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Home My WebLink About13-4290 IN THE COURT OF COMMON PLEAS OF DOCKET # /3 -4 0- 17 CUMBERLAND COUNTY, PENNSYLVANIA DATE ENTERED CERTIFIED COPY OF LIEN COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY TO THE PROTHONOTARY OF SAID COURT: UNINSURED EMPLOYERS GUARANTY FUND Pursuant to Section 1605 of the Pennsylvania Workers' Compensation Law, 77 P.S. § 2705 this is a Certified Proof of vs. Payment for the balance of payments made by the Fund on behalf of the uninsured employer to be entered of record by KEYSTONE POOLS, INC. �? M C= you and indexed as judgments are indexed. 301 E. LOUTHER STREET rte` N -; CARLISLE, PA 17013 r CD BUREAU OF WORKERS' COMPENSATION CS CLAIM NUMBER: 4038916 UNINSURED EMPLOYER GUARANTY FUND CLAIM NUMBER: UEGI -11598 ACCOUNT NUMBER: DATE DISBURSEMENTS BALANCE DUE AMT PAID CREDIT Total $ 423.00 -0- $ 423.00 Expenses Total $ -0- -0- $ -0- Indemnity Legal $ 3,428.90 -0- $ 3,428.90 Fees ACS $ 2,114.11 -0- $ 2,114.11 Adjusting Costs Total $ -0- -0- $ -0- Medical TOTAL: $ 5 ,966.01 FILING FEE(S): $ 21.50 ADDITIONAL -0- COSTS: SATISFACTION $ 5,987.51 AMOUNT: The undersigned, Director, Bureau of Workers' Compensation, Department of Labor & Industry, certifies that the above balance is due and payable by the above tamed defendant under the provisions of the Pennsylvania Workers' Compensation Law. Pursuant to section 1605 of said law, 77 P.S. § 2705, the above balance is a judgment and statutory lien upon th e franchises and property, both real and personal, including after acquired property, of the above named defendant and attach thereto from the date o entry this Certified Cop f Lien. t phen J Fireov Date D rector, ureau f rkers' Compensation Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET # DATE ENTERED COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND V. NOTICE TO DEFENDANT OF ENTRY OF LIEN KEYSTONE POOLS, INC. This is a copy of the Certified Copy of Lien which has been filed with the Prothonotary of the Court 301 E. LOUTHER STREET designated on the reverse side of this notice. CARLISLE, PA 17013 The Department of Labor & Industry of the Commonwealth of Pennsylvania, at the expiration of ten (10) days after the receipt of this notice, is authorized by law to execute upon this lien. This means CERTIFIED COPY OF LIEN UNDER that your property may be levied upon, attached and sold to the extent necessary to satisfy this lien. PENNSYLVANIA WORKERS' COMPENSATION Execution will not occur if this lien is satisfied. LAW Payment should be made by a Cashers Check, Certified Check or Money Order made payable to the Commonwealth of Pennsylvania. The Account Number shown on the reverse side of this document should be affixed to the lower left corner of the remittance and mailed to the address below: Pennsylvania Uninsured Employers Guaranty Fund Post Office Box 1774 Harrisburg, PA 17105 -1774 Any questions concerning this Lien should be addressed to the Uninsured Employers Guaranty Fund office at the address or telephone number shown on the enclosure. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2013-4290 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due Commonwealth of Pennsylvania Department of Labor& Industry Uninsured Employers Guaranty Fund Plaintiff(s) From Keystone Pools,Inc. -301 East Louther Street,Carlisle,PA 17013 (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 F& M Trust BankGARNISHEE(S)as follows: F&M Trust Bank-214 Westminster Drive,Carlisle,PA 17013 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$5,996.01 Plaintiff Paid$ Interest Attorney's Comm. % Law Library$.50 Attorney Paid$50.50 Due Prothonotary$2.25 Other Costs$179.00 Date: September 10th,2013 David D.Buell,Prot notary By: Deputy REQUESTING PARTY: Name : Leah M.Lewis,Assistant Counsel Address: Commonwealth of Pennsylvania Department of Labor& Industry Uninsured Employers Guaranty Fund Office of Chief Counsel-Worker's Compensation Division 1171 S. Cameron Street,Room 327 Harrisburg,PA 17104-2501 Attorney for: Plaintiff Telephone: 717-783-4467 Supreme Court ID No. 207045 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR& INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND VS. No. 004290 July 2013 KEYSTONE POOLS, INC. 301 EAST LOUTHER STREET CARLISLE, PA 17013 LIEN Defendant And 13- qX10 F & M TRUST BANK 214 WESTMINSTER DRIVE CARLISLE, PA 17013 C- Garnishee -O:t MCD PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY OF SAID COURT: (ZJ Issue a writ of execution in the above captioned matter: 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. Against Keystone Pools, Inc., Defendant 3. Against F & M Trust Bank, Garnishee 4. Balance of payments made by the Uninsured Employers Guarantee Fund of behalf of the Uninsured employer $ 5,966.01 Fees $ 179.00 Less Payments -0- Total Amount Due: $ 6,145.01 Date: September 10, 2013 By: Leah M. Lewis, Assistant Counsel (Attorney I.D. #207045) Commonwealth of Pennsylvania Department of Labor & Industry Office of Chief Counsel Workers' Compensation Division 1171 S. Cameron Street Room 327 Harrisburg, PA 17104-2501 (717) 783-4467 leahlewis @pa.gov . 00p� � � F 1 6-v LT q 53 f C C) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 004290, July 2013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR AND INDUSTRY . To the use of the UNINSURED EMPLOYERS GUARANTY FUND, Plaintiff V. KEYSTONE POOLS, INC., Defendant And F &M TRUST BANK, Garnishee PRAECIPE FOR WRIT OF EXECUTION Uri Leah M. Lewis (Attorney I.D. #207045) Assistant Counsel Office of Chief Counsel Workers' Compensation Division 1171 South Cameron Street Harrisburg, PA 17104 leahlewis @pa.gov IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR& INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND VS. KEYSTONE POOLS, INC. No. 004290 301 EAST LOUTHER STREET JULY 2013 CARLISLE, PA 17013 Defendant LIEN And C-) F & M TRUST BANK, 2WM r1l M--- 214 WESTMINSTER DRIVE -0 CARLISLE, PA 17013 Garnishee Z C AFFIDAVIT OF MAILING NOTICE OF ENTRY OF LIEN LEAH M. LEWIS, being duly sworn according to law, deposes and says that she is an employee of the Commonwealth of Pennsylvania, Department of Labor and Industry, and that as such makes the following affidavit. That on July 25, 2013, she mailed by regular, first class mail, prepaid and certified mail, return receipt requested, NOTICE TO EMPLOYER OF ENTRY OF LIEN, as provided by Section 1605 of the Pennsylvania Workers' Compensation Act, Act of June 2, 1915, P.L., as amended, addressed to Keystone Pools, Inc. 301 East Louther Street, Carlisle, PA 17013, the last known post office address of the defendant. This affidavit is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. AA A Date: September 10, 2013 By: )ALF LeahM. Lewis,'*Esquire `-*' Assistant Counsel SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson -- Sheriff ,1 r w y tix n of L"aruniir ftxfy i' i, , t' PROTI�0,40 h� � Jody S Smith Chief Deputy ° 2913 SEP -16 P 2: 50 Richard W Stewart Solicitor OFF ;E OF TkE$KRIFF C,U MiSERLAND C 0UN'T � PENNSYLVANIA Commonwealth of PA Department of Labor and Industry Uninsured Employer Case Number vs. Keystone Pools, Inc. 2013-4290 SHERIFF'S RETURN OF SERVICE 09/14/2013 09:37 AM -Shawn Harrison, Deputy,who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, F&M Trust Company, 214A Westminster Drive, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to David Winters, Assistant Vice President and Manager, 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 him. The writ of execution and notice to defendant was mailed on Septemb 1 , 20 3 Keystone Pools, Inc. at 301 E Louther Street, Carlisle, PA 17013. S AR ISON, DEPUTY SO ANSWERS, 2 September 16, 2013 RONNY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoff,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR& INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND VS. No. 004290 KEYSTONE POOLS, INC. July 2013 301 EAST LOUTHER STREET CARLISLE, PA 17013 - LIEN Defendant And F &M TRUST BANK c _° 214 WESTMINSTER DRIVE m Ce) - CARLISLE, PA 17013 M .�D na Garnishee �,� w co , / DC: N c7 Vt INTERROGATORIES IN ATTACHMENT To F & M TRUST BANK (Garnishee) You are required to file answers to the below 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 defendant any money or were you liable to it on any negotiable or other written instrument, or did it claim that you owed it any money or were liable to it for any reason? yes, V-eysbNe' PODIS 11-10 MmhtaIrIs Gl dToS 1 t A(C a AY)-fi W i-I V) f-�N -TYW S+- 2. At the time you were served or 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. If the Answer to question number two above was "Yes," please state the nature of the property owned by defendant. If the nature of the property is money or other financial assets, identify a) the amount; b) the type of account(s) in which the money or financial asset is held; and c) the account number(s). C41eCILl r XX AC( U 1/1+ � X12.5 q ANoM VI-f- 3 0 2 4. 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 party by the defendant or in which the defendant held or claimed any interest. X10. 5. 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? N 6. 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? N D. 1)4+e, o�F IAS+ peposi-t-- e MUY-Ch 5120i3 7. 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 his or her direction or otherwise discharge any claim of the defendant against you? 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 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 reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 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 funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. S _W e A((6 U 1)+ b A I 0jr)C-t-, *3 D b 10. If you have answered "Yes" to any of the interrogatories numbered 1 through 7 above, state the amount of money or claim, or other liability which you hereby admit to be owed to, owned'by, or claimed by the defendant and describe the nature of such claim or liability and such other property as you have hereby admitted to be in your possession. 014 ki t k,,111 I q h G0- I QS S 444 m n -e X eM Pi t l"j Respectfully submitted, Date: September 10, 2013 . ewe, Leah M. Lewis, Assistant Counsel (Attorney I.D. #207045) Commonwealth of Pennsylvania Department of Labor & Industry Office of Chief Counsel - Workers' Compensation Division 1171 S. Cameron Street Room 327 Harrisburg, PA 17104-2501 (717) 783-4467 leahlewis @pa.gov 13 � F �� Rainbow D. Hopkins 1 ! TRUST Compliance and Security- FrNANCtAL SOLUTIONS... ' FROM PEOPLE YOU KNOW - I Memorial Square Office 20 South Main Street (717)261-3635 1 Po Box 6010 (7.17)264-6116 Chambersburg,PA 17201 'fax:(717)261-3646 www.fmtrustonline.com rainbow:hopki6s @f-mtrust.com 1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith + ' Chief Deputy .s .. O`;T 4 0E: Richard W Stewart "*' (rl° 3) Solicitors. ri `sro' 's'E `� x ,x ! r'X 1 Commonwealth of PA Department of Labor and Industry Uninsured Employer Case Number vs. Keystone Pools, Inc. 2013-4290 SHERIFF'S RETURN OF SERVICE 09/1412013 09:37 AM-Shawn Harrison, Deputy,who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, F &M Trust Company, 214A Westminster Drive, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to David Winters, Assistant Vice President and Manager, 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 him. The writ of execution and notice to defendant was mailed on September 16, 2013 to Keystone Pools, Inc. at 301 E Louther Street, Carlisle, PA 17013. 1013012013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ is returned SATISFIED. SHERIFF COST: $208.29 SO ANSWERS, October 30, 2013 RbNW R ANDERSON, SHERIFF c -c-�) , C+ 3 41TRIBUTION PLAINTIFF Commonwe:Ith of Pennsylvania Department of Labor& Industry Uninsured Employers Guaranty Fund WRIT NO. 2013-34290 Commonwealth of PA Vs Keystone Pools Real Debt $ 5,996.01 Interest Attorney's Comm. Writ Costs,Atty 50.50 Writ Costs, Pltff. Miscellaneous 179.00 Attorneys Fees TOTAL $ 6,225.51 Sheriff's Costs Docketing $ 18.00 Poundage 119.92 Law Library .50 Prothonotary 2.25 Service Mileage 6.78 Postage 1.84 Advertising Garnishee 9.00 Postpone Sale Bad Check Charge Surcharge 30.00 Levy 20.00 TOTAL $ 208.29 Remitter Paid to Sheriff $ 6,433.80 Advance Costs 150.00 Total Collected $ 6,583.80 DISTRIBUTION Pd. To Pltff. $ 6,225.51 Refund of Adv. Costs 150.00 Sheriff's Costs 208.29 So Ans ers: y R. Anderson riff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY UNINSURED EMPLOYERS GUARANTY FUND Plaintiff(s) vs. KEYSTONE POOLS, INC. 301 EAST LOUTHER STREET CARLISLE, PA 17013 Defendant F & M TRUST BANK 214 WESTMINSTER DRIVE CARLISLE, PA 17013 /3 -Lf 4O DOCKET NO. 004290 July 2013 c r11 70 c(1 cda -o C3 0 ca'e5 +,f C4-5`` .R- 31,1669 PRAECIPE TO DISSOVE ATTACHMENT TO THE PROTHONOTARY OF SAID COURT: Please release the Garnishee, F & M TRUST BANK, and discontinue the Writ of Execution that was filed in this case by the Commonwealth of Pennsylvania, Uninsured Employers Guaranty Fund. Dated: October 23, 2014 Respectfully submitted, 44,14, Leah M. Lewis, Assistant Counsel Supreme Court I.D. #207045 Commonwealth of Pennsylvania Department of Labor and Industry Office of Chief Counsel 1171 South Cameron Street, Room 327 Harrisburg, PA 17104 (717) 783-4467 Attorney for the Plaintiff CERTIFICATE OF SERVICE I, Leah M. Lewis, Esquire, attorney for the Plaintiff, hereby certify that on this date I served a copy of the foregoing Praecipe Dissolve Attachment 011 the following individuals, by mailing same to them by regular first class United States Mail, postage prepaid, at the following addresses: Keystone Pools, Inc. 301 East Louther Street Carlisle, PA 17013 F & M Trust Bank 214 Westminster Drive Carlisle, PA 17013 Dated: October 23, 2014 By: Leah M Lewis, Assistant Counsel Supreme Court I.D. #207045 Commonwealth of Pennsylvania Department of Labor and Industry Office of Chief Counsel 1171 South Cameron Street, Room 327 Harrisburg, PA 17104 (717) 783-4467 Attorney for the Plaintiff