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HomeMy WebLinkAbout12-7066~~ I ~' i la k_~ ~:w F ~~~ ~ ~~i(:JFI~ le-~, ~~~I2'0'~ ~~ P~ ~~ -~ '~`'~=ee ~~~°SS~-~~rt~ C~Qi~n~~T'~~ ~ C~IAIV~ t t~~~[7~M REAGER & ADLER, P.C. Thomas O. Williams, Esquire Attorney I.D. No. 67987 Wayne S. Martin, Esquire Attorney I.D. No. 208078 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for W. C. Eshenaur & Son, Inc. W. C. Eshenaur & Son, Inc. IN THE COURT OF COMMON PLEAS OF 200 S. 41St Street CUMBERLAND COUNTY, PENNSYLVANIA Harrisburg, PA 17111, Plaintiff v. Allen Grace 289 Farm Road Newville, PA 17241, Defendant ' ~Olplo GV ~~ No. ~ o~ - PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Please enter the attached Notice of Judgment from MDJ No. 12-2-01 into the record. REAGER & LER, P.C. Date: November 2, 2012 Th O. Williams, Esquire Attorney I.D. No. 67987 Wayne S. Martin, Esquire Attorney I.D. No. 208078 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Q}}~ Facsimile: (717) 730-7366 C~,µ~ ''~ ~~• ~~ `._' ~ 3D`~9 ~ Attorneys for Plaintiff ~ ~3 ~ -~ ~a o~h~e ~le~ c~~ ~~U ~- 1 '~ o ~a COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF DAUPHIN Case Mag. Dist. No: MDJ-12-2-01 MDJ Name: Honorable Michael J. Smith Address: 1281 South 28th Street Harrisburg, PA 17111 Telephone: 717-558-1160 W.C. Eshenaur & Son, Inc. 200 S. 41st Street Harrisburg, PA 17111 W.C. Eshenaur & Son, Inc. V. Allen Grace Docket No: MJ-12201-CV-0000396-2012 Case Filed: 7/2/2012 Disposition Summary Docket No Plaintiff Defendant Qjsposition Disposition Date MJ-12201-CV-0000396-2012 W.C. Eshenaur & Son, Inc. Allen Grace Default Judgment for Plaintiff 08/01/2012 Judgment Summary Participant Join t/5everal Liability Individual Liability Amount Allen Grace $0.00 $816.39 $816.39 W.C. Eshenaur & Son, Inc. $0.00 $0.00 $0.00 Judgment Detail ~"PostJudgment) __ In the matter of W.C. Eshenaur & Son, Inc. vs. Allen Grace on 8/01/2012 the judgment was awarded as follows: Judgment Component Joir rt/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $718.39 $71g.3g Costs $0.00 $98.00 $98.00 Grand Total: $816.39 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARYlCLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTRRANSGRIPT FORM WITH YOUR 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. ,; UNtEB& fiHE ,3MfHT.~I&~~#N~1~~6QtJR~,;~. _ ~~N - OR OTHERWISE COMPLIES WITH THE JUDGMENT. ,. ,i e+o~sro a., r \ /, ~`y`) J ~ Date Ma ' terial istrict Michael J. Smith ~=-=-a~ ce r a is is a true an con's copy o e recur o e procee. -ngs'co amm e ~ gmen A ,^, ~r~E'ti {' '~ Dafe ,agist isttict,Judge r_ ,.` ~. , a ~ .~ ,~ v ;k } w, ,t MDJS 315 Page 1 of 2 Printed: 08/01/2012 4:20:15PM ', .. W.C. Eshenaur & Son, Inc. Docket No.: MJ-12201-CV-0000396-2012 v. Allen Grace ~ -~ '-~"' F ~ Pa~rtici.pant List r 3~1 ~-~ ~; ~--; ., ~.~ Cj j~ W.C. Eshenaur & Son, Inc. := N ~'' `' 200 S. 41st Street ~ ;;~• ~`_ Harrisburg, PA 17111 "; Defendants) Allen Grace _ , _ ._ Newville, PA 17241 ri _, } ., .: .. ' ~. r ~ ~ . t . ` 4 ;. ` h - .. .~, .. 4~~: _ _ ~ _ .,..w ..~ _v„,.~ .._.....:.. .. 4~•. ~~. ~ » ~ ~- .Y .. .~ F.. 4~ ~/ f,. 1 ; r .. ~ - - ~ MDJS 315 Page 2 of 2 Printed: 08/01/2012 4:20:15PM • OFFICE OF PROTHONOTARY Stephen E. Farina Prothonotary Front & Market Streets Harrisburg, PA 17101 (717) 780-6520 CERTIFICATION OF NO APPEAL FROM DISTRICT JUSTICE JUDGMENT DAUPHIN COUNTY. PENNSYLVANIA PLAINTIFF V. DEFENDANT DISTRICT JUSTICE DOCKET NUMBER ~..~ ~~~., C _ __ T~ " f:J '""' '~ a:,. .... { ~ .~ ::Y y ~ i::J r -.. "~ i~ ~ ~~ ~: . As of the date certified below, the following action has been taken on the above- referenced appeal: (~ There has been no appeal taken to the Court of Common Pleas () The following party has taken an appeal to the Court of Common Pleas: ~~~, ~ ~, ao ~a Date Steph E. Farina, Prothonotary B Deputy Proth. - 75 REAGER & ADLER, P.C. Thomas O. Williams, Esquire Attorney I.D. No. 67987 Wayne S. Martin, Esquire Attorney I.D. No. 208078 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for W. C. Eshenaur & Son, Inc. W. C. Eshenaur & Son, Inc. IN THE COURT OF COMMON PLEAS OF 200 S. 41 sc Street CUMBERLAND COUNTY, PENNSYLVANIA Harrisburg, PA 17111, Plaintiff v. Allen Grace 289 Farm Road Newville, PA 17241, Defendant TO: Allen Grace "1b~a~n ~~~~~ No. ~ ~" NOTICE You are hereby notified that judgment by praecipe w entered against you in the sum of $816.39 in the above captioned case Date: 1 '~ Prothonotary YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 34 S. Bedford Street, Carlisle, PA 17013 (717) 249-3166 I hereby certify that the name and address of the proper person to receive this notice is: Allen Grace 289 Farm Road, Nevwille, PA 17241 Atto ey for Plaintiff NE PRO @ONIGT ', 1112 DEC 19 PM 3: 24 vuMBERLAND COUNTY PENNSYLVANIA REAGER & ADLER, P.C. Thomas O. Williams, Esquire Attorney I.D. No. 67987 TWilliarns@ReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attornevs for Plaintiff W. C. Eshenaur & Son, Inc. IN THE COURT OF COMMON PLEAS OF 200 S. 41St Street CUMBERLAND COUNTY, PENNSYLVANIA Harrisburg, PA 17111, Plaintiff V. No. 12-7066 Civil Allen Grace 289 Farm Road Newville, PA 17241, Defendant and Metro Bank, Garnishee -Iq a l?`.Q FV,-jvp ?PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly enter a writ of execution in the above matter, (1) directed to the sheriff of Cumberland County; (2) against Allen Grace, defendant; and (3) against Metro Bank, garnishee; (4) and enter this writ in the judgment index a ? Pd a? Li ?t cL'W 311IS P *d644 4 t).)r -? 6 & D SA (a) against Allen Grace, defendant, and (b) against Metro Bank as garnishee, as a lis pendens against real property of the defendant in name of garnishee as follows: anv and all personal propertv (5) Amount due $ 816.39 Interest from August 1, 2012 $ 18.65 Costs as of the date of this Praecipe $ 59.75 Poundage $16.33 Attorneys' Fees $500.00 Returned Check Fee $10.00 TOTAL $ 1,421.12 REAGEVADLE C. Date: December 18, 2012 Thomas. Williams, Esquire Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 2012-7066 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due W.C. ESHENAUR & SON, INC. Plaintiff (s) From ALLEN GRACE, 289 FARM ROAD, NEWVILLE, PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell (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, 742 WERTZVILLE ROAD, ENOLA, PA 17025, ANY AND ALL PERSONAL PROPERTY 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 Due$816.39 Interest $18.65 Atty's Comm % Atty Paid $62.75 L.L. S.50 Due Prothy 2.25 Other Costs - ATTORNEYS FEES - $500.00 RETURNED CHECK FEE - $10.00 Plaintiff Paid Date: DECEMBER 19, 2012 (Seal) David D. Buell, Prothonotary By: -;? - Deputy RF,QUESTING PARTY: Name : THOMAS O. WILLIAMS, ESQUIRE Address: REAGER & ADLER, P.C. 2331 MARKET STREET CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-763-1383 Supreme Court ID No. 67987 _ 7?1?3PE 20 P? t: 33 pip [ ?ovI-VNNIA REAGER & ADLER, P.C. Thomas O. Williams, Esquire Attorney I.D. No. 67987 TWilliams@,)ReagerAdlerPC.com 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Plaintiff W. C. Eshenaur & Son, Inc. 200 S. 41St Street Harrisburg, PA 17111, Plaintiff V. Allen Grace 289 Farm Road Newville, PA 17241, Defendant and IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 12-7066 Civil Metro Bank, Garnishee INTERROGATORIES TO GARNISHEES To: Metro Bank 742 Wertzville Road Enola, PA 17025 Pursuant to Pa.R.C.P. 3144, 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: 1. At the time you were served or at any subsequent time did you owe the defendants 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 defendants any money or were liable to the defendant for any reason? No Accounts 2. 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 of any nature owned solely or in part by the defendant? 3. 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 either of the defendants or in which the defendant held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 5. At any time before or after you were served did the defendant 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 therefore? 6. At any time after you were served did you pay, transfer or deliver any money or property 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? 7. If you are a bank or other financial institution, 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 under Pennsylvania or federal law? If so, identify each account and state the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account. If so, identify any and all accounts, by account number, account holder(s) and amount of funds in each account in which the defendant has funds on deposit. Include all accounts owned solely or jointly owned by Defendant. 9. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have any safe deposit boxes at your institution? If so, identify the contents of the box and the identifying number of the box. REAGER & A ER, P.C. Date: December 18, 2012 Thom O. Williams, Esquire Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Plaintiff VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unswom 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. HSIG TURE) i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Anderson 11 r S Smith T HLE kG1 1"P,�F�"�tt t; ,f Deputy 2013 SEP '-5 PM 2: 53 dchard W Stewart Solicitor FCEOF kESkERtF.- CUMBERLAND COUNTY PENNSYLVANIA W.C. Eshenaur&Son, Inc. vs. Case Number Allen Grace 2012-7066 SHERIFF'S RETURN OF SERVICE 01/15/2013 12:25 PM -William Cline, Deputy Sheriff,who being duly sworn according to law, states that on January 15, 2013 at 1224 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Allen Grace, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle, Cumberland County, Pennsylvania, by handing to Sue Yingling, Customer 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 her. 02/11/2013 07:35 PM -Shawn Gutshall, Deputy, being duly sworn according to law, states that on February 11, 2013 at 7:35 PM hours, served the requested Writ of Execution and Claim for Exemption Form by"personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit:Allen Grace at 289 Farm Road, Penn Township, Newville, PA 17241, informed Defendant of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on 02-12-13. 09/04/2013 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: $132.64 SO ANSWERS, 6�Z September 04, 2013 RON R ANDERSON, SHERIFF (c)Counryguito Sheriff,Te!eosoft Inc, w i 11 @"!L D-()F TI-i r�OT�i0N0TPAR l 2413 SEP 13 AK 1O* 53 PEYL NN VCOUNTY REAGER& ADLER, P.C. Thomas O. Williams, Esquire Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff W. C. Eshenaur& Son, Inc., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. Allen Grace, No. 12-7066 Civil Defendant and Metro Bank, Garnishee PRAECIPE TO SATISFY AND DISCONTINUE TO THE PROTHONOTARY: Please mark the captioned judgment and action as satisfied and discontinued. REAGER rR, P.C. Date: September 11, 2013 Tho6KO. Williams, Esquire Attorney I.D. No. 67987 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Facsimile: (717) 730-7366 Attorneys for Plaintiff CERTIFICATE OF SERVICE 1, Alana L. Souders,Paralegal to Thomas O. Williams,Esquire, hereby certify that I have this date caused a true and correct copy of the foregoing document to be served upon the following counsel of record via First Class U.S. Mail,postage prepaid, addressed as follows: Allen Grace 289 Farm Road Newville,PA 17241 la Dated: SeptemberK, 2013