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HomeMy WebLinkAbout13-0515.~ i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Notice of Judgment/Transcript Civil Case Mag. Dist. No: MDJ-09-3-04 MDJ Name: Honorable Paula P. Correa! Address: 5275 East Trindle Road Suite 110 Mechanicsburg, PA 17050 ,Telephone: 717-697-2201 Hampden Township 230 South Sporting Hill Rd Mechanicsburg, PA 17050 Disposition Summary MJ-09304-CV-0000291-2012 Judgment Summary Participant Christopher Lee Priar Hampden Township Plaintiff Defendant Hampden Township Christopher Lee Priar JointlSeveral Liability Individual Liability $0.00 $1, 250.48 $0.00 $0.00 Hampden Township V. Christopher Lee Priar c`, c~ ...,.~ ..~~ w Docket No: MJ-093000(~829 ~ 1y~p~~ Case Filed: 8/23/201 ~ ~ ~`-" -r~ ~~, ; ~ s, ~ ~ , mac; -=:'t ~' C'> .:~ ~ :e7 ~`) ~+ ~ r-,~ . _ _ ~~ _> Disposition Judgment for Plaintiff Judgment Detail (`Post Judgment) In the matter of Hampden Township vs. Christopher Lee Priar on 10/04/2012 the judgment was awarded as follows: Judament Component Joint/Sev eral Liability Indi vidual Liability Deposit Applied Civil Judgment $0.00 $981.98 Filing Fees $0.00 $87.50 Costs $0.00 $6.00 Attorney Fees $0.00 $175.00 Grand Total: Amount $981.98 $87.50 $6.00 $175.00 $1,250.48 Disposition Date 10!04/2012 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT 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. 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, Amount $1,250.48 $0.00 MDJS 315 Page 1 of 2 Printed: 01/2 / 37PM ~~ ~. /n'1 fp !/,Cad Lt~~ Hampden Township v. Christopher Lee Priar Participant List Plaintiff(s) Hampden Township 230 South Sporting Hill Rd Mechanicsburg, PA 17050 Defendant(s) Christopher Lee Priar 4604 N Clearview Dr Camp Hill, PA 17011 Docket No.: MJ-09304-CV-0000291-2012 MDJS 315 Page 2 of 2 Printed: 01/28/2013 1:16:37PM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION ° =? - Hampden Township ❑Confessed Judgment ; _. � Y' Plaintiff 0 Other � vs. File No. 2013-515 Christopher Lee Priar Amount Due $1,250.48 _T Defendant Interest Address: Atty's Comm $250.00 4604 North Clearview Drive,Apt. C Costs Camp Hill, PA 17011 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CUmberland County,for debt,interest and costs,upon the following described property of the defendant(s) Any and all personal property of Defendant Christopher Lee Priar located at 4.604 North Clearview Drive, Apartment C, Camp Hill, Pennsylvania. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of _— County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property (if real estate,supply six copies of the description;supply four copies of len.athy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). E] (Indicate) Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s)described in the attached exhibit. Date March 21, 2013 _ Signature: Print Name: Keith O. Brenneman Address: 44 West Main Street i Mechanicsburg PA 17055 Attorney for: Plaintiff Hampden Township Telephone: 717-697-8528 Supreme Court ID No: 47077 _ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OFPENNSYLVANIA) N013-515 Civil COUNTY 0FCUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF 0F CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Hampden Township Plaintiff(x) From Christopher Lee Priur 4G04 North Cleurvimw Dc,Apt.C Camp Hill,PA 17811 (|) You are directed to levy upon the property of the defendant(s)and to sell Any and all personal property of Defendant Christopher Lee Prior located ut46O4 North ^C/oar,imvDr.,Apt.^[, Comp Hill, Pennsylvania /2) � (]) You are also directed to attach the property of the defendant(s)not levied upon in the possession of G/\KN\8RE2(S)uofollows: and no notify the garuiyhcc(x)that:(a)an attachment has been issued;(b)the guruisbmo(o) |s enjoined frum paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (u)or otherwise disposing thereof, (4) 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 io enjoined an above stated. Amount Due $1~250.48 L.L. $ .50 Interest S10.56 Aoy's Comm 96 Due Prntby$I.25 &ttyPaid 059.75 Other Costs P|uin6tTPuid Date: 3/21/13 David D. Buell, Prothonotary (0m|) Deputy R8(}DG8TlNO PARTY: Name : Keith 0. 0renoemun, Emg. Address: 44W. Main St. Mechanicsburg, PA 17055 Attorney for: PLAINTIFF Telephone: 717-697-8528 Supreme Court lD No. 47077 r A L � t?3_ f r rT Y < 3j£7 .t-C) _ Z_ rr T" 4 C:yy--u� ia,I �Mr Keith O. Brenneman, Esquire - N) Supreme Court ID No. 47077 Snelbaker & Brenneman, P. C. 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Hampden Township HAMPDEN TOWNSHIP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER LEE PRIAR, NO. 2013-515 Defendant MOTION TO COMPEL Plaintiff, Hampden Township, by its Solicitor, Snelbaker & Brenneman, P. C. submits this Motion To Compel and in support thereof states the following: 1. On January 29, 2013 judgment was entered against the Defendant in favor of Hampden.Township docketed to the above number. 2. On April 30, 2013 Plaintiff's attorney served upon Defendant Interrogatories in Aid of Execution, a true and correct copy of which Interrogatories are attached hereto and incorporated by reference herein as"Exhibit A". 3. Transmitted with the Interrogatories served upon Defendant was a letter dated April 30, 2 013 advising Defendant he had thirty (30) days from the date of the service of the LAW OFFICES SNELBAKER& Interrogatories by which to complete responses and provide them to Plaintiff's attorney. A true BRENNEMAN, P.C. and correct copy of the letter of April 30, 2013 is attached hereto and incorporated by reference herein as "Exhibit B". 4. Defendant has failed or refused to provide responses to the Interrogatories in Aid of Execution although more than sixty days has elapsed from the date that Defendant was served with the Interrogatories in Aid of Execution. 5. Defendant is not represented by counsel of record; accordingly, concurrence of counsel cannot be obtained in accordance with C.C.R.P. 208.2(d). 6. No judge has ruled upon any other issue in this matter or any related matter. 7. Plaintiff claims all reasonable expenses in connection with discovery in the event it is ascertained by discovery that Defendant has property liable to execution in accordance with Pa.R.C.P. 3117(b). WHEREFORE, Plaintiff requests this Court to issue an Order compelling Defendant to respond to the Interrogatories in Aid of Execution. SNELBAKER&BRENNEMAN, P. C. Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Date: July 8, 2013 Solicitor for Plaintiff Hampden Township -2- LAW OFFICES SNELBAKER& BRENNEMAN, P.C. - VERIFICATION I verify that the statements made in the foregoing Motion are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Keith O. Brenneman Date: July 8, 2013 LAW OFFICES SNELBAKER& BRENNEMAN, P.C. HAMPDEN TOWNSHIP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER LEE PRIAR, NO. 2013-515 Defendant INTERROGATORIES IN AID OF EXECUTION TO: Christopher Lee Priar, Defendant PLEASE TAKE NOTICE that you are hereby required,pursuant to Pennsylvania Rules of Civil Procedure 4006 and 3117, to serve upon the undersigned within thirty (30) days after service of this Notice, answers in writing and under oath to the following Interrogatories. SNELBAKER& BRENNEMAN, P. C. Keith 0. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Hampden Township Date: April 30, 2013 EXHIBIT A LAW OFFICES SNELBAKER & - BRENNEMAN. P.C. DEFINITIONS AND INSTRUCTIONS "You" and "your" shall mean and refer to Christopher Lee Priar, his agents, representatives, accountants, attorneys and any person, firm,business or entity acting on behalf of or at the request or direction of Christopher Lee Priar. "Identify" as used herein with respect to persons, means state the name, last known address,phone number, employer and employment position of the person. When used with respect to businesses, corporations, associations or entities, "Identify" means state the full name, last known address of its principal place of business and phone number of such business, corporation, association or entity. LAW OFFICES SNELBAKER& BRENNEMAN, P.C. 2 i INTERROGATORIES 1. For each savings account, checking account, certificate of deposit, money market account, mutual fund account or investment account owned by or maintained by you, either alone or jointly with another or others: a. describe the type or nature of the account or certificate (e.g. savings, checking, investment, etc.); b. state the name and address of the bank, institution or company that has or holds the account or certificate; c. state the title number, account number or identifying reference of the account or certificate; d. state the current balance of the account or value of the certificate; e. identify any co-owners or other owners of the account; and f. state when the account was opened or the certificate purchased. ANSWER: LAW OFFICES SNELBAKER& BRENNEMAN, P.C. 3 2. Identify and describe all items of tangible personal property which you own alone or . jointly with. another or others including, but not limited to, motor vehicles, furniture, office equipment, tools, power tools and appliances and for each item owned by you with another or others, identify each owner with reference to that item and the location of the item. ANSWER: LAW OFFICES SNELBAKER& ' BRENNEMAN, P.C. 4 I 3. Are you a shareholder in Hampden Automotive, Inc. or any other corporation? If so, state: a. The name of the corporation; b. The number of shares you own; and c. Identify the names of all officers and directors of each corporation. ANSWER: LAW OFFICES SNELBAKER& BRENNEMAN. f.C. 5 4. Identify, as that word is defined above, each person or entity that you claim is indebted to you or owes you any money, stating: a. the name and address of the person or entity; b. the total amount owed to you; and c. the reason or nature of the obligation giving rise to the debt owed. ANSWER: LAW OFFICES SNELBAKER& BRENNEMAN. P.C. 6 VERIFICATION I verify that the statements made in the foregoing Response to Interrogatories are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Christopher Lee Priar Date: LAW OFFICES - SNELSAKER& - BRENNEMAN, P.C. V Y CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN; ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Interrogatories in Aid of Execution to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS: Christopher Lee Priar 4409 Royal Oak Road Camp Hill, PA 17011 SNELBAKER &BRENNEMAN, P.C. Keith O. Brenneman, Esquire 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717)697-8528 Date: April 30, 2013 Attorneys for Plaintiff Hampden Township LAW OFFICES SNELBAKER& BRENNEMAN, P.C. SNELBAKER 8 BRENNEMAN, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 KEITH O.BRENNEMAN P.O.BOX 318 RICHARD C.SNELBAKER-OF COUNSEL 717-697-8528 FACSIMILE(717)697-7681 April 30, 2013 Christopher Lee Priar 4409 Royal Oak Road Camp Hill, PA 17011 Re: Hampden Township v. Christopher Lee Priar No. 2013-515, C.C.P., Cumberland County Dear Mr. Priar: Enclosed please find two copies of Interrogatories in Aid of Execution. You are required to provide responses to the Interrogatories that are enclosed. Once you have completed the interrogatory responses, you are to sign the Verification page and return the completed responses to interrogatories and the signed Verification page to me in the self-addressed stamped envelope that I have provided for you. You are to keep the other copy of the Interrogatories for your records. Please note that you have thirty days from the date of this letter by which to complete the responses and mail them back to me. If I do not receive the responses within that period of time, I will take appropriate action with the Court. Please be guided accordingly. Yours truly, Keith O. Brenneman KOB/sm Enclosures CC: Terri Noll, Hampden Township (w/enclosure) EXHIBIT B CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Motion to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Christopher Lee Priar 4409 Royal Oak Road Camp Hill, PA 17011 SNELBAKER&BRENNEMAN, P.C. By. jv1. � Keith O. Brenneman, Esquire 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717)697-8528 Date: July 8, 2013 Solicitor for Plaintiff Hampden Township LAW OFFICES SNELBAKER& BRENNEMAN, P.C. HAMPDEN TOWNSHIP, Plaintiff IN THE COURT OF COMMON PLEAS V. OF THE NINTH JUDICIAL DISTRICT CHRISTOPHER LEE PRIAR, Defendant 2013-00515 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION ORDER OF COURT AND NOW, this 12th day of July 2013, upon consideration of Plaintiffs Motion to Compel, a RULE is issued upon Defendant to show cause why an order compelling Defendant to respond to the Interrogatories in Aid of Execution should not be issued. PLAINTIFF shall effectuate service of this Order upon Defendant. A motion to make this Rule absolute will not be entertained until proof of service is filed. RULE RETURNABLE twenty (20) days from the date of service by Plaintiff. BY THE COURT, Thomas A. Placey C.P.J. D�istnbufion* C"') Keith O. Brenneman, Esq. z6hristopher Lee Priar CD C- C) -T-1 RONNY R.ANDERSON _�� -�,, RICHARD W.STEWART Sheriff Solicitor JODY S.SMITHY Chief Deputy OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 rn July 15,15, 2013 Hampden Township ,. C:; Vs rte `= Christopher Priar Writ No. 2013-515 =°� Property Claim Determination To Whom It May Concern: Reference is made to Property Claim dated July 5, 2013, entered by Melanie Thomas, Writ of Execution No. 2013-515, Hampden Township vs. Christopher Priar. Ronny R. Anderson, Sheriff, has determined that the claimant, Melanie Thomas, in the above mentioned property claim, is the owner of the property set forth in the claim. So Answers: R. Anderson, Sh riff By cc Keith Brenneman, Attorney for Plaintiff Melanie Thomas, Claimant Christopher Priar, Defendant NOTICE OF PROPERTY CLAIM Hampden Township In the Court of Common Pleas VS Cumberland County, Pennsylvania Christopher Priar No. 2013-515 Civil Term Writ of Execution TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Melanie Thomas, claiming property listed therein. Unless an appraisal of the property is requested within(10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 07-05-13 e ' f of Cumberland County Cc Keith Brenneman, Attorney for Plaintiff Melanie Thomas, Claimant Christopher Priar, Defendant PROPERTY CLAIM {,, In the Court of Common Pleas of 1 � _ � �����J�Y 1� Cumberland/County,Pennsylvania Writ No. 11 S I S TO THE SHERIFF OF CUMBERLAND COUNTY,PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant,but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE :5n 0S Or 00 ' , a - C ,b 00 . SC WSUr2 60C)( 66 1 1uh pin -- YAlb(o n D I Do, Do q 0 DD lo ,oD 1 44 A WtnQcLe 0 5kPlc 25 � DO THE CLAIMANT OBTAINEP TITLE TO THE PROPERT AS FOLLOWS: Date ` Claimant State.of Pennsylvania: County of Cumberland MG,m. being duly sworn according to law,deposes and says that the above list in the property claim.are correct and true. Sworn and subscribed to before me s b�z' day of ct oI NOTARIAL SEAL claimant Notary ublic JODY SMITH, NOTARY PUBLIC Carlisle Boro, Cumberland County MY Commission Expires April 4,2017 g w cha� rs ��� 6)() p CA,�-c OD 1 �a aoo, no �Ywr a ov, a�) U2KX/)dW 4'too ,6-1) I -e✓%Ee�-�a��rn�vrf ��� Sc�. ba Pa-:ho �w ri-i -1vc � IDo , 00 Ga5 �aS C�D f Ck q« scuA1 Lawyl rVl wer- `� I o D I DO uleed kiavr `� ao , 0D Luoyr- 4(Avlj -tml 5 Go I a oo S � DD , 60 Ml SC qtA-es 4 ZS,bD v,z �� /oa 00 moo l —TV a� �o00 -Xo. )e,, Chu,i R j 00.00 �duc�cS So Z I I Cj S- i € Elul _ t z �(�k �'�-r/s �_,. t S`i iW 14 I�7�SJ { 110�V0"A it I 20113 JUG 18 PM . I CUMBERLAND �:C1i�r4l°�' PENNSYLVANIA Keith O. Brenneman, Esquire Supreme Court ID No. 47077 Snelbaker& Brenneman, P. C. 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Hampden Township HAMPDEN TOWNSHIP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER LEE PRIAR, NO. 2013-515 Defendant PROOF OF SERVICE Keith O. Brenneman, Esquire, being duly sworn according to law, deposes and says that on July.17„2013 he did serve upon Defendant Christopher Lee Prior at his last known address a true and correct copy of the Order of Court issued in the above matter, which Order was dated July 12, 2013, by first class mail,postage prepaid. i Attached hereto and incorporated by reference herein as "Exhibit A” is a copy of the cover letter to Defendant Christopher Lee Prior dated July 17, 2013 transmitting a copy of the Order identified above on that date. i Keith O. Brenneman, Esquire Solicitor for Hampden Township Sworn to and subscribed before me this 10'r'4 day of July, 2013. LAW OFFICES SNELBAKER& a.COMMONWEALTH OF PENNSYLVANIA BRENNEMAN, P.C. .��— - Notarial Seal Notary Public Susan L.Mabrazi,Notary Public Mechanicsburg Boro,Cumberland County . My Commission Expires Nov.24,2015 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES I SNELBAKER 8 BRENNEMAN, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 P.O.BOX 318 KEITH O.BRENNEMAN RICHARD C.SNELBAKER-OF COUNSEL 717-697-8528 FACSIMILE(717)697-7681 July 17, 2013 Christopher Lee Priar 4409 Royal Oak Road Camp Hill, PA 17011 Re: Hampden.Township v. Priar No. 2013-515, C.C.P., Cumberland County Dear Mr. Priar: Enclosed please find a copy of the Order of Court issued by Judge Placey dated July 12, 2013 issuing a Rule upon you to show cause why an order compelling you to respond to the Interrogatories in Aid of Execution should not be issued. Please be guided accordingly. Yours truly, Keith O. Brenneman KOB/sm Enclosure CC: Terri Noll, Hampden Township (w/enclosure) EXHIBIT A e CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Proof of Service to be served upon the person and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS: Christopher Lee Priar 4409 Royal Oak Road Camp Hill, PA 17011 SNELBAKER&BRENNEMAN, P.C. Y• Keith O. Brenneman, Esquire 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717)697-8528 Date: tip (717)697-8528�-oi3 Solicitor for Hampden Township i LAW OFFICES SNELBAKER& BRENNEMAN, P.G. i i k,-,I'L t l.f,^� "�•r 4.L.i"S��' wi Darrell C. Dethlefs, Esquire h �)0}"liJfl�r�rti ID# 58805 ? j � DETHLEFS-PYKOSH LAW GROUP, LLC P 30 2132 Market Street C""I"ERLAND Camp PL 'NNSYLVAt j '`�' Cam Hill, PA 17011 PH#: (717) 975-9446 DDethlefs @aol.com HAMPDEN TOWNSHIP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO.: 2013-515 CHRISTOPHER LEE PRIAR, Defendant PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Darrell C. Dethlefs, Esquire in the above referenced matter for the Defendant, Christopher Lee Priar, per his request. Respectfully bmitted, Date: � �?' Darrell ethlefs, Esquire ID# 58805 DETHLEFS-PYKOSH LAW GROUP, LLC 2132 Market Street Camp Hill, PA 17011 PH#: (717) 975-9446 DDethlefs @aol.com S Darrell C. Dethlefs, Esquire ID# 58805 DETHLEFS-PYKOSH LAW GROUP, LLC 2132 Market Street Camp Hill, PA 17011 PH#: (717) 975-9446 DDethlefs @aol.com HAMPDEN TOWNSHIP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO.: 2013-515 CHRISTOPHER LEE PRIAR, : Defendant CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date, a true a correct copy of the foregoing Entry of Appearance was served by first class mail upon the following: Keith O. Brenneman, Esquire Snelbaker&Brenneman, PC 44 West Main Street Mechanicsburg, PA 17055 Attorney for Plaintiff Date: 7 r� 1 Darrel .4e , Esquire F!t.F()-11FF;C' Gr H PROTHOJ� ' ARY 2013 JUL 23 PM 3: 31 Ctl,MBERLAND COO,1�TY PEN,N'SYLYA14fA Darrell C. Dethlefs, Esquire ID#58805 DETHLEFS-PYKOSH LAW GROUP, LLC 2132 Market Street Camp,Hill, PA 17011 PH#: (717) 975-9446 DDethlefs @aol.com HAMPDEN TOWNSHIP, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO.: 2013-515 CHRISTOPHER LEE PRIAR, Defendant RESPONSE TO MOTION TO COMPEL Defendant, Christopher Lee Priar, by and through his attorney, Darrell C. Dethlefs, Esquire and Dethlefs-Pykosh Law Group, LLC replies to the Motion to Compel and in support thereof states the following: 1. Admitted. 2. . Admitted. 3. Admitted. 4. Denied. Defendant has provided answers to the Interrogatories in Aid of Execution. The Answers to Interrogatories are attached hereto. 5. Denied. Defendant is now represented by Darrell C. Dethlefs, Esquire. 6. Admitted. 7. Denied. The information in paragraph 7 states conclusion of law to which a response is not required. WHEREFORE, Defendant requests the Motion to Compel be denied. Respectfully Submitted, Date: Darrell C. Dethlefs, Esquire ID# 58805 DETHLEFS-PYKOSH LAW GROUP, LLC 2132 Market Street Camp Hill, PA 17011 PH#: (717) 975-9446 DDethlefs @aol.com VERIFICATION I, Christopher Lee Priar, verify that the statements made in the foregoing Answer to Motion to Compel are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. -DATE CHRISTOP ER LEE PRIAR HAMPDEN TOWNSHIP, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER LEE PRIAR, NO. 2013-515 Defendant INTERROGA lft1 Xffi OF EXECUTION TO: Christopher Lee.Priar, Defendant PLEASE TAKE NOTICE that you are hereby required,pursuant to Pennsylvania Rules of Civil.Procedure 4006 and 3117,to serve upon the undersigned within thirty(30)days after service of this Notice, answers in writing and under oath to the following Interrogatories. SNELBAKER& BRENNEMAN, P. C. Keith 0.Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Hampden Township Date: April 30, 2013 LAW OFFICES EXHIBIT A SNELBAKER& BRENNEMAN, P.C. } r i?�TFRFZt)�e,�ltlt�,lf � r. For F;.^.C:.7 Stit 1:1"C*,.'�' z'.�:��'412Z..�'.h4Clir;`F,_l.:t'J;.I:t,i.CrCrf�t4:At1:1/t t�C'Tl..'ar% :71C`rlt'} tt`.i+.r '.:t Iaccclunt.T11ti-M:. flit': :-t�LoV..t o. Itlt� C!li�t'.t wi:t`i1C+t Jti�r`cd by o r1Yr`tia.alnt� d F: y,.,j.i`.lt;'ltif 'a.One or jol" d'. �k iwh unok'l r or.ghera: N th. IN PC(.7 :1,1ture v f the JcciItar, ur.crti;1cat.: Sal in,4'.s. Gil'"LC��7Tt !r�tStGlcTlt, 'ICA, } � r r i 1 b. stag:the 1tamc and adiretios of the bank,inst.tt,tion or conipan that has car �i holds: the account or c:rtiL�catw: c. state:the tit': ltl n�h.r,accowit nuniber or ide-tifN ing reflerencc of the r rxcounl or tzrtit;ratet !r d. st utc the ctirrent'1al:rnco of the account or Value Of the certificate: t e. identify an,. co-ovwers or utter ON-ms of OW ac count;and j; t: state NN hen the account u as opened or the certificate purchase=d. ANSk\TR- ' 1. a. Health savings account � 1 �. b. Wells Fargo bank i 'j C. unknown d $6.00 e. none it f. unknown .I 1 r, 'I I + CFr r` 1 aN7.jl..Lt F1 4k CPC :! c i 11 i, �, identify and descabe 1!1 items,oftnnr2'Hc p- wnni p���I - which t'+�ti Ot�i� O;On+ or i jjoind# WW1 an[)Ui er or t OWTS bUt fl(It 1I III ited to.Motor farniture"Ofil e etpiprneat,tools. power tools nn ,1pliaiices and For c-.ch hern owned b� N�ou v:-it.h anvtlGCor cthtn. identify e.1ch eat nvx ttith Nferenee to that it:nu and the (ncotioo of the it,-.11, i i Defendant is the owner of a one bedroom suite at 105 Orrs Bridge Road, Mechanicsburg, Pennsylvania. Defendant is the owner of ! a 2005 Chevrolet Malibu with 130,000 miles. i t I ` f + I 1 i I f f c I t M 1 t + i i FF 0 r t 4 I + I+ � i 3. An!)'oti j shareholder in 11nmodm Automotive. Inc. Or aw, ;.;41. you,w ij;Ond c. Idot&-- Lhe-nnnies of all Aicer�mld diN."I'Drsof ea eh eor�qrjtiojl, AN E R, 3. Yes a. Hampden Automotive, Inc. b. 100 C. Christopher Priar t. LAW rr-w cc$ S'qxt4N-zLtA?w'Rc. ljerlljfy,as thil word L"dlcl'Tr-&d above,each pasonul- dral you claini is i3.d6ted to yvv Or Owes you 3,1-1 11,011e.N. staim"": li the tolal mQuill Cmvd to yox and P. the rwson oT hature offiv,ob.11-g.ndon j;Mng,rizic 10 aw, eebt owed. 4. a. none b. none C. none rl LAW cAllrAxMI 6 ! Y VERIFICATION I verify that the statements made in the foregoing Response to Interrogatories are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Christopher ee Priar Date: LAW OFFICES SNELSAKER& BRENNEMAN, P.C. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r 11-FD-0 1-'F i Sheriff f H 0 PRO"' Jody S Smith 2013 JUL 29 API 10: 34 Chief Deputy Richard W Stewart Solicitor OPME OFTt<SHERIFF CUM61-:RLAN10 COLINfY PEtiNSYLVIANIA Hampden Township vs. Case Number Christopher L Priar 2013-515 SHERIFF'S RETURN OF SERVICE 04/03/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Christopher L Priar, but was unable to locate the Defendant in his bailiwick, The Sheriff therefore returns the within requested Writ of Execution as"Not Found"at 4604 N. Clearview Drive,Apt. C, Hampden Township, Camp Hill, PA 17011. Per LISPS,defendant moved and left no forwarding address. 05/16/2013 05:55 PM -Amanda Cobaugh, Deputy , being duly sworn according to law, states that on May 16, 2013 at 5:55 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: Christopher L Priar at 4409 Royal Oak Road, Hampden Township, Camp Hill, PA 17011, 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 May 20, 2013. 06/18/2013 Sheriffs sale scheduled for July 15, 2013 at 3:00 p.m. 06/27/2013 03:00 PM-Deputy William Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Sheriffs Sale Bill in the above titled action, upon the property located at 4409 Royal Oak Road, Hampden Township, Camp Hill, PA 17011, Cumberland County. 07/05/2013 On July 05, 2013, a property claim was filed by Melanie Thomas.All parties notified by mail this date. 07/15/2013 Reference is made to Property Claim dated July 5, 2013, entered by Melanie Thomas, Writ of Execution No.2013-515, Hampden Township vs. Christopher Priar. Ronny R.Anderson, Sheriff, has determined that the claimant, Melanie Thomas, in the above mentioned property claim, is the owner of the property set forth in the claim. 07/26/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states that this writ of execution is returned STAYED per Pennsylvania Rules of Court 3206(c) pertaining to property claims. SHERIFF COST: $178.67 SO ANSWERS, July 26, 2013 RbNW FANDERSON, SHERIFF avt (c)CountySufte Sheriff,Toleosoft,Im, THE P R 0 T H,0NO.-, 2014 OCT 16 PM 1: 3C CUMBERLAND COUNTY PENNSYLVANIA HAMPDEN TOWNSHIP, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, V. PENNSYLVANIA CHRISTOPHER LEE PRIAR, NO. 2013 - 515 Defendant PRAECIPE TO THE PROTHONOTARY: Please mark the judgment entered in the above-captioned matter satisfied upon your docket and indices. Snelbaker& Brenneman, P.C. By: 1� Date: October 16, 2014 Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 Solicitors for Hampden Township LAW OFFICES SNELBAKER& BRENNEMAN, P.C.