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HomeMy WebLinkAbout12-3559'e -,., WRIT OF EXECUTION and / or ATTACHMENT IN THE COURT OF COMMON PLEAS OF PERRY COUNTY, PENNSYLVANIA CIVIL DIVISION Manufacturers and Traders Trust Co. Ia 3ss9 V. NO. CV-2010-1203 WAIT doll- Mikabo Enterprises Michael S. Bowser Kathleen E. Bowser TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Manufacturers and Traders Trust Co. PLAINTIFF(S) from Mikabo Enterprises, Michael S. Bowser, and Kathleen E. Bowser DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell interest(s) therein: (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Fulton Bank and Members First Federal Credit Union GARNISHEE as follows: ANY AND ALL BANK ACCOUNTS IN THE NAME OF THE ABOVE DEFENDANTS and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is / are 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 and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him or her that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $50,124.40 Plaintiff Paid Interest Defendant Paid Due Prothy/Clerk Atty's Comm. % Other Costs -?-- /? Date: o? (3 1 `?o l o-1, ?/?t.J CERTIFIED A TRU Copy Prothonotary by: -?- D PUTYPROTHONOTARY Deputy REQUESTING PARTY: Name: Sarah A. Elia. Esauire/ Weber Gallagher Address: 2000 Market Street, 13 "' Floor V 1 W VA-1),S N ? d Philadelphia. PA 19103 ` 1 r!f1f''l (I1!'?j.js Attorney for: Plaintiff C15, P°( o`# Telephone: 267-295-3364 id-nr w Supreme Court ID No. 206946 7 Ll- .- No: CV-2010-1203 IN THE COURT OF COMMON PLEAS OF PERRY COUNTY, PA Manufacturers and Traders Trust Co. VS. Mikabo Enterprises Michael S. Bowser Kathleen E. Bowser Praecipe for Writ of Execution (Money Judgment) P.R.C.P. 3101 to 3149 Weber Gallaaher Simpon Stapleton Fires & Newby, LLP Sarah A. Elia, Esquire Attorney for Plaintiff 2000 Market Street, 13'h Floor, Philadelphia, PA 267-295-3364 Address of Defendants: Mikabo Enterprises 226 Reigle Road Marysville, PA17053 Michael S. Bowser 226 Reigle Road Marysville, PA17053 Kathleen E. Bowser 226 Reigle Road Marysville, PA17053 Address of Garnishees: Where papers may be served FULTON BANK 6520 CARLISLE PIKE #600 MECHANICSBURG, PA 17050 Members First Federal Credit Union 6280 Carlisle Pike Mechanicsburg, PA 17050 z 10Z SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith fi;?.j r) Chief Deputy Richard W Stewart ray t ,?, ?? Solicitor OFFICE OF rhs s?EatFF P-- 3 SS9 avr"I Manufacturers and Traders Trust Co., vs. Case Number Mikabo Enterprises, Inc (et al.) 2012-110 SHERIFF'S RETURN OF SERVICE 06/13/2012 10:15 AM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on June 13, 2012 at 1014 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Mikabo Enterprises, Michael S. Bowser, and Kathleen e. Bowser, in the hands, possession, or control of the within named garnishee, Fulton Bank, 6520 Carlisle Pike, Suite 600, Mechanicsburg, Cumberland County, Pennsylvania 17050, by handing to Jody L. Lewis, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. 06/18/2012 09:51 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 18, 2012 at 0951 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Mikabo Enterprises, Michael S. Bowser and Kathleen E. Bowser, in the hands, possession, or control of the within named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Gloria Dellanoce, 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 June 19, 2012 to Mikabo Enterprises at 226 Reigle Road, Marysville, PA 17053; to Michael S. Bowser at 226 Reigle Road, Marysville, PA 17053; and to Kathleen E. Bowser at 226 Reigle Road, Marysville, PA 17053. SO ANSWERS, June 19, 2012 RON R ANDERSON, SHERIFF Ti B ack, Deputy A ezlll? William Cline, Deputy ic; CounttySuite Shentf, Teleosoft. Inc. WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY, By: Peter E. Meltzer COU" Identification No.: 39828.±.?, 'x'11 C By: Sarah A. Elia Identification No.: 206946 2000 Market Street, 13`h Floor Philadelphia, PA 19103 (267) 295-3364 MANUFACTURERS AND TRADERS TRUST CO. 1100 Wehrle Drive, Ground Floor Williamsville, New York 14221 Plaintiff vs. MIKABO ENTERPRISES 226 Reigle Road Marysville, Pennsylvania 17053 MICHAEL S. BOWSER 226 Reigle Road Marysville, Pennsylvania 17053 KATHLEEN E. BOWSER 226 Reigle Road Marysville, Pennsylvania 17053 Defendants Attorneys for Plaintiff Court of Common Pleas of Perry County Members First Federal Credit Union 6280 Carlisle Pike Mechanicsburg, PA 17050 S?W's INTERROGATO ES IN ATTACHMENT RECEMED JUN 1 S YO1L You must file with the Court answers to the following interrogatories within 20 days after service upon you. Failure to do so may result in a default judgment being entered against you. A copy of said answers must be served on the undersigned. If your answers to any of the foregoing interrogatories is affirmative, specify the amount, value and/or nature of the subject property. (1) Identify every account (not previously noted), titled in the name Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser or in which you believe Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser has an interest, in whole or in part, including without limitation whether styled as a payroll account, individual retirement account, tax account, partnership account, corporate account, joint or tenants by 1 entirety account, insurance account, trust or escrow account, attorney's account or any other form of account, and for each account, state (a) the type of account, (b) the names of all account holders on the account, (c) the amount in the account and (d) the account number for the account. C "p9 Ac Poux l' - Ka-A /em C &ajSiec - &IW4jc/ Aa-4 yY9Z70 j.V1 anG? (2) At the time you were served or at any subsequent time, did you owe Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser any money or were you liable to Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser on any negotiable or other written instrument, or did Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser claim that you owed any money or were liable to Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser for any reason? J{S . ?O nd s lo C?Jci ac COA + (3) 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 control of yourself or one or more persons, any property of any nature owned solely or in part by Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser? No (4) At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser or in which Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser held or claimed any interest? NO (5) At any time before or after you were served or at any subsequent time, did you hold as a fiduciary any property in which Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser had an interest? N (6) At any time before or after you were served, did Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefor? 1 a (7) At the time you were served or at any subsequent time, did you pay, transfer or deliver any money or property to Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser or to any person or place pursuant to the direction of Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser? If your answer is in the affirmative, state, for each payment, transfer or delivery (a) the date, (b) the amount, and (c) the identity (including address) of the person who received the money or property. MO (8) At the time you were served or at any subsequent time, did you have or share any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, or collateral in which there was an interest claimed by Mikabo Enterprises, Inc., Michael S. Bowser and/or Kathleen E. Bowser? N6 Dated: May 10, 2012 By: a&?ak SARAH A. ELIA, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY IOE iff OF ` qH ROTH01`40 AIA-' and y S Smith ��0111 �,� r{#�� 2013 MA 18 PM 27 34 Chief Deputy Richard W Stewart ` ` � AND COUNTY Solicitor OFF t'E,'DF TkE S4ER1F: MhYLVANIA Manufacturers and Traders Trust Co., Case Number vs. Mikabo Enterprises, Inc(et al.) 2012-110 SHERIFF'S RETURN OF SERVICE l 06/13/2012 10:15 AM-Tim Black, Deputy Sheriff,who being duly sworn according to law,states that on June 13, 2012 at 1014 hours, attached as herein commanded all goods,chattels, rights,debts, credits, and monies of the within named defendants,to wit: Mikabo Enterprises, 4chael S. Bowser,and Kathleen e. Bowser, in the hands, possession, or control of the within named gar*hee, Fulton Bank, 6520 Carlisle Pike, E Suite 600, Mechanicsburg,Cumberland County, Perinsylvarift 17050,by handing to Jody L. Lewis, Branch Manager,personally three copies of interrogatories together with three true and attested copies of - the writ of execution and made the contents there of known to her. _ 06/18/2012 09:51 AM-William Cline, Deputy Sheriff,who being duly sworn according to law,states that on June 18, 2012 at 0951 hours, attached as herein commanded all goods,chattels, rights,debts,credits,and monies of the within named defendants,to wit: Mikabo Enterprises, Michael S. Bowser and Kathleen E. Bowser, in the hands, possession, or control of the within named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle,Cumberland County, Pennsylvania 17013, by handing to Gloria Dellanoce, 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 June 19, 2012 to Mikabo Enterprises at 226 Reigle Road, Marysville, PA 17053;to Michael S. Bowser at 226 Reigle Road, Marysville, PA 17053; and to Kathleen E. Bowser at 226 Reigle Road, Marysville, PA 17053. 03/14/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law,states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $212.99 SO ANSWERS, 11 I'll -0;22�7 �� March 18, 2013 RbNW R ANDERSON, SHERIFF 1 i t 1 ' I (c)CountySulle Sheriff,Teleosott Inc.