HomeMy WebLinkAbout12-4022COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Mag. Dist. No: MDJ-09-2-02
MDJ Name: Honorable Jessica Brewbaker
Address: 18 North Hanover Street, Suite 106
Carlisle, PA 17013
Telephone: 717-240-6564
Brad L Glenn
100 Carroll Drive
Dillsburg, PA 17019
Disposition Details
Grant possession.
Grant possession if money judgment is not satisfied by the time of eviction.
Eric Guerin
Wage attachment is prohibited due to lack of personal service.
Wage attachment is prohibited under Title 42 Section 8127.
Ken Brower
Wage attachment is prohibited due to lack of personal service.
Wage attachment is prohibited under Title 42 Section 8127.
Tiffany Brower
Wage attachment is prohibited due to lack of personal service.
Wage attachment is prohibited under Title 42 Section 8127.
Vickie Guerin
Wage attachment is prohibited due to lack of personal service.
Wage attachment is prohibited under Title 42 Section 8127.
Disposition Summary
Docket No
MJ-09202-LT-0000167-2011
MJ-09202-LT-0000167-2011
MM'9202-LT-0000167-2011
Judgment Summary
Participant
Brad L Glenn
Eric Guerin
Ken Brower
Tiffany Brower
Vickie Guerin.
N '6' / ? - *'? ; C \":I
Notice of Judgment/Transcript
Residential Lease
Brad L Glenn
V.
Ken Brower, Tiffany Brower, Eric Guerin,
Vickie Guerin
Docket No: MJ-09202-LT-0000167-2011
Case Filed: 12/30/2011 n ,-, 4
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Plaintiff Defendant Disposition Disposition Date
Brad L Glenn Ken Brower Judgment for Plaintiff 01/13/2012
Brad LGlenn Tiffany Brower Plaintiff
Judgment ffoor 01/13/2012
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Brad L Glenn Vickie Guerin Judgment for Plaintiff 01/13/2012
Joint/S everal Liability Individual L iability Amo
nt
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$0.00 $0.00 $0.00
$1,900.33 $0.00 $1,900.33
$1,900.33 $0.00 $1,900.33
$1,900.33 $0.00 $1,900.33
$1,900.33 $0.00 $1,900.33
Judgment Detail ('Post Judgment)
In, the matter•of Breda, Glenn vs. Ken Brower; Tjffany. Brower; Eric Guerin; Vickie Guerin on 1/13/2012 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 $820.00
Judgment Component JointlSeveral Liability Individual Liability Deposit Applied Amount
Rent in Arrears $1,740.00 $0.00 $1,740.00
Costs $160.33 $0.00
$180.33
MDJS 315A Page 1 of 3 Printed: 01/13/2012 8:42:57AM
0
Brad L Glenn
v.
Ken Brower, Tiffany Brower, Eric Guerin, Vickie
Guerin
Docket No.: MJ-09202-LT-0000167-2011
Grand Total: $1,900.33
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
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 PROTHONOTARY/CLERK 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 OTHIEAWIS6_-PROWDED 114 THE RULE& OF CIVIL PROCEDUREt-FOR ?tSTERIAL DISTRICT JUDGES,-IF THE
JUDGMENT HOLDER ELECTS TO ENTER1P1ME JUDGMENt1N T' E'COum-OF COMMON OLEA , 'E:PLTR7HtffPRbOES§-IVfIJST 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.
Date Magisterial District Judge Jessica Brewbaker
certify t at t is is a true an correct copy o the record o the proceed ing ont ining the lu gmen .
Date Magi rial District Judge Jessica Brewbaker
v?
Y-:
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MDJS 315A Page 2 of 3 Printed: 01/13/2012 8:42:57AM
OMMMMM
Brad L Glenn
v.
Ken Brower, Tiffany Brower, Eric Guerin, Vickie
Guerin
Participant List
Docket No.: MJ-09202-LT-0000167-201 1
Plaintiff(s)
Brad L Glenn
100 Carroll Drive
Dillsburg, PA 17019
Defendant(s)
Ken Brower
119 E North St
y,
Carl+sle;,PA 17013
S y .
fiS,
Tiffany Brower
119 E. North St.
C4ri'Sic??? r?of3
Carlisle, PA 17013
Eric Guerin
1
19 E. North St.
14 Yi
Carlisle, PA 17013
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Vickie.Guerin
119 E. North St. ?C(c? f„ Cc Fct
Carlisle, PA 17013 k !w Co??cr /
??.r3irace-V; ? $yroYff
UJJ 51 5H Page 3 of 3 Printed: 01/13/2012 8:42:57AM
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV
BRAD L. GLENN,
Plaintiff
V.
ERIC GUERIN, VICKIE GUERIN,
KEN BROWER, TIFFANY BROWER,
Defendants
NO.: 2012-4022 -O
CIVIL ACTION - LANg c n
r,
PRAECIPE FOR NOTICE OF INTENT TO ATTACH WAGES
To the Prothonotary:
Issue a Notice of Intent to Attach Wages in the above matter against:
1. Ken Brower, Defendant;
257 S. Pitt Street, Carlisle, PA 17013
2. Tiffany Brower, Defendant;
257 S. Pitt Street, Carlisle, PA 17013
3. Eric Guerin, Defendant;
Home Depot #976,1621 N. Olden Ave., Ewing, NJ 08638
4. Vickie Guerin, Defendant;
Lawrenceville Nursing & Rehab Center, 112 Franklin Corner Rd, Lawrenceville, NJ 08
5. Carco Auto Service Center;
302 S. Queen Street, Littlestown, PA 17340
6. Lawrenceville Nursing & Rehabilitation Center;
112 Franklin Corner Rd, Lawrenceville, NJ 08648
7. Home Depot #976;
1621 N. Olden Ave., Ewing, NJ 08638
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By:
Andrew H. Shaw, squire
Sup. Ct. I.D. No. 87371
200 S. Spring Garden St., Suite 11
Carlisle, PA 17013
(717) 243-7135
Attorney for Plaintiff
Certification by Judgment Creditor - Landlord
I certify that:
1. The Plaintiff judgment-creditor is:
Brad L. Glenn
100 Carroll Drive, Dillsburg, PA 17019
2. Defendant judgment-debtors are:
a. Ken Brower
257 S. Pitt Street, Carlisle, PA 17013
b. Tiffany Brower
257 S. Pitt Street, Carlisle, PA 17013
c. Eric Guerin
Home Depot #976,1621 N. Olden Ave., Ewing, NJ 08638
d. Vickie Guerin
Lawrenceville Nursing & Rehab Center, 112 Franklin Corner Rd, Lawrenceville NJ
08648
3. The employer garnishees are:
a. Carco Auto Service Center, Employer of Ken Brower
302 S. Queen Street, Littlestown, PA 17340
b. Home Depot #976, Employer of Eric Guerin
1621 N. Olden Ave., Ewing, NJ 08638
c. Lawrenceville Nursing & Rehabilitation Center, Employer of Vickie Guerin
112 Franklin Corner Rd, Lawrenceville, NJ 08648
4. The judgment arises out of a residential lease for the premises at:
119 E. North Street, Carlisle, PA 17013
5.
a. The amount of the judgment is $3,214.48.
b. A security deposit in the amount of $0.00
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
execution is sought.
7. The judgment was entered (check one):
in a civil action commenced in the Court of Common Pleas;
in a civil action commenced in the Court of Common Pleas;
X in an action brought before a magisterial district judge;
in an action commenced in the Philadelphia Municipal Court.
8. Check the appropriate paragraph and attach the required documents:
(a) If the judgment was entered in a civil action (Pa.R.C.P.M.D.J. 301 et seq.) befo a
magisterial district judge, a copy of the complaint filed with the magisterial district judg is
attached to this Notice, showing that the action arose from a residential lease;
X (b) If the judgment was entered in an action for the recovery of possession or
property (Pa.R.C.P.M.D.J. 501 et seq.) before a magisterial district judge, copies of
appropriate magisterial district judge records are attached showing that the action arose f
a residential lease and that the defendant appeared or filed papers in the action or that
complaint was served by handing a copy to the defendant;
(c) If the judgment was entered in an action in the Philadelphia Municipal Court in
which the defendant was served pursuant to the Phila.M.C.R.Civ.P.No. 111(A) or (C) a
copy of the complaint filed with the Philadelphia Municipal Court is attached to this Noti e,
showing that the action arose from a residential lease;
(d) If the judgment was entered in an action in the Philadelphia Municipal Court
which the defendant was served pursuant to Phila.M.C.R.Civ.P.No. 111(B), copies of 1
appropriate Philadelphia Municipal Court records are attached showing that the action arc
from a residential lease and that the defendant appeared or filed papers in the action.
I certify that the statements made in this Certification are true and correct. I understand that f
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsv
falsification to authorities. , -?
F,
Date: low «- "
Tenn, en itor-Landlord
-Jul. '2. 2012 4:42PM CITIZENS HOSE No, 4089 P. 1
COMIyWN ItAL I H 01- rtNNSYLVANIA
LANDLORD AND CUMRFRI,ANn covNTY OF: TENANT COMPLAINT
MaplsleAef DISWCI Nwnbee:
09-2-02
015141 Jus110e Neme: Mon.
JESSICA E_ BREWBAKER
Address! 18 North Hanover Street
Suite 106
Carlisle, PA 17013
Telephone: (717)240-6564
TO THE DEFENDANT: The above named plaintiff(s) asks
judgment together with costs against you for the
possession of real property for:
Lease is ® Residential ? Nonresidential.
PLAINTIFF: NAME and AODRESS
Brad L Glenn
100 Carroll Drive
Dillsburg, PA 17019
(717) 773-0320
I
VS. _..
DrDANT: NAME and ADDRESS
Ken 8 Tiffany Brower
Eric & Vickie Guerin
119 E North St
Carlisle, PA 17013
Docket No.: LT-167-11
Date Filed: 12/30/11
AMOUNT DATE PAID
Filing Costs g 94.00
Service Costs $ 66.33
Total $ 160.33 12/ 0/11
Damages for injury to the real property, to wit:
Damages for the unjust detention of the real property in the amount of
Rent remaining due and unpaid on filing date in the amount of
And additional rent remaining due and unpaid on hearing date
THE PLAINTIFF FURTHER ALLEGES THAT:
1. The location and address, if any, of the real property is 1
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.
$ 870.00
Total: $
1
under whom you
5. ? The term for which the property was leased or rented is fully ended, or .
? A forfeiture has resulted by reason of a breach of the conditions of the lease, to wit:
® Rent reserved and due has, upon demand, remained unsatisfied.
6. You retain the real property and refuse to give up its possession.
I, Brad Glenn, 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 904
of the Crimes Code (18 PA. C. S. 3 4904) relating to unsworn falsification to authoritje . d INAL ? ;:, r r ;
(Signature of Plaintiff)
(Plaintiffs 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 district justice jurisdiction and which you intend to awed at the hearing, YOU MUST FILE it on a complaint form at this o
BEFORE THE TIME set for the hearing. IF YOU 00 NOT APPEAR AT THE HEARING, a judgment for possession and costa, and for damages and ent If
claimed, may nevertheless be entered against you. A judgment against you for possession may result in your EVICTION from the premises. a you re
dlcabled and require assistance, plesse contact the Magisterial District office at the address above.
AOPC 31 0A (12-1-96)
in the amount of. $
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
OFP ICE !,I` 'rG Ste; RIFF
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
H112 AUG -2 PM 12: 5
' UMBERLAND COUNT
PENNSYLVANIA
Brad L. Glenn Case Number
vs.
Eric Guerin (et al.) 2012-4022
SHERIFF'S RETURN OF SERVICE
08/01/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent se
and inquiry for the within named defendant to wit: Eric Guerin, but was unable to locate him in his
bailiwick. He therefore returns the within Notice of Intent to Attach Wages as not found as to the
defendant Eric Guerin. Request for service at 257 S. Pitt Street, Carlisle, Pennsylvania 17013 the
Defendant was not found. Deputies were advised, Eric Guerin has not resided at this address in over
year.
08/01/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent se;
and inquiry for the within named defendant to wit: Vickie Guerin, but was unable to locate her in his
bailiwick. He therefore returns the within Notice of Intent to Attach Wages as not found as to the
defendant Vickie Guerin. Request for service at 257 S. Pitt Street, Carlisle, Pennsylvania 17013 the
Defendant was not found. Deputies were advised, Vickie Guerin has not resided at this address in ov,
one year.
SHERIFF COST: $60.45
SO ANSWERS,
August 01, 2012
R ANDERSON, SHERIFF
c) ICountyS ite Sheriff, "I"ei os ft, Irr
IN THE COURT Oh COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BRAD L. GLENN,
Plaintiff
v. NO.: 2012-4022
ERIC GUERIN, VICKIE GUERIN, C[VIL ACTION -LAW
KEN BROWER, TIFFANY BROWER,
Defendants
AFFIDAVIT OF RETURN OF SERVICE
Andrew H. Shaw, being duly sworn according to law, deposes and says:
1. He is a competent adult who is not a party to the above action.
2. On September 14, 2012, service of the Notice of Intent to Attach Wages in the above action was
made by the undersigned by mailing said Notice to Eric Guerin, via certified mail.
3. Service occurred at 1621 North Olden Avenue, Ewing, NJ 08638, which is defendant's place of
employment, on September 14, 2012.
4. A copy of the signed return receipt is attached here ~ ~~~
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BRAD L. GLENN,
Plaintiff .
~'• NO.: 2012-4022
ERIC GLIERIN, VICKIE GUERIN, CIVIL ACTION -LAW
KEN BROWER, TIFFANY BROWER,
Defendants .
PRAECIPE FOR WRIT OF ATTACHMh:NT
To the Prothonotary: Please issue a Writ of Attachment of Wages, Salary or Commissions in the above-
captioned matter, in the amount of $1,900.33, plus costs.
1. Directed to Home Depot #976, 1621 N. Olden Ave., Ewing, NJ 08638;
2. against, Eric Guerin, Defendant;
~. and index this writ against Eric Guerin, Defendant, as an attachment of wages, salary or
i;ommissions.
Amount due
Interest from April 24, :2012
At an interest rate of 6°ro per year
Attorney fees
Costs
Date / _~ ~`{~:~
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$1,900.33
Total $ Plus costs, attorney fees and interest
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Andrew .Shaw, Esquire
Attorney LD. #87371
200 S. Spring Garden St., Suite 11
Carlisle, PA 17013
(717)243-7135
Attorney for Plaintiff
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Brad IJ. Glenn IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSY~_VANIA
VS CIVIL DIVISION
Eric Guerin, Vickie Guerin,
Ken Brower, Tiffany Brower No. 2012-4022 Civil Term
Employees
~f~): Eric Guerin
RF: Residential Lease between Plaintiff and Defendant
'WRIT OF ATTACHMENT
I'he above employer shall attach and deduct from the wages of the above employee a sum not to
exceed ten (10°,~0) 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 i~ffice 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.LC.A. payments and non-voluntary retirement payments;
3. Union dues; and,
4. Health insurance premiums
The amount wages to be attached shall total $1,900.33 (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: Brad L.
Glenn within fifteen (1 ~) days from the close of the last pay period in each month. The employer she!( 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 Che Writ of Attachment, not exceeding 55.00 of
the amount of the. wages so deducted. I;f you, the employer, are served with more than one Writ of
Attachment for dama,~es 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 he 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
coml7~issions have been attached, Violations may result in (i) you being adjudged in contempt aid
committed to jail or fined by the court and (ii) an action against you by the employee for damages.
1~'illful failutie 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 a~l~ount not
withheld, or withheld but not forwarded to the Prothonotary's office; and, (iii) attachment of your funds ~or
property.
S'his Writ of Attachment has been entered pursuant to ~32 PA. C.S.A. 8127, as amended by House
Bii(908. Act 5 of 1996, effective February 15, 1996. A copy of this Writ of Attachment has been sent by
~~ .~5 Mail. postage prepaid, to the employee's last known address at:
Home Depot #976, 1621 N. Olden Ave., Ewing, N! 08638
Any questions should be directed to the Plaintiff-Creditor:
Andre~~ H. Shaw, Esquire - 200 S, Spring Garden St., Suite 11, Carlisle, PA 17013
Date: 10 3 l /2012
____- ~ ~ ~L uF'L L ___
David D. Buell, P,ir~thonotary ~
Coats: $I?0.20 By Deputy: ~~// ~
You shall send the following notice to the Prothonotary if the defendant has never been or is on longer an
employee on company letterhead:
f have received a Writ of Attachment in the following case:
Plaintiff v. Defendant
No--- -__------ of Year- ~~---- ---
The following person, ~_ _ ___ _ has never been (_)
Or is no longer and employee (~)
Date:
Signature of Employer
Print name of Employer
Address
Address
Telephone #
i:;<xY.x*:k~;~: K~c ~F is ~k ~k ~c k~F ~Fk*~ek9ckkx~'c kir ~F kir 9ckk~Fkx~F*~k~*****:F*~: ~c***~c*~r is*ir is k~'c ~*xxxi<*x
For Prothonotary use only
Date: _ _ __ _ __
David D. Buell, Prothonotary
Deputy
(Seal of the Court)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BRAD L. GLENN,
Plaintiff
v. NO.: 2012-4022
ERIC GUERIN, VICKIE GUERIN, CIVIL ACTION -LAW
KEN BROWER, TIFFANY BROWER,
Defendants
AFFIDAVIT OF RETURN OF SERVICE
Andrew H. Shaw, being duly sworn according to law, deposes and says:
He is a competent adult who is not a party to the above action.
2. On September l 4, 2012, service of the Notice of Intent to Attach Wages in the above action was
made by the undersigned by mailing said Notice to Vickie Guerin, via certified mail.
3. Service occurred at 112 Franklin Corner Road, Lawrenceville, NJ 0864$, which is defendant's place
of employment. on September 14, 2012.
4. A copy of the signed return receipt is attached hereto.
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IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PF.NNSYL.VANIA
BRAD L.. GLENN,
Plaintiff
v. NO.: 2012-4022
ERIC GUERIN, VICKIE GUER[N, CIVIL ACTION -LAW
KEN BROWER, TIFFANY BROWER,
Defendants
PRAECIPE FOR WRIT OF ATTACHMENT
To the Prothonotary: Please issue a Writ of Attachment of Wages, Salary or Commissions in the above-
captioned matter, in the amount of $1,900.33, plus costs.
1. Directed to Lawrenceville Nursing & Rehab Center, 112 Franklin Corner Road,
Lawrenceville, NJ 08648.
2. against, Vickie Guerin, Defendant;
3. and index this writ against Vickie Guerin, Defendant, as an attachment oti wages, salary ar
commissions.
Amount due $1,900.33
Interest from April 24, 2012 $
At an interest rate of 6% per year
Attorney feeti $
Costs $
Total $ Plus costs, attorne~~ fees and interest
Date _~_ ,~f~ f ,; ~,-- ,~~f /{fir =------
Andrew H. Shaw, Esquire
Attorney LD. #87371
200 S. Spring Garden St., Suite 11
Carlisle, PA 17013
(717) 243-7135 ~' ;~ _LL:
Attorney for Plaintiff ~°o~ ~ ~ ~.,
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Brad L. Glenn IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS CIVIL DIVISION
Eric Guerin, Vickie Guerin,
Ken Brower, Tiffany Brower No. 2012-4022 Civil Term
Employees
T+J: 'Vickie Guerin
RF.~ Residential Lease between Plaintiff and Defendant
WRIT OF ATTACHMENT
I'he 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, evhichever is less. "Net wages'" shall mean all wages paid, less only the following items:
L Federal, State and Local income taxes;
2. F.LC.A. payments and non-voluntary retirement payments;
3. Union dues; and,
4. Health insurance premiums
The amount wages to be attached shall total $1,900.33 (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: L~rad I_.
Glenn within fifteen (l5) 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 55.00 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
commit..ted 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 yotn- funds or
property.
'('his Writ of Attachment has been entered pursuant to 42 PA. C.S.A. 8~ 127, as amended by House
Bi I 1908, Act 5 of 1996, effective February 15, 1996. A copy of this Writ of Attachment has bee~ia sent by
U.S. Mail, postage prepaid, to the employee's last known address at:
L~~wrenceville Nursing & Rehab Center, 1 l2 Franklin Corner Road, Lawrenceville, NJ 01648
yny questions should be directed to the Plaintiff-Creditor:
Andrew H. Shaw, Esquire-200 S. Spring Garden St., Suite 11, Carlisle, P.A 17013
Date: 10~ i 112012
David D. Buell, Prothonotat-~
Costs: :~ 120.20 By Deputy:
-_T~___~ __ .
You shall send the following notice to the Prothonotary if the defendant has never been or is on ion;;er an
employee on company letterhead:
I have received a Writ of Attachment in the following case:
Plaintiff v. Defendant
No of Year
T'he following person, ___ _ _ _ has never been ( )
i)r is no longer and employee (~
Date:
Signature of employer
Print name of Employer
Address
Address
Telephone #
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For Prothonotary use only
Dale:
David D. Bue11, Prothonotary
Deputy
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
RonnyRAnderson ~'L~.i7-UFFtt,~
Sheriff ~%?'~ ~~~ PROTND!dOTi~~~ .r
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Jody S Smith 2d (~' ~~Lf -~ k~ ~; ~ ~
Chief Deputy ~'
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Richard w stewart ~' ~ CUMBERLA,t~D COti~iTY
Solicitor ~~F~u~ ' "~ ~^~~'F~ PENNSY[.VANIA
Brad L. Glenn Case Number
vs. 2012-4022
Eric Guerin (et al.)
SHERIFF'S RETURN OF SERVICE
11/07/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Ken Brower, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Intent to Attach Wages as "Not
Found" at 257 S. Pitt Street, Carlisle Borough, Carlisle, PA 17013. The residence is vacant. The Carlisle
Postmaster provided a forwarding address of 85 Paige Hill Road, Landisburg, PA 17040.
11 /07/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Tiffany Brower, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Intent to Attach Wages as "Not
Found" at 257 S. Pitt Street, Carlisle Borough, Carlisle, PA 17013. The residence is vacant. The Carlisle
Postmaster provided a forwarding address of 85 Paige Hill Road, Landisburg, PA 17040.
SHERIFF COST: $60.45
November 07, 2012
SO ANSWERS,
.~ ----
RON R ANDERSON, SHERIFF
!c? Ceun!ySuite Snc-riff, Te~er.~so't, 4nc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BRAD L. GLENN,
Plaintiff
v.
ERIC GUERIN, VICKIE GUERIN,
KEN BROWER, TIFFANY BROWER,
Defendants
NO.: 2012-4022
CIVIL ACTION -LAW
NOTICE OF INTENT TO ATTACH WAGES, SALARY OR COMMISSIONS
Date of service of this Notice:
(Date to be inserted by the Sheriff)
A judgment has been entered against you in court for nonpayment of rent for, or damage to,
residential property that you rented. The judgment creditor-landlord has begun proceedings to
attach 10% of your net wages, salary or commissions for each pay period until the judgment is
satisfied.
The following exception will prevent your wages from being attached:
Poverty Guidelines -Your wages may not be attached if your net income is below the
poverty income guidelines as provided annually by the Federal Department of Health and Human
Services or if the amount of the attachment would cause your net income to fall below the poverty
income guidelines. A copy of the guidelines is attached to this notice.
If this exemption is applicable to you, you must return the claim for exemption of wages
which is attached to the prothonotary within 30 days of the date of service of this notice upon you.
The date of service of this notice is set forth above. If you return the form claiming this exemption
within 30 days, your wages will not be attached without subsequent court proceedings.
There may be other legal grounds for opposing the wage attachment that you may be able to
raise by filing a motion with the court. For example, your wages may not be attached if you are an
abused person or victim as set forth in Section 8127(f) of the Judicial Code when the attachment is
to satisfy a judgment for physical damages to the leased premises.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FOR THE BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
y ~~
•. C.w
~1Q~ ~
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Supreme Court of Pennsylvania
Civil Procedural Rules Committee
Poverty Income Guidelines
Pennsylvania Rule of Civil Procedure 3302(b) governs the attachment of wages,
salary and commissions under Section 8127(a)(3.1) of the Judicial Code. The rule requires
the prothonotary to attach to the Notice of Intent to Attach Wages "the most recent poverty
income guidelines issued by the Federal Department of Health and Human Services as
they appear on the web site of the Civil Procedural Rules Committee." The guidelines for
2012 are set forth in the following chart:
2012 HHS Poverty income Guidelines
Expressed in Monthly Amounts
Size of
Famil Unit Poverty Guideline
Monthl Amount
1 $930.83
2 1,260.83
3 1,590.83
4 1,920.83
5 2,250.83
6 2,580.83
7 2,910.83
8 3,240.83
For each additional
erson, add 330.00
~ ~ w
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BRAD L. GLENN,
Plaintiff
v.
ERIC GUERIN, VICKIE GUERIN,
KEN BROWER, TIFFANY BROWER,
Defendants
NO.: 2012-4022
CIVIL ACTION -LAW
CLAIM FOR EXEMPTION FROM WAGE ATTACHMENT
Notice
This Claim for Exemption must be filed with the Prothonotary of the Court within 30 days of
service upon you of the Notice of Intent to Attach Wages.
To the Prothonotary:
I, the above-named defendant, claim exemption of my wages, salary or commissions from
attachment on the following ground:
My net monthly income is below the poverty income guidelines as provided by the Federal
Department of Health and Human Services;
OR
The amount of wages to be attached would place my net income below the poverty income
guidelines as provided annually by the Federal Department of Health and Human Servivices.
I have dependents. (Number)
My net monthly income is $
(Net monthly income is your total monthly wages less (1) any support payments made to the court,
(2) federal, state and local income taxes, (3) F.I.C.A. payments and nonvoluntary retirement
payments. (4) union dues and (5) health insurance premiums.)
I certify that the statements made in this Claim for Exemption are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4404 relating to
unsworn falsification to authorities.
Date:
Defendant