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HomeMy WebLinkAbout05-0625 LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs Vs. LEE LEIDIGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 2481 CIVIL 1991 q&,_ ~/q/.". C.I~;L '--r~ ()~ -ls,~ c.iu~L ~~ PRAECIPE FOR REVIVAL OF JUDGMENT LIEN TO THE PROTHONOTARY; Please revive the lien of judgment entered at 2481 Civil 1991, Court of Common Pleas, Cumberland County and index enter it in the judgment index against Lee Leidigh in the amount of$160,540.00 with interest from June 18,1991, in accordance with the Agreement to Revive. Christian S. Daghi squire Etzweiler and Associates 105 N. Front Street Harrisburg, P A 17101 (717) 234-5600 Sup. Ct. I.D. #47741 Dated: January 31, 2005 G:\ WP\DOCICIV,FLEIHofTman- Writ, wpd b-U t-~ r.;;:;--o t p~ j1Jl ____ I t-~ '" ~ Ii---. r .' t~~ ;;;, r- F r~ ~ V-~ ( ~r- ~ ..() p- I .c - ..( 6' LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs Vs. LEE LEIDIGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2481 CIVIL 19.91 C-,-... 91- - 4/9!p C!.lc.>~ L l~ DS-l.:,~ AGREEMENT TO REVIVE C.l~'(~~ The undersigned hereby agree thatthe line of the judgment entered on June 18, 1991, to No. 2481 Civil 1991 be revived and authorize the Prothonotary to enter in the judgment index ajudgment orrevival in the amountof$160,540.00, with interest from June 18,1991, plus costs. Signed and dated J 1\10. 1. \_, 2005. (--- \ , "- '\ ~. '""'.0. (/ \ \ \ , ! G:\WP\Doc\C1VFLE\Hoffuy,,_Woil.,,% . ~ () ~~ -4 .,', - .... "'" ...-C:l S0 ~ - """ :C-P ~ (" .l:. (""1 \,\"f~", "-.! <:) V\ 0' _n\~f\ 0 ~ \ ~-':; \:;.-\ Q ~ \) f'O (-~':{<~~\\ C> r \' ~ -r' \/; ~~ I V) i ::.r. 0 Ci' ~ ~ ..r::. t:? ,;:::::\ :: - .c:: 0 0' :!~El - ':t- ~..;.- - J (.," .. O<:J ;:. ~ ~ '" -------- - r - Vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-625 CIVIL TERM AMOUNT $160,540.00 INTEREST TO 5/30/06 $81,033.30 COSTS: (To be Completed by Prothonotary) Plaintiff Attorney Sheriff This Writ LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs LEE LEIDIGH, Defendant And M& TBANK, Garnishee PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) directed to Sheriff of Cumberland County, Pennsylvania; (2) against L;~~~id~~c~Ge~i~, Cd(zLJ.dr, '/) f) (?c'16 (3) and against M & T Bank, of One West High Street, Carlisle, Pennsylvania, Garnishee(s). (4) and index this writ (a) against Lee Leidigh, Defendant and (b) against M & T Bank, Garnishee(s). (5) Amount due Interest to 5/30/06 (Costs to be added) $160,540.00 $ 81,033.30 Total $ Signature (~i-;/ikJv</I) ~hH' Christian S. Daghir, sqUire Address 105 North Front Street Harrisburg. PA 17101 Attorney for Plaintiff Telephone (717) 234-5600 DATE: Mav f . 2006 G:I WPIDOOC1V,FLE\Hn[rman. WriLWrxi -I s -p. ~ ~ iCJJt -r- -\1:--'- ~ - VI ~ ..t:: ~ -..: \> "'v '> ('(\, C"l ('. l., c. ;> , \A ~ '",' "" " ~ V'\ o cJ R r:\ ~ W' 'r;: ~. r "t4. -<:Q --- l( \) C' \;.. ~.~, ) \) :\( - c\ 9~ Z c c (" ~ ("'. 0- \... ,....;. "- :.\ -- ""'+ -- ~:J (;->.. ,.-., " v, V' C " IV ~ ~::-,~ 1/1 r- :+ '"T' - -r-J:2 --. \...~ ~ ~rf ,..., ~:~~ ..-.::T' -- -"'" :-:; ~~ -~.... - "' N W WRIT OF EXECUTION and/or ATTACHMENT ,/ - COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LYNN D. HOFFMAN AND SUZANNE HOFFMAN, N005-625 Civil CIVIL ACTION - LAW Plaintiff (s) From LEE LEIDIGH, 2911 ENOLA RD., CARLISLE, P A 17013 (I) 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 M & T BANK, ONE WEST HIGH STREET, CARLISLE, P A 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 thau a named garnishee, you are directed to notify hirn/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $160,540.00 Interest TO 5/30/06 - $81,033.30 Atty's Cornrn % Ally Paid $50.00 Plaintiff Paid Date: MAY 11, 2006 LL $.50 Due Prothy $1.00 Other Costs l~~ Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name CHRISTIAN S. DAGHIR, ESQillRE Address: 105 NORTH FRONT STREET HARRISBURG, PA 17101 Attorneyfor:PLAlNTIFF Telephone: 717-234-5600 Supreme Court lD No. 47741 Vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 05-625 CIVIL TERM AMOUNT $160,540.00 INTEREST TO 5/30/06 $81,033.30 COSTS: (To be Completed by Prothonotary) Plaintiff Attorney Sheriff This Writ LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs LEE LEIDIGH, Defendant PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) directed to Sheriff of Cumberland County, Pennsylvania; (2) against Lee Leidigh, Defendant (3) and against Garnishee(s) . (4) and index this writ (a) against Lee Leidigh, Defendant and as a lis pendens against the real property of the defendant(s) as follows: 2911 Enola Road Carlisle, P A 17013 (5) Amount due Interest to 5/30/06 (Costs to be added) $160,540.00 $ 81,033.30 Total $ Signature dkAn A'. /JtV~' Christian S. Daghir, ft'squire Address 105 North Front Street Harrisbur.:. PA 17101 Attorney for Plaintiff Telephone (717) 234-5600 DATE: May F' . 2006 G:\ WP\DOC\CIY.FLE\HofTman-Writ. wpd rc) ~ ~ ~ f(~ .- c. f2 \:) '- , ~ if "-l ~ ~ ~ ............ 6J ~ ~ E:~ U ~ ,......." . ~ ~ \) C> ~ g ~ r-.:l (') g ~ c:r- ::K ~. -< o " ~-n rn- FTi ~C? \D :"j ~;~: _ n~ _'(.~ ::;: :;~ ~ co ~ "'> , , ~i:l ,..., ....,." =< .-< cr\ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-625 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LYNN D. HOFFMAN AND SUZANNE HOFFMAN, Plaintiff (s) From LEE LEIDIGH (1 ) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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) Ifproperty 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 $160,540.00 Interest TO 5/30/06 - $81,033.30 Atty's Comm % Atty Paid $15.00 Plaintiff Paid Date: MAY 19, 2006 L.L. Due Prothy $1.00 Other Costs (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name CHRISTIAN S. DAGlllR, ESQillRE Address: 105 NORTH FRONT STREET HARRISBURG, PA 17101 Attorney for: PLAINTIFF Telephone: 717-234-5600 Supreme Court ID No. 47741 '. ,.; LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs Vs. LEE LEIDIGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-625 CIVIL TERM Amount Due-$160,540.00 CIVIL ACTION - LAW AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYL VANIA ) SS: COUNTY OF DAUPHIN ) LYNN D. HOFFMAN and SUZANNE HOFFMAN, PlaintitTs in the above action, set forth as of the date of the Writ of Execution in this matter, the following information concerning the real property located in Lower Frankford Township, Cumberland County, Pennsylvania, known as 2911 Enola Road, Carlisle, PA 17013. 1. Name and address ofOwner(s) or reputed Owner(s): Lee M. Leidigh, 2911 Enola Road, Carlisle, PA 17013. 2. Name and address of Defendant(s) in the judgment: Lee Leidigh, 2911 Enola Road, Carlisle, P A 17013. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Lynn D. HotTman and Suzane HotTman, 101 Shady Lane, Carlisle, P A 17013. 4. Name and address of the last recorded holder of every mortgage of G:\WP\DOC\CIV.FLE\Hoffman-Writ. wpd .,I . record: None 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by sale: Lower Frankford Township, 1205 Easy Road, Carlisle, P A 17013 Tax Claim Bureau, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 6. Name and address of every other person of whom the Plaintiff.has knowledge who has any interest in the property which may be affected by the sale: None. The addresses listed above are the last known reasonable ascertainable addresses after a reasonable search conducted by the Plaintiff. I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: May.-I 1- , 2006 ~,/~~ Christian S. Dag ir, squire 105 North Front Street Harrisburg, PA 17101 (717) 234-5600 Attorney for Plaintiff Sworn and subscribed to before me this \ ~ day of May, 2006. 'Y~L. ~\~ No ary ublic GIWFIDOCICIY.f1.E\Hoffman-Wri'wpd NOTARiAl SEAL PATTY L. STROHECKER, Notary Public CIty of Harrisburg, DauphIn County My Comnis8Ion ExpInI8.1an. 6, 2W1 I C) ('- ".c ~" co w O"l \.. ""-3 <,;;;:;, = cro. 3l: ;l;:...,. -'~< o " :;:I i'iliJ1 -orn :~iJ6 {~'~ ~~~ :SrT1 ~;.-/ :l5 -< '-0 :z:". ~ r " LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs Vs. LEE LEIDIGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-625 CIVIL TERM Amount Due-$160,540.00 CIVIL ACTION - LAW NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: LEE LEIDIGH Your real estate in Lower Frankford Township, Cumberland County, Pennsylvania, known as 2911 Enola Road, Carlisle, P A 17013, is scheduled to be sold at Sheriffs Sale on September 6, 2006, at 10:00 A.M. in the Cumberland County Courthouse located in Carlisle, Pennsylvania, to enforce the court judgment of $160,540.00 obtained by the above-named Plaintiffs against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE. To prevent this Sheriffs Sale, you must take immediate action: 1. The same will be canceled if you pay to the above named Plaintiff the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Christian S. Daghir, Esquire, at (717) 234-5600. 2. You may be able to stop the sale by filing a petition asking the Court G:\ WP\DOC\CIV.FLE\Hoffman-Writ.wpd to strike or open the judgment, ifthe judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY, AND YOU HA VE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the county courthouse. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff at the county courthouse. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. G:\WP\DQC\ClV.FLE\Hoffman-Wril.wpd 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on October 6, 2006. This schedule will state who will be receiving that money. They money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after sale date. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 1-800-990-9108 The Sheriffs phone number is: (717) 240-6390 ~...A'd~' Christian aghir, Esquire 105 North Front Street Harrisburg, PA 17101 (717) 234-5600 Attorney for Plaintiff G:\ WP\DOC\CIV.FLE\Hoffman-Wril.wpd (") ~:: t- I ......., = <= 0-- o -n ~11 rn r'- -r: rn :;)9 ~C1 Ie.:;:::' ...,.- I -',Oi (~~ -h ~.o .< :::z: J;;~~ -<.. w 2:~ _".do CO (..) en .. .. Tax Parcel No. 14-05-0423-022A ALL THOSE CERTAIN TRACTS OR PARCELS OF LAND SITUATE IN Lower Frankford Township, Cumberland County, Pennsy Ivania, bounded and described as follows, to wit: TRACT NO. 1: BEGINNING at an ash tree on the boundary line between lands of the Grantors herein and lands of George Shughart, which said ash tree is three hundred seventy-nine (379) feet west of a point common to the lands of the Grantors herein, George Shughart and John Darr; thence along lands of George Shughart South sixty-nine and one-half (69.5) degrees west four hundred ninety-two (492) feet to the east side of a lane; thence along the east side of said lane in a southerly direction one hundred seventy- four (174) feet to a cherry tree; thence in an easterly direction along lands of the Grantors four hundred ninety-two (492) feet to a locust post; thence in a northerly direction along lands of the Grantors one hundred seventy- four (174) feet to an ash tree at the place of BEGINNING. CONTAINING two (2) acres, more or less. TRACT NO.2: BEGINNING at a point on the side ofthe public road designated as Pa. State Highway 944 and where the line between the parties hereto intersects said side of road; thence by the side ofthe road North 41 degrees 30 minutes East 507.2 feet, more or less to a guard post on the side ofthe road; thence by other land of the Grantors South 75 degrees Est 310 feet to a tree; thence still by same South 48 degrees East 243 feet to a post on the line between Fry and Leidigh; thence along said line South 70 degrees 30 minutes West 855 feet, more or less, to the side of the highway, the place of BEGINNING. CONTAINING 3.3 acres, more or less. TRACT NO. 3: BEGINNING at an ash tree by line ofland of Carroll W. Leidigh and Nelson H. Shughart North 74 degrees 5 minutes East a distance of 400.65 feet to a post; thence South 7 degrees 55 minutes East a distance of274.00 feet by land of J. Ellsworth Wickard to a stake; thence South 74 degrees 5 minutes West a distance of 1105.50 feet by land ofC. Carroll Leidigh to a stake; thence North 7 degrees 55 minutes West a distance of274.00 feet to a railroad spike; thence North 74 degrees 5 minutes East a distance of212.85 feet by lands of Carroll W. Leidigh to a point; thence South 12 degrees 15 minutes East a distance of 174.00 feet by lands of Carroll W. Leidigh by a point; thence North 74 degrees 5 minutes East a distance of 492.00 feet by lands of Carroll W. Leidigh to a point; thence North 12 degrees 15 minutes West a distance of 174.00 feet by lands of Carroll W. Leidigh to an ash tree, the point of BEGINNING. CONTAINING 4.925 acres, more or less. G:\ WP\DOC\CIV.FLE\Hoffman~Writ.wpd J ~ BEING the same premiss which Carroll W. Leidigh and Esther M. Leidigh, his wife, by their Deed dated January 25, 1979, and recorded in the Office for the Recording of Deeds in and for Cumberland County in Deed Book G, Vol. 28, Page 496, granted and conveyed to Carroll W. Leidigh and Esther M. Leidigh, his wife, and Lee H. Leidigh, with the said Carroll W. Leidigh and Esther M. Leidigh having died, leaving to survive Lee H. Leidigh. G:\ WP\DOC\CIV.FLE\HotTman-Writ wpd , LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 05-625 Civil Term vs. LEE LEIDIGH Defendant and M & T Bank, Amount Due $160,540.00 CIVIL ACTION - LAW Garnishee PRAECIPE FOR ENTRY OF JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Please enter Judgment in favor of Plaintiff and against the Garnishee, M & T Bank, in the amount of $28,820.46, being the amount Garnishee admits in its Answers to Plaintitrs Interrogatories in Attachment to be the property of Defendant in its possession, Le. - the amount of TWENTY-EIGHT THOUSAND EIGHT HUNDRED TWENTY DOLLARS AND FORTY-SIX CENTS ($28,820.46). TO CUMBERLAND COUNTY Prothonotary Dated: q/U/t)6 aL.t~~. Christian S. Daghir, squire Supreme Court J.D. #47741 Attorney for Plaintiff Etzweiler & Associates 105 North Front Street Harrisburg, PA 17101 (717) 234-5600 G:\WP\DOC\C1V,FLElHGrr........wrlt wpd ~ ";:::) ~ "'9 1- ..0 C) C) ~ ,.',"" ---II . , c. C) _ , ~ f- i"" (''t''l C ,"'- ~ ........ - ,",.," ..::t Vt f! (27, "(', ~ ~ V) - . ~ - ..() 1 ~ ~ r,~ _._' ~ C'""'-- ;, .-" '\ '~ ,. ~ ~ \ ^" ' . vs. LEE LEIDIGH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 05-625 Civil Term LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs Defendant and M & T Bank, Amount Due $160,540.00 CIVIL ACTION - LAW Garnishee To M & T Bank. Garnishee You are hereby notified that on ,Jt .I, \ ~ .2 L . 2006, the following (Judgment) has been entered against you in the above-captioned case. Judgment entered in the amount of $28,820.46 per attached Answers to Interrogatories. DATE: ~ /1 (.. /Ob I I ~~ I hereby certify that the name and address of the proper person( s) to receive this notice is: M & T Bank P.O. Box 844 Buffalo, NY 14240 M & T Bank. Garnishee/alas Por este medio se Ie esta notificando que el del 2006, el/la siguiente (Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. Judgment entered in the amount of $28,820.46 per attached Answers to Interrogatories. FECHA: Protonotario Certificao que la siguiente direccion es la del defendido/asegun indicada en al certificado de residencia: M & T Bank P.O. Box 844 Buffalo, NY 14240 Abogado del Demandante G:\WP\DOCICN.FLE\HoffinaD-Wrlt.wpd " 06-23-'06 12:05 FROM- 1-362 P003/006 F-290 , ETZWEILER & ASSOCIATES By: Christian S. DlIghir, Esquire 105 North Front Street Harrisburg, PA 17101 Attorney for Plaintiff (717) 234-5600 LYNN D. HOFFMAN and SUZANNE HOFFMAN, l'laintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, l'ENNSYL VANIA No, 05-625 Civil Term vs. LEE LEIDIGH Defendant and M & 'I' Bank, Amount Due $160,540.00 CIVIL ACTION - LAW Garnishee ANJWERS 10 INTERROGATORIES IN ATTACHMENT TO: M & 'I' Bank (Garnishee) One West High Street Carlisle, P A 17013 You must file with the COUl't answcrs to the following intcl'I'ogatories within twenty (20) days afte,' service upon you. Failure to do so may ,'esult ill a default judgment being entered against you. A copy of sllid answers must be served on the undersigned, If yonI' answer to any of the fOI'ee:oinl: interroelltories is affirllllltive. specifv the amonnt. value and/ol' nature of the subiect l)rOpertv. 1. At the time you were served or at lIny subsequent time, did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim tbllt you owed any money or were liable to defendllnt(s) for any rellsou'! y<!'~ G:\WI'\DOl.'CIV,ft.~.\llol,....~.WI;I.""" 06-23-'0612:06 FROM- T-362 P004/006 F-290 , 2. At the time you were served or at any subsequent time, was thcI'c in YUill' possession, custody or control or in the joint possession, custody or contl'ul of yourself or one or more other persons any pI'operty 01' allY nature owned solcly or in part by the defelldant(s)? (\0 3. At anytime you wel'e sel'Ved or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the defendllnt(s) OJ' in which defendant(s) held or claimed any interest? fl.0 4. At any time you were served OJ' at any subsequent time, did you hold as II fiduciary any property in which the defendant(s) had all interest? ,\n"\ I,v (l-,\W....OOl:\l..IVJI.I\\llnllill,....Wlit"pIl 06-23-'06 12:06 FROM- T-362 P005/006 F-290 5. At any time before 01' afteryolI were served, did the defendant(s) tnlllsfel' 01' deliver any propel'ty to you or to llllY person or place pnrsuant to YOIII' direction or consent and, if so, what was the considel'ation therefor? rf0 6. At the time you were served or at allY subseqnent time, did yon IJay, transferor deliver any money or property to the defendallt(s) 01' to any IJel'SOIl or place pursuant to the direction ofdefendant(s) against YOII? '-;;'0 \ 7. At the time YOII were served or at any subsequent time, did you have or share any safe-deposit boxes, pledges, documents of title, securities, notes, coupons, receivable, or collateral in which there was 1\11 interest claimed by defelldant(s)? /\.0 I (t\\'MIIUr.'CIY_FtMtl'"w.W'ii.\lpd 06-23-'0612:06 FROM- T-362 P006/006 F-290 8. Identify every account (not pl'eviously noted), titled in thc mIme of defendant(s) or in which you believe defendant(s) have an interest in whole 01' pal't, whether or not styled as a payroll account, individuall'ctirement account, tax account, lottery account, partnership account, joint or tenants by entirety lIccount, insurllncc account, trust or escrow account, attol'lley's account or otherwise, including but 1I0t limited to Checking Account No. 03302955:424307 and Checl,iug Accouut No. . 031302955:0000612723and~lrren~.~ah~I.lc~(s) of all account~ .' cJ.,,(\. j~.~(~l-*, 42 Lf ?)~') .',. '"'(,2)/ 6J-0 "~V:' txlY. ct. ,~~- (j t.7~\_ I~\ ' Le. uJlt\ll BAU\NCES PROVIDED \ .. ' (,) MAY NOT REFLECT 1,....JL.k~__ L(l.d~l'1') UNPOS,TED () TRANSACTIONS l_('~ \ (ll L?) f'JIJ \~ ( Q... \lJ ~k:>-C~~') I{cd il: , j-... TI-!N /eo , , ,,) 1\ ,.JC\1{\1r M & r /'1' .'" ACCOU1...'P ., . ,)1),\ rno '.. IY, hlJthnriz",. t,. - .UJ'~$) ""'rl't/en .,. -. on "'- ' . a , If(1JOVor Orrl..,". onth ownors - \./ to r,,!p.r'''R .. and/or 0.. rI./(k/s, Etzweiler & Associates By: .~ / I Christian S. Da r, ES1luire Attorneys for Plaintiff JUN J 1 200S .---kh /I ~!~~':~~""~;f.~':,:~i,~Ii:1J "-..) ,V V ,.",", /'., "\1';''-' (;:\\'I~IK.H).CfV_l'l.m'lol~"'n.Yln:I,"'pl .06-23-'0612:05 FROM- T-362 P002/006 F-290 m!M&rBank Legal Document Processing Phone # 716-635-7718 Fall # 716-635-7725 .Julle 21, 2006 Elzweiler & Associates 105 N0l1h Front Street Harrisburg, PA 17\0\ Rc: Writ of Garnishment on Garnishee received by Manufacturers and Traders Trost Company Lynn D. & Suzanne Hoffman vs. Lee Lcidigh No. 05-625 Pursuant to the nbove referenced Writ of Garnishment and Interrogatories on Garnishee., manufacturer, and Traders Tru.'il Company has sClU'ched its nx:ords and hms idenljfit.~ lhe lollowing open 3Ceou"'S with oolances due ils \.'Ustomcr(s). '~ I\cct No. 24307 Oalancc 528,820.46 Acel No. ---_. Ifthe Writ orGnrnishment ilnd Interrogatories nISI) sought 1'0 rcslrnin f.\ccess 10 safe dcpm:il hoxes, rhen .my sale deposit boxes identified lit any of our branches arc listed below. __ ~~me ~ Branch NUIl\Il\:fo Slife Deposit Box Number Ir~my oflhc ahove llccounls or safe deposit boxes are dtsignatcd by n "J" thai menllS they arc accounts or safe deposil boxes in which persons other than Ihose idcntiJied in the Writ ofCiarnishmcnt and InterrogalOries mllY also h:lVC.1n interest. With respect to all SilrC deposit boxes, an order dil-ccting the drilling of the hox must first be obtained and Manufacturers and Traders Trust Company mllst be reimbursed lor the cost of drilling and replacing the lock on Ihe box. Pa.R.C.I). No. 3110. 42 fla.C.S.A. Itcsponscs to InICl1"l)gatorics lhat )'ou propounded, ifi'lUY. arc enclosed. Sincerely, Talia S.PaJmcr Legal Document Analyst (716) 6J5.771H 1~llclosul'c: Responses to Interrogatories Manufacturers and Traders Trust Company P,O. Box #844, Buffalo, New YOI'k 14240 t "'" , ..' ETZWEILER & ASSOCIATES By: Christian S. Daghir, Esquire 105 North Front Street Harrisburg, PA 17101 Attorney for Plaintiff (717) 234-5600 LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA No. 05-625 Civil Term vs. LEE LEIDIGH Defendant and M & T Bank, Amount Due $160,540.00 CIVIL ACTION - LAW Garnishee tbLCers 10 INTERROGATORIES IN ATTACHMENT TO: M & T Bank (Garnishee) One West High Street Carlisle, P A 17013 You must file with the Court answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default judgment being entered against you. A copy of said answers must be served on the undersigned. If your answer to anv of the foreeoinl! interroeatories is affirmative. specifv the amount. value and/or nature of the subject property. 1. At the time you were served or at any subsequent time, did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed any money or were liable to defendant(s) for any reason? y~ G:\ WPIDOCICIV.FlEIHoffIllBJt.Wril. wpd ~ ~ 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 or one or more other persons any property or any nature owned solely or in part by the defendant(s)? (\0 3. At any 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(s) or in which defendant(s) held or claimed any interest? (v0 4. At any time you were served or at any subsequent time, did you hold as a fiduciary any property in which the defendant(s) had an interest? rvo G:\WP\DQCICIV.FLE\HotJ'man.Wri1.wp6 . 5. At anytime before or after you were served, did the defendant(s) 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 therefor? ,v:> 6. At the time you were served or at any subsequent time, did you pay, transfer or deliver any money or property to the defendant(s) or to any persou or place pursuant to the direction of defendant(s) against you? (V0 7. At the time you were served or at any subsequent time, did you have or share any safe-deposit boxes, pledges, documents of title, securities, notes, coupons, receivable, or collateral in which there was an interest claimed by defendant(s)? (LD G:\WP\DOC\CIV.FLEIH"ffrnan-Wril. wpd . . 8. Identify every account (not previously noted), titled in the name of defendant(s) or in which you believe defendant(s) have an interest in whole or part, whether or not styled as a payroll account, individual retirement account, tax account, lottery account, partnership account, joint or tenants by entirety account, insurance account, trust or escrow account, attorney's account or otherwise, including but not limited to Checking Account No. 03302955:424307 and Checking Account No. . 031302955:0000612723 and current balance(s) of all acc~unt~ cY-fr JM c\cc:HI-lfZ'-/ :'07 l-~'I~W.<t1f (;>'UL~ ~'L- IV\ . LeV::t~h BAl.ANCES PROVIDED \ _ ~ J ."~.. U . MAY NOT REFLECT ~ LX..-. UNPOSTED TRANSACTIONS II)\~ ll.?y N<J\tC (VJ+h~ Ac:d~ Vi THIS IS A J M & T Bank re OINT ACCOUNT Authorization oiU/res Written a Turnover Order t both oWners a....' o release fUnd . ""or s. Etzweiler & Associates By: Christian S. Da r, Esquire Attorneys for Plaintiff JON J 1 2006 A S. PALMER M&T BANK G:\WPIDOC\CIV.FLE\Hoffman-Wril.wpd 11t1 :b 'o;:j b \ ml qUUZ 'lfd ',uHIIGJ mIVl2!,,8WnJ ,J;l1l:l3HS 3111 .:10381.:1.10 ;-) ~~1 .-.\ ~-!- \"i1 , Co) -1~' r'-.' r<') vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 05-625 Civil Term - Revived ,/' from No. 4196 Civil 1996 - Revived From No. 2481 Civil 1991 LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs LEE LEIDIGH Defendant Amount Due $160,540.00 CIVIL ACTION - LAW PRAECIPE TO SATISE..Y. SE'ITLE..lllSCONTIMJE AND END TO THE PROTHONOTARY: Please satisfy the judgment in the above action and mark the action settled, discontinued and ended. Dated: June 3D ,2006 &*:dX{~~' hristian S. Daghir, Es e Attorney for Plaintiff 105 North Front Street Harrisburg, PA 17101 (717) 234-5600 F:\WPDQC\Crv.FLElHoft'man-Wril.wpd " . ~~ ,,~ - . ..,. ,', ~ ~ ?- ..t;: .',\ ...:, '- l-, ~ ~ <) ~ I' -<;,. 1v ,;i, c_ :~:-J ,....." i'," \~-; . ~ r ~ ~ p "- ~ 11\ ~ ~ C/\ ~ vs. LEE LEIDIGH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA No. 05-625 Civil Term LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs Defendant Amount Due $160,540.00 CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROmONOTARY: Kindly enter my appearance on behalf of the Plaintiffs, Lynn D. Hoffman and Suzanne Hoffman, in the action above-captioned. Dated: June ~, 2006 . f~~1E~~. ETZWEILER & ASSOCIATES 105 North Front Street Harrisburg, PA 17101 (717) 234-5600 Attorney for Plaintiff F:\WP\DOCICIV.~Writ,wpd ,,' \ \ . ',~ ....;. , \ :' ' c C' '- .-<: SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-00625 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HOFFMAN LYNN D ET AL VS LEIDIGH LEE And now WILLIAM CLINE ,Sheriff or Deputy Sheriff of Cumberland County of pennsylvania, who being duly sworn according to law, at 0019:20 Hours, on the 24th day of May , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT LEIDIGH LEE , in the hands, possession, or control of the within named Garnishee M & T BANK 812 1/2 W. HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to CARIE DERICK (TELLER) 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 Service Affidavit Surcharge .00 .00 .00 .00 .00 ~ .00-./ {,/~D(O{ OS/25/2006 Subscribe to / ~ , . this day of By /~V ~~ ~ Deputy Sheriff So answers: r;:,~-.H: &L:.~ . Thomas Kline' Sheriff of Cumberland County Sworn and before me A.D , Lynn D. Hoffman and Suzanne Hoffman VS Lee Leidigh In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-625 Civil Term /' Real Estate Writ, Notice of Sale R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Christian Daghir. Sheriffs Costs: Docketing Surcharge Law Library Prothonotary Levy Advertising Posting Handbills Mileage Share of Bills Poundage 30.00 20.00 .50 1.00 15.00 15.00 15.00 4.40 19.31 2.200.00 $2,320.21/ 9- 711'1/~~ so~: MA ~ ~~~~-<< ~ R. Thomas Kline, Sheriff BYU~JmrtL, Real Estate gt. Jody Smith \,".1) ...,{ ~ \R~Lt~( ~ J fDW;J -# .. ,j LYNN D. HOFFMAN and SUZANNE HOFFMAN, Plaintiffs Vs. LEE LEIDIGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 05-625 CIVIL TERM Amount Due-$160,540.00 CIVIL ACTION - LAW NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: LEE LEIDIGH Your real estate in Lower Frankford Township, Cumberland County, Pennsylvania, known as 2911 Enola Road, Carlisle, PA 17013, is scheduled to be sold at Sheriffs Sale on September 6, 2006, at 10:00 A.M. in the Cumberland County Courthouse located in Carlisle, Pennsylvania, to enforce the court judgment of $160,540.00 obtained by the above-named Plaintiffs against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE. To prevent this Sherifrs Sale, you must take immediate action: 1. The same will be canceled if you pay to the above named Plaintiff the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Christian S. Daghir, Esquire, at (717) 234-5600. 2. You may be able to stop the sale by filing a petition asking the Court G:\ wp\ooacl V.FLE\HolTman- Wril. wpd , .. .. to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney.) YOUMA Y STILL BE ABLE TO SAVE YOUR PROPERTY, AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Sheriff at the county courthouse. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff at the county courthouse. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. G:\ WP\DOaCIV FLE\Hoffman-WriL wpd '" 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on October 6, 2006. This schedule will state who will be receiving that money. They money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after sale date. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 1-800-990-9108 The Sheriffs phone number is: (717) 240-6390 , Christian aghir, Esquire 105 North Front Street Harrisburg, PA 17101 (717) 234-5600 Attorney for Plaintiff G:\ WP\DOC\CIVFLE\Hoffman-Wril.wpd - ............ Tax Parcel No. 14-05-0423-022A ALL THOSE CERTAIN TRACTS OR PARCELS OF LAND SITUATE IN Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: TRACT NO. 1: BEGINNING at an ash tree on the boundary line between lands of the Grantors herein and lands of George Shughart, which said ash tree is three hundred seventy-nine (379) feet west of a point common to the lands of the Grantors herein, George Shughart and John Darr; thence along lands of George Shughart South sixty-nine and one-half (69.5) degrees west four hundred ninety-two (492) feet to the east side of a lane; thence along the east side of said lane in a southerly direction one hundred seventy-four (174) feet to a cherry tree; thence in an easterly direction along lands of the Grantors four hundred ninety -two (492) feet to a locust post; thence in a northerly direction along lands ofthe Grantors one hundred seventy- four (174) feet to an ash tree at the place of BEGINNING. CONTAINING two (2) acres, more or less. TRACT NO.2: BEGINNING at a point on the side of the public road designated as Pa. State Highway 944 and where the line between the parties hereto intersects said side of road; thence by the side ofthe road North 41 degrees 30 minutes East 507.2 feet, more or less to a guard post on the side of the road; thence by other land of the Grantors South 75 degrees Est 310 feet to a tree; thence still by same South 48 degrees East 243 feet to a post on the line between Fry and Leidigh; thence along said line South 70 degrees 30 minutes West 855 feet, more or less, to the side of the highway, the place of BEGINNING. CONTAINING 3.3 acres, more or less. TRACT NO. 3: BEGINNING at an ash tree by line ofland of Carroll W. Leidigh and Nelson H. Shughart North 74 degrees 5 minutes East a distance of 400.65 feet to a post; thence South 7 degrees 55 minutes East a distance of274.00 feet by land of J. Ellsworth Wickard to a stake; thence South 74 degrees 5 minutes West a distance of 1105.50 feet by land ofC. Carroll Leidigh to a stake; thence North 7 degrees 55 minutes West a distance of274.00 feet to a railroad spike; thence North 74 degrees 5 minutes East a distance of212.85 feet by lands of Carroll W. Leidigh to a point; thence South 12 degrees 15 minutes East a distance of 174.00 feet by lands of Carroll W. Leidigh by a point; thence North 74 degrees 5 minutes East a distance of 492.00 feet by lands of Carroll W. Leidigh to a point; thence North 12 degrees 15 minutes West a distance of 174.00 feet by lands of Carroll W. Leidigh to an ash tree, the point of BEGINNING. CONTAINING 4.925 acres, more or less. G:\ WP\DOO.ctV. FLE\HoITman.W rit. wpd ~ ...,.,~. BEING the same premiss which Carroll W. Leidigh and Esther M. Leidigh, his wife, by their Deed dated January 25, 1979, and recorded in the Office for the Recording of Deeds in and for Cumberland County in Deed Book G, Vol. 28, Page 496, granted and conveyed to Carroll W, Leidigh and Esther M. Leidigh, his wife, and Lee H. Leidigh, with the said Carroll W. Leidigh and Esther M. Leidigh having died, leaving to survive Lee H. Leidigh. G:\ WP\OOC\C1V.FLE\HofTman-Wril. wpd . . WRIT OF EXECUTION and/or ATTACHMENT . . COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-625 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LYNN D. HOFFMAN AND SUZANNE HOFFMAN, Plaintiff (s) From LEE LEIDIGH (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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) Ifproperty 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $160,540.00 Interest TO 5/30/06 - $81,033.30 Atty's Corom % Atty Paid $15.00 Plaintiff Paid L.L. Due Prothy $1.00 Other Costs Date: MAY 19, 2006 ~ (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name CHRISTIAN S. DAGHIR, ESQillRE Address: 105 NORTH FRONT STREET HARRISBURG, PA 17101 Attorney for: PLAINTIFF Telephone: 717-234-5600 Supreme Court ID No. 47741 , .-...~ iE2; =fi cC::;-r=l1 !11.l ;=--~ ;-~{11 Real Estate Sale # 69 On June 2, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Lower Frankford Twp, Cumberland County, P A Known and numbered as 2911 Enola Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 2, 2006 By:" \ It. 1tuxS.... . .} I ,.) v v (). Vl/\);L.V\ Real Estate Sergeant E 0 :01 V E G ^ V~ QOOl ~~~ "9fiJ =u=il = ~ :f1fU l\ . ;,) i c.) V i'j i. ,_i .:L:Jltl3HS ~!HJ:lO 3:JI.:J.:JO Thomas Kline, Sheriff, who being duly sworn ac~ording to law, states this writ is returned STAYED. Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL $ 18.00 1.66 Advance Costs: 150.00 Sheriffs Costs: 84.56 $ 65.44 Sheriffs Costs: .50 1.00 4.40 30.00 20.00 Refunded to Arty on 07/19/06 9.00 84.56 y ~.. 1- ;A~(J(p 7~~~~ ~. Thomas Klin. e'.S.hen. . ff / ~ Cj ~O'~ .~lr/ ~ By ClaudIa A. Brewbaker V\ ~ ~ ~. ~: ~: ~. h t) :b 'v' b I A VH qaaZ Vj.l~~~~ 0 jJHJ.lj Ol~ Jl~] 2 J r ,.SO ~' ~ ~. lb!' HJl:- .~ cle.. 5'V90/ ~ jHi ,,(' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LYNN D. HOFFMAN AND SUZANNE HOFFMAN, N005-625 Civil CIVIL ACTION - LAW Plaintiff (s) From LEE LEIDIGH, 2911 ENOLA RD., CARLISLE, P A 17013 (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 M & T BANK, ONE WEST IDGH STREET, CARLISLE, PA 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) Ifproperty 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. AmountDue $160,540.00 Interest TO 5/30/06 - $81,033.30 Atty's Conun % Atty Paid $50.00 Plaintiff Paid Date: MAY 11, 2006 L.L. $.50 Due Prothy $1.00 Other Costs ckns R. (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name CHRISTIAN S. DAGHIR, ESQUIRE Address: 105 NORTH FRONT STREET HARRISBURG, PA 17101 Attorney for: PLAINTIFF Telephone: 717-234-5600 Supreme Court ID No. 47741