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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
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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~ ''~ ~~• ~~ `._'
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Attorneys for Plaintiff ~ ~3 ~ -~
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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.
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Date Ma ' terial istrict Michael J. Smith ~=-=-a~
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MDJS 315 Page 1 of 2 Printed: 08/01/2012 4:20:15PM ',
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W.C. Eshenaur & Son, Inc. Docket No.: MJ-12201-CV-0000396-2012
v.
Allen Grace ~ -~ '-~"'
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200 S. 41st Street ~ ;;~• ~`_
Harrisburg, PA 17111 ";
Defendants)
Allen Grace
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Newville, PA 17241
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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
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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:
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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
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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,
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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