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Home My WebLink About13-4647 COPY OF DOCKET ENTRIES COMMONWEALTH OF PENNSYLVANIA) 13_gqgqC ALLEGHENY COUNTY ) SS. Among the Records and Proceedings of the Court of Common Pleas in and for the County of Allegheny, and Commonwealth of Pennsylvania, the following is a true and correct copy of the Docket Entries at No. GD -12- 010753 DOCKET ENTRY 84 LUMBER COMPANY, L.P. Z) ! rj- r (75 ``'T VS -e-- HUGHES CONTRACTING, INC. and SETH HUGHES and JENNIFER HUGHES, as personal guarantors I, Kate Barkman, Director of the Department of Court Records of the Court of Common Pleas in and for said County, certify that the foregoing is a full and correct copy of the Docket Entries wherein 84 LUMBER COMPANY, L.P. Plaintiffs) and HUGHES CONTRACTING, INC and SETH HUGHES and JENNIFER HUGHES, as personal guarantors before the said Court, at No. GD -12- 010753 Defendant(s); as the remains of record IN TESTIMONY WHEREOF, I have hereunto set my hand an ffixed th seal of the said Court, the 2nd day of JULY 7013 DIRECTOR OF THE D . RTMENT M c�',C - F - r j(1RDC Certified by c CLERK 33. 50 C# d'a q ?9'6 1-1 4 /2jF - 0( /.- l jv °�e-e- ' PP zect" N GD -12- 010753 84 LUMBER COMPANY, L.P. vs HUGHES CONTRACTING, INC. and SETH HUGHES AND JENNIFER HUGHES as personal guarantors EXEMPLIFICATION OF RECORD At No. GD - 12- 010753 from the Court of Common Pleas, in and for the County of Allegheny, Pennsylvania DEBT $ 105,717.13 INTEREST FROM 'ALLEGHENY COUNTY COSTS $339.50 THIS RECORD $20.00 S. MANOJ JEGASOTHY, ESQUIRE ATTORNEY FOR PLAINTIFF Allegheny County - Department of Court Records Home Civil /Family Division Docket Report GD -12- 010753 84 Lumber Company L.P. vs Hughes etal Run Date: 07/02/2013 Court Type: General Docket Run Time: 12:42:40 PM Case Type: Contract - Debt Collection Related Cases: Judge: No Judge Current Status: Default Judgment Jury Requested: No Amount In Dispute: $ 105717.13 Parties -- Litigants -- ID 111-Name FName MI ype Address Phone Attorney @1583814 84 Lumber 1019 Route 519 Annex Company L.P. - -- Plaintiff Building Eighty Four PA __ Jegasothy S. 15330 Manoj, @1908109 Hughes Jennifer - -- Defendant 1787 West Trindle Road Carlisle PA 17015 -- @1908108 Hughes Seth - -- Defendant 1787 West Trindle Road Hughes 0 Carlisle PA 17015 -- @1908107 g s - -- - -- Defendant - Contracting Inc. 1787 West Trindle Road #801 Carlisle PA 17015 -- -- Attorney -- ID LName FName MI Type Address 80084 Phone Jegasothy �] Manoj Plaintiff's Attorney No Default Address Available -- -- Non Litigants -- No Listing Docket Entries Filing Docket Date T Docket Text Filing Party 06/22/2012 Complaint Returnable 07/22/12. 84 Lumber Company • L.P. Hughes Contracting Inc. was served by Served - Adult Agent or Sheriff person in charge of Defendant(s) office or usual place of business 84 Lumber 08/07/2012 Return Service Upon Hughes Contracting Inc. with Complaint on 7/18/2012. Company Served Jennifer Hughes Co -Owner Served at 14 Cardinal Drive Carlisle, PA 17013 L.P. �� Seth Hughes was served by Served - Adult family member with whom 08/07/2012 Sheriff said Defendant(s) reside(s) Service Upon Seth Hughes with Complaint P Return on 7/18/2012. Served Jennifer Hughes Wife Served at 14 Cardinal Drive Carlisle, PA 17013 Sheriff Jennifer Hughes was served by Served - Defend 08/07/2012 ant(s) Personally Return Served Service Upon Jennifer Hughes with Complaint on 7/18/2012. ompany Defendant served at 14 Cardinal Drive Carlisle, PA 17013 09/17/2012 Default In default of an answer in the amount of $105717.13. Certification of 84 Lumber Judgment mailing of 10 day notice on 8/17/12 upon Defendants. Notice of judgment sent. Company L.P. Judgment Against ID Type Name — Amount Satisfied Docket Filing Date @1908107 Defendant Hughes Contracting Inc. 105717.13 N @1908109 Defendant Hughes Jennifer �� Default Judgment 09/17/2012 _ 105717.13 � pefault Judgment 09/17/2012 @1908108 Defendant Hughes Set —� 105717.13 L�� pefault Judgment 09/17/2012 Judgment For ID Type Name _ - _--- -- Amount Doc Filing Date @1583814 Plaintiff =um Company L.P. 105717.13 Default Jud menu g 09/17/2012 I FL i i 17 25 IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA CIVIL DIVISION i 84 LUMBER COMPANY, L.P., Plaintiff, PRAECIPE FOR ENTRY OF DEFAULT VS. JUDGMENT AGAINST DEFENDANTS, HUGHES CONTRACTING, INC. and HUGHES CONTRACTING, INC. and SETH SETH HUGHES and JENNIFER HUGHES HUGHES and JENNIFER HUGHES, as personal guarantors, No.: GD- 12 010753 I Filed on behalf of: Defendants. 84 LUMBER COMPANY, L.P., Plaintiff S. Manoj Jegasothy, Esquire Pa. Id. #80084 Alexander W. Saksen, Esquire Pa. Id. #86049 GORDON & REES LLP I The Gulf Building, Suite 2305 707 Grant Street Pittsburgh, PA 15219 412- 316 -2900 3 I DPS$JCONNO2 99 -18 -29121 09:24;15 GD -12- 8107$3 I 1�S I i i IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA CIVIL DIVISION 84 LUMBER COMPANY, L.P., ) Plaintiff, ) PRAECIPE FOR ENTRY OF VS. DEFAULT JUDGMENT AGAINST i ) DEFENDANTS, HUGHES HUGHES CONTRACTING, INC. and ) CONTRACTING, INC. and SETH HUGHES and JENNIFER HUGHES ' SETH HUGHES and JENNIFER HUGHES, as personal guarantors' ) No. GD- 12- 010753 Defendants. i I PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT AGAINST DEFENDANTS, HUGHES CONTRACTING INC. and SETH HUGHES and NNIFER HUGHES TO THE DEPARTMENT OF COURT RECORDS: Kindly enter judgment in favor of the Plaintiff, 84 Lumber Company, L.P., and against the Defendants, Hughes Contracting, Inc., Seth Hughes, and Jennifer Hughes, for said Defendants' failure to file an Answer to Plaintiffs Complaint in the above - captioned action pursuant to Pa. R.C.P..' 1037. Pursuant to the Complaint filed in the above - captioned action, i judgment against Defendants is hereby requested in the amount of $105,717.13 with continuing finance /late charges thereon at the rate of 1.5 %, together with attorneys' fees and costs. 1 It is certified that on August 17, 2012, a written ten -day notice of intention to file this Praecipe was served on Defendants at their last known address by first class mail, postage prepaid. A copy of thi Plaintiffs letter forwarding said notice to Defendants, and a copy of said notice are attached hereto as Exhibit "A ". I I I It is further certified that no extension of time for filing of an Answer or other response was granted to Defendants Hughes Contracting, Inc., Seth Hughes, and Jennifer Hughes nor was any requested. No Answer or other response to the Complaint has been received by the Plaintiff from Defendants as of this date. Dated: September 7, X2012 GORDON & REES LLP e I 1 I S. Manoj Je sothy, Esquire (Pa. Id. #80084) Alexander W. Saksen, Esquire (Pa. Id. #86049) i The Gulf Building, Suite 2305 707 Grant Street Pittsburgh, PA 15219 412 - 316 -2900 I I I I i c I I ' i i I I l t . I I i I I EfLUM/I I)ftl)NN IM 3355757v. I i i I I 2 GORDON & REES LLP ALEXANDER W.SAKSEN ASAKSEN @GORDONREES.COM ATTO RNEYS AT LAW DIRECT DIAL: (412) 316 -2921 707 GRANT STREET SUfrE 2305 i PrTTSBURGH, PA 15219 PHONE: (412) 577 -7400 j FAX: (412) 347 -5461 f WWW.CORL�ONRL'GS.COM i August 17, 2012 ! I Hughes Contracting, Inc; Seth Hughes 1787 W. Trindle Road, 3801 1787 W. Trindle Road, 3801 Carlisle, PA 17015 Carlisle, PA 17015 Jennifer Hughes 1787 W. Trindle Road, 3801 Carlisle, PA 17015 Re: 84 Lumber Company, L.P. v. Hughes Contracting, Inc. and Seth Hughes and Jennifer: Hughes, as personal guarantors Allegheny County Case No. GD- 12- 010753 I Dear Sir /Madam: E Enclosed please find a true and correct copy of the 10 Day Notice to Enter Judgment by Default in regard to the' above- captioned action. We are required to provide this to you pursuant to Pennsylvania Rule of Civil Procedure 237.1'. Kind Re ards, Alexan er aksen I . AWS /tjl Enclosure I I EXHIBIT Ii /133SS65fiv.1 � � CALIFORNIA • NEW ) ♦ TEXAS • ILLINOIS •'NEVADA • ARIZONA ♦ COLORADO • WASHINCTON • OREGON NEW )i ♦ FLORIDA • GFORCIA • CONNF:CTICUl" • PENNSYLVANIA ♦ MARYI."D ♦ VIRGINIA I i ' I I IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA CIVIL DIVISION 84 LUMBER COMPANY, L.P., i Plainti +f, No. GD 12- 010753 vs. I 10 -DAY NOTICE OF DEFAULT HUGHES CONTRACTING, INC. and SETH JUDGMENT HUGHES and JENNIFER HUGHES, as personal guarantors, Filed on behalf of: 84 LUMBER COMPANY, L.P., Plaintiff Defend i ants. Counsel of Record for this Party: S. Manoj Jegasothy, Esquire Pa. Id. #80084 I Alexander W. Saksen, Esquire Pa. Id. #86049 I GORDON & REES LLP The Gulf Building, Suite 2305 707 Grant Street Pittsburgh, PA 15219 412- 316 -2900 . f f I i I i I I IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA CIVIL DIVISION ' 84 LUMBER COMPANY, L.P., I Plaintiff, ) f ) vs. ) No. GD 12- 010753 HUGHES CONTRACTING, INC, and SETH HUGHES and JENNIFER HUGHES, as personal ) guarantors, � Defendants. ) TO: Hughes Contracting, Inc. 1787 W. Trindle Road, 3801 Seth Hughes Carlisle, PA 17015 1787 W. Trindle Road, 3801 Carlisle, PA 17015 Jennifer Hughes 1787 W. Trindle Road, 3801 Carlisle, PA 17015 DATE; August.17, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTE PERSONALLY OR BY ATTORNEY AND FILE IN N APPEARANCE DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAIN WITHIN TEN (10) DAYS FROM THE DATE OF WRITING WITH THE COURT YOUR I TRANCE E ENTERED AGAINST YOU WITHOUT A ARING A THIS NOTICE ST YOU. , A JUDGMENT MAY A i OTHER IMPORTANT RIGHTS. AND YOU MAY LOSE YOUR PROPERTY OR YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW PROVIDE YOU WITH INFO HAVE A INFORMATION ABOUT HIRING A LAWYER. THIS OFFICE CAN IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO P YOU WITH INFORMATION ABOUT AGENCIES THAT MAY O ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. FFER LEGAL SERVICES ID TO I LAWYER REFERRAL SERVICE Allegheny County Bar Association I I O ' Floor Koppers Bldg. 436 Seventh Ave, Pittsburgh, pA 15219 ( 261 -5555 GORDON & By. Manoj Jegasoth Y, quire (Pa. Id. #80084) Alexander W. Saksen, Esquire (Pa. Id. #86049) i The Gulf Building Suite 2305 707 Grant Street Pittsburgh, PA 15219 412- 316 -2900 CERTIFICATE OF SERVICE This is to certify that the undersigned has this date served the foregoing 10- NOTICE OF DEFAULT JUDGMENT, in the above - entitled action upon all other r DAY I cause by depositing a� copy hereof in a postpaid wrapper in a post office or official deposit under the exclusive care and custody of the United States Postal Servic arties to this : ce addressed as follows: Hughes Contracting, Inc. 1787 W. Trindle'Road, 3801 Seth Hughes Carlisle, PA 17015 1787 W Trindle Road, 3801 Carlisle, PA 17015 I Jennifer Hughes 1787 W. Trindle Road, 3801 Carlisle, PA 17015 THIS the 17` day of August, 2012. f er W. Saksen i ' � I I I F.FLUNVI(1N(IN81 /13335(19v, I 1 s t . d t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - CIVIL DIVISION 84 LUMBER COMPANY, L.P., Plaintiff, No. 7 v vs. PRAECIPE FOR WRIT OF EXECUTION HUGHES CONTRACTING, INC. and SETH Filed on behalf of: HUGHES and JENNIFER HUGHES, as 84 LUMBER COMPANY, L.P., Plaintiff personal guarantors, Counsel of Record for this Party: Defendants, S. Manoj Jegasothy, Esquire VS. Pa. Id. #80084 ST mjegasothy @gordonrees.com PNC BANK, N.A. AND MEMBERS 1 _ FEDERAL CREDIT UNION m m r ' Richard T. Victoria, Esquire Fn Garnishees. Pa. Id. #76681 u r , - rvictoria @gordonrees.com °o GORDON & REES LLP = s y > ;r: The Gulf Building_ ' 707 Grant Street, Suite 3800 c-, Pittsburgh, PA 15219 412 -577 -7400 412- 347 -5461 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - CIVIL DIVISION 84 LUMBER COMPANY, L.P., ) Plaintiff, ) vs. ) No. GD HUGHES CONTRACTING, INC. and ) SETH HUGHES and JENNIFER HUGHES, ) as personal guarantors, ) Defendants, ) vs. ) PNC BANK, N.A. AND MEMBERS 1 sT ) FEDERAL CREDIT UNION, ) Garnishees. ) PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Kindly issue writ of execution in the above matter, 1) directed to the Sheriff of Cumberland County; 2) against Defendant Hughes Contracting, Inc.; 3) against PNC Bank, N.A., Garnishee; and 4) against Members 0 Federal Credit Union, Garnishee; 5) and enter this writ in the judgment index: (a) against Defendant Hughes Contracting, Inc.. 6) Amount due: $105,717.13 Post - Judgment Interest from 9/18/2012 thru $5,578.39 7/30/2013: Costs to be added: $622.50 TOTAL $111,918.02 Dated: August 5, 2013 Respectfully submit / d, V S. Manoj Jegasothy, Esquire (Pa. Id. #80084) Richard T. Victoria, Esquire (Pa. Id. #76681) 707 Grant Street, Suite 3800 Pittsburgh, PA 15219 412 - 577 -7400 X9.00 �d 33- 5-0 17ve Co. 5 G L I�( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - CIVIL DIVISION 84 LUMBER COMPANY, L.P., ) Plaintiff, ) WRIT OF EXECUTION VS. No. t 3 - e7 HUGHES CONTRACTING, INC. and ) SETH HUGHES and JENNIFER HUGHES, ) as personal guarantors, ) Defendants, ) vs. ) PNC BANK, N.A. AND MEMBERS 1 sT ) FEDERAL CREDIT UNION, ) Garnishees. ) NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of $300. There are other exemptions which may be applicable to you. Attached is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following promptly: (1) Fill out the attached claim form and demand for a prompt hearing. (2) Deliver the form or mail it to the Sheriff's Office at the address noted. You should come to court ready to explain your exemption. If you do not come to court and prove your exemption, you may lose some of your property. YOU SHOULD TAKE THIS 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 MAY BE 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 32 S. Bedford Street Carlisle, Pennsylvania (717) 249 -3166 CERTIFICATE OF SERVICE This is to certify that the undersigned has this date served the foregoing Praecipe for Write of Execution, in the above - entitled action by depositing a copy hereof in a postpaid wrapper in a post office or official depository under the exclusive care and custody of the United States Postal Service, addressed as follows: Hughes Contracting, Inc. Hughes Contracting, Inc. 1787 W. Trindle Road, 3801 14 Cardinal Drive Carlisle, PA 17015 Carlisle, PA 17015 Seth Hughes 1787 W. Trindle Road, 3801 Carlisle, PA 17015 Jennifer Hughes 1787 W. Trindle Road, 3801 Carlisle, PA 17015 g THIS Ir day of August 2013. r / v Richard T. Victoria EFLUM/]080881/16266582v.I WRIT OF EXECUTION and /or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2013 -4647 Civil COUNTY OF CUMBERLAND) CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due 84 Lumber Company, L.P. Plaintiff (s) From Hughes Contracting, Inc. - 1787 West Trindle Road, 3801 Carlisle, PA 17015 (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 PNC Bank, N.A., and Members 0 Federal Credit Union GARNISHEE(S) as follows: PNC Bank, N.A. - 105 Noble Blvd. Carlisle, PA 17013 Members 0 Federal Credit Union - 1166 Walnut Bottom Rd. 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 $105,717.13 Plaintiff Paid $ Interest - Post - Judgment Interest from 9/18/2012 thru 7/30/2013: $5,578.39 Attorney's Comm. % Law Library $.50 Attorney Paid $62.50 Due Prothonotary $2.25 Other Costs $622.50 Date: August 8, 2013 12W-47�a David D. Buell, Prothonotary (seal) . Deputy REQUESTING PARTY: Name: Richard T. Victoria, Esquire Address: Gordon & Rees, LLP 707 Grant Street, Suite 3800 Pittsburgh, PA 15219 Attorney for: Plaintiff Telephone: 412 - 316 -2926 Supreme Court ID No. 76681 SHERIFF'S OFFICE OF CUMBERLAND COUNTY . Ronny R Anderson �L0_.OFF ICI Sheriff .3 .F PE PP0TH0N6T;ftii't' �t�rlrah�i Jody S SmithQkt��tr ;, r# Chief Deputy 2013 AUG 23 AM 10; Richard W Stewart CUMBERLAND COUNTY Solicitor QFPICE,`F THE SHERIFF PENNSYLVANIA 84 Lumber Company Case Number vs. Hughes Contracting, Inc. 2013-4647 SHERIFF'S RETURN OF SERVICE 08/16/2013 10:27 AM -Jeff Kolodzi, 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Brianna Nornhold, 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 him/her. i J of K LODZI, DEPUTY SO ANSWERS, August 22, 2013 RONNY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosotf.Inc. Ronny R Anderson SHERIFF'S OFFICE OF CUMBERLAND. COUNTY Sheriff Jody S Smith of COIN S' z' I'LED OFFICE Chief Deputy Richard W Stewart 1013 AUG 23 AN 10. 23 Solicitor p r OFFICE OFTHEfiN.RIFF 0,11BERLA'ND COUN.Ty PENNSYLVANIA 84 Lumber Company vs. Hughes Contracting, Inc. Case Number 2013-4647 SHERIFF'S RETURN OF SERVICE 08/22/2013 01:36 PM-Jeff Kolodzi, Deputy, who being duly sworn accordin to all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands o of the within named garnishee, Members 1st Federal Credit Union 1711 w attached as herein commanded Township, Carlisle, PA 17013, Cumberland County, by handing to Denise Harman Branch or control Spring Road, North Middleton Personally three copies of interrogatories together with three true and attested copies of the Writ Execution and made the contents there of known to him/her. COPY Manager, mailed to defendant on August 23, 2013. )t of py of levy mailed to attorney and letter .�e JE,Fj KO ODZI, DEPUTY SO ANSWERS, August 22, 2013 4NR ANDE RSON, SHERIFF ry (c)CountySuilo Sherifl,Toleosoft,Inc. s 1-;, LO-OF iCE 13 F T I;E RoTHomOTAR*( 2013 SEP -3 AM 11: 29 CUMBERLAND PENNSYLVANIA �Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, _ PENNSYLVANIA - CIVIL DIVISION 84 LUMBER COMPANY, L.P., Plaintiff, No. GD 2,0 13--t4o L{7 vs. Q nS,.46-s - o INTERROGATORIES TO GARNISHEE HUGHES CONTRACTING, INC. and SETH Filed on behalf of: HUGHES and JENNIFER HUGHES, as 84 LUMBER COMPANY, L.P., Plaintiff personal guarantors, Defendants, Counsel of Record for this Party: vs. S. Manoj Jegasothy, Esquire Pa. Id. #80084 PNC BANK, N.A. AND MEMBERS 1sT mjegasothy @gordonrees.com FEDERAL CREDIT UNION, Richard T. Victoria, EsquirY Garnishees. Pa. Id. #76681 rvictoria@gordonrees.com GORDON& REES LLP The Gulf Building 707 Grant Street, Suite 3800 Pittsburgh, PA 15219 412-577-7400 (Phone) 412-347-5461 (Fax) i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - CIVIL DIVISION 84 LUMBER COMPANY, L.P., ) Plaintiff, ) vs. ) No. GD HUGHES CONTRACTING, INC. and ) SETH HUGHES and JENNIFER HUGHES, ) as personal guarantors, ) Defendants, ) vs. ) PNC BANK, N.A. AND MEMBERS 1 ST ) FEDERAL CREDIT UNION, ) Garnishees. ) INTERROGATORIES TO GARNISHEE To: Members l s`Federal Credit Union 1166 Walnut Bottom Rd. Carlisle, PA 17013 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. State the name, business address, business phone, of the person answering these Interrogatories, and the relationship to the Business. AN- Ke M 0 0 �� .► S �Y VC D �4 tei ( 1 9q 7o t SS UL I I Aug 26 2613 12;69;37 415-996-8854 -> Members 1st FCU Tracy Logan Page 882 2. At the time you were served or at any Subsequent titre dial you owe Hughes Contracting, Inc, (hereinafter, "defendant") any money or were you liable to the defendant on any negotiable or other written instrunie.nt, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? ANSWER: 3. 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 propc;fty of any nature owned solely or in part by the defendant? If so, please describe such property, ANA'', . 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 part by the defendant or in which the defendant held or claimed any interest? If so,please describe such property. ANSWER: 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? If so, please describe such property. ANSWER: 3 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? If so, please describe such property. ANSWER: I vv 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 the defendant's direction or otherwise discharge any claim of the defendant against you? If so, please describe such property. ANSWER: 4 8. 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. ANSWER: 9. 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 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. ANSWER: aa"{ s 5 ' I 6 10. At any time before and after you were served did you have or share any safe-deposit boxes, pledges, documents of title, securities, notes, coupons, receivable, or collateral in which there was an interest claimed by the defendant(s)? If so, please describe such safe- deposit boxes, pledges, documents of title, securities, notes, coupons, receivable, or collateral. ANSWER: 6 1L Identify every account (not previously noted), titled in the name of the defendant(s) which you believe the defendant(s) have an interest in whole or ( ) in styled as a payroll account, individual retirement account, tax account, lottery eaccount, Partnership account, joint or tenants by entirety account, insurance account, trust or escrow account, attorney's account or otherwise. ' ANSWER: Dated: August 5, 2013 Respectfully submitted, GORDON& REES LLP By: S. Manoj Jegasothy, Esquire Pa. Id. #80084 Richard T. Victoria, Esquire Pa. Id. #76681 707 Grant Street, Suite 3800 Pittsburgh, PA 15219 412-577-7400 (Phone) 412-347-5461 (Fax) 7 I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff arr � Jody S Smith at Chief Deputy Hill MAR -t+ PM 2: 30 Richard W Stewart Solicitor r a3 ., 3 w 0U IL IY� 1-.Nv LooN I k PENNSYLVANIA 84 Lumber Company Case Number vs. Hughes Contracting, Inc. 2013-4647 SHERIFF'S RETURN OF SERVICE 08/16/2013 10:27 AM-Jeff Kolodzi, 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Brianna Nornhold, 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 him/her. 08/22/2013 01:36 PM -Jeff Kolodzi, 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Denise Harman, Branch 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/her. Copy of levy mailed to attorney and letter mailed to defendant on August 23, 2013. 03/03/2014 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: $157.29 SO ANSWERS, March 03, 2014 RONNW ANDERSON, SHERIFF �• ,,I. & ,57) G ro/- y 3o�S�9 i::cu } u: She