HomeMy WebLinkAbout04-6269
Plaintiff
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
; NO. D4 - Io:ll.:.'l (2~(J~L 18Ly>\
MARY E. HUMMEL
v.
MICHAEL CRUMLING
Defendant
: CIVIL DIVISION - LAW
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages,
you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance
personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you.
You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff.
You may lose money or property or other rights important to you.
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU
WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE 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
TWO LIBERTY A VENUE
CARLISLE PA 17013
(717) 249-3166
MARY E. HUMMEL
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 04-l-J1,,9 dD~L ~~
CIVIL DIVISION - LA W
v.
MICHAEL CRUMLING
Defendant
COMPLAINT
The Plaintiff, MARY E. HUMMEL, by her attorneys, KNUPP, KODAK & IMBLUM, P.c., brings this action of
Assumpsit against the Defendant to recover the sum of SEVENTEEN THOUSAND, FOUR HUNDRED DOLLARS AND
ZERO CENTS ($17,400.00), along with attorney's fees at the Statutory Rate and interest thereon from September 6, 2003,
upon a cause of action of which the following is a statement:
I. The Plaintiff, MARY E. HUMMEL, is an adult individual residing at 237 Grandview Road, Hummelstown,
Pennsylvania 17036.
2. The Defendant, MICHAEL CRUMLING, is an adult individual residing at 829 State Street, Lemoyne,
Cumberland County, Pennsylvania 17043.
3. On or about September 5, 2003 the Defendant did sign a Promissory Note to pay the Plaintiff the sum of
Nineteen Thousand Dollars and Zero Cents ($19,000.00). A true and correct copy of said Promissory Note is attached hereto,
marked Exhibit "A" and made a part hereof.
4. The Defendant paid to Plaintiff on account of the aforementioned charges certain sums of money as more
particularly set forth on Plaintiffs Bank Statement, hereto attached, marked Exhibit "B" and made a part hereof, in the total
amount of One Thousand, Six Hundred Dollars and Zero Cents ($1,600.00). .
F:\USER\ST ACY\CCP COMPLAINTS\WORK\30941.wpd:26Nov04
Non-recourse promissory note
NON-RECOURSE, NON-NEGOTIABLE PROMISSORY NOTE
Michael Crumling, referred to herein as MAKER, promises to pay to Mary Hummel,
referred to as HOLDER,
the sum of $ 19,000.00 (nineteen thousand & 00/100 Dollars),
with interest at the rate of 0 per cent, per annum; however, at no time shall the rate of
interest charged ~rein exceed the applicable limit provided by controlling interest and
usury statutes. If interest is charged in excess of the applicable maximum rate, any
overpaid interest shall be credited to principal.
This note shall be due upon demand.
Upon default, the sums due herein shall accrue interest at the highest legal rate. THIS
NOTE IS NON-RECOURSE, AND THE HOLDER MAY NOT SEEK RECOURSE TO
ANY PERSONAL ASSETS OF THE DEBTOR. The Maker does not agree to subject
any of his personal assets to the payment of this debt. However, the HOLDER of this
note may seek to subject any and all security for this debt for foreclosure or other
applicable legal or equitable remedies. However, a deficiency, if any, shall not be a
personal obligation of the HOLDER. The HOLDER shall be entitled to receive
attorney's fees and other costs of collection, provided that the same shall only
collected from proceeds from foreclosure or other legal or equitable remedies related
to security for this debt, if any. Such attorney's fees and collection costs shall not be
a personal obligation of the MAKER and the MAKER's personal assets shall not be
subject to the payment of these sums, however any property which is specifically
pledged may be subject to foreclosure or other remedy allowed by law.
Dated 91'10 ?
M~t~f[l~! ,1 tVf
Witness:
BELCO
Community C!edit U":lion
L getting you there
STATEMENT OF ACCOUNT
II
MAIN OFFICE:
403 N. 2nd Street
P.O. Box 82
Harrisburg, PA 17108
Page
1
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JOINT OWNERS
1...111...111.....11..11..1.1....1.1.11...1..1..11.1...1..1.11
MARY E HUMMEL PATRICIA A.
237 GRANDVIEW RD
HUMMELSTOWN?A 17036
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0817
0817
0820
0823 *
0826
0827
0830
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0817 *
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HUMMEL
PREVIOUS BALANCE ~ ~ SAVINGS
PAYMENT VIA OFFICE/MAIL
PREAUTHORIZED AUTO TRANSF
PREAUTHORIZED AUTO TRANSF 840788
PHONE TRANSFER VIA BELLE
DIVIDEND
ANNUAL PERCENTAGE RATE IS 1.00
ANNUAL PERCENTAGE YIELD IS 1.00
ANNUAL PERCENTAGE YIELD EARNED IS 1.00
NEW BALANCE
PREVIOUS BALANCE S4 ~ CHECKING
PAYMENT VIA OFFICE/MAIL
DRAFT PAID
DRAFT PAID
DRAFT PAID
DRAFT PAID
DRAFT PAID
PAYMENT VIA OFFICE/MAIL
ACH DRAFT
OLD NAVY #6550 PURCHASE -HARRPA
DRAFT PAID
DRAFT PAID
PHONE TRANSFER VIA BELLE
DRAFT PAID
DRAFT PAID
DRAFT PAID
NEW BALANCE
0459
0460
0461
0462
0463
0465
0464
0468
0466
0467
0469
80000
-22587
27587
-100000
595
10000
-2474
-10408
-2500
-3000
-5752
23573
-2800
-5000
-2100
100000
-7246
-3000
-59621
ACCOUNT NUMBER
737310
SOCIAL SECURITY if
STATEMENT PERIOD
From To
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712088
689501
717088
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617683
617683
52941
62941
60467
50059
47559
44559
38807
62380
59580
54580
52480
152480
145234
142234
82613
82613
------------------------ CLEARED DRAFT SUMMARY ----------------------
0459 0460 0461 0462 0463 0464 **** 0466 0467 0468 0469
PREVIOUS BALANCE L2 02 MERC SABL 517
PREAUTHORIZED AUTO TRANSF
NEW BALANCE-PERIODIC RATE.013671%
>> ANNUAL PERCENTAGE RATE 4.990%<<
**CONTINUED**
TOTAL DIVIDEND YEAR- TO-DATE
for aU savings except IRA.
Dividunds shown. if $1 0 or over, will be
reported to the Intemal Revenue Service
for this calendar year.
'INDICATES EFFECTIVE DATE
18353
4234
TAL FINANCE CHARGE YEAR- TO-DATE
for all loans .
999152
980799
980799
0718833
BELeo
STATEMENT OF ACCOUNT
Page
1
Community Credit Union
L gettingyou'there
MAIN OFFICE:
403 N. 2nd Street
PO, Box 82
Harrisburg. PA 171 D8
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JDINT DWNERS
ACCOUNT NUMBER
737310
SOCIAL SECURITY II
176-XX-XXXX
STATEMENT PERIOD
From To
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MARY E HUMMEL
237 GRANDVIEW RD
HUMMELSTOWN PA J7036
PATRICIA A. HUMMEL
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1101 PREVIOUS BALANCE 51-SAVINGS 962322
1117 * PREAUTHORIZED AUTO TRANSF -22587 939735
1117 * PREAUTHORIZED AUTO TRANSF 840788 27587 967322
1128 PAYMENT VIA OFFICE/MAIL 80000 1047322
1130 DIVIDEND 879 1048201
THE ANNUAL PERCENTAGE RATE IS 1. 10
THE ANNUAL PERCENTAGE YIELD IS 1.11
THE ANNUAL PERCENTAGE YIELD EARNED IS 1. 11
1130 NEW BALANCE 1048201
1101 PREVIOUS BALANCE 54-CHECKING 75398
1105 PAYMENT VIA OFFICE/MAIL 27620 103018
1105 DRAFT PAID 0361 -6904 96114
1117 PAYMENT VIA OFFICE/MAIL 34990 131104
1126 DRAFT PAID 0365 -8954 122150
1128 DRAFT PAID 0364 -3433 118717
1130 NEW BALANCE 118717
------------------------ CLEARED DRAFT SUMMARY ----------------------
0361 **** 0364 0365
1101
1117 *
1130
PREVIOUS BALANCE ~ ~ ~ ~ ~
PREAUTHORIZED AUTO TRANSF 17664 4923
NEW BALANCE-PERIODIC RATE.013671%
>> ANNUAL PERCENTAGE RATE 4.990%<<
** NEXT PAYMENT DUE: 12/18/03 MINIMUM PAYMENT AMOUNT:
1161598
1143934
1143934
225.87
TOTAL DIVIDEND YEAR- TO-DATE
for all savings except IRA.
Dividends shown, if $1 0 or over, will be
reported to the Internal Revenue Service
for this calendar vear.
*INDICATES EFFECTIVE DATE
262.54
TOTAL FINANCE CHARGE YEAR. TO-DATE
for aU loans.
154.47
NOTICE: See roverse side for important infonnation.
0701693
VERIFICA TION
I, MARY E. HUMMEL, verify that the statements made in the aforegoing document are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. S4904, relating to unsworn
falsification to authorities.
i'Y\o.ul C, '-\-\~ Q ,
Mary E. ~mel
Dated: \'L I \ \ O~
30941
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No(}(-62/,Q- CIVIL TERM
,
:CIVIL ACTION - LAW
: DIVORCE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take prompt action. You are warned that if you fail to do
so, the case may proceed without you and a decree of divorce or annulment may be entered
against you by the court. A judgment may also be entered against you for any other claim. or
relief requested in these papers by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at the Dauphin County Courthouse, Harrisburg, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT QNCE. 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
32 S. Bedford Street
Carlisle, P A 17013
(717) 249-3166
RE: Mary E. Hummel v Michael Crumling
In The court of Common Pleas
Cumberland County, Pennsylvania
NO 04-6269 Civil
11 /J5tJf:' /2.
I am not an attorney, however I will attempt to respond to the complaint, Mary
Hummel, Plaintiff, received by me on Dec 31, 2004, and hereby advise of my intention
to defend.
I feel it important to make some correction of facts, and offer some germane
details at this time. Defendant seeks to set aside this complaint, and continue paying
under the agreed terms. The following is a statement:
1. In the summer of 2003, Michael Crumling discussed with his close friends,
leaving his employment and creating a restaurant. Mary Hummel expressed an interest
in securing a place in the business for her future husband, Michael Hocker. She.
offered $ 15,000 for the purpose of investment, as she was "not making any money on
the savings account.' The defendant did agree that a partnership with Mr. Hocker would
be very desirable, but wished rather to borrow the funds personally. It was discussed
then, that the creation of a new business involves a great deal of planning and research,
and that any viable business plan would take several months to develop. The defendant
would start the process of forming a corporation and write a business plan. The funds in
question would be used to aid the defendant in setting up a real estate partnership with
Daniel Robison, for the purpose of securing real estate for the restaurant. Mr. Crumling,
and Mr. Robison executed a mortgage on the property. The defendant and partner
agreed to involve the Plaintiff and Mr. Hocker in a future investment property when
feasible Mr. Hocker and the defendant did become 25% shareholders when the
restaurant corporation was formed in 2004.
2. The plaintiff, and the defendant did make a verbal contract at the time the funds
were disbursed. The terms were as follows:
A. The defendant would add to the principle the amount of $ 4, 000 for a
total of $19,000 to be paid which would represent interesVinvestment income at the rate
of $ 1,000 a year for a four year term.
B. Payments of $ 400. would start and would correspond with estimated real
estate settlement date in November, 2003. Further, it was understood that there may be
a delay in payment from the time the defendant left his employer and until after the
restaurant was opened and operating well, and that it would be discussed on a month to
month basis.
C. The defendant could pay the note early if desired and it was agreed that
the disposition of interest or penalty would be discussed at that time.
D. If the aggregate of payments made did not satisfy the $ 19,000 at the end
of four years, a balloon payment for the balance would be paid immediately.
E. The plaintiff and the defendant agreed to retain the details of this loan as
a private matter specifically from those involved in the restaurant business. Though,
they were told at a later time.
3. On or about August, 2003 the funds were disbursed, and the process begun. Of
his own volition, the defendant did create the promissory note on or about September 5,
........^^ ___ _. ...J'~' __"_ _ ___L"... L_ L'- _ __'_'__,,-'11
6. Plaintiff has received payments for October 2004, November 2004, December,
2004. Plaintiff is also in receipt of payment for January 2005. All of these funds were
delivered to the plaintiff, prior to the service of complaint to the defendant.
7. Defendant last spoke with plaintiff, on or about September 17, 2004. Defendant
did attempt contact with the plaintiff on at least four occasions to discuss this and other
matters. Such calls and messages were not returned.
8. The defendant has never refused to pay. The defendant is current under the
terms of the original agreement, and intends to stay that way. The defendant believes
that the court should rule in favor of the defendant. Should the court rule in favor of the
plaintiff, the defendant asks that the principle be restated to reflect the facts $ 19,000
less $ 4,000 interest added to principle and less $ 3,200.00 in payments made to the
plaintiff for a balance of 11,800.00 before the imposition of interest and related charges.
WHEREFORE, Defendant will offer defense and will seek to set aside the
complaint.
Respectfully submitted,
DEFENDANT
6059 Allentown Blvd 229
Harrisburg, PA 17110
717469-0344
VERIFICATION
I, MICHAEL E. CRUMLlNG, affirm that the statements made in the aforegoing
document are true and correct.
I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. 4904, relating to unsworn falsification to authorities.
~/(o;tj
Oaed
Notarial Seal
Deborah M. Donofrio, Notary
Lower Paxton T wp., Dauphin nty
My Commission Expires .July 2. 2006
Member, Pennsylvania As~oc'ation Of Notaries
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-06269 CIVIL
MARY E. HUMMEL
v.
MICHAEL CRUMLlNG
Defendant
RULE 1312-1.
form:
The Petition for Appointment of Arbitrators shall be substantially to the following
PETITION FOR ApPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Robert D. Kodak, Counsel for the Plaintiff in the above action, respectfully represents that:
1. The above-captioned action is at issue.
2. The claim of the Plaintiff in the action is $17,000.00.
The counterclaim of the Defendant in the action is $n/a.
The following attorneys are interested in the case as counselor are otherwise disqualified to sit as
Arbitrators: Robert D. Kodak, Esquire, Knupp, Kodak & Imblum, P.C. and/or none. Defendant responded
pro se.
WHEREFORE, your Petitioner prays Your Honorable Court to appoint three (3) Arbitrators to whom the
case shall be submitted.
~
Robert D. Kodak
Attorney 1.0. No. 18041
ORDER OF COURT
AND NOW, ' 2005, in consideration of the foregoing Petition,
, Esquire, ' Esquire
and
, Esquire are appointed Arbitrators in the above-captioned
action as prayed for.
By the Court,
J.
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MARY E. HUMMEL
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
NO. 2004-06269 CIVIL
MICHAEL CRUMLlNG
Defendant
RULE 1312-1.
form:
The Petition for Appointment of Arbitrators shall be substantially to the following
PETITION FOR ApPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Robert D. Kodak, Counsel for the Plaintiff in the above action, respectfully represents that:
1. The above-captioned action is at issue.
2. The claim of the Plaintiff in the action is $17,000.00.
The counterclaim of the Defendant in the action is $n/a.
The following attorneys are interested in the case as counselor are otherwise disqualified to sit as
Arbitrators: Robert D. Kodak, Esquire, Knupp, Kodak & Imblum, P.C. and/or none. Defendant responded
pro se.
WHEREFORE, your Petitioner prays Your Honorable Court to appoint three (3) Arbitrators to whom the
case shall be submitted.
Robert D. Kodak
Attorney I.D. No. 18041
ORDER OF COURT
AND NOW, ':k/I:vu.u:;;/
0dA ;.it!.. ",-A a~ jJf
and );U;Jd; rYJU~~
action as prayed for.
.I D , 2005, in consideration of the foregoing Petition.
!;dt!. .r/j~!-(A- J~
, Esquire,
, EsquirE
, Esquire are appointed Arbitrators in the above-captione
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SHERIFF1S RETURN - REGULAR
CASE NO: 2004-06269 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HUMMEL MARY E
VS
CRUMLING MICHAEL
RON KERR
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
CRUMLING MICHAEL
the
DEFENDANT
at 1849:00 HOURS, on the 29th day of December, 2004
at 829 STATE STREET
LEMOYNE, PA 17043
by handing to
DEBORAH DONOFRIO, MANAGER,
ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
11.84
.00
10.00
.00
39.84
i,:i;s.;.~"C"'"
////"
::' '~'~'".~S~-t:'
R. Thomas Kline
12/30/2004
KNUPP KODAK IMBLUM
Sworn and Subscribed to before
By:
f2---/~
Deputy Sheriff
me this JIJ::; day of
1
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Y;;. () 111<;&.,~
rothonotary
MA.ey 6. !-fUHHcL
Plaintiff
In The Court of Common Pleas of Cumbe land
L/
County, Pennsylvania No. ~.. Z C li..I/ L--
/'tIC6I-XL CR(;N(I;U~
Defendant
Civil Action - Law.
Oath
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of
States and the Constitution of this Commonwealth and that we will discharge the duties of 0
w. fidelity.
e United
office
Signature
~
Signature
t!.~/
1utmI Jt1.
Signature
IJ-A-~() S" (~JtJ - {!;:>
Name (Chairman)
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Law Firm
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Name
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Law Finn '
At ;t.iI It! /Ii. :>eIOI>t; ,Ie;
Name
7u{0 l.t.", Of~ i e<.,
Law Firm
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Address
/ZJ /!!tar 51 ,)d}by/'
Address
~(fJ'Vft! 74 /7/tfIf
City, Zip
1.~ 1:.. ~; \1 <)
Address
CftJC.lJrLL 17.). '7013
City, Zip
(t;lliJ{ M 110 1,
City, Zip
Award
We, the undersigned arbitrators, having been duly appointed and swom (or affirmed), make th
following award: (Note: If damages for delay are awarded, they shall be separately stat .)
&/. ~..
.)
Date of Hearing: 4 /27 Ie )'
Date of Award: 4 /1 7 (05'-
(Chairman)
/lItW( IItt tl
Notice of Entry of Award
Now, therl7 dayof Ap.RlL- ,20~, at,??: .09 , L.M., the above aw d was
entered upon the ~d notice thereof given by mail to the parties or their attomeys.
Arbitrators' compensation to be paid upon appeal: $ c:; <=J ( )
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
MARY E. HUMMEL
v.
: NO. 2004-6269 CIVIL
MICHAEL CRUMLING
Defendant
: CIVIL DIVISION - LAW
TO: PROTHONOTARY, COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
PRAECIPE
Please enter Judgment in favor ofthe Plaintiff, MARY E. HUMMEL, and against Defendant,
MICHAEL CRUMLlNG, in the amount of$20,046.25, plus costs, per the attached copy ofthe Notice
of Entl)' of Award from the Award of Arbitrators filed with this Honorable Court on or about April
27,2005.
TO: Cumberland County
Prothonotary
Dated: June 16.2005
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Robert D. Kodak, Attorney for Plaintiff
AttomeyI.D. No. 18041
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MARY E. HUMMEL
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2004-6269 CIVIL TERM
MICHAEL CRUMLlNG
Defendant
CIVIL DIVISION - LAW
To MICHAEL CRUMLlNG, Defendant(s)
You are hereby notified that on r .;zL}
entered against you in the above-captione ase.
, 2005, the following Judgment has been
Judgment entered in the amount of $4.025.00. plus from July I. 2004.
DATE: e,'../il'~
Prothonotary
I hereby certify that the name and address ofthe proper person( s) to receive this notice is:
MICHAEL CRUMLlNG
% ARROWHEAD GRILLE
829 STATE STREET
LEMOYNE, PA 17043
AI MICHAEL CRUMLlNG, Defendido/a Defendidos/as
Por este medio se Ie esta notificando que el _ de
sido anotado en contra suya en el caso mencionado en el epigrafe.
del 2005, el/la siguiente Fallo ha
Jud~ment entered in the amount of$4.025.00. plus from Julv I. 2004.
FECHA:
Protonotario
Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de residencia:
MICHAEL CRUMLlNG
% ARROWHEAD GRILLE
829 STATE STREET
LEMOYNE, PA 17043
. PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
MARY E. HUMMEL
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Writ No.
Term 20
Plaintiff
NO. 2004-6269 CIVIL TERM Term 202.i.-
vs
Amount due $ 20.046.25
MICHAEL CRUMLING
409 4TH STREET
NEW CUMBERLAND PA 17070
Interest FROM DATE OF JUDG. 06/20/05
Atty's COIRm.
$ 1,002.31
and CostsTO BE DETERMINED$
Defendant(s)
TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of C~~
County, Pennsylvania;
(2) against MICHAEL CRUMLING
(3) and against
Defendant (s)
Garnishee (sl,
(4) and index this writ
(a) against MICHAEL CRUMLING
(b) against
Defendant(s) and
Garnishee(s),
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s)
as follows:
(Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for
real estate levy)
LEVY UPON ALL PBRSONlU. PROPERTY 01' ABOVE-LISTED DEI'ZIIDAN'.r (S) M ABOVE-LUTED ADDRESS INCLUDING
B1l'J! NOT LIHITED ro 1'ORNJ:TlllUl:, BQtJIBIENT, BLBCTRONJ:CS, INVBII'l!ORY,
(5) Exemption has (not) been waived.
Dated 08/09/05
Robert D. Kodak, Esquire
PO Box 11848
Harrisburg, PA 17108
(717) 238-7159
Attorney For Plaintiff(s)
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-6269 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MARY E. HUMMEL, Plaintiff (s)
From MICHAEL CRUMLING, 409 4TH STREET, NEW CUMBERLAND, PA 17070
(I) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL
PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING
BUT NOT LIMITED TO FURNITURE, EQUIPMENT, ELECTRONICS, INVENTORY, ETC.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
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 ofthe 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 helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due $20,046.25
Interest FROM DATE OF JUDG 6120/05
Arty's Comm % $1,002.31
Atty Paid $97.00
Plaintiff Paid
L.L. $.50
Due Prothy $1.00
Other Costs
Date: AUGUST 10,2005
CURTIS R. LONG
(Seal)
ProthonotijI)'
~rJ/>o.O -2.7r,./Z/?/Jt.~
Deputy
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQillRE
Address: PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 18041
Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriffs Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Surcharge
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage
TOTAL $
Advance Costs:
Sheriffs Costs:
150.00
54.98
$ 95.02
18.00
1.08
.50
1.00
14.40
20.00
Refunded to Ally on 09/06/05
54.98
So Answers;
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R. Thomas Kline, Shfn;;-
oJ QuclOt_Q I ~chcJu./
By Claudia A. Brewbaker
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Sworn and Subscribed to before me
2005 A.D.
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-6269 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MARY E. HUMMEL, Plaintiff (5)
From MICHAEL CRUMLING, 409 4TH STREET, NEW CUMBERLAND, P A 17070
(1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL
PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING
BUT NOT LIMITED TO FURNITURE, EQUIPMENT, ELECTRONICS, INVENTORY, ETC.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
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 ofthe 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 himlher that helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due $20,046.25
Interest FROM DATE OF JUDG 6/20105
Atty's Comm % $1,002.31
Atty Paid $97.00
Plaintiff Paid
Date: AUGUST 10, 2005
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
Prothonotary ~
___By: h (J/>o, J! . 'lJ~
Deputy
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 18041