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Home My WebLink About13-6989 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW c� C; PETERSON TRANSPORT, Plaintiff No. VS. N: SCOTT E. CURTIS, U CURTIS LINDEN WAYNE, CURTIS GANG, INC. AND DOES 1 -10 o Defendants 9 o PRAECIPE FOR JUDGMENT J ` TO THE CLERK OF JUDICIAL RECORDS OF SAID COURT: Enter Judgment in favor of Plaintiff and against the Defendant, Scott E. Curtis, for want of an exemplified copy of the Default Judgment entered in the Superior Court for the State of California County of Los Angeles as attached) (X) Assess damages as follows: Debt $152,947.76 P.✓ Interest from 11/28/12 to 11/21/2012-@ — 41.90 per diem $ 15,000.207 �"` Attorney's Fee $ Costs $ 33.50 TOTAL $167,981.46 ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint ( X ) Pursuant to Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of record. O Pursuant to Pa. R.C.P. 237.1, 1 certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of filing of this praecipe and a copy of the notice is attac Date: �� Signature: ` Print Name: ANNE K. MANLEY EZQUIRE Attorney for: Plaintiff Address: 101 Larry Holmes Drive, Suite 202 Easton, PA 18042 X 33,50 Telephone: (610) 820 -5450 Supreme Court ID No: 51857 u(4 oa ' tQcl%o�q NOW,_��W- 2013, JUDGMENT ENT D ABOV Prot /C er , C LV ivision by: Deputy EXEMPLIFICATION CASE TITLE. CASE NUMBER c v PETERSON TRANSPORT VS SCOTT E. CURTIS, ET AL LC096310 SUPERIOR COURT FOR THE I, SHERRI R. CARTER, Executive Officer /Clerk of the Superior Court of STATE OF CALIFORNIA, the State of California for the County of Los Angeles do hereby certify COUNTY OF LOS ANGELES and attest that I am the custodian of records of the said Court, and that the foregoing document is a full, true and correct copy of the original Seal of the Superior Court, County of Los Angeles JUDGMENT FILED ON NOVEMBER 28, 2012 on file or of record in my office, and that I have carefully compared the same with the original. Executed and Seal of said Court affixed in the County of Los Angeles, California on NOVEMBER 6, 2013 r (DATE) EX TIVE OFFICER/CLERK OF THE SUPERIOR COURT OF An original seal is embossed within this area CALIFORNIA FOR THE COUNTY OF LOS ANGELES and may or may not be affixed with a gold seal, SUPERIOR COURT FOR THE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I, DAVID S. WESLEY, Presiding Judge of the Superior Court of the State of California for the County of Los Angeles do hereby certify that SHERRI R. CARTER is Executive Officer /Clerk of the Superior Court of the State of California for the County of Los Angeles (which is a court of record having by law a seal); that the signature to the foregoing certificate and attestation is the genuine signature of the said SHERRI R. CARTER as such officer, that the seal annexed thereto is the seal of said Superior Court, that said SHERRI R. CARTER as such officer is the legal custodian of the original records or documents described and referred to in the foregoing certificate; is the proper officer having the authority to execute said certificate and attestation, and that said attestation is in due and proper form according to the laws of the State of California. I further certify that my oath of office as a Judge of the Superior Court of California and handwritten signature, or a true and correct copy thereof, is on file or of record with the Secretary of State for the State of California for the purposes of authentication. Executed at Los Angeles, California on NOVEMBER 6,, 2013 (DATE) PRESIDING JUDGE OF THE SUPERIOR COURT OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES LACIV 111 (Rev. 9/13) LASC Approved 04/04 EXEMPLIFICATION For Optional Use i 100 ATTORNEY 02 PARTY WITHOUT ATTORNEY (Name, sta number, and address): FOR COURT USE ONLY S.r.ai Oved Shai Oved, CBN 185526 C — The Law Offices of Shai Oved (Ceti 7445 Topanga Cyn Blvd, Suite 220 Canoga Park, California 91303 TELEPHONE NO.: (8 18) 992 FAX NO. (Optional): f a X 992-6511 EMAIL ADDRESS (Optional): ssoesq @aol.com ATTORNEY FOR (lVame): Peterson Transport SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles STREETADDRESS: 6230 Sylmar Ave. OR�� MAILING ADDRESS: 6230 Sylmar Ave. N CITY AND ZIP CODE: ajar] Nuy s, CA 91401 J Q�l1I 4 C � BRANCH NAME: Northwest Q PLAINTIFF: Peterson Transport � n �RI�H, DEFENDANT: Scott E. Curtis, et . al . p'�PWV JUDGMENT CASE NUMBER: [� By Clerk x0 By Default After Court Trial LC096310 Unl . Dpt [Xil By Court On Stipulation Defendant Did Not Appear at Trial 1, 0 BY DEFAULT JUDGMENT a. Defendant was properly served with a copy of the summons and complaint. b. Defendant failed to answer the complaint or appear and defend the action within the time allowed by law. c. Defendant's default was entered by the clerk upon plaintiffs application. d. = Clerk's Judgment (Code Civ. Proc., § 585(a)). Defendant was sued only on a contract or judgment of a court of this state for the recovery of money. e. FT] Court Judgment (Code Civ. Proc., § 585(b)). The court considered (1) plaintiffs testimony and other evidence. (2) plaintiffs written declaration (Code Civ. Proc., § 585(d)). 2. ON STIPULATION a. Plaintiff and defendant agreed (stipulated) that a judgment be entered in this case. The court approved the stipulated judgment and b. the signed written stipulation was filed in the case. c. the stipulation was stated in open court = the stipulation was stated on the record. 3. 0 AFTER COURT TRIAL. The jury was waived. The court considered the evidence. a. The case was tried on (date and time): before (name of judicial officer): b. Appearances by: Plaintiff (name each): Plaintiffs attorney (name each): ( ( (2) (2) 0 Continued on Attachment 3b. Defendant (name each): Defendant's attorney (name each): ( ( ( ( Continued on Attachment 3b. c. 0 Defendant did not appear at trial. Defendant was properly served with notice of trial. d. A statement of decision (Code Civ. Proc., § 632) = was not was requested. ^' Page 1 of 2 Farm Approved for Optional Use JUDGMENT { . al Code of Civil Procedure, §§ 585, 664.6 Judicial Council of California SO t�I JUD -100 (New January 1, 20021 1 n LASC -Case Summary Page 1 of 4 Case Summary Case Number: LCO96310 PETERSON TRANSPORT VS CSCOTT E. CURTIS ET AL Filing Date: 02/08/2012 Case Type: Othr Breach Contr /Warr -not f=raud (General Jurisdiction) Status: Judgment by Court 11/29/2012 Future Hearings 12/16/2013 at 08:30 am in department T at 6230 Sylmar Ave., Van Nuys, CA 91401 Examination- Judgment Debtor(TO: SCOTT E. CURTIS) Documents Filed I Procoeding Information Parties CURTIS GANG INC. - Defendant CURTIS LINDEN WAYNE - Defendant CURTIS SCOTT E... Defendant DOES 1 -10 - Defendant OVER SHAT SHAUL - Attorney - Plaintiff PETERSON TRANSPORT - Plaintiff C ase Intorrnaticn (Pa;a' !i1ors °r,?stitn Procee,:iing Information Documents Filed (Filing dates listed in descending order) Click on any of the below link(s) to see documents filed on or before the date indicated: 02i0812012 09/25/2013 Writ - Execution (WRIT ISSUED TO LA) Filed by Attorney - Plaintiff 09/16/2013 Application- Appearance and Exam & Filed by Attorney - Plaintiff 06/05/2013 Application- Appearance and Exam & (as to Scott Curtis } Filed by Attorney - Plaintiff 03/07/2013 Abstract (ABSTRACT ISSUED } Filed by Attorney - Plaintiff 03/07/2013 Writ - Execution (WRIT ISSUED TO LA) Filed by Attorney - Plaintiff http:// courtnet/ intemet/ civilcasesummarynet /ui /popupCaseSummary.aspx 11/6/2013 LASC - Case Summary Page 2 of 4 S 01/14/2013 Miscellaneous (REJECTION: WRIT & ABSTRACT SUB. 11/29/12, PLEASE RESUBMIT ABSTRACT & WRIT WITHOUT THE NAMES YOU CROSSED OUT. IF THERE IS AN ERROR THEN THE CLERK IN SUPERIOR COURT MUST INITIAL THE ERROR /CORRECTIONS) Filed by Clerk 12/03/2012 Application- Appearance and Exam & Filed by Attorney - Plaintiff 11/2812012 Judgment Filed by Attorney - Plaintiff 10/29/2012 Request - Dismissal- Partial (without prejudice - complaint as to doe defendants only } Filed by Attorney - Plaintiff 10129/2012 Request- Judicial Notice (RE: DECLARATION RE: NONMILITARY STATUS IN SUPPORT OF DEFAULT JUDGMENT FOLLOWING TESTIMONY ON DEFAULT PROVE-UP) Filed by Attorney - Plaintiff 09107/2012 Proof of Service - Summons & Cam Filed by Attorney - Plaintiff 09/07/2012 Default Entered (DEFAULT ENTERED - AS TO SCOTT E. CURTIS, CURTIS GANG INC. AND LINDEN WAYNE CURTIS) Filed by Attorney - Plaintiff 08115/2012 Proof of Service- Summons & Cam Filed by Attorney - Plaintiff 07/18/2012 Notice -Case Management Conference (AND HEARING ON OSC RE: PROOF OF SERVICE OF AMENDED COMPLAINT) Filed by Attorney - Plaintiff 0711612012 Complaint- Amended (1st) Filed by Attorney - Plaintiff 07/1612012 Summons- Issued (ON FIRST AMENDED COMPLAINT) Filed by Attorney- Plaintiff 05/0312012 Statement -Case Management Filed by Attorney - Plaintiff 04/25/2012 Proof of Service - Amended (AS TO SCOTT E. CURTIS SERVED BY MAIL: 2/13/2012 } Filed by Attorney - Plaintiff 04/2512012 Default Entered (DEFAULT ENTERED - AS TO SCOTT E. CURTIS) Filed by Attorney - Plaintiff 04/23/2012 Notice (OF CASE REASSIGNMENT FOR ALL PURPOSES TO THE HONARABLE MARIA STRATTON DEPT. NWT) Filed by Attorney- Plaintiff 04/20/2012 Notice - Reassignment and Order Filed by Clerk http: / /courtnet/ intemet/ civilcasesummarynet /ui /popupCaseSummary.aspx 11/6/2013 LASC -Case Summary Page 3 of 4 04/1912012 Request -Enter Default (DEFAULT REJECTED - AMENDED PROOF OF SERVICE NOT SIGNED) Filed by Attorney - Plaintiff 04/19/2012 Proof of Service- Amended (AS TO SCOTT E. CURTIS MAILING: 02/13/2012 } Filed by Attorney - Plaintiff 04/12/2012 Request -Enter Default (DEFAULT REJECTED - NO CERTIFIED MAIL RECEIPT FILED) Filed by Attorney - Plaintiff 02/14/2012 Notice - Continuance Filed by Attorney - Plaintiff 02/10/2012 Notice (of Errata Re: Amount of Damages Sought) Filed by Attorney - Plaintiff 02/10/2012 Proof of Service- Summons & Com (Scott E. Curtis, Notice and Adknow€edgment of Receipt 2/9/12 } Filed by Attorney - Plaintiff Click on any of the below link(s) to see documents filed on or before the data indicated: TOP 02/08/2012 02/08/2012 Summons - Issued Filed by Attorney- Plaintiff 02/08/2012 Notice -Case Management Conference 02108/2012 Complaint Click on any of the below link(s) to see documents filed on or before the date indicated: TOP 02M312012 Case Information I Party Information I Documents Filed Proceedings Held (Proceeding dates listed in descending order) 09/16/2013 at 08:30 am in Department NWT, Maria E. Stratton, Presiding Examination - Judgment Debtor (as to Scott E. Curtis) - Off calendar 02/19/2013 at 08:30 am in Department NWT, Maria E. Stratton, Presiding Exam ination- Judgrrlent Debtor - Off calendar 11/29/2012 at 08:30 am in Department NWT, Maria E. Stratton, Presiding OSC- Dismissal - Judgment- Granted 10/25/2012 at 08:30 am in Department NWT, Maria E. Stratton, Presiding Non - Calendar Matter - Order -Court 10119/2012 at 01:30 pm in Department NWT, Maria E. Stratton, Presiding Hearing- Default Prove -up (SET FOR PROVE -UP RE: FRAUD) - Submitted 09/20/2012 at 08:30 am in Department NWT, Maria E. Stratton, Presiding Conference -Case Management - Continued http:// courtnet/ intemet/ civilcasesummarynet /ui /popupCaseSummary.aspx 11/6/2013 LASC -Case Summary Page 4 of 4 0711712012 at 08:30 am in Department NWT, Maria E. Stratton, Presiding 0SC- Failure to File Default Judg - Held 05/21/2012 at 09:00 am in Department NWY, Maria E. Stratton, Presiding Conference - Initial Status - Held-Order made Case Inforrnaflon I Party Inform&Uor, C Docunne €Its Filed I Proceeding Infor mation http:// courtnet/ intemet/ civilcasesummarynet /ui /popupCaseSummary.aspx 11/6/2013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW PETERSON TRANSPORT, Plaintiff No. vs. SCOTT E. CURTIS, CURTIS LINDEN WAYNE, CURTIS GANG, INC. AND DOES 1-10 Defendants AFFIDAVIT IN SUPPORT OF PRAECIPE TO TRANSFER JUDGMENT, CERTIFICATION OF ADDRESSES AND VALIDITY AND ENFORCEABILITY 1, Anne K. Manley, Esquire, being duly sworn according to law, depose and state: 1. I am an attorney in good standing, admitted to practice in the Courts of this Commonwealth, and am counsel of record for the Plaintiff - judgment creditor, Peterson Transport, in the above captioned matter. 2. 1 am authorized to make this Affidavit on behalf of the Plaintiff. 3. The address of the Plaintiff is 16854 Severo Place, Encino, CA 91436. The address for the Plaintiff's California attorney is Shai Oved, Esquire, the Law offices of Shai Oved, 7445 Topanga Cyn Blvd., Suite 220, Canoga, Park, California, 91303. 4. The last known address of the Defendant, Scott E. Curtis, is 3237 Hiawatha Drive, Dayton, Ohio 45144. 5. The judgment reflected by Case No. LC096310 in the Superior Court for the State of California, County of Los Angeles, in the amount of $144,536.76 plus prejudgment interest at a rate of 10% per annum in the amount of $7,787.20 plus costs in the amount of $623.80 and postjudgment interest at a rate of 10% per annum from the date of this Judgment until paid. 6. 1 hereby certify that the foreign judgment is valid, enforceable and unsatisfied and is final, has not been modified, altered, amended, set aside or vacated, and that the enforcement of such judgment has not been stayed or suspended. GROSS MCGINLEY, LLP Subscribed and sworn to before me this 22rv ay o vember, 2013 BY: ANNE K. MANLE , ESQUIRE Attorney I.D. 51857 Notary Public 101 Larry Holmes Drive, Suite 202 COMMONWEALTH Of PBMMN#A Easton, PA 18042 NOTARIAL (610) 820 -5450 DONNA M OARTOUZOS NoWy PuMic EASTON CITY, NORTHAMPTON COU MTV Mr CO"Islon Explrn Stp 10, 2017 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW PETERSON TRANSPORT, PLAINTIFF Confessed Judgment x Other n (� Q vs. lS/ / Q File No. — LW SCOTT E. CURTIS, Debt $ 1,5-x �1 X17, 7G'* CURTIS LINDEN WAYNE, CURTIS GANG, INC. AND DOES 1 -10 Interest from /21/20134 -n^ DEFENDANTS At 41 er diem $ (�tQ ot er vs. Atty's Co m. $ y ( O ►� c:. THOMAS C. SUNDAY, INC. Costs $ 4� 00� Al egi GARNISHEE, Address: PO Box 217 24 E. Main Street - G New Kingstown, PA 17072 - ca- - _. T-" n -a- r- TO THE PROTHONOTARY OF THE SAID COURT: C -- The undersigned hereby certifies that the below does not arise out of a retail in tgllpea t sak' contract, or account based on a confession of judgment, but if it does, it is based on the ia' p{priate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described personal property of the Defendant: PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above -named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list): Any and all payments and monies of whatsoever kind and nature due and owing to Scott E. Curtis w ho resides at 3237 Hiawatha Drive, Dayton, Ohio 45144, including but no limited to commissions, advances, accounts receivable, monies due for any services as a subc or independent contractor and any other monies due and owing to Scott E. Curtis and all other property of the defendant(s) in the possession, custody or control of the said gamishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. GROSS McGINLEY, LLP BY: Date: ANNE EY, ESQ RE, I.D. #51857 Attorney for Plaintiff owl 11 101 Larry Holmes Drive, Suite 202 o�� a Easton, PA 18042 O W.(610) 820 -5450 3� ��. ao cc� aela�l�al WRIT OF EXECUTION and /or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13 -6989 Civil COUNTY OF CUMBERLAND) CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PETERSON TRANSPORT Plaintiff (s) From SCOTT E. CURTIS, CURTIS LINDEN WAYNE, CURTIS GANG, INC. AND DOES 1 -10, 3237 HIAWATHA DRIVE, DAYTON Ohio 45144 (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 GARNISHEE(S) as follows: THOMAS C. SUNDAY, INC., P.O. BOX 217,24 E. MAIN STREET, NEW KINGSTOWN, PA 17072, ANY AND ALL PAYMENTS AND MONIES OF WHATSOEVER KIND AND NATURE DUE AND OWING TO SCOTT E. CURTIS WHO RESIDES AT 3237 HIAWATHA DRIVE, DAYTON, OHIO, 45144, INCLUDING BUT NOT LIMITED TO COMMISSIONS, ADVANCES, ACCOUNTS RECEIVABLE, MONIES DUE FOR ANY SERVICES AS A SUBCONTRACTOR OR INDEPENDENT CONTRACTOR AND ANY OTHER MONIES DUE AND OWING TO SCOTT E. CURTIS. 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 $152,947.76 Plaintiff Paid $ Interest FROM 11/28/12 AT $41.90 PER DIEM Attorney's Comm. % Law Library $ .50 Attorney Paid $ 62.50 Due Prothonotary $2.25 Other Costs $ Date: 11/25/13 David D. Buell, Prothonotary By: Y, )&4 Deputy REQUESTING PARTY: Name: ANNE K. MANLEY, ESQ Address: GROSS MCGINLEY, LLP, 101 LARRY HOLMES DRIVE, SUITE 202, EASTON, PA 18042 Attorney for: PLAINTIFF Telephone: 610- 820 -5450 Supreme Court ID No. 51857 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?1-7 t; Jody S Smith Chief Deputy , � � ` ' �, Richard W Stewart E1P�It RL ,�d c -' Cr Solicitor `Py, EN S YLVA#�IJ�a Peterson Transport vs. Case Number Scott E Curtis(et al.) 2013-6989 SHERIFF'S RETURN OF SERVICE 12/03/2013 02:15 PM - Dennis Fry, 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, Thomas C. Sunday, Inc., 24 E Main Street, Silver Spring Township, New Kingstown, PA 17072, Cumberland County, by handing to Thomas C. Sunday, owner, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to him. The writ of execution and notice to defendants was mailed on December 5, 2013 to: 1 - Scott E. Curtis at 3237 Hiawatha Drive, Dayton, OH 45144 2-Curtis Linden Wayne at 3237 Hiawatha Drive, Dayton, OH 45144 3-Curtis Gan, Inc., at 3237 Hiawatha Drive, Dayton, OH 45144 4- Does 1-10, at 3237 Hiawatha Drive, Dayton, OH 45144 DE■ 1IS FRY, I' 'U SO ANSWERS, December 05, 2013 RONR ANDERSON, SHERIFF • t'.c�u'0,hart.,Te oseft ;..,,. JP PETERSON TRANSPORT, : IN THE COURT OF COMMON PLEAS OF Plaintiff vs. : CUMBERLAND COUNTY, PENNSYLVANIA SCOTT E. CURTIS CURTIS LINDEN WAYNE, �:.) r-- CURTIS GANG, INC. AND DOES 1-10 Defendants rn J3-1oQ84 r� vs. THOMAS C. SUNDAY, INC. : NO.-29-F3=6$-89— 1 ' Garnishee : CIVIL ACTION - LAW kEi PRAECIPE - ' TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the attached Answers to Interrogatories of Garnishee,Thomas C. Sunday,Inc., as part of the record in the above matter. MARTSON LAW OFFICES By: No V. Otto III, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Supreme Court No. 27763 Dated: December 11, 2013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION -LAW PETERSON TRANSPORT, _ PLAINTIFF Confessed Judgment x Other VS. File No. SCOTT E. CURTIS, CURTIS LINDEN WAYNE, Debt $167,091.46 CURTIS GANG,INC.AND DOES 1-10 Interest from 11/21/2013 DEFENDANTS At 41.90 per diem $ vs. Atty's Comm. $ THOMAS C. SUNDAY, INC. Costs $ 29.00 GARNISHEE INTERROGATORIES TO THE ABOVE-NAMED GARNISHEE TO: THOMAS C. SUNDAY, INC. PO BOX 217 24 E. MAIN STREET NEW KINGSTOWN, PA 17072 You are required to file answers to the following interrogatories within twenty(20) day after service upon you. Failure to do so may result in Judgment against you: 1 . At the time you were served or at any subsequent time did you owe the Defendant, Scott E. Curtis, any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? IV C3, 2. 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 property of any nature owned solely or in part by the Defendants, Scott E. Curtis? Ai 0 3. 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, cott E. Curtis, or in which the Defendant, Scott E. Curtis, held or claimed any interest? 6 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant, Scott E. Curtis, had interest? 1v p • 5. At any time before or after you were served did the Defendant, Scott E. Curtis, transfer or deliver any money or property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefore? N ' 6. At any time after you were served did you pay, transfer, or deliver any money or property to the Defendant, Scott E. Curtis, or to any person or place pursuant to her direction or otherwise discharge any claim of the Defendant, Scott E. Curtis, against you? f Q 7. Does the Defendant, Scott E. Curtis, have any safe deposit boxes or bank accounts of any kind whatsoever with you? If so,please provide the account number,the type of account and the amount in each account. 1\) 0 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption,the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. r f o 9. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. pU/ft kt GROSS McGINLEY, LLP BY: Date: t ANNE K. MAN EY, ESQUIRE, I.D. #51857 Attorney for Plaintiff 101 Larry Holmes Drive, Suite 202 Easton, PA 18042 (610)820-5450 TO THE CLERK OF COURTS: Enter Rule on said Garnishee to answer the within Interrogatories In 20 days. By: Anne K. anley, Esquire Attorney for Plaintiff TO THE GARNISHEE NAMED: NOTICE Interrogatories of which the foregoing is a copy, have been filed in the within-stated case, and a Rule has been entered upon you in the said case to answer the same within twenty (20) days. Prothonotary BY: Deputy VERIFICATION 1, 76-14(4-S (7, --->e) /1 ei , hereby state and verify that I am of THOMAS C. SUNDAY, INC., that I am authorized to take this Verification on behalf of said THOMAS C. SUNDAY, INC. and that the Answers set forth in the foregoing Answers to Plaintiff's Interrogatories are true and correct to the best of my knowledge, information and belief I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S.A. §4904,RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. THOMAS C. SUNDAY, INC. DATE: /21 - /5 BY: CERTIFICATE OF SERVICE I,Victoria L.Otto,an authorized agent for Martson Deardorff Williams Otto Gilroy&Faller, hereby certify that a copy of the foregoing Praecipe and Answers to Interrogatories of the Garnishee, Thomas C. Sunday,Inc.,were served this date by depositing same in the Post Office at Carlisle,PA, first class mail,postage prepaid, addressed as follows: Anne K. Manley, Esquire Attorney for Plaintiff 101 Larry Holmes Drive, Suite 202 Easton, PA 18042 MARTSON LAW OFFICES By CGGL�� Victoria L. Otto Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: /Z_ /Z_/3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff at Jody S Smith 4_00.:t"- Ciura irri4 Chief Deputy Richard W Stewart Solicitor oFF1rE OF THE SHERIFF THa=�P`, O1 HONU JUL. —3 AM: U PE NN NSYLVAN AY Peterson Transport vs. Scott E Curtis (et al.) Case Number 2013-6989 SHERIFF'S RETURN OF SERVICE 12/03/2013 02:15 PM - Dennis Fry, 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, Thomas C. Sunday, Inc., 24 E Main Street, Silver Spring Township, New Kingstown, PA 17072, Cumberland County, by handing to Thomas C. Sunday, owner, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to him. The writ of execution and notice to defendants was mailed on December 5, 2013 to: 1 - Scott E. Curtis at 3237 Hiawatha Drive, Dayton, OH 45144 2 - Curtis Linden Wayne at 3237 Hiawatha Drive, Dayton, OH 45144 3 - Curtis Gan, Inc., at 3237 Hiawatha Drive, Dayton, OH 45144 4 - Does 1-10, at 3237 Hiawatha Drive, Dayton, OH 45144 07/02/2014 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: $123.03 SO ANSWERS, July 02, 2014 RONNY R ANDERSON, SHERIFF (c) CnuntySuite Sheriff, Teleosoft. Inc. el, Co e,14 r767q or304'0