HomeMy WebLinkAbout02-0862~;OMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERI-AND
Mag, Dist, NO.:
09-1-02
DJ Name: Hon.
ROBERT V. Ia_AN~OVE
/~!:~1901 STATE STREET
CAMP HILL, PA
Telephone: (717) 761- 0583
ATTORNEY FOR PLAINTIFF :
AMY F. WOLFSON~ESQ.
267 E MARKET ST
YORK, PA 17403
THIS !S TO NOTIFY YOU THAT:
Judgment:
~-] Judgment was entered for:
(Name)
Judgment was entered against: (Name)
17011-0000
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
FMANORCARE HEALTH SERVICES
267 E MARKET ST
YOEK, PA 17404
VS.
DEFENDANT: NAME and ADDRESS
~WINGARD, RAY' ET AL.
16 TORY CIRCLE
ENOLA~ PA 17025
Docket No.: CV-0000335-01
Date Filed: 10/03/01
_J
._J
DEFAULT JO~M~T PLTF
M~~ g~AT,~ ~VT~
WINC~RD: RAy
in the amount of $
I: '71 R _ 02 on:
(Date of Judgment) 11/8,;/{31
Defendants are jointly and severally liable.
Darnageswill be asseSsed on: ' , :: : ,:, ,,
This Case dismissed without prejudice. "
[~ Amount of Judgment Subject to
Attachment/Act 5 of 1996 $.
Levy is stayed for days or [~ generally stayed.
~ Objection to levy has been filed and hearing will be held:
(Date & T!me)
Amount Of Judgment,' ~;$ , 651.52
Judgment Costs ' $ 66.50
Interest on Judgment . $ . O0
Att°rney Fees $ .__. oo
ITotal $ 1,718.02
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
Date:
Time:
Place:
ANY pARTy HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUsTII~cLUDE~ A COPY i)i :r
/¢/j4 isatruE this
My commission expires first Monday of January. 2006
AOPC 315-99
IM WITH YOU~I;IT),C. E OF APPEAL.-
OMMONWEALTH OF PE SYLVANIA
COUNTY OF: ~I~.RLAND
Mag Dist. No
09-1-02
DJ Name: Hon.
ROBERT V. MANLOVE
Address 1901 STATE STREET
~, CAMP HIL, L, PA
L- 00~00
AMY F. WOLFSON,
267 E MARKET ST
YORK, PA 17403
ESQ.
NOTICE OF JU.DGMENT/TRANSCR T
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
267 E MARKET ST
YORK, PA 17404
_ /
DEFENDA~N I: NAME and ADDRESS
FWINe~LD--; RAY,
ET"AL.
16 Tp~RY ' CIRCLE
Docket No.: CV'-0000335-01 [ ~,..~l~
Date F ed: 10/03/01
~Judgment: ....... ~
]--~ Judgment was entered for: (Name)
~ Judgment.wasentered against: (Name)
in the amount of $ I :'71R_~ on:
~-] Defendants are jointly and severally liable.
!'.]-3"{ ' Da~nages will be assessed on
-']This ca~e dismissed without prejudice.
~] Amount of Judgment Subject to
AttachmentJAct 5 of 1996 $.
[~ Levy is stayed for days or [--] generally stay~d.
['~ Objection to levy has been filed and hearing will be heid:
(Date of Judgment)
(Date & Time)
11!n, !n1
Amount of Judgment $ ,1,'651.52
Judgment Costs " $ 66.50
Interest on Judgment $ .00
Attorney Fees $ o 00
Total $ 1,718.02
Date: ~ Place:
Post Judgment Credits
Post Judgment Costs
Certified.,, Judgment Total
Time:
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OFTHE COURT OF COMMON PLEAS CIVIL DIVISION. YOU
· . 'MUS.'[ INCLU~)E A COPY OF T S.I~]~f~E ~D~ JUD(jt~'I~/'JI'[~A'I~C,J;I/PT FIj~ClM W1TH. YOUI~NOW~?OF.~PPEAL
:~: ":..','"~'~:::~ ... Date ?.,~,"-~~~.' 1,~~ .'Z
I ced?y t~at th~s ~s ~ A~d c~[,~t copy o,f the record of th~roc~d~ng~n~m~the j~megt.
[ /,f,/~ Date. ,~-., .~-~,-' ~.- /- .,'.?'(~./~, ;' ¢;.~*"' ~ ,.~':N;~tJu?c~=
% % ' .......
My commission expires first Monday of January, 2006 } ~ SEAL
AOPC
31
5-99
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
HCR MANOR CARE,
Plaintiff
P-~Y WINGARD,
MARY ANN WINGARD
Defendants
NO.
CIVIL ACTION: LAW
ENTRY OF APPEARANCE
Please Enter the Appearance of Amy F. Wolfson, Esquire, as the Attorney for the Plaintiff.
Respectfully Submitted,
A~F. Wolfson, l~q~Jire
WOLFSON ~ ASSOCIATES, P.C.
267 E. Market Street
York, Pennsylvania 17403
Telephone No. (717) 846-1252
I.D. # 87062
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
HCR MANOR CARE,
vs NO.
RAY WINGARD,
MARY ANN WINGARD
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: ( ) PLAINTIFF (X) DEFENDANT ( ) GARNISHEE ( ) ADDITIONAL DEFENDANT
YOU ARE HEREBY NOTIFIED THAT THE FOLLOWING ORDER, DECREE OR JUDGMENT HAS BEEN ENTERED
AGAINST YOU ON
IN ACCORDANCE WITH THE PROVISIONS OF PA.R.C.P. 236
( ) DECREE NISI IN EQUITY
( ) FINAL DECREE IN EQUITY
(X) JUDGMENT OF
( ) CONFESSION ( ) VERDICT
(X) DEFAULT ( ) NON-SUIT
( ) NON-PROS ( ) ARBITRATION AWARD
( ) JUDGMENT IS IN THE AMOUNT OF $
PLUS COSTS.
(X) DISTRICT JUSTICE TRANSCRIPT OF JUDGMENT IN CIVIL ACTION IN THE AMOUNT OF
$1,651.52 PLUS COST5 $ 66.50 FOR A TOTAL OF $1,718.02
( ) IF NOT SATISFIED WITHIN SIXTY (60) DAYS, YOUR MOTOR VEHICLE OPERATOR'S LICENSE WILL BE
SUSPENDED BY THE PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
PROTHONOTARY
NAME OF (ATTORNEY/FILING PARTY): WOLFSON ~ ASSOCIATES, P.C.
ADDRESS: 267 EAST MARKET STREET
YORK, PA 17403
TEEEPHONE NUMBER: (717) 846-1252
NOTICE SENT TO:
NAME RAY ~ MARYANN WINGARD
16 TROY CIRCLE
ENOLA, PA. 17025
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 to 3149
HCR Manor Care,
VS.
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
JUDGMENT NO. 02-862 CIVIL
Ray Wingard,
Mary Ann Wingard,
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
(MONEY JUDGMENT)
To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of Cumberland County, Pennsylvania;
(2) against, Ray Wingard & Mary Ann Wingard- 16 Tory Circle, Enola, PA 17025
(3) and against, Allfirst Bank- 812 1/2 W. High St., Carlisle, PA 17013
Defendant(s);
Garnishee(s);
(4) and index this writ
(a) against, Ray Wingard ~ Mary Ann Wingard, Defendant(s) and
(b) against, AIIfirst Bank, Garnishee(si,
as a lis pendens against the real property of the Defendant(s) in the name of the Garnishee(s) as follows:
(Specifically describe property)* , ..
***ADDRESS*** 16 Tory Circle, E~nola, PA 17025
ALL PERSONAL PROPERTY OF ANy NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE
VICINITY OF THE DEFENDANT(S) AD~,RESS AND ALL OTHER PERSONAL PROPERTY WITHIN THE
DOMINION AND CONTROL OF THE DEFENDANT(S) WHEREVER IT IS LOCATED SHALL BE SUBJECT
TO THE LEVY. ALSO: '"
You are directed to attach the property of the Defendant(s) not levied upon in the possession of AIIfirst Bank
812 1/2 W. High St.
Carlisle, PA 17013 Garnishee(s)
All accounts including but not limited to all savings, checking and other accounts, certificates of deposit,
notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes.
Amount due $1,651.52
Interest from February 19, 2002
At an interest rate of 6% per year
To Be Determined
Total $1,651.52 Plus costs & interest
Dated
An~ F. ~'olfso~,-Eso~re
Attorney ID # 87062
267 E. Market Street
York, PA 17403
(717)846-1252
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
HCR Manor Care,
Plaintiff
VS,
Ray Wingard,
Mary Ann Wingard,
Defendants
NO. 02-862 CIVIL
CIVIL ACTION-LAW
TO:
INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION
AIIfirst Bank
812 1/2 W. High St.
Carlisle, PA 17013
PURSUANT TO RULE 3114 OF THE RULES OF CIVIL PROCEDURE, THE
FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION.
GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING
INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING
INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL
OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S).
IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE!
A. 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.
B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of
Execution was issued.
C. "You" means the main office and all branch offices, representatives, employees,
and agents of your organization.
D. By service of the Writ of Execution upon you, all property of the Defendant(s)
subject to attachment which is in your possession, custody or control is attached, including all
property of the Defendant(s) which comes into your possession thereafter.
E. These Interrogatories are considered to be continuing and therefore should be
modified or supplemented as you receive further or additional information.
F. Where exact information cannot be furnished, estimated information is to be
supplied. When an estimate is to be used, it should be identified as such, and an explanation
should be given as to the basis on which the estimate is made, and the reason the exact
information cannot be furnished.
G. Where knowledge or information in possession of a party is requested, such
request includes knowledge of the party's agents, representatives, and attorneys.
PLAINTIFF'S INTERROGATORIES TO GARNISHEE
DEFENDANTS - RAY WINGARD & MARY ANN WINGARD
SS# RAY: 201-16-6417
MARY: 200-24-2194
1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time,
state whether or not the Defendant(s) maintains any checking, savings, lines of credit,
certificate of deposit's or other depository accounts with your institution. If so, state the
identification numbers of those accounts, and the amount or amounts the Defendant(s) has
in each account. If the Defendant(s) maintains any of these jointly with any other person, or
persons, give their name and address.
direct deposit accounts?
lA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above
If yes, please state the identification numbers of those accounts.
2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time,
state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include
the identification number or other designation of the box or boxes. Include a full description
of the contents and also the amount of cash among those contents. If the Defendant(s)
maintains any of these jointly with any other person or persons give their full name and
address.
3. PERSONAL PROPERTY: At the time you were served or at any subsequent time, state
whether or not Defendant(s) owns any personal property that was in your possession and/or
control. If so, include a full description of all personal property giving full value and present
location. State also whether or not there are any encumberances or liens holders, the present
balance of the encumberance. State where and when the encumberances or liens was
recorded. If the Defendant(s) owns any personal property jointly with any person or persons,
give names and address.
4. OTHER ASSETS: At the time you were served or at any subsequent time, did you
know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the
preceding Interrogatories. If so, please set forth all details concerning those asset.
5. PROPERTY: At the time you were served or at any subsequent time, was there in
your possession, custody, or control or in the joining possession, custody, or control of yourself
and one or more other persons any property of any nature owned solely or in part by any
Defendant(s)? If so, please describe for each Defendant each item of property including its
value.
6. REAL PROPERTY: At the time you were served or at any subsequent time, did you hold
legal, or equitable title to any property of any nature owned solely or in part by the
Defendant(s) or in which and Defendant(s) held or claimed any interest? If so, describe for
each Defendant each item of property including its value and the interest held by the
Defendant(s).
7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any
subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an
interest? If so, please describe for each Defendant(s) the nature of the property including its
value and the interest of Defendant(s).
8. TRANSFER OF PROPERTY: At any time before or after you were served, did any
Defendant(s) transfer or deliver any property to you or to any person or place pursuant to your
direction or consent If so, for each Defendant(s) describe the property transferred or delivered
including the dates of delivery or transfer and state the consideration paid.
9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees
charged by you against the Defendant(s) or account(s) of the Defendant(s) for the completion
of this Answer. If yes, outline the exact amount of any fees due and owing to the garnishee
or the attorney for the garnishee for the preparation of the Answer.
WOLFSON & ASSOCIATES, P.C.
Dated:
267 East Market Street
York, PA 17403
(717) 846-1252
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-862 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HCR MANOR CARE, Plaintiff (s)
From RAY WINGARD AND MARY ANN WINGARD, 16 TORY CIRCLE, ENOLA, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL
PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE
VICINITY OF THE DEFENDANT(S) ADDRESS AND ALL OTHER PERSONAL PROPERTY
WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT(S) WHEREVER IT IS
LOCATED SHALL BE SUBJECT TO THE LEVY.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of ALL FIRST BANK, 812 1/2 W HIGH ST., CARLISLE, PA 17013, ALL ACCOUNTS
INCLUDING BUT NOT LIMITED TO ALL SAVINGS CHECKING AND OTHER ACCOUNTS,
CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES,
DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES.
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 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 $1,651.52 L.L. $.50
Interest FROM FEBRUARY 19, 2002 AT AN INTEREST RATE OF 6 % PER YEAR
Atty's Comm % Due Prothy $1.00
Atty Paid $32.25 Other Costs
Plaintiff Paid
Date: MAY 6, 2002
REQUESTING PARTY:
Name AMY F. WOLFSON, ESQUIRE
Address: 267 E. MARKET STREET
YORK, PA 17403
Attorney for: PLAINTIFF
Telephone: 717-846-1252
Supreme Court ID No. 87062
CURTIS IL LONG
Prothonotary, Civil Division
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2002-00862 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
MANORCARE HEALTH SERVICES
VS
WINGARD RAY ET AL
And now CPL. MICHAEL BARRICK
Cumberland County of Pennsylvania,
to law, at 0014:10 Hours, on the
as herein commanded all goods, chattels,
moneys of the within named DEFENDANT
WINGARD RAY
,Sheriff or Deputy Sheriff of
who being duly sworn according
8th day of May , 2002, attached
rights, debts, credits, and
hands, possession, or control of the within named Garnishee
ALLFIRST BANK 8 1/2 W. HIGH ST
, in the
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
RAJ BORGONKAR (FINANCIAL SERVICES REP)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION
and made
the contents there of known to His
Docketing .00 ~
Service .00
Affidavit .00 R. Thomas Kline
Surcharge
Sheriff of Cumberland County
Sworn and subscribed to before me B~
this /7 ~ day of~. / Deputy ~nerlzz ~
onotary ~
SHERIFF'S RETURN -
CASE NO: 2002-00862 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
GARNISHEE
MANORCARE HEALTH SERVICES
VS
WINGARD P~AY ET AL
And now CPL. MICHAEL BARRICK
Cumberland County of Pennsylvania,
to law, at 0014:10 Hours, on the
as herein commanded all goods, chattels,
moneys of the within named DEFENDANT
WINGARD MARY ~
,Sheriff or Deputy Sheriff of
who being duly sworn according
8th day of May , 2002, attached
rights, debts, credits, and
hands, possession, or control of the within named Garnishee
ALLFIRST BANKE 8 1/2 W HIGH ST
, in the
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
RAJ BORGAONKAR (FINANCIAL SERVICES REP.)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to His
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
So anew : .
R. Thomas Kline
Sheriff of Cumberland County
.00
00/00/0000 /
Sworn and subscribed to before me B~~//~~~///)
this /7~ day of~k~7
~ A.D. ~/~ Deputy
P~ofhon~tary
VERIFICATION
I, Joan E. German, verify that I am a Legal Assistant for Allfirst Bank a Maryland state-chartered
commercial bank organized and doing business under the laws of the State of Maryland; that I
make this verification on its behalf, being authorized to do so; that the statements made in the
foregoing Answers to Plaintiff's Inten-ogatories to Garnishee are tree and correct to my personal
knowledge or information and belief. I understand that false statements made herein are made
subject to penalties of 18 Pa.C.S. s4904 relating to unswom falsification to authorities.
Legal Assistant
Allfirst Bank
(410) 244-3803
PLAINTIFF'S INTERROGATORIES TO GARNISHEE
DEFENDANTS - RAY WlNGARD & MARY ANN WINGARD
SS# RAY: 201-16-6417
MARY: 200-24-2'194
1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time,
state whether or not the Defendant(s) maintains any checking, savings, lines of credit,
certificate of deposit's or other depository accounts with your institution. If so, state the
identification numbers of those accounts, and the amount or amounts the Defendant(s) has
in each account. If the Defendant(s) maintains any of these jointly with any other person, or
persons, give their name and address.
Account number 908-4841-1 is maintained jointly by Maryann and Ray Wingard
with Allfirst Rank. The amount of $874.92 is being held in an escrow
acciunt pending further order of the court.
lA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above
direct deposit accounts? If yes, please state the identification numbers of those accounts.
2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time,
state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include
the identification number or other designation of the box or boxes. Include a full description
of the contents and also the amount of cash among those contents. If the Defendant(s)
maintains any of these jointly with any other person or persons give their full name and
address.
NO
3. PERSONAL PROPERTY: At the time you were served or at any subsequent time, state
whether or not Defendant(s) owns any personal property that was in your possession and/or
control. If so, include a full description of all personal property giving full value and present
location. State also whether or not there are any encumberances or liens holders, the present
balance of the encumberance. State where and when the encumberances or liens was
recorded. If the Defendant(s) owns any personal property jointly with any person or persons,
give names and address.
As indicated in answer one.
4. OTHER ASSETS: At the time you were served or at any subsequent time, did you
know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the
preceding Interrogatories. If so, please set forth all details concerning those asset.
5. PROPERTY: At the time you were served or at any subsequent time, was there in
your possession, custody, or control or in the joining possession, custody, or control of yourself
and one or more other persons any property of any nature owned solely or in part by any
Defendant(s)? If so, please describe for each Defendant each item of property including its
value.
As indicated in answer one
6. REAL PROPERTY: At the time you were served or at any subsequent time, did you hold
legal, or equitable title to any property of any nature owned solely or in part by the
Defendant(s) or in which and Defendant(s) he d or claimed any interest? If so, describe for
each Defendant each item of property including its value and the interest held by the
Defendant(s).
NO
7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any
subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an
interest? If so, please describe for each Defendant(s) the nature of the property including its
value and the interest of Defendant(s).
8. TRANSFER OF PROPERTY: At any time before or after you were served, did any
Defendant(s) transfer or deliver any property to you or to any person or place pursuant to your
direction or consent If so, for each Defendant(s) describe the property transferred or delivered
including the dates of delivery or transfer and state the consideration paid.
NO
9. FEES OUTSTANDING TO GARNISHEF' Are there any attorneys fees or processing fees
charged by you against the Defendant(s) or account(s) of the Defendant(s) for the completion
of this Answer. If yes, outline the exact amount of any fees due and owing to the garnishee
or the attorney for the garnishee for the preparation of the Answer.
The amount::of $150.00 has been collected from the customers account to
process this court order.
WOLFSON & ASSOCIATES, P.C.
Attorney I.D. # 87062
267 East Market Street
York, PA 17403
(717) 846-1252
allfirst
10Z-850
Allfirst Bank
P.O. Box 1596
Baltimore, MD 21203
(410)~44-3803
Fax (410)Z44-3817
May 28. 2002
Cumberland County
Office of the Prothonotary.
1 Courthouse Square
Carlisle, PA 17013
Re: HCR Manor Care V Ray and Mary Ann Wingard
Case No.: 02-862 CIVIL
To Whom It May Concern:
Enclosed please find Garnishee's Allfirst Bank, answers to PlaintiWs Interrogatories in
Writ of Execution for the matter referenced above.
CC: Wolfson & Associates PC
CC: Ray and Mary Ann Wingard
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
HCR MANOR CARE,
Plaintiff,
RAY WINGARD,
MARY ANN WINGARD,
Defendants,
NO. 02-862 cIVIL
CIVIL ACTION;LAW
ALLFIRST BANK,
Garnishee,
PRAECIPE TO DISCONTINUE ATTACHMENT E)
TO THE PROTHONOTARY:
Kindly mark the attachment against the Garnishee, Allfirst Ban
payment of your costs only. ,
:ECUTION
k, discontinued, upon
Respectfully submitte~d,
WOLFSON & ASSOCIATES, P.C.
Dated:
12 June 2002
ABly F. Wolfso~, ~s(~uire //
Attorney for plaintiff~ ~"
WOLFSON & ASSOP~IATES, P.C.
267 East Market Street
York, Pennsylvania 1 '403
Telephone No. (717) 46-1252
Attorney I.D. No. 87C i2
R..Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff's Costs:
Docketing $ 18.00
Poundage 17.49
Advertising
Law Library .50
Prothonotary 1.00
Mileage 13.80
Misc.
Surcharge 40.00
Levy 40.00
Post Pone Sale
Garnishee 9.00
1.39.79
Advance Costs: 150.00
Sheriff's Costs:_ 139.79
10.21
Refunded to Arty on
9/17/02~
Sworn and Subscribed to before me
This j,;, ~_ day of
2002 A.D. ~ 1~,.,,
/Ptoth~nbtary
8o Ans~ters:.,
R. Thomas Kline, Sheriff '
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-862 Civil
cOUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HCR MANOR CARE, Plaintiff (s)
From RAY WINGARD AND MARY ANN WINGARD, 16 TORY CIRCLE, ENOLA, PA 17025
(1) You are directed to levy upon the propert~ of the defendant (s)and to sell ALL PERSONAL
PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE
VICINITY OF THE DEFENDANT(S) ADDRESS AND ALL OTHER pERSONAL PROPERTY
WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT(S) WHEREVER IT IS
LOCATED SHALL BE SUBJECT TO THE LEVY.
(2) You are also directed t° attach the pr°petty °f the defendant(s) n°t levied up°n in the p°ssessi°n
of ALL FIRST BANK, 812 1/2 W HIGH ST., CARLISLE, PA 17013, ALL ACCOUNTS
INCLUDING BUT NOT LIMITED TO ALL SAVINGS CHECKING AND OTHER ACCOUNTS,
CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES,
DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES.
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 of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If propertyof the defendant(s) n°t levied up°n an subject t° attachment is f°und in the p°ssessi°n
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.
AmountDue $1,651.52 L.L. $.50
Interest FROM FEBRUARY 19, 2002 AT AN INTEREST RATE OF 6 % PER YEAR
Atty's Corem % Due Prothy $1.00
Other Costs
Arty Paid $32.25
Plaintif~ Paid
Date: MAY 6, 2002
KEQUESTING PARTY:
Name AMY F. WOLFSON, ESQUIRE
Address: 267 E. MARKET STREET
YORK, PA 17403
Attorney for: PLAINTIFF
Telephone: 717-846-1252
Supreme Court ID No. 87062
CURTIS R. LONG
Prothonotary, Civil Division
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
HCR MANOR CARE,
Plaintiff
VS.
RAY WINGARD,
MARY ANN WINGARD
Defendant(s)
NO. 02-862
CIVIL ACTION-LAW
TO:
INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION
ALLFIRST BANK
812.5 WEST HIGH STREET
CARLISLE, PA 17013
PURSUANT TO RULE 3114 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING
INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY
REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND
FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE
CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED
DEBTOR(S).
IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE!
A. 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.
B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of
Execution was issued.
C. "You" means the main office and all branch offices, representatives, employees, and agents
of your organization.
D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to
attachment which is in your possession, custody or control is attached, including all property of the
Defendant(s) which comes into your possession thereafter.
E. These Interrogatories are considered to be continuing and therefore should be modified or
supplemented as you receive further or additional information.
F. Where exact information cannot be furnished, estimated information is to be supplied.
When an estimate is to be used, it should be identified as such, and an explanation should be given
as to the basis on which the estimate is made, and the reason the exact information cannot be
furnished.
G. Where knowledge or information in possession of a party is requested, such request
includes knowledge of the party's agents, representatives, and attorneys.
SS# 201-16-6417
PLAINTIFF'S INTERROGATORIES TO GARNISHEE
DEFENDANT(S) - RAY WINGARD,
MARY ANN WlNGARD
SS# 201-16-6417 & 200-24-2194
1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state
whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of
deposit's or other depository accounts with your institution. If so, state the identification numbers of
those accounts, and the amount or amounts the Defendant(s) has//,j~ .~ account. If the
Defendant(s) maintains any of these jointly with any other person, or p_ers~,~-g~.~ir name and
address.~ O0n ~ ~;~
lA. DIRECT DEPOSIT ACCOUNTS. Are any of the accounts you have listed above direct
deposit accounts? If yes, please state the identification numbers of those accounts.
,'9O
2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state
whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the
identification number or other designation of the boxor boxes. Include a full description of the contents
and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly
with any other person or persons give their full name and address.
3. PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether
or not Defendant(s) owns any personal property that was in your possession and/or control. If so,
include a full description of all personal property giving full value and present location. State also
whether or not there are any encumbrances or liens holders, the present balance of the encumbrance.
State where and when the encumbrances or liens was recorded. If the Defendant(s) owns any
personal property jointly with any person or persons, give names and address.
4. OTHER ASSETS: At the time you were served or at any subsequent time, did you
know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the
preceding Interrogatories. If so, please set forth all details concerning those asset.
5. PROPERTY: At the time you were served or at any subsequent time, was there in
your possession, custody, or control or in the joining possession, custody, or control of
yourself and one or more other persons any property of any nature owned solely or in part
by any Defendant(s)? If so, please describe for each Defendant each item of property
including its value.
6. REAL PROPERTY: At the time you were served or at any subsequent time, did you
hold legal, or equitable title to any property of any nature owned solely or in part by the
Defendant(s) or in which and Defendant(s) held or claimed any interest? If so, describe for
each Defendant each item of property including its value and the interest held by the
Defendant(s). .,7~
7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any
subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an
interest? If so, please describe for each Defendant(s) the nature of the property including its
value and the interest of Defendant(s).
8. TRANSFER OF PROPERTY: At any time before or after you were served, did any
Defendant(s) transfer or deliver any property to you or to any person or place pursuant to
your direction or consent If so, for each Defendant(s) describe the property transferred or
delivered including the dates of delivery or transfer and state the consideration paid.
9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees
charged by you against the Defendant(s) or account(s) of the Defendant(s) for the completion
of this Answer. If yes, outline the exact amount of any fees due and owing to the garnishee
or the attorney for the garnishee for the preparation of the Answer.
WOLFSON & ASSOCIATES, P.C.
Dated: July 14, 2003
Amy F. ~¢vVolf~n, Esq~e~
Attorney I.Df # 8706~/
267 East Market StrUt
York, PA 17403
(717) 846-1252
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 to 3149
HCR MANOR CARE,
Plaintiff
VS.
RAY WINGARD,
MARY ANN WINGARD
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
JUDGMENT NO. 02-862
PRAECIPE FOR WRIT OF EXECUTION
(MONEY JUDGMENT)
To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) against, RAY WINGARD, MARY ANN WINGARD, 16 TROY CIR, ENOLA PA 17025, Defendant(s);
(3) and against, ALLFIRST BANK, 812.5 WEST HIGH STREET, CARLISLE, PA 17013 Garnishee(s);
(4) and index this writ
(a) against, RAY WINGARD, MARY ANN WlNGARD, Defendant(s) and
(b) against, ALLFIRST BANK, 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) .... GARNISH ONLY***
You are directed to attach the property of the Defendant(s) not levied upon in the possession of
ALLFIRST BANK
812.5 WEST HIGH STREET
CARLISLE, PA 17013
Garnishee(s)
All accounts including but not limited to all savings, checking and other accounts, certificates of deposit,
notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes.
Amount due
Interest from February 19, 2002
At an interest rate of 6% per year
Dated July 14, 2003
$ $1,718.02
To Be Determined
Total $ $1,718.02 Plus costs & interest
Amy F/'W olfsc~./,,,E s q u i re
Attorney ID # 87062
267 E. Market Street
York, PA 17403
(717)846-1252
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-862 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HCR MANOR CARE, Plaintiff (s)
From RAY V~INGARD AND MARY ANN WINGARD, 16 TROY CIR, ENOLA, PA 17025
(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 ALL FIRST BANK, 812.5 WEST HIGH STREET, CARLISLE, PA 17013 ~ ALL ACCOUNTS
INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS,
CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES,
DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES.
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(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 &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 $1,718.02 L.L.
Interest FROM 2/19/02 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm % Due Prothy $1.00
Atty Paid $189.54 Other Costs
Plaintiff Paid
Date: JULY 18, 2003
(Seal)
REQUESTING PARTY:
Name AMY F. WOLFSON, ESQUIRE
Address: 267 E. MARKET STREET
YORK, PA 17403
Attorney for: PLAINTIFF
Telephone: 717-846-1252
Supreme Court 1D No. 87062
CURTIS R. LONG
By:
Deputy
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2002-00862 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
MANORCARE HEALTH SERVICES
VS
WINGARD RAY ET AL
And now HAROLD WEARY ,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0013:26 Hours, on the 24th day of July , 2003, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
WINGARD RAY , in the
hands, possession, or control of the within named Garnishee
ALLFIRST BANK 8 1/2 WEST HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
KATHY ZENGERK (EMPLOYEE IN CHARGE~
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION
and made
the contents there of known to Her .
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
.00
So answers-
R. Thomas Kline
Sheriff of Cumberland County
00/00/0000
Sworn and subscribed to before me
this y~ day of
~_~ A.D. 7
Prothf}notary / ' '
By
Deputy ShY'ri f f
SHERIFF'S RETURN -
CASE NO: 2002-00862 P
COMMON-WEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
GARNISHEE
MANORCARE HEALTH SERVICES
VS
WINGARD RAY ET AL
And now HAROLD WEARY ,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0013:26 Hours, on the 24th day of July , 2003, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDAi~T ,
WINGARD MARY ~2%1N in the
hands, possession, or control of the within named Garnishee
ALLFIRST BANK 8 1/2 WEST HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
KATHY ZENGERK (EMPLOYEE IN CHARGE)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION
and made
the contents there of known to Her
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
.00
answ~
Thomas
Sheriff of Cumberland County
oo/oo/oooo
Sworn and subscribed to before me
this ~ day of O~/~
~ A. D.
p~r ~t o~no t~ry~tZ~, ~
By
uny Sh~ff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
HCR MANOR CARE,
Plaintiff,
V.
RAY WlNGARD
MARY ANN WINGARD,
Defendant,
V.
ALLFIRST BANK,
Garnishee,
NO. 02-862
Garnishee:
AIIfirst Bank
812.5 West High Street
Carlisle, PA 17013
PRAECIPE FOR JUDGMENT UPON ADMISSION
To the Prothonotary:
Please enter judgment in favor of the Plaintiff and against the Garnishee, AIIfirst
Bank, in the amount of $ 848.63, as admitted in the answer to interrogatories to be in
the Garnishee's possession. The amount of the judgment together with interest and
costs of the Plaintiff against the Defendant is $848.63.
Dated: August 8, 2003
WOLFSON & ASSOCIATES, P.C.
267 East Market Street
York, PA 17403-2000
Telephone: (717) 846-1252
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
HCR MANOR CARE,
Plaintiff,
V.
RAY WlNGARD
MARY ANN WINGARD,
ALLFIRST BANK,
Defendant,
Garnishee,
NO. 02-862
NOTICE OF FILING JUDGMENT
( x ) Notice is hereby given that a judgment in the above-captioned matter has been
entered against you in the amount of $848.63.
( )
A copy of all documents filed with the Prothonotary in support of the within
judgment is/are enclosed.
Protl~onotary Civil ~
If you have any questions regarding this Notice, pl~se co~tact th~filing pady.
'A~y ~ Wolfs~, Esquire
WOLFSON ~ASSOClATES, P.C.
267 East Market Street
York, PA 17403-2000
(717) 846-1252
(This Notice is given in accordance with Pa.R.C.P. 236.)
NOTICE SENT TO:
AIIfirst Bank Ray Wingard / Mary Ann Wingard
812.5 West High Street 16 Troy Circle
Carlisle, PA 17013 Enola, PA 17025
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
HCR MANOR CARE,
Plaintiff
VS.
RAY WINGARD
MARY ANN WlNGARD,
Defendant(s)
NO. 02-862
and
ALLFIRST BANK,
Garnishee
PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE
TO THE PROTHONOTARY:
Kindly mark the judgment entered against the Garnishee, AIIfirst Bank, in the
above matter, satisfied upon payment of your costs only.
Arrf'y F. WCf~on, Esquj~J¢'~ %.
Attorne¢)r Plaintif~
267 East Market ~eet
York, PA 17403
(717) 846-1252
Attorney I.D.¢ 87062
Dated: August 14, 2003
R. Thomas Kline, Sheriff, who being duly swom according to law, states
this writ is returned STAYED.
Sheriff's Costs:
Docketing 18.00
Poundage 1.63
Advertising
Law Library
Prothonotary 1.00
Mileage 3.45
Surcharge 30.00
Levy 20.00
Post Pone Sale
Garnishee ~ 9.00
TOTAL $ 83.08
Advance Costs: 150.00
Sheriff's Costs: 83,08
$ 66.92
Refunded to Atty on 08/22/03
Sworn and Subscribed to before me
This ,~'~2~ day of
2003 ^.D.
l~ro{honotary
So Answers;
R. Thomas Kline, Sheriff
y Claudia A. Brewbaker