HomeMy WebLinkAbout05-0654
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
MCSHANE & HITCHINGS, LLC
vs.
NO. 05- &,!;1(
C~;l 'IUL~
DOLORES O'BRIEN
Defendant
CIVIL ACTION
ENTRY OF APPEARANCE
PRAECIPE FOR ASSESSMENT OF DAMAGES
AND CONFESSION OF JUDGEMENT
TO THE PROTHONOTARY:
Kindly enter our appearance for and on behalf of the Defendant above named.
Pursuant to the authority in the Warrant of Attorney, the original or a copy of
which is attached to the Complaint filed in this action, I hereby appear for the Defendant
in this matter, Dolores O'Brien, and confess judgment authorized, in favor of the Plaintiff
and against the Defendant for Six Hundred and Eighty Four Dollars and Fifty Cents
($684.50).
Respectfully submitted,
McShan
Date: 1/ ( 1-\ b~
17109
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 05- &.54 (j{;~ L ~ ~
CIVIL ACTION
MCSHANE & HITCHINGS, LLC
vs.
DOLORES OBRIEN
Defendant
COMPLAINT
AND NOW COMES, the Plaintiff, McShane & Hitchings, LLC, by and through
its undersigned Attorney, Justin J. McShane, Esquire and avers in support of this
Complaint against Defendant as follows:
1. The Defendant, Dolores O'Brien, is an adult individual residing at 7125 Salem
Park Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Plaintiff, McShane & Hitchings, is a Limited Liability Corporation with an
address of 481 I Jonestown Road, Suite 125, Harrisburg, Dauphin County,
Pennsylvania 17109.
3. A true and correct copy of the Warrant of Attorney is attached.
4. Judgment by confession is not being entered against a natural person in
connection with a consumer credit transaction.
5. The Warrant has not been assigned.
6. Judgment has not been entered on the instrument in any jurisdiction.
7. Defendant has defaulted on the agreement by failing to pay one hundred dollars
($100.00) on November 4, 2004, one hundred dollars ($100.00) on November 18,
2004 and fifty dollars ($50.00) on December 2, 2004. Efforts to obtain payment
have not been fruitful and Defendant has been advised that this failure has
accelerated the contract for payments due per the Warrant of Attorney.
8. This action is being filed in Cumberland County pursuant to the Warrant of
Attorney as that is the County in which the Defendant resides.
9. The Defendant now owes two hundred and fifty dollars ($250.00) in payments, a
ten percent (10%) penalty of twenty five dollars ($25.00), two hundred twenty
five dollars ($225.00) in collection fees and one hundred and eighty-four dollars
and fifty cents ($184.50) in filing fees as agreed upon in the Warrant of Attorney.
10. Wherefore, Plaintiff demands that judgment be entered against the Defendant in a
sum of six hundred eight four dollars and fifty cents ($684.50) as authorized by
the Warrant of Attorney.
WHEREFORE, Plaintiff, McShane & Hitchings, LLC, requests that this
Honorable Court, enter judgment in its favor and against the Defendant in an amount
of Six Hundred and Eight Four Dollars and Fifty Cents ($684.50), plus costs, fees,
and other such relief as the Court deems appropriate under the circumstances.
Respectfully submitted,
McShane & i 1,ings, LLC
Date: 'lJ 1J ~'J
\
17109
Justin J. McShane
J ustin@1866mcshane.com
MCSHANE & HITCHINGS, LLC
ATTORNEYS AT LAW
4807 J onestown Road
Suite 242
Harrisburg, Pennsylvania 17109
Judy Deeney
Legal Assistant
Joseph L. Hitchings
jlh.law@verizon.net
(717) 657-3900
Fax: (717) 657-2060
Heather M. Clark
Legal Assistant
September 23, 2004
Non-Refundable Retainer Agreement and Agreement on Fees-Time Payment Option
Dear Ms. O'Brein:
You have asked my firm and I to act as your attorney in connection with the below enumerated
matter. I accept the representation on the terms set forth below:
1. I will represent you to the best of my ability in the matter, but can not guarantee that the matter
will be resolved to your satisfaction. I shall keep you fully informed as to the progress of your
case. I will be available to you by telephone or in person for consultation. If no one is available
when you telephone, your call will be returned promptly.
2. You agree to pay my firm an initial retainer fee of four hundred dollars ($400), which is paid to
me as consideration for my agreement to become your attorney and assuring my future
availability in your matter. This retainer fee is not refundable under any circumstances, is earned
by me upon receipt, and represents the minimum fee for the services to be rendered. It is retained
even upon your termination of my services.
3. You agree to pay a flat fee on an a la carte schedule for my services on a per event basis. This
means that all representation will cease at the end of representation for the event listed below.
You have agreed to pay a sum of three hundred and fifty dollars ($750) for my representation in
your matter currently pending before District Justice Manlove. The total fee in this matter
wonld be seven hundred and fifty dollars ($750). Some of the work on your case will be done
at rates by other attorneys or paralegal assistants or law students under my personal supervision.
You will be billed for their services at their standard rates if necessary. It is impossible to
determine in advance the amount of time that will be required to bring your case to a conclusion.
I assure yon that I will proceed in an expeditious and efficient fashion and will consult with you
in advance if any exceptional activity is necessary. I expect and require prompt payment ofthese
bills and reserve the right to tenninate my relationship with you should you fail to pay on time.
4. In the event that McShane and Hitchings, LLC is required to institute any legal action for
collection of our agreed upon fees or costs, you agree to pay additional reasonable fees, costs and
the value of my time in bringing such an action. McShane and Hitchings, LLC will charge one
hundred and fifty dollars ($150) per hour in any attempt to recover fees. By signing this
document you agree to this fee. In the event, that we accept a credit card, debit card, draft or
check in your case and that credit card, debit card check or draft is returned for Non-sufficient
~ '~8G6~MCSHANE
CENTRAJ, PENNS\l~VANI:\'S ONLY CRHvnNAL DEFENSE ATTORNEY
j-\. v i\ lLABr ,R 24 HOURS i\ DAY SEVEN DAYS ;\ \VEEK
funds, a charge back instituted by the payor or other method of denial of payment for any reason
or no reason at all, you agree that your account will become immediately due in full and you will
be assessed a forty dollar ($40) returned item fee as well as a twenty dollar ($20) processing fee.
This money will be due by you regardless of whether or not a third party is paying this fee or co-
signs this instrument.
5. Costs will be incurred by me in my handling of this matter. Costs are out-of-pocket expenses,
and can include such items as filing fees, fees for subpoena servers, transcripts (including the
stenographer's appearance fee), investigators, appraisers and accountants, excessive
telecopying and photocopying, and excessive postage. They do not include charges for clerical or
secretarial time which are part of my flat fee. These costs are your responsibility and will be
itemized and billed on a bimonthly basis.
6. The payment of the non-refundable retainer will not include any other appearance in court.
You are required to pay an additional sum for additional appearances or actions.
7. The payment of any money does not include the filing of omnibus pretrial motions or bail
modification motions. This payment does not include appearances attendant to bail modification
hearing (e.g., bail forfeiture hearings, bail revocation hearings). This payment does not include
the filing of motions to reduce or reinstate bail. This payment does not include any sort of
appellate work including but not limited to direct appeals as of right, discretionary appeals,
interlocutory appeals, Petition for Allowance of Appeal and Post Conviction Relief Act (PCRA)
petitions.
8. Should you as the client fail to appear at a hearing or required court appearance, by your
absence, you will have agreed to forfeit the money paid for that appearance to McShane and
Hitchings, LLC and will be required to pay a new fee for further representation. Further, you will
be assessed a charge of five hundred dollars ($500) on top of the non-refundable retainer fee as
new legal fees if you miss a hearing and McShane and Hitchings, LLC attends it regardless of
whether or not a warrant is issued.
This agreement shall become effective and my representation will commence upon my receipt of
a signed copy of this letter and the specified fee below. With said endorsement and payment, you
signify that you agree to all the terms and conditions contained herein.
TIME PAYMENTS
McShane and Hitchings, LLC accepts your request for time payments at the following schedule:
Your first payment will be made on the October 7, 2004 in the amount of fonr hundred dollars
($400)J
The second payment on the balance of the monies owed will be due on October 21, 2004 by no
Jater than three o'clock in the afternoon (3 p.m.). This would be a payment of one hundred
. dollars ($100). In the event of non-payment or untimely payment, all efforts on your behalf by
this firm will cease and you will be charged a late payment fee often percent (10%). In addition,
the entire balance outstanding will come due immediately with a fee assessed at ten percent
(10%) as a penalty.
~........'....'
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1-866-MCSHANE
CENTRAL PENNS'l'LV:\NI/\'S ONLY CRHvflNAL DEFENSE ATIORNEY
A v AIL\BLE 24 HOURS:\ 0:\ Y SEVEN DAYS;\ WEEK
The next several payments will be due on the following dates with money received by my office
no later than three o'clock in the after noon (3 p.m.). If said payments are not made on these
dates and received by these dates, you agree implicitly to the immediate termination of our firm's
efforts and representation on your behalf. In other words, McShane and Hitchings, LLC will not
represent you. Further, you will be assessed a late payment fee often percent {I 0%). In addition,
the entire balance outstanding will come due inunediately with a fee assessed at ten percent
(10%) as a penalty. In the event that payments are made late, the priority of payments will go
towards any arrearages first.
November 4, 2004
$100
November 18, 2004
$100
December 2, 2004
$50
As mentioned previously, in the event McShane and Hitchings, LLC is required to institute any
legal action for collection of our agreed upon fees or costs, you agree to pay additional reasonable
fees, costs as well as the value of McShane and Hitchings, LLC's time in bringing such an action.
McShane and Hitchings, LLC will charge one hundred and fifty dollars ($150) per hour in any
attempt to recover fees. By signing this document you agree to this fee. Additionally, by signing
this agreement you agree that if you were to default for any reason you assert a dual recognition
that: (I) You acknowledge that you intentionally obtained services for yourself or for another
which you know is available only for compensation and (2) that you intend to permanently
deprive McShane and Hitchings, LLC of the balance of the monies accumulated and due.
Please execute a copy of this agreement where indicated below and retum to McShane and
Hitchings, LLC with a check, money order, cash or credit card transaction for McShane and
Hitchings, LLC's fee outlined above.
Very truly yours,
McShane and Hitchings, LLC
~
By signing this document, I assert that I have read and fully understand all of the provisions and
conditions contained within. Further, I assert that I agree knowingly, intelligently, and
~
1-866-MCSHANE
CENTRAL PENNSYLVANIA'S ONLY CRIMINAL DEFENSE A TIORNEY
A V AlIABLE 24 HOURS ADA Y SEVEN DAYS A WEEK
voluntarily to these terms and conditions outlined above. Finally, I acknowledge that this
document contains the full and complete understanding between the parties and that no
amendments to this agreement will be permitted unless promulgated in writing and signed by the
parties.
09/;r3/&'--/
Date
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Surety, Client, or Co-signer of debt
~
1-866-MCSHANE
CENTRAL PENNSYL V t\NI:\ 's ONLY CRIMINAL DEFENSE A ITORNEY
AV!\rf"ABI.E 24 HOURS r\ DAY SEVEN DAYS;\ 'W'EEK
WARRANT OF ATTORNEY:
In event of default which is measured by a failure to make a timely payment as
outlined above and to secure the payment of credit given and in
acknowledgement for the debt outlined above, I hereby empower the
Prothonotary of any court with proper jurisdiction and authorize irrevocably, any
attorney of any Court of Record to appear in any court with proper jurisdiction for
McShane and Hitchings, LLC at any time hereafter; and confess a judgment
without process, in favor of McShane and Hitchings. LLC for such amount as
may appear to be unpaid thereon, whether due or not together with reasonable
attorney's fees calculated at a rate of ten percent (10%) of the debt owed, court
costs, sheriff's fees and bond costs and to waive and release all errors which
may intervene in any such proceedings and to consent to immediate execution
upon such judgment hereby ratifying and confirming all that said attorney may do
by virtue hereof.
I also waive the right of inquisition of any real estate levied on, voluntarily
condemns the same, authorizes the Prothonotary or clerk to enter the writ of
execution on said voluntary condemnation, I agree that said real estate may be
sold on a writ of execution, and also waive and release all relief from any and all
appraisement, stay or exemption law of any state now in force or enacted in the
future. I acknowledge that the authority and power to appear for and enter
judgment against me will not be exhausted by any single exercise of the
authorized power, and the same may be exercised from time to time as often as
the holder deems necessary or desirable; and this instrument will be a sufficient
warrant.
I expressly waive presentment, demand, notice, protest and all other demands
and notices in connection with the delivery, acceptance, performance, default or
enforcement of this Acknowledgement of Debt. and an action for any amounts
due and unpaid shall therefore accrue immediately.
WARNING - BY SIGNING THIS PAPER YOU GIVE UP YOUR RIGHT TO
NOTICE AND COURT TRIAL. IF YOU DO NOT PAY ON TIME A COURT
JUDGMENT MAY BE TAKEN AGAINST YOU WITHOUT YOUR PRIOR
KNOWLEDGE AND THE POWERS OF A COURT CAN BE USED TO
COLLECT FROM YOU REGARDLESS OF ANY CLAIMS YOU HAVE
AGAINST THE CREDITOR WHETHER FOR FAILURE ON THEIR PART TO
COMPLY WITH THE AGREEMENT, OR FOR ANY OTHER CAUSE.
I agree that this document constitutes the full and complete understanding of the
parties. No other provisions exist oral or otherwise. This Agreement may only
be amended or modified by a written instrument executed by the parties.
.~
~
1-866-MCSHANE
CENTRAL PENNSYLV ANI A'S ONLY CRIJ\HNAL DEFENSE i\ ITORNEY
j\'V!\[LABLE 24 HOURS A DAYSEVFN DAYS;\ WEEK
This Agreement will be construed in accordance with and governed by the laws
of the Commonwealth of Pennsylvania and be litigated before the Dauphin
County Court of Common Pleas.
The parties acknowledge that this Agreement is reasonable, valid and
enforceable. However, if a court of competent jurisdiction finds any of the
provisions of this Agreement to be too broad to be enforceable, it is the parties'
intent that such provision be reduced in scope by the court only to the extent
deemed necessary by that court to render the provision reasonable and
enforceable. bearing in mind that it is my intention to give McShane and
Hitchings, LLC the broadest possible enforcement possible to collect the debt
above outlined.
This Agreement will inure to the benefit of and be binding upon the respective
heirs, executors. administrators. successors and assigns, as the case may be, of
the parties.
Having fully read and understood the above and in full contemplation of the
consequences. I hereby knowingly. intelligently and voluntarily enter into this
agreement. I acknowledge that no threats, promises or other forms of coercion
have been used in securing my signature.
Executed this ,;/J day of -5> nklhmr 2004 at 4807 Jonestown Road,
Suite 242, Harrisburg, PA 17112 '
Signed: .{'&~( 7: O~
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1-866-MCSH1'\NE
CENTRAL PENNSYLV..\NI..\'S ONLY CR1?\HNAL DEFENSE ATTORNEY
AV/\TLABr,E 24 HOURS;\ O,.\YSEVEN DAYS;\ \N'EEK
IMPORTANT NOTICE
McShane & Hitchings, LLC utilizes the services of a Consumer Collection
Agency, otherwise known as a "Collection Agency," for accounts that are past
due. By signing this fee agreement you consent to having materials in the
possession of McShane & Hitchings, LLC necessary to collect on this debt be
released to the "Collection Agency" used by McShane & Hitchings, LLC. Such
information may include, but is not limited to any and all contact information (e.g.,
telephone numbers. addresses) as well as a copy of this fee agreement and
payment history. Furthermore, you agree to hold McShane & Hitchings. LLC
harmless for any actions taken by the Collection Agency while enforcing this
agreement. You further agree to a flat rate of one and one half hours (1 %) that
would be spent by McShane & Hitchings. LLC in forwarding this matter to the
Collection Agency. The specific Collection Agency employed by McShane &
Hitchings. LLC is subject for change with no prior notice given to you.
Having read all of the above, I knowingly, intelligently, and voluntarily
acknowledge and consent to the above listed terms.
d/~u O~
iignature
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1-866.MCSHANE
CENTRAL PENNSYLVl\NL\'S ONLY CRIi\HNAL DEFENSE A ITORNEY
AV!\ILABLE 24 J-JOURSA DAY SEVEN DAYS A \'<lEEK
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
MCSHANE & HITCHINGS, LLC,
vs.
NO. 05-
DOLORES O'BRIEN,
CIVIL ACTION
Defendant
VERIFICATION
I, Erin M. Zimmerer, an Associate for McShane & Hitchings, LLC, Plaintiff, in
the above-captioned matter, verify that the statements made in the Complaint are true and
correct. I understand that false statements herein are made subject to the penalties of 18
Pa. C. S. A. Section 4904 relating to unsworn falsification to authorities.
..~
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
MCSHANE & HITCHINGS, LLC
Plaintiff,
DOLORES OBRIEN
Defendant
NO. 05-
CIVIL ACTION
TO THE HONORABLE JUDGES OF SAID COURT:
CERTIFICATE OF SERVICE
I, Justin J. McShane, Esquire, hereby certify that the following service has been
completed in compliance with the Rules of Civil Procedure:
Via fIrst class mail:
Dolores Obrien
7125 Salem Park Circle
Mechanicsburg, P A 17050
Respectfully submitted,
McSha e & Hitchings, LLC
. c e, Esquire
ey D#87919
Att ey for the Petitioner
I Jonestown Road
Suite 125
Harrisburg, PA 17109-1739
Telephone: 717-657-3900
Facsimile: 717-657-2060
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PRAECIPE FOR WRIT OF EXECUTION
P. R. C. P. 3101 TO 3149
MCSHANE AND HITCHINGS, LLC
and Erin M. Zimmerer, Esq.
4811 Jonestown Road,
Suite 125
Harrisburg, PAl 7109
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
Plaintiffs,
v.
:NO. 0.(" -fs,~!
C~'uLL ~8L~
Dolores O'Brien
7125 Salem Park Circle
Mechanicsburg, P A, 17050
Defendant.
: CIVIL ACTION - EQUITY
TO THE PROTHONOTARY OF SAID COURT:
ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of Cumberland County, Pennsylvania;
(2) against Dolores O'Brien, 7125 Salem Park Circle, Mechanicsburg, P A 17050.
(3)
and against the following Garnishees:
N/A
(4) and index this writ
(a) Dolores O'Brien, 7125 Salem Park Circle, Mechanicsburg,
Cumberland County, P A 17050
(b)
against
N/A
Garnishee (s),
as a lis pendens against the real property of the Defendant in the name of the Garnishees
as follows: all that certain tract ofland situate in Cumberland, known as 7125 Salem
Park Cricle, Mechanicsburg, Cumberland County, PA 17050.
(5) Exemption has (not) been waived.
(6) Amount due: $684.50.
(7) Please have the Sherifflevy upon any and all personal property of Dolores
O'Brien, 7125 Salem Park Circle, Mechanicsburg, Cumberland County, P A 17050,
including any automobiles or other vehicles.
Respectfully submitted,
MCSHANE & HITCHINGS, LLC
Justi J. M e, Esquire
tto ey I.D. #87919
Attorney for Plaintiffs
4811 Jonestown Road, Suite 125
Harrisburg, Pennsylvania 17109
Telephone: (717) 657-3900
Fax: (717) 657-2060
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 05-654 Civil
CIVIL ACTION - LA W
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MCSHANE AND HITCHINGS, LLC, Plaintiff (s)
From DOLORES O'BRIEN, 7125 SALEM PARK CIRCLE, MECHANICSBURG, PA 17050
(I) YOll are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL
PERSONAL PROPERTY OF DOLORES O'BRIEN, 7125 SALEM PARK CIRCLE,
MECHANICSBURG, PA 17050 INCLUDING ANY AUTOMOBLIES OR OTHER VEHICLES
(2) You are also directed to attach the property of the defendant( s) not levied upon in the possession
of
GARt'lISHEE(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
(5) 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 hinvher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $684.50
L.L. $.50
Interest
Atty's Comm %
Atty Paid $36.75
Plaintiff Paid
Due Prothy $1.00
Other Costs
Date: FEBRUARY 4, 2005
CURTIS R. LONG
(Seal)
Prothonotary
~: 1I/?tV.. "
p . ?~/7A'V' r-
Deputy
REQUESTING PARTY:
Name JUSTIN J. MCSHANE, ESQUIRE
Address: MCSHANE & HITCHINGS, LLC
4811 JONESTOWN ROAD, SUITE 125
HARRISBURG, PA 17109
Attorney for: PLAINTIFF
Telephone: 717-657-3900
Supreme Court ID No. 87919
R. THOMAS KLINE
Sheriff
EDWARD L. SCHORPP
Solicitor
OFFICE OF THE SHERIFF
One Courthouse Square
Carlisle, Pennsylvania 17013
j
May 5, 2005
McShane and Hitchings, LLC
vs
Dolores O'Brien
Writ No. 2005-654 Civil Term
Property Claim Determination
Dear Sir,
Reference is made to Property Claim dated April 26, 2005, entered
by Regina O'Brien, pertaining to Writ of Execution No. 2005-654 Civil Term,
McShane and Hitchings, LLC -vs- Dolores O'Brien.
~NN~. ANQERSON
c.. OIlI>Jf DeiJ'Jty
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R. Thomas Kline, Sheriff, has determined that the claimant, Regina O'Brien,
in the above mentioned property claim, is prima facie the owner of the property set forth
therein.
So Answers:
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By
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McShane and Hitchings, LLC, Pltff
cc: Dolores O'Brien, Deft.
Regina O'Brien, Claimant
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PROPERTYt:LA~
lJ e...<;nO(\ e.. C\ f\(.l \+i .lch,oCp; lUL
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ NO.i:fJJ5 -0:, .:'))1
Lb VS
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TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA
The property listed below and levied upon in this case is not the property of the defendant, but is the property of the
undersigned. A list of the claimed property and the values thereof are:
LIST OF PROPERTY
VALUE
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THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS:
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Claimant
l\t&nJA' 11\ {'/'Pe.., f,<j
being duly sworn according to law, deposes and says that the
p-~EWB' (
Ca!ll8le Boro. cumbertand Coun\y
\IIi CQn\I\\isSion ExPires April 4,2009
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Claimant
PROPERTY ~LAIM"
32 f ~CL4~
fO~e..- 2.
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No.
vs
TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYL VANIA
The property listed below and levied upon in this case is not the property of the defendant, bnt is the property of the
undersigned. A list of the claimed property and the values thereof are:
LIST OF PROPERTY
VALUE
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THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS:
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Date
State of Pennsylvania:
County of Cumberland
Claimant
above list in the property claim are correct and true.
being duly swam according to law, deposes and says that tbe
Sworn and subscribed to before me
This _ day of
Claimant
Nomry Public
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriffs Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Surcharge
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage
TOTAL $
Advance Costs:
Sheriff s Costs:
150.00
114.47
$ 35.53
18.00
13.69
10.00
.50
1.00
16.28
20.00
20.00
Refunded to Atty on 05/12/05
15.00
II 4.47
Sworn and Subscribed to before me
This 11~ day of ~}ttAl ,
,
2005 A.D. ~" Q !J1{(;PLL/, AfJ;J4
Prot onotary
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 05-654 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MCSHANE AND HITCHINGS, LLC, Plaintiff (s)
From DOLORES O'BRIEN, 7125 SALEM PARK CIRCLE, MECHANICSBlJRG, P A 17050
(1) You are directed to levy upon the property of the defendant (s)and to sell Ai'lY AND ALL
PERSONAL PROPERTY OF DOLORES O'BRIEN, 7125 SALEM PARK CIRCLE,
MECHANICSBlJRG, P A 17050 INCLUDING ANY AUTOMOBLIES OR OTHER VEHICLES
(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) lS enJoined from
paying any debt to or for the account of the defendant (s) and from delivering any property ofthe defendanr
(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 himJber that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $684.50
L.L. $.50
Interest
Atty's Corum %
Atty Paid $36.75
Plaintiff Paid
Date: FEBRUARY 4, 2005
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
prothon:a . ~/V /
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Deputy L
REQUESTING PARTY:
Name JUSTIN J. MCSHANE, ESQUIRE
Address: MCSHANE & HITCHINGS, LLC
481I JONESTOWN ROAD, SUITE 125
HARRISBURG, PA 17109
Attorney for: PLAINTIFF
Telephone: 717-657-3900
Supreme Court lD No. 87919