORIES TO METRO BANK, GARNISHEE TO: Metro Bank 42 Bellaire Avenue Carlisle, PA 17015 Pursuant to Pa. R.C.P. No. 3253, 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'. INSTRUCTION AND DEFINITIONS Answer Every Interrogatory. No question is to be left blank. If the answer to an Interrogatory is "none" or "unknown", such statement must be written in the answer. If the question is inapplicable, "N/A" must be written in the answer. Whenever a date, amount or other computation or figure is requested, the exact date, amount, computation or figure is to be given unless it is unknown. If so, give the best estimate or approximation thereof and note that such answer is an estimate or approximation. Whenever the word "identify" or "identity" is used in reference to a person, corporation or other entity, this means to state, if appropriate, his, hers or its full name, present address and business affiliation. DEFINITIONS A. As used herein, the words "you" and "your" refer to Metro Bank's agents, representatives, attorneys and all other persons acting or purporting to act on behalf of Metro Bank. B. As used herein, the words "defendant" or "defendants" refer to Janine Smith. C. As used herein, the word "document" shall mean the original and any copy, regardless of origin or location, or any book, pamphlet, periodical, letter memorandum, telegram, report, study, handwritten note, working paper, or any other written, recorded, punched, or taped matter, however produced, to which you have or have had access. D. As used herein, "corporation," "company" or "entity" shall mean any corporation, partnership, sole proprietorship, company, entity or business operation. E. As used herein, "communication" shall mean all conversations, whether oral or written, all telephone calls, telegrams, letters, memoranda, documents, discussions or any other form of communication. F. As used herein, "identify" or "identity" used in reference to an individual or person means to state her full name, present business and private addresses and telephone numbers, her present or last known occupation, her employer, and employer's address. G. As used herein, "identify" or "identity" when used in reference to a corporation, company, entity or institution means to state its full name and present address and telephone numbers, any fictitious names under which it operates.. and the present owners, officers and directors thereof with their current addresses. H. As used herein, "identify" or "identity" when used in reference to a document or communication means to state the date, author, type of document or communication (e.g., letter, memorandum, telegram, chart, etc.) or any other means of identifying it, its present location, and the name and address of its custodian.. If any such document or communication was, but is no longer, in your possession or subject to your control, state what disposition was made of it and who presently has it. If a precise value amount or date cannot be supplied in response to an interrogatory, provide an approximate value, amount or date. INTERROGATORIES 1. At the time you were served or at any subsequent time, did you owe the Defendant, any money or were you liable to the Defendant on any negotiable or other written instrument, or did the Defendant, claim that you owed the Defendant any money or were liable to her for any reason'? If so, fully state all particulars. ANSWER: Defendant has no accounts At the time you were served, or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons, any property or money of any nature owned solely or in part from the Defendant? If so, fully state all particulars. ANSWER: 3. At the time you were served, or at any subsequent time, did you hold legal title to any property or money of an,y nature owned solely or in part by the Defendant or in which the Defendant held or claim any interest? If so, fully state all particulars. ANSWER: 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any money or property of any nature in which the Defendant had an interest? If so, fully state all particulars, including but not limited to what property and/or money, how much, and of what value. ANSWER: At any time after you were served did you pay, transfer or deliver any money or property of any nature to the Defendant or to any person or place pursuant to the Defendant's direction, or otherwise discharge any claim of the Defendant against you? If so, fully state all particulars. ANSWER: 6. At the time you were served, or at any subsequent time, did the Defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment tinder Pennsylvania or Federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. ANSWER: 7. At the time you were served, or at any subsequent time, did the Defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa. C.S. § 8123? If so, identify each account. ANSWER: 8. At the time you were served with these Interrogatories, what is the account balance of the Defendant of any savings, checking, certificate of deposit, or any accounts held with Metro Bank? ANSWER: 9. At the time you were served, or at any subsequent time, did the Defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa. C.S. § 8123? If so, identify each account. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: May 15, 2012 By. Kimberly A. Bonner, Esquire Attorney I.D. #89705 P.O. Box 650 Hershey, PA 17033-0650 (717\ rggq-R?Rn ? If Attorneys for Plaintiff 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. f t4 / (SIG ATURE)