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Home My WebLink About13-4995 " JAiU 2! x'11 ; CUMBERLAND C,0W4 John W. Purcell, Jr., Esquire PENNSYLVANIA ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234 -4178 urcell Pkh corn FUTUREGUARD BUILDING IN THE COURT OF COMMON PLEAS PRODUCTS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. :NO. it MID PENN AWNINGS & TINTING, And JOSEPH SULLENBERGER, CIVIL ACTION - LAW PRAECIPE TO: THE PROTHONOTARY Pursuant to the attached exemplified record of judgment entered in the Eighth District Court of the State of Maine, please enter judgment in favor of the Plaintiff and against the Defendants in the following amounts: 1. Damages for breach of contract in the amount of $17,535.59; 2. Pre - judgment interest accruing at the rate of 1.5% per month or 18% annum; 3. Post judgment interest accruing at the rate of 1.5% per month or 18% annum; and 4. Reasonable attorney fees in the amount of $2,098.10, based on review of Plaintiff's Affidavit Regarding Attorney's Fees and Costs dated January 3, 2012; PURCi29955 KRUG & HA PR By: . Purcell, Jr., Esquire Plaintiff for or aintiff DATE: �j -�a - \� o UPA G clut SAN aqu�u9 1 t.. r ;L,t 1)1-0 IHONO John W. Purcell, Jr., Esquire ID#29955 20!3 ACT 17 AM 11: 39 Purcell, Krug & Hailer 1719 North Front Street CUMBERLAND COUNTY Harrisburg, PA 17102 (717)234-4178 PENNSYLVANIA jpurcell @pkh.com FUTUREGUARD BUILDING : IN THE COURT OF COMMON PLEAS PRODUCTS, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 13-4995 • MID PENN AWNINGS & TINTING • AND JOSEPH SULLENBERGER, Defendants : CIVIL ACTION-LAW PRAECIPE To The Prothonotary: Please enter judgment pursuant to Pa. R.C.P. 3146(b) against the Garnishee, Members First Federal Credit Union and in favor of Plaintiff in the judgment amount of$17,535.59, pre- judgment interest accruing at the rate of 1.5% per month or 18% annum ($2,516.48),post judgment interest accruing at the rate of 1.5% per month or 18% annum ($5,776.66) and attorney fees in the amount of$2,098.10, and costs of $512.50, for a total garnishment of $26,341.23, less claimed expenses and/or exemptions, as per the Answers to Interrogatories to Garnishee, Members First Federal Credit Union. PURCELL, KRUG & HALLER By: • ► 'urcell, Jr., Esquire ID #29955 1719 North Front Street Harrisburg, PA 17102 g\t.cbPd Ot (717) 234-4178 (Zj M} !// Attorney for Plaintiff eLt4. 30 960 DATE: October 10, 2013 p#. ^�..)0�..t god kr S MEMBERS 1St FEDERAL CREDIT UNION September 6, 2013 John W Purcell Jr Esquire 1719 North Front Street Harrisburg PA 17102 RE: Writ of Execution for Mid Penn Awnings Dear Sir: A search of our records has revealed one account bearing the name Min Penn Awnings with an address of 4620 Carlisle Pike Mechanicsburg PA 17050. The account reflects an available balance of$17535.59. Pursuant to the writ, all funds in the aforementioned accounts above and beyond the monetary exemption provided by 42 P.S. Section 8123 and Pa. Rule of Civil Procedure 3111.1(3) in the amount of$300.00 have been frozen. Except for the exempt funds in the amount of$300.00 which are statutorily not subject to attachment, the accounts have been restricted from any further withdrawal transactions. Should you have any questions or need any additional information, feel free to contact me at (800)283-2328, ext. 6022. Sincerely, cc Alice McCloskey Deposit Operations Analyst 5000 Louise Drive • P.O.Box 40 • Mechanicsburg,Pennsylvania 17055 • (800) 283-2328 • wwwmemberslst.org SUPERIOR COURT STATE OF MAINE DISTRICT IWON Docket No. ' ss, Location Docket No. - - EXEMPLIFICATION IN TESTIMONY that the foregoing is a true copy of The Courts Order dated 1/11/12 I make this cert' 'cate and set my hand and the official seal (Seal) of the court o u1y 29, 2013 Clerk I JOHN BELIVEAU Court for the State of Maine, certify that Mfl? e/Judge of the h Superior/Di strict above, is Clerk of theme � /District Court for the County /Division of S?s6dignature is and is by law the proper person to make out and certify copies of the court's records and that full faith and credit is and ought to be given to the acts and attestations and that the attestation is in due form of law. In testimony w reof, I have set my hand and the seal of the court on J 1 29. 2013 (Seal) age I SUSAN BEMENT o f Lewiston , Clerk of thhee � /District Court n d for the County or District and State, do ce certify t ate % N same being a court of Is commissioned and qualified and acting as such, and s prop cu t for the State of Maine, duly n to mae out the aforegoing and annexed certificate, and that full faith and credit is and ofright ou ht to cert given to the acts and attestations and that the attestations are in due form of law. g In testimony whereof, I have set my hand and the seal of (Seal) the court on July 29 2013 Clerk CR -040, Rev. 08/97 STATE OF MAINE EIGHTH DISTRICT COURT ANDROSCOGGIN, SS. Located at Lewiston Docket No. LEW -CV -11 -681 FUTUREGUARD BUILDING ) PRODUCTS, ) Plaintiff, ) V. ) ORDER MID PENN AWNINGS & ) TINTING, ) and ) JOSEPH SULLENBERGER, ) Defendants 1 On December 14, 2011, this court granted judgment by default in favor of Plaintiff against Defendants. Judgment was also granted on Count I for Breach of Contract. Accordingly, judgment is expressly entered on Count I as follows: 1. Damages for breach of contract in the amount of $17,535.59; 2. Pre judgment interest accruing at the rate of 1.5% per month or 18% annum; 3. Post judgment interest accruing at the rate of 1.5% per month or 18% annum; and 4. Reasonable attorney fees in the amount of $2,098.10, based on review of Plaintiff's Affidavit Regarding Attorney's Fees and Costs dated January 3, 2012; The Clerk is directed to enter this Order upon the civil docket by reference pursuant to Rule 79(a) of the Maine Rules of Civil Procedure. Dated: Rick E. awren , J dge Maine istr' Court bll i c � s RUE C A T T/ ATTES • � CLERK p�� C4URrS FUTUREGUARD BUILDING PRODUCTS INC - PLAINTIFF DISTRICT COURT Attorney for: FUTUREGUARD BUILDING PRODUCTS INC LEWISTON DAVID SHERMAN - RETAINED Docket No LEWDC -CV- 2011 -00681 DRUMMOND WOODSUM 84 MARGINAL WAY SUITE 600 PORTLAND ME 04101 -2480 DOCKET RECORD Vs MID PENN AWNINGS AND TINTING LLC - DEFENDANT 1286 HUNTERS RIDGE DRIVE MECHANICSBURG PA JOSEPH SULLENBERGER - DEFENDANT 1286 HUNTERS RIDGE DRIVE MECHANICBURG PA Filing Document: COMPLAINT Minor Case Type: CONTRACT Filing Date: 07/06/2011 Docket Events: 07/08/2011 FILING DOCUMENT - COMPLAINT FILED ON 07/06/2011 07/08/2011 Party(s): FUTUREGUARD BUILDING PRODUCTS INC ATTORNEY - RETAINED ENTERED ON 07/06/2011 Plaintiff's Attorney: DAVID SHERMAN 07/08/2011 Party(s): MID PENN AWNINGS AND TINTING LLC SUMMONS /SERVICE - CIVIL SUMMONS SERVED ON 05/06/2011 07/08/2011 Party(s): MID PENN AWNINGS AND TINTING LLC SUMMONS /SERVICE - CIVIL SUMMONS FILED ON 07/06/2011 07/08/2011 Party(s): JOSEPH SULLENBERGER SUMMONS /SERVICE - CIVIL SUMMONS SERVED ON 05/06/2011 07/08/2011 Party(s): JOSEPH SULLENBERGER SUMMONS /SERVICE - CIVIL SUMMONS FILED ON 07/06/2011 07/08/2011 CERTIFY /NOTIFICATION - CASE FILE NOTICE SENT ON 07/08/2011 CARA THIBODEAU , COURT MONITOR 07/27/2011 Party(s): FUTUREGUARD BUILDING PRODUCTS INC SUPPLEMENTAL FILING - AMENDED COMPLAINT FILED ON 07/18/2011 10/05/2011 ORDER - COURT ORDER ENTERED ON 10/05/2011 RICK E LAWRENCE , JUDGE ORDERED INCORPORATED BY REFERENCE AT THE SPECIFIC DIRECTION OF THE COURT. COPIES TO PARTIES /COUNSEL ORDER. DEADLINE 12/5/11 NO ANSWER SCHEDULING 10/24/2011 NOTE - OTHER CASE NOTE ENTERED ON 10/11/2011 CARA THIBODEAU , COURT MONITOR DEFENDANT'S COPY OF NO ANSWER SCHEDULING ORDER MAILED TO 1286 HUNTERS RIDGE DRIVE, MECHANICSBURG, PA 17050 RETURNED UNDELIVERABLE. NO NEW ADDRESS. Page 1 of 3 Printed on: 07/26/2013 LE WDC - CV - 2011 -00681 10/24/2011 Party(s): MID DOCKET RECORD PENN AWNINGS AND TINTING LLC SUMMONS /SERVICE - CIVIL SUMMONS SERVED ON 10/10/2011 10/24/2011 Party(s): MID PENN AWNINGS AND TINTING LLC SUMMONS /SERVICE - CIVIL SUMMONS FILED ON 10/19/2011 10/24/2011 Party(s): JOSEPH SULLENBERGER SUMMONS /SERVICE - CIVIL SUMMONS SERVED ON 10/10/2011 10/24/2011 Party(s): JOSEPH SULLENBERGER SUMMONS /SERVICE - CIVIL SUMMONS FILED ON 10/19/2011 12/08/2011 Party(s): FUTUREGUARD BUILDING PRODUCTS INC MOTION - AFFID & REQUEST DEFAULT /JUDG FILED ON 12/05/2011 12/15/2011 Party(s): MID PENN AWNINGS AND TINTING LLC,JOSEPH SULLENBERGER ORDER - DEFAULT ENTERED ON 12/14/2011 RICK E LAWRENCE , JUDGE ORDERED INCORPORATED BY REFERENCE AT THE SPECIFIC DIRECTION OF THE COURT. COPIES TO PARTIES /COUNSEL 12/15/2011 FINDING - JUDGMENT DETERMINATION ENTERED ON 12/14/2011 RICK E LAWRENCE , JUDGE ORDERED INCORPORATED BY REFERENCE AT THE SPECIFIC DIRECTION OF THE COURT. COPIES TO PARTIES /COUNSEL DENIED. JUDGMENT IS ONLY FOR COUNT I FOR BREACH OF CONTRACT. COUNT II AND II ARE ORDER - DEFAULT JUDGMENT ENTERED ON 01/11/2012 RICK E .LAWRENCE , JUDGE ORDERED INCORPORATED BY REFERENCE AT THE SPECIFIC DIRECTION OF THE COURT. COPIES TO PARTIES /COUNSEL DENIED. JUDGMENT IS ONLY FOR COUNT I FOR BREACH OF CONTRACT. COUNT II AND II ARE Judgment entered on COUNT 1 for FUTUREGUARD BUILDING PRODUCTS INC and against MID PENN AWNINGS AND TINTING LLC, JOSEPH SULLENBERGER in the amount of $17535.59, Attorney fee of $2098.10. 1 2/29/2011 NOTE - OTHER CASE NOTE ENTERED ON 12/27/2011 CARA THIBODEAU , COURT MONITOR DEFENDANTS' COPY F JUDGMENT MAILED TO 1286 HUNTERS RIDGE DRIVE, MECHANICSB RETURNED UNDELIVERABLE. NO NEW ADDRESS. URG, PA 17050 01/10/2012 Party(s): FUTUREGUARD BUILDING PRODUCTS INC OTHER FILING - AFFIDAVIT FILED ON 01/04/2012 0 1/30/2012 NOTE - OTHER CASE NOTE ENTERED ON 01/26/2012 CARA THIBODEAU , COURT MONITOR DEFENDANT'S COPY OF JUDGMENT MAILED TO 1286 HUNTERS RIDGE RD, MECHANICSBURG, PA 17050 RETURNED UNDELIVERABLE. NO NEW ADDRESS PROVIDED BY POST OFFICE. 02/24/2012 Party(s): FUTUREGUARD BUILDING PRODUCTS INC MOTION - AFFID & REQUEST DEFAULT /JUDG FILED ON 01/31/2012 ON COUNTS II AND III Page 2 of 3 Printed on: 07/26/2013 LEW DC - CV - 2011 -00681 02/24/2012 Part DOCKET RECORD Y(sJ: FUTUREGUARD BUILDING PRODUCTS INC MOTION - AFFID & REQUEST DEFAULT /JUDG DENIED ON 02/21/2012 RICK E LAWRENCE , JUDGE 02/24/2012 ORDER COURT ORDER ENTERED ON 02/21/2012 RICK E LAWRENCE , JUDGE ORDERED INCORPORATED BY REFERENCE AT THE SPECIFIC DIRECTION OF THE COURT. COPIES TO PARTIES /COUNSEL DEFAULT ON COUNTS II AND III DENYING REQUEST FOR 03/08/2012 NOTE - OTHER CASE NOTE ENTERED ON 03/05/2012 CARA THIBODEAU , COURT MONITOR DEFENDANT'S COPY OF FURTHER ORDER ON MSJ MAILED TO 1286 HUNTERS RIDGE RD, MECHANICBURG, PA 17050 RETURNED UNDELIVERABLE. NO NEW ADDRESS PROVIDED BY POST OFFICE 04/03/2012 Party(s): MID PENN AWNINGS AND TINTING LLC,JOSEPH SULLENBERGER WRIT - WRIT OF EXECUTION ISSUED ON 03/29/2012 TRICIA BLANCHARD , ASSOCIATE CLERK PRINCIPLE 17535.59, PREJUDGMENT INTEREST 180 ( ATTY FEES 2098.10, POSTJUDGMENT INTEREST 18$ (319.96) A TRUE COPY ATTEST: Clerk Page 3 of 3 Printed on: 07/26/2013 FUTUREGUARD BUILDING IN THE COURT OF COMMON PLEAS PRODUCTS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. 1 3- L 199S MID PENN AWNINGS & TINTING, NO And JOSEPH SULLENBERGER, CIVIL ACTION — LAW AFFIDAVIT I hereby swear and affirm that the foregoing Exemplified Record of the Judgment in the above matter is valid, enforceable and unsatisfied to the best of my knowledge. II, Jr., Esquire I. 29955 1719 North Front Street Harrisburg, PA 17102 (717) 234 -4178 1purcellCc�om Sworn to and subscribed befo a me this day of , 2013 M M -..gi t. r' , r M n 4fo h L D- r -- _... NOTARIAL SEA =� t < ANGELA S SHAFF R �' ; —+ Notary Public C HARRISBURG CITY, DAUPHIN COUNTY My Commission Expires Jan 23, 2016 W F L John W. Purcell, Jr., Esquire j iFw r'. "11�Url;f j , ID #29955 Purcell, Krug & Haller 20 AUG 2 ! PN 3: 00 1719 North Front Street Harrisburg, PA 17102 CUIIBERLA D COUNTY (717) 234 -4178 P FUTUREGUARD BUILDING : IN THE COURT OF COMMON PLEAS PRODUCTS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 1 1 l MID PENN AWNINGS & TINTING, And JOSEPH SULLENBERGER, CIVIL ACTION — LAW CERTIFICATION OF ADDRESSES OF PARTIES I hereby certify that the following are the last known addresses for the parties in the above - referenced matter: Plaintiff: Futureguard Building Products P.O. Box 2030 Auburn, ME 04211 -2030 Defendant: Mid Penn Awnings and Tinting, LLC Joseph Sullenberger 1286 Hunters Ridge Drive Mechanicsburg, PA 17050 And /or 4620 Carlisle Pike Mechanicsburg, PA 17050 PURCELL, KRU By: o 299 1719 North Front Street Harrisburg, PA 17102 (717) 234 -4178 DATE: Attorney for Plaintiff FUTUREGUARD BUILDING IN THE COURT OF COMMON PLEAS PRODUCTS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vi. NO. MID PENN AWNINGS & TINTING, And JOSEPH SULLENBERGER, CIVIL ACTION — LAW NOTICE OF ENTRY OF JUDGMENT TO: Penn Awnings and Tinting, LLC and Joseph Sullenberger, Defendants You are hereby notified that on _ off/ , 2013, the following Judgment has been entered against you in the above - captioned case. 1. Damages for breach of contract in the amount of $17,535.59; 2. Pre - judgment interest accruing at the rate of 1.5% per month or 18% annum; 3. Post judgment interest accruing at the rate of 1.5% per month or 18% annum; and 4. Reasonable attorney fees in the amount of $2,098.10, based on review of Plaintiff's Affidavit Regarding Attorney's Fees and Costs dated January 3, 2012; DATE: � ovl /,3 w PROTHOHOTARY I hereby certify that the name and address of the proper person to receive this notice is: Mid Penn Awnings and Tinting, LLC Joseph Sullenberger 1286 Hunters Ridge Drive Mechanicsburg, PA 17050 And /or 4620 Carlisle Pike Mechanicsburg, PA 17050 A: Mid Penn Awnings and Tinting, LLC and Joseph Sullenberger, Defendida Por este medio se le esta notificando que el de del 2013, el /la siguiente Fallo)ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: PROTONOTARIO Certifico que la siguiente direccion es la del defendido /a segun indiaca en el certificate de residencia: Mid Penn Awnings and Tinting, LLC Joseph Sullenberger 1286 Hunters Ridge Drive Mechanicsburg, PA 17050 And /or 4620 Carlisle Pike Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION FUTUREGUARD BUILDING ❑ Confessed Judgment PRODUCTS Plaintiff Other � � /r l VS. File No. /� // MID PENN AWNINGS &TINTING Amn Tngp cttr r �rT Amount Due See attached HEXER Defendant Interest Address: Atty's Comm 1286 Hunters Ridge Drive Mechanicsburg, PA 17050 Costs AND /OR 4620 Carlisle Pike Mechanicsburg, PA 17050 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) C/) ry 7D . CD 7 See attached list of Garnishees —� c C:) PRAECIPE FOR ATTACHMENT EXECUTION r Issue writ of attachment to the Sheriff of C' 1 end County, for debt, int re est and costs, as above, directing attachment against the above -nam �� mher ed garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ❑ (Indicate) Index this writ against the garnishee (s) as a ]is agai a of the defendant(s) described in the attached exhibit. Date 2c7 - f Signature: Print Name: W. Purcell Jr. /[�p a Address: 1719 N. Front St reet ,33 • sd (24b OP Harrisburg, PA 17102 s O Attorney for: Pl aintiff Telephone: —717-2-44-4178 Supreme Court ID No: 29955 �Qf 3�a-a S r#-dqL1 W - CY 1. Damages for breach of contract in the amount of $17,535.59; 2. Pre judgment interest accruing at the rate of 1.5% per month or 18% annum; 3. Post judgment interest accruing at the rate of 1.5% per month or 18% annum; and 4. Reasonable attorney fees in the amount of $2,098.10, based on review of Plaintiff's Affidavit Regarding Attorney's Fees and Costs dated January 3, 2012; 1. Americhoice Federal Credit Union 20 Sporting Green Drive Mechanicsburg, PA 17050 2. Belco Community Credit Union 5304 Carlisle Pike Mechanicsburg, PA 17050 3. Fulton Bank 6520 Carlisle Pike Mechanicsburg, PA 17050 4. Members First 6280 Carlisle Pike Mechanicsburg, PA 17050 5. Metro Bank — Hampton Center Branch 4860 Carlisle Pike Mechanicsburg, PA 17050 6. New Cumberland Federal Credit Union 6692 Carlisle Pike Mechanicsburg, PA 17050 WRIT OF EXECUTION and /or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13 -4995 Civil COUNTY OF CUMBERLAND) CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FUTUREGUARD BUILDING PRODUCTS Plaintiff (s) From MID PENN AWNINGS & TINTING AND JOSEPH SULLENBERGER, 1286 HUNTERS RIDGE DRIVE MECHANICSBURG, PA 17050 AND /OR 4620 CARLISLE PIKE, MECHANICSBURG, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: AM.ERICHOICE FEDERAL CREDIT UNION, 20 SPORTING GREEN DRIVE, MECHANICSBURG, PA 17050 BELCO COMMUNITY CREDIT UNION, 5304 CARLISLE PIKE, MECHANICSBURG, PA 17050 FULTON BANK, 6520 CARLISLE PIKE, MECHANICSBURG, PA 17050 MEMBERS 1 6280 CARLISLE PIKE, MECHANICSBURG, PA 17050 METRO BANK - HAMPTON CENTER BRANCH, 4860 CARLISLE PIKE, MECHANICSBURG, PA 17050 NEW CUMBERLAND FEDERAL CREDIT UNION, 6692 CARLISLE PIKE, MECHANICSBURG, PA 17050 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; (2) 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 $17,535.59 Plaintiff Paid $ Interest PRE- JUDGMENT/POST- JUDGMENT INTEREST ACCURING AT THE RATE OF 1.5% PER MONTH OR 18% ANNUM Attorney's Comm. % Law Library $.50 Attorney Paid $6 .1.50 Due Prothonotary $2.25 Other Costs $2,098.10 ATTORNEY FEES Date: AUGUST 21, 2013 � l_��/.� David D. Buell, Prothonotary (Seal) j r - Deputy REQUESTING PARTY: Name: JOHN W. PURCELL, ESQUIRE Address: PURCELL, KRUG & HALLER 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717- 234 -4178 Supreme Court ID No. 29955 i Or PROTHONt? f `t 2 13 'UG 29 PM � 22 CUMBERLAND COUNTY John W. Purcell, Jr., Esquire PENNS ID#29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell @pkh.com FUTUREGUARD BUILDING IN THE COURT OF COMMON PLEAS PRODUCTS, ' CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. MID PENN AWNINGS & TINTING, AND JOSEPH SULLENBERGER, Defendant CIVIL ACTION — LAW INTERROGATORIES TO GARNISHEE TO: Metro Bank — Hampton Center Branch 4860 Carlisle Pike Mechanicsburg, PA 17050 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. PURCELL, KRUG & HALLER By: John V4. Purcell, Jr., Esquire ID # 9955 1 19 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney for Plaintiff DATE: i f INTERROGATORIES 1. At the time you were served or at any time subsequent thereto, did you owe Defendant any money or were you liable to her on any negotiable or written instrument, or did she claim that you owed her any money or were you liable to her for any reason? ANSWER: No Accounts a. If the answer to Interrogatory 1 is in the affirmative, please state with specificity those amounts of money owed or obligations to Defendant outstanding. ANSWER: 2. At the time you were served with these Interrogatories or at any time subsequent thereto, was there in your possession, custody or control, or in the joint possession, custody or control of yourself or one or more other persons any property of any nature owned solely or in part by Defendant? ANSWER: a. If the answer to Interrogatory 2 is in the affirmative, please state with specificity those properties possessed or controlled by yourself or in part with Defendant. ANSWER: 3. At the time you were served with these Interrogatories or at any time subsequent thereto, did you hold legal title to any property of any nature owned solely or in part by Defendant or in which Defendant held or claimed any interest? ANSWER: a. If the answer to Interrogatory 3 is in the affirmative, please list those properties in which you held title. ANSWER: 4. At the time you were served with these Interrogatories or at any time subsequent thereto, did you hold as a fiduciary any property in which Defendant had an interest? ANSWER: a. If the answer to Interrogatory 4 is in the affirmative, please state with specificity those properties in which you hold as such fiduciary for Defendant. ANSWER: 5. At any time before or after you were served with these Interrogatories, did 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? ANSWER: a. If the answer to Interrogatory 5 is in the affirmative, please state with specificity those properties so transferred, the transferees in each transaction and the dates such transfers took place. ANSWER: 6. At the time you were served with these Interrogatories, or at any time subsequent thereto, did you pay, transfer, or deliver any money or property to Defendant or to any person or place pursuant to its direction or otherwise discharge any claim that Defendant has or had against you? ANSWER: a. If the answer to Interrogatory 6 is in the affirmative, please state with specificity those properties so transferred, the dates of the transfer, and the respective transferees. ANSWER: 7. At the time you were served with these Interrogatories, or at any time subsequent thereto, did you have any safe deposit boxes, pledges, documents of title, securities, tax or other accounts or deposits in which Defendant has an interest? ANSWER: a. If the answer to Interrogatory 7 is in the affirmative, please state with specificity those accounts, account numbers, deposits, balances, transactions involving said accounts or deposits, instruments, certificates, drafts, notes or other instruments in which Defendant may have an interest. ANSWER: 8. At the time you were served or at any time subsequent thereto, did Defendant have any funds on deposit with you in her name or jointly with another person in any type of account (checking/savings/certificate of deposit/money market/passbook)? ANSWER: a. If the,answer to Interrogatory 8 is in the affirmative, please state for each, with specificity, the account type, account number, amount on deposit and the titled account holder(s). ANSWER: VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. n (SI AfUjRE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff iR THE 1t HON 01- 0,TA 1 Jody S Smith 2613 AUG 30 PM 3y Chief Deputy Richard W Stewart ' CUMBERLAND COUNTY Solicitor. OC 7�E V -rPV PENNSYLVANIA Futureguard Building Products, Inc. Case Number vs. 2013-4995 Mid Penn Awnings&Tinting LLC (et al.) SHERIFF'S RETURN OF SERVICE 08/26/2013 01:45 PM-William Cline, Deputy,who being duly swom 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, BELCO Community Credit Uhnion, 5304 Carlisle Pike, Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Emily Garofalo, Branch Manager, personally three copies of interrogatories together with three true and atte ed copies of the Writ of Execution and made the contents there of known to her. i AM CLIN , DEPU SO ANSWERS, August 27,2013" RONW R ANDERSON, SHERIFF (c)CauntySuite Sheriff,7e(eosoft,Inc. 4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson "0F Sheriff ��4k4'34��t t.s[ata��3x�re� Jody S Smith - 20111U&30 .pp Chief Deputy :c Richard W Stewart Solicitor OFR �O Va=RIFF PEHNS YLVA'U `j Futureguard Building Products, Inc. Case Number VS. Mid Penn Awnings&Tinting LLC (et al.) 2013-4995 SHERIFF'S RETURN OF SERVICE 0812612013 02:06 PM-William Cline, 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, Fulton Bank, 3344 Trindle Road, Camp Hill Borough, Camp Hill, PA 17011, Cumberland County, by handing to Kathleen Yoder,Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and mad the ntents there of known to her. C LIA INE, DEPUTY SO ANSWERS, August 27, 2013 RONN9 R ANDERSON, SHERIFF (c)CountySufte ShenH.TeieosoR,Inc. s ' - SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson If. �:. s- ?f" -CC';.., Sheriff Qk~kx�,Of Cara31 e/?�a' �F i HIE PRO T H O N,u #�i E s i Jody S Smith ;0111 j a J Chief Deputy ° n, 4 2013 AUG 3 PM Richard W Stewart ° Richard M K u l-.a CUMBERLAND COUNTY PENNSYLVANIA Futureguard Building Products, Inc. Case Number vs. Mid Penn Awnings&Tinting LLC (et al.) 2013-4995 SHERIFF'S RETURN OF SERVICE 08/26/2013 11:54 AM-William Cline, 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 1 st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Ashley Hoke, Members Services, personally three copies of interrogatories together with three true and aft ted copies of the Writ of Execution and made the contents there of known to her. r,7 - Wll�!-WM ItILINE, DEPUTY SO ANSWERS, .August 27,2013 RONNY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. ' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff I„r THE PRO T1-+ONO Ti'i Wit ' Jody S Smith Chief Deputy 2013 AUG 30 PM 3• Richard W Stewart CUMBERLAND COUNTY Solicitor OF"�- c :tY PENNSYLVANIA Futureguard Building Products, Inc. Case Number vs. Mid Penn Awnings&Tinting LLC (et al.) 2013-4995 SHERIFF'S RETURN OF SERVICE 08/26/2013 12:04 PM-William Cline, 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, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Darijo Celikovic, Customer Service, personally three copies of interrogatories together with three true and attested copies of the Writ of Execu lon a d made the contents there of known to him/her. WILL INE, D PUTY SO ANSWERS, August 27, 2013 RONW R ANDERSON, SHERIFF _ (c)CountySuite Shenff.TeleosoR,Inc. ' - SHERIFF'S OFFICE OF CUMBERLAND COUNTY- Ronny R Anderson -„ E Sheriff -!lr 1{; . Jody S Smith ' I Chief Deputy AUG 30 R�i .x Richard W Stewart � Solicitor CUMBERLAND COUAITY �"��"' ,. �"�`I�� PENNSYLVANIA Futureguard Building Products, Inc. Case Number vs. Mid Penn Awnings&Tinting LLC (et al.) 2013-4995 SHERIFF'S RETURN OF SERVICE 08/26/2013 01:29 PM-William Cline, 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, New Cumberland Federal Credit Union, 6692 Carlisle Pike, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, by handing to Kari Myers,Assistant Manager, personally three copies of interrogatories together with three true and attested copies f the Writ of Execution and made the contents there of known to her. f t WIL CL NE, bEPUtV SO ANSWERS, / August 27, 2013 RONNY R ANDERSON, SHERIFF (c)CountySuite Shenff,Teleosoft,Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff [ ppts in r�'; Jody S Smith Chief Deputy 20 13 AUG 30 PM 31; I I Richard W Stewart Solicitor OFF CEOF THE SI*ERIE= CUMBERLAND COUNTY PENNSYLVANIA Futureguard Building Products, Inc. vs. Case Number Mid Penn Awnings &Tinting LLC (et al.) 2013-4995 SHERIFF'S RETURN OF SERVICE 08/30/2013 Service on garnishee AmeriChoice Federal Credit Union on"hold" by Attorney. The writ of execution and notice to defendants was mailed on August 30, 3013 to Joe Sullenberger at 4620 Carlisle Pike, Mechanicsburg, PA 17050 and to Mid Penn Awnings&Tinting, LLC at 4620 Carlisle Pike, Mechanicsburg, PA 17050. SO ANSWERS, August 30, 2013 RONIV R ANDERSON, SHERIFF (c?CountySuite Sheriff,Teleosoft,Inc. F T�� o a lCE o �� o ea TA F r?J3 SEP - 4 pp''6ERLA;tjp PE"SYLVAtjlA' Y John W. Purcell, Jr., Esquire ID#29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell @pkh.com FUTUREGUARD BUILDING IN THE COURT OF COMMON PLEAS PRODUCTS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. q NO. MID PENN AWNINGS & TINTING, AND JOSEPH SULLENBERGER, Defendant CIVIL ACTION — LAW 14 swcfs f'o INTERROGATORIES TO GARNISHEE TO: Members First 6280 Carlisle Pike Mechanicsburg, PA 17050 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. PURCELL, KRUG & HALLER By: Joh II, Jr., Esquir 1 29955 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney for Plaintiff DATE: 1 INSTRUCTIONS We are enclosing herewith Interrogatories propounded by the Plaintiff in the above-captioned matter to be answered by Members First, in writing and under oath within thirty (20) days from the date of service hereof, with a request that a copy of the answers be served upon Counsel for Plaintiff. Each Interrogatory hereinafter set forth calls not only for the knowledge of Members First, but also for the knowledge that is available to said Members First by reasonable inquiry, including inquiry of representatives, attorneys and others. These shall be deemed to be continuing Interrogatories. If, between the time of your answers and the time of trial in this case, you or anyone else acting in your behalf, learn of further information not contained in your answers, you. shall promptly furnish said information to the undersigned attorney by Supplemental Answers. Please attach all written materials to any answer you provide referring to documents. If they are not available, state where they can be obtained. Label the written materials with the number of the Interrogatory to which they pertain. If there are no written materials relevant to a question, please state. If any problems arise in answering the Interrogatories or interpreting the scope of the request, please contact the attorney whose name appears at the end of the Interrogatories. Following such a procedure may obviate the need to make objections to questions and may eliminate the need for a Motion to Compel Discovery. If any objection is asserted or document withheld under claim or privilege, please furnish the following: (a) Identify the Interrogatory to which an objection is asserted or identify that document withheld; (b) State the nature of the asserted privilege and the basis upon which it is claimed; (c) Provide a description of the nature and subject matter of the information requested or the document withheld. 1. When you are asked to identify anything: a. If it is a person, give that person's name, address and telephone number. b. If it is a document, state the nature of the document, its date, identify the person who prepared it and the person in whose possession it is, and a brief statement of its subject matter. C. If it is anything other than a person or document, give a brief description of it sufficient to inform as to its nature, location, value, ownership, possession and control, if applicable. 2. The words "you" and "your" shall mean the Party to whom these interrogatories are propounded. 3. The term "documents" means the original, all copies and all translations of any writing and any written, recorded or graphic material, whether typed, handwritten, printed or otherwise, and any photograph, photostat, microfilm, computer file or other reproduction. "Document" as used herein also means any type of audible recording, any photograph, and any non-identical copy of any document as previously defined, e.g., any copy of a document as previously defined which differs from any other copy thereof, either by virtue of other material appearing thereon, such as handwriting or typewriting, or otherwise. 4. The term "person" or"persons" refers to any natural person, firm, or corporation, partnership, joint venture, or any other form of business entity. 5. In each instance where you deny knowledge or information sufficient to answer the interrogatory, you are to set forth the name and address of each person, if any, who is known by you to have such information or knowledge. 6. In each instance where you aver insufficient knowledge or information as a ground for not providing information or for providing only a portion of the information requested by an interrogatory, you are to set forth a description of the efforts made by you or anyone acting on your behalf to locate information necessary for such answer. 7. In each instance where you claim an objection or privilege, list a general description of the information with the basis for your claiming a privilege or objection. 8. The interrogatories shall be deemed continuing interrogatories. Between the time of your answers to said interrogatories and the time of trial, if you, or anyone acting on your behalf, learn the identity or whereabouts of any witness not disclosed in your answer, or if you obtain or learn of additional information requested, but not supplied in your answer then you shall promptly furnish a supplemental answer under oath containing the same. You cooperation will be appreciated. INTERROGATORIES 1. At the time you were served or at any time subsequent thereto, did you owe Defendant any money or were you liable to her on any negotiable or written instrument, or did she claim that you owed her any money or were you liable to her for any reason? ANSWER: S a. If the answer to Interrogatory 1 is in the affirmative, please state with specificity those amounts of money owed or obligations to Defendant outstanding. ANSWER: 2. At the time you were served with these Interrogatories or at any time subsequent thereto, was there in your possession, custody or control, or in the joint possession, custody or control of yourself or one or more other persons any property of any nature owned solely or in part by Defendant? ANSWER: N a. If the answer to Interrogatory 2 is in the affirmative, please state with specificity those properties possessed or controlled by yourself or in part with Defendant. ANSWER: 3. At the time you were served with these Interrogatories or at any time subsequent thereto, did you hold legal title to any property of any nature owned solely or in part by Defendant or in which Defendant held or claimed any interest? ANSWER: �'V a. If the answer to Interrogatory 3 is in the affirmative, please list those properties in which you held title. ANSWER: n 4. At the time you were served with these Interrogatories or at any time subsequent thereto, did you hold as a fiduciary any property in which Defendant had an interest? ANSWER: a. If the answer to Interrogatory 4 is in the affirmative, please state with specificity those properties in which you hold as such fiduciary for Defendant.* ANSWER: 5. At any time before or after you were served with these Interrogatories, did 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? ANSWER: oo a. If the answer to Interrogatory 5 is in the affirmative, please state with specificity those properties so transferred, the transferees in each transaction and the dates such transfers took place. ANSWER: 6. At the time you were served with these Interrogatories, or at any time subsequent thereto, did you pay, transfer, or deliver any money or property to Defendant or to any person or place pursuant to its direction or otherwise discharge any claim that Defendant has or had against you? ANSWER: a. If the answer to Interrogatory 6 is in the affirmative, please state with specificity those properties so transferred, the dates of the transfer, and the respective transferees. ANSWER: 7. At the time you were served with these Interrogatories, or at any time subsequent thereto, did you have any safe deposit boxes, pledges, documents of title, securities, tax or other accounts or deposits in which Defendant has an interest? ANSWER: a. If the answer to Interrogatory 7 is in the affirmative, please state with specificity those accounts, account numbers, deposits, balances, transactions involving said accounts or deposits, instruments, certificates, drafts, notes or other instruments in which Defendant may have an interest. ANSWER: �A V` i 8. At the time you were served or at any time subsequent thereto, did Defendant have any funds on deposit with you in her name or jointly with another person in any type of account (checking/savings/certificate of deposit/money market/passbook)? ANSWER: � O a. If the answer to Interrogatory 8 is in the affirmative, please state for each, with specificity, the account type, account number, amount on deposit and the titled account holder(s). ANSWER: John W. Purcell, Jr., Esquire ID#29955 x I3 OCT 28 Pi4. 3: Ci l Purcell, Krug & Haller 1719 North Front Street CUMBERLAND COUNTY Harrisburg, PA 17102 PENNSYLVANIA (717)234-4178 jpurcell @pkh.com FUTUREGUARD BUILDING : IN THE COURT OF COMMON PLEAS PRODUCTS, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 13-4995 • MID PENN AWNINGS & TINTING • AND JOSEPH SULLENBERGER, Defendants : CIVIL ACTION-LAW PRAECIPE To The Prothonotary: Please dissolve the garnishment against Members First Federal Credit Union, Belco Community Credit Union, Fulton Bank, Metro Bank and New Cumberland Federal Credit Union. PURCELL, KRUG & HALLER By: • u rce , r., Esquire ID #29 5 17 orth Front Street arrisburg, PA 17102 (717) 234-4178 Attorney for Plaintiff DATE: October 24, 2013 � sq. o J ati-vt cy_,4 gbiv a� � Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY f= ((_EU -0F FICE Jr THE PR01 H0N0 TAR 2014 APR 22 AM 10: 19 CUMBERLAND COUNTY PENNSYLVANIA Futureguard Building Products, Inc. vs. Mid Penn Awnings & Tinting LLC (et al.) Case Number 2013 -4995 SHERIFF'S RETURN OF SERVICE 08/26/2013 11:54 AM - William Cline, 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, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Ashley Hoke, Members Services, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. 08/26/2013 12:04 PM - William Cline, 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, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Darijo Celikovic, Customer Service, 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. 08/26/2013 01:29 PM - William Cline, 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, New Cumberland Federal Credit Union, 6692 Carlisle Pike, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, by handing to Kari Myers, Assistant 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 her. 08/26/2013 01:45 PM - William Cline, 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, BELCO Community Credit Uhnion, 5304 Carlisle Pike, Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Emily Garofalo, 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 her. 08/26/2013 02:06 PM - William Cline, 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, Fulton Bank, 3344 Trindle Road, Camp Hill Borough, Camp Hill, PA 17011, Cumberland County, by handing to Kathleen Yoder, Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. 08/30/2013 Service on garnishee AmeriChoice Federal Credit Union on "hold" by Attorney. The writ of execution and notice to defendants was mailed on August 30, 3013 to Joe Sullenberger at 4620 Carlisle Pike, Mechanicsburg, PA 17050 and to Mid Penn Awnings & Tinting, LLC at 4620 Carlisle Pike, Mechanicsburg, PA 17050. 04/21/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as SATISFIED. Plaintiffs attorney was able to collect full amount of judgment from garnishee Members 1st Federal Credit Union. (c) Count9Suite Sheriff, Teleosoft. Inc. 06 3e>V7 SHERIFF COST: $721.42 SO ANSWERS, April 21, 2014 RONNYR ANDERSON, SHERIFF