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Home My WebLink About05-0538 Gates. Halbruner & Hatch, P.C. By: Albert N. Peterlin, Esquire PA Attorney ID No. 84180 1013 Mumma Road, Suite 100 Lemoyne, P A 17043-1144 (717) 731-9600 (717) 731-9627 facsimile a. peterlin@gateslawfirm.com Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA -------------------.------------.--.----- -J( GATES, HALBRUNER & HATCH, P.C., : Civil Action Plaintiff, Case No. O!; - S 3} (!;~cl LSi2-{ v. DEE A. THOMPSON, Defendant. -----------.----.------------.--.-------.-------.-----J( PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Please enter the attached money judgment in the amount of $2,085.32. The undersigned certifies that a copy of this Praecipe has been mailed to the defendant. Respectfully Submitted, GATES, HALBRUNER & HATCH, P.C, Dated: , / L.6/0 S By: cdl/1/t. ttt!f)~4 Albert N. Pe erlin, Esquire Attorneys for Plaintiff .' - COMMONWEAL TH\OF PENN: VANIA COUNTY OF: CUMBERLAND 09-1-02 NOTICE L JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'GATES,HALBRUNER, & HATCH, PC I 1013 MUMMA RD APT/STE 100 LEMOYNE, PA 17043 Mag Dls! Nc OJ Narlle Hen ROBERT V. MANLOVE Ad<j"" 1901 'STATE STREET CAMP HILL, PA L --1 VS. Te"ph"" (7171 761- 0583 17011-0000 DEFENDANT: NAME and ADDRESS 'THOMPSON, DEE A 160 JUMPER RD NEWBURG, PA 17240 L I GATES , HALBRUNER, & HATCH, PC 1013 MUMMA RD APT/STE 100 LEMOYNE, PA 17043 Docket No.: CV-0000468-04 Date Filed: 9/22/04 --1 . -", THIS IS TO NOTIFYYOUIHill:1I1 '."' Judgment: DEFAULT .TITnGMRNT PLTF [!] [!] Judgment was entered for: (Name) ~lIT"R!'l lIl1T;RRT11ITRR, Ii, 'RA.IJ1r!H, PC' Judgment was entered against: (Name) TlIOMPSON, n"RF. A In the amount of $ ?',OR" l? on: (Date of Judgment) (Date & Time) 11/?l/04 o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice. O Amount at Judgment Subject to Attachmen\i42 Pa.C,S. S 8127 $ o Portion of Judgment tor physical damages arising out of residential lease $ __ Amount of Judgment $ 2,001.32 Judgment Costs $ 84,00 Interest on Judgment $ .001 Attorney Fees $ .00 Total $ 2,085,32 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN ao 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 MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. , District Justice he proceedings containing the judgment, ~, , District Justice My commission expires first Monday at January, 2006 SEAL AOPC 315.03 DATE PRINTED: 11/23/04 10:17:50 AM CERTIFICATE OF SERVICE I, Jeffrey L. Shaffer, Legal Assistant, hereby certify that a true and correct copy of the foregoing Praecipe to Enter Judgment has been served this day upon the following parties by United States first class mail, postage prepaid, addressed as follows: Dee A. Thompson 160 Jumper Rd. Newburg, PA 17240 pro se GATES, HALBRUNER & HATCH, P.C. D.mtr ~ 6 2005 BY~ L~t- Je ey . Shaffer Attorneys for Plaintiff -\A. p~~ ~ Il \L ~ ~~~~ ~\'"~ IS ..---..J:- ,.. If': ,--.- --- <::i'. ~~.-f.l f\"'.~~l:\ .~(1 ('1 -.9,1.) f"'-') (:::t~, OJ ~"C-,.." .';;r) ~t~~:; , " ......> ~, v' <..- ~~:: "'11 .:~ '-:? -- cJ' ~"-J ':::::.. - ' Gates, Halbruner & Hatch, P.C. By: Albert N. Peterlin, Esquire PA Attorney ID No. 84180 1013 Mumma Road, Suite 100 Lemoyne, P A 17043-1144 (717) 731-9600 (717) 731-9627 facsimile a.oeterlin@qateslawfirm.com Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA ----------------.---------------.----.---------------.)( GATES, HALBRUNER & HATCH, P.C., : Civil Action Plaintiff, Case No. oS - .5'3P r!t~~L '7-&'L v. DEE A. THOMPSON, Defendant. -------------------------------------.----------------)( PRAECIPE FOR WRIT OF E)(ECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above malter, (1 ) (2) (3) (4) directed to the Sheriff of Cumberland County; against Dee A. Thompson, defendant; and II.. 6 Jk.n-,f UL- Qd ( ./L)c.~ ,qLLp~"'0a..L ?n.c.f~ *' . against M& T Bank, garnishee; ':\ J W. #l"'l"-- C:;:.f.-., ~'S~ ri+- f761~ and index this writ I (a) against Dee A. Thompson, defendant and (b) against , as garnishee as a lis pendens against real property of the defendant in name of garnishee as follows: (5) Amount Due $:1001.32 4~~.2J~-4-1:- Interest from 11/23/2004 $ 20.72 [Costs to be added] $ 184.75 Respectfully Submitted, GATES, HALBRUNER & HATCH, P.C. Dated '{<6/05 ~. By: 0 /J(} ~---;;-A '. // ~ ~ N~erlin, Esq re ~11- Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Jeffrey L. Shaffer, Legal Assistant, hereby certify that a true and correct copy of the foregoing Praecipe for Writ of Execution has been served this day upon the following parties by United States first class mail, postage prepaid, addressed as follows: Dee A. Thompson 160 Jumper Rd. Newburg, PA 17240 pro se GATES, HALBRUNER & HATCH, P.C. Date: JAN 2 6 2005 BY'~ LA . Jef L. Shaffer Attorneys for Plaintiff s p +- n 1(~ -- .... t. ~ ~ -<<l."""- - \) ~ c ;::~ ~ \? (' L ~ ' ~ ~ r-- -Cq. -- ~ ~ ill ~ ~ . . V 0 8C')\) I ! _.) _ ~ (L - t.t r- , ~~ -"3 tt: ~ ~ ~ t/I ..:.i) fir --tJ~ :p- <--J D (;j ,-.,) (~ c.~ _,\ t~h w::f ~ 1 ....1"1 t.-... '-"{l'c';":;' '1:.'" I 1 r1 ~":;'r: ~C't'" ;:, ~~~:~ ~ '''-'." co ---'i""n --1.. -""l,,\ -tJ (:.,1. ["") -,,:,:.-> rn ... 1,:?\ 0) :,\7- ., "Xl - :...;. {TI \..J ~ t ~ -J ~ -u t ---....L. i.- ~r ~1- --.J:- c, 11\- r -- ~tr ~f ~ ~ ~ 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-538 Civil CIVIL ACTION - LAW TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GATES, HALBRUNER & HATCH, P.C., Plaintiff (s) From DEE A. THOMPSON, 160 JUMPER RD, NEWBURG, P A 17240 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of M&T BANK, 1 WEST HIGH ST., CARLISLE, PA 17013 GARNlSHEE(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 thereot; (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. Amolmt Due $2,085.32 Interest FROM 11/23/04 - $20.72 L.L. $.50 Atty's Comrn % Atty Paid $36.75 Plaintiff Paid Due Prothy $1.00 Other Costs Date: JANUARY 28, 2005 CURTIS R. LONG (Seal) Prothonotary ~~~ €- f? 71I/l/zr'L~ Deputy REQUESTING PARTY: Name ALBERT N. PETERLIN, ESQUIRE Address: 1013 MUMMA ROAD, SUITE 100 LEMOYNE, PA 17043-1144 Attorney for: PLAINTIFF Telephone: 717-731-9600 Supreme Court ID No. 84180 Gates. Halbruner & Hatch, P.C. By: Albert N. Peterlin, Esquire PA Attorney ID No. 84180 1013 Mumma Road, Suite 100 Lemoyne, PA 17043-1144 (717) 731-9600 (717) 731-9627 facsimile a.peterlin@gateslawfirm.com Attorneys for Debtor IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA ------------------------------------------------------J( GATES, HALBRUNER & HATCH, P.C., : Civil Action Plaintiff, Case No. 05-538-Civil v. DEE A. THOMPSON, Defendant. ----------------------------------------";<)----------J( KU I.)CJ,...) SC INTERROGATORIES TO GARNISHEE h TO: M&T Bank if? ~S!., At <fi' ,S,q YOU ARE REQUIRED TO FILE ANSWERS UNDER OATH TO T~~ll'bh INTERROGATORIES WITHIN TWENTY DAYS AFTER SERVICE UP~;:?~~~/i. ~>-4 FAILURE TO DO SO MAY RESULT IN JUDGMENT AGAINST YOU. -'i;6~t6):.r%-". CCO 0,. '"" 1/,\ ~A. "t>", r.:-", 0" '11')- 1. At the time you were served or at any subsequent time, has the Defendant:~I9~",lS>1'8il: either individually or jointly with any other party, maintained a checking, savingSf. ~I' comrnercial or other type of accourt ly~ur i')stitution either as owner, agent, maker or in any other capacity? ~ 2. If the answer to Interrogatory NO.1 is "yes", state for each account: a. Name in which such was maintained; -'D~ 11 ~~~"A...J (Y\IUW\-D\ 2:,~~~V~ b. Names and addresses of all persons or entities having an~nterest therein; 0 M Bt.l/ance " I~O' 2Jv14~ ay not.'1 S PrOVided '-V " , ' o rransact~~ect UnpOst Interrogatories to Garnishee, Page I of 3 f ' v P _ OCUrnSnt P!;~~~ Or Lega/ed J l2lfu 9:)~ . '"SSIT'/gr:. ees 3. Names aRd, ~ a~d~d~re.ssss,~!;!SS oOlf all persons or entities authorized to draw thereon; VJU'V'--X---- Account Number; %0ct <--{tU 'iJJ e. Location of office where account maintained; 1. Date opened; Cf /2 Sf7$( g. Dollar amount therein on date of service; / '(70 . 1, '/ ~<9. re. % h. Date and amount of each deposit or withdrawal theref~~q~4fJe date of . %~~~ service. O'y~~ "00'b. <r lj, 0'0-0 ~Qof Oy;:'o", fro.'O/J.r:;o/J 0;0.11) 1!l,0y flJl,r At the time you were served or at any subsequent time, did Yd'lt>~~~~, <200'%"<1<9.1'& possession, custody or control (as fiduciary, trustee or otherwise) ~~ ~t?:;r~al1);/JI,rq, tangible or intangible, in which the Defendant had any interest whatso ,7~QI Sbo~w;:''''r 'Of including but not limited to trust accounts, certificates of deposit, pledges, 0' O'IJ~;: 0.07:0: promissory notes, etc. (\, 0 "'~<l11) '7<90' d. c. a. If the answer to Interrogatory NO.3 is "yes", state: n! ^--' Brief description thereof; 4. b. Location thereof; c. Date that you received same; d. Dollar amount or value thereof; e. Terms upon which the property is being held; f. Names and addresses of all persons, entities or companies having an interest therein. 5. At the time you were served or at any subsequent time, did you have a security interest in any property in which the Defendant had an interes either individually or jointly with any other party or were you holding any document of title or other collateral of any land as security for any loan or time purchase transaction in which your institution was a party. (1 U If the answer to NO.5 is "yes", state for each loan: 6. a. Names and addresses of parties thereto; n/~ Interrogatories to Garnishee, Page 2 of 3 . ,'-.... b. Oei,ioallo", am,"", aod p'e,eot bal",,, owed; n( r:^J c. Amount of monthly payments and whether current; d. With regard to the collateral for such loan, the names and addresses of the owners thereof, a brief description thereof and the dollar amount or value thereof. Dated: I J,?IJO; Respectfully Submitted, GATe, HALBRUNER By: MAR 0 3 2005 -, ~lA S. WALSTON , M&r BANI( M& K LEGAL DOCUMENT PROCESSING P.O. BOX 844 J:\IIFFI\I n NY 14240 Interrogatories to Garnishee, Page 3 of 3 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Postage Garnishee TOTAL So Answers; Advance Costs: Sheriff s Costs 150.00 75.99 74.01 18.00 1.49 .50 1.00 16.00 Refunded to Atty on 09/12/05 30.00 9.00 75.99 Sworn and Subscribed to before me ~~~~ R. CI Klioo, ShJiff b okl By ~-:~. t; "" <:). ':-'" 2005 A.D. ptothonot~ -- {'id',r ~_: I~::::'- Ik'h. fbI1=, 9 n: :01 V ~ - 911 IDOl ;\ '-. Vd :~. ! <tl(j,j <~ Ii.L':bir-.lft~J .;.:l1~3HS 3Hl ciO :JJI.:UD , ;~~ ,.., " (~~~/, ,. ;1) <:It 5-111 r /~. II. j 7''/ WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-538 Civil CIVIL ACTION - LAW TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GATES, HALBRUNER & HATCH, P.c., Plaintiff (s) From DEE A. THOMPSON, 160 JUMPER RD, NEWBURG, P A 17240 (1), You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of M&T BANK, 1 WEST HIGH ST., CARLISLE, PA 17013 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 gamishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2,085.32 Interest FROM 11/23/04 - $20.72 Atty's Comm % Atty Paid $36.75 P laintiff Paid Date: JANUARY 28, 2005 LL $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothono~ ~ ____By: , k{d ~ --"' ~ Deputy REQUESTING PARTY: Name ALBERT N. PETERLIN, ESQUIRE Address: 1013 MUMMA ROAD, SUITE 100 LEMOYNE, PA 17043-1144 Attorney for: PLAINTIFF Telephone: 717-731-9600 Supreme Conrt ID No, 84180