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
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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
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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.
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(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
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March 18, 2013 RbNW R ANDERSON, SHERIFF
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