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HomeMy WebLinkAbout14-2833IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FEDERATED FINANCIAL, Plaintiff v. Kimberly HILL THEODORE PRODUCTIONS, Defendant : No. 07-253 4 , x433 131221.001 PRAECIPE FOR WRIT OF REVIVAL TO THE CLERK OF JUDICIAL RECORDS: Issue Writ of Revival of judgment entered in the Court of Common Pleas of CUMBERLAND County, 07-253, and index it in the judgment index against Kimberly HILL THEODORE PRODUCTIONS , in the amount of $24,538.14 with interest from May 24, 2007 at 6% per annum and costs for a total amount of $34,731.22. Date: April 24, 2014 0,11A".-12, s SA go e.gto It « SS, S 1L, p0 N a�.sa Sk� �. LtLi.gQa 1 Respectfully Submitted, /s Demetrios H. Tsarouhis DEMETRIOS H. TSAROUHIS I.D. #88513 Attorney for Plaintiff 21 S. 9t Street—Suite 200 Allentown, PA 18102 610-439-1500 _,a(s .0.4.fi • CLt4. 3613 WuA ��e�aVp.P 345(49 3a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FEDERATED FINANCIAL, Plaintiff v. Kimberly HILL THEODORE PRODUCTIONS, Defendant To: Kimberly HILL THEODORE PRODUCTIONS 162 KEN LIN DRIVE CARLISLE PA : No. 07-253 131221.001 WRIT OF REVIVAL CV; I (1)You are notified that the plaintiff has commenced a proceeding to revive the lien of the judgment entered at 07-253 in the Court of Common Pleas of CUMBERLAND County, Pennsylvania. (2)The plaintiff claims that the amount due and unpaid is $24538.14 with interest from May 24, 2007 for a total amount of $34,731.22. (3)You are required within twenty (20) days after service of this writ to file an answer or otherwise plead to this writ. If you fail to do so, judgment of revival in the amount claimed by the plaintiff may be entered without a hearing and you may lose your property or other important rights. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. sh H Date1424)11 Cumberland County Bar Association 34 S. Bedford Street Carlisle, Pennsylvania - telephone number 717-249-3166 soo s 5:701. vA &Ai ca. D, —buk 1>e• Mai OS f:4d1(61-k- 1 s• 9411 St•ti"-te Wityttt , -04 12-/t) AL) -10-- H39 lSoo (Name of Prothonotary Clerk) (Deputy) # /3 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 'THE PROTHONOTAR). 2OII MAY 23 Ni I0. 17 CUMBERLAND COUNTY PENNSYLVANIA Federated Financial vs. Kimberly Hill Theodore Productions Case Number 2014-2833 SHERIFF'S RETURN OF SERVICE 05/19/2014 03:20 PM - Sergeant Bryan D. Ward served the requested Writ of Revival by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Kimberly Hill Theodore Productions at the Cumberland County Sheriffs Office, One Courthouse Square,, Carlisle, PA 17013. BRYAN P ' D DEPUTY SHERIFF COST: $34.78 SO ANSWERS, 'May 21, 2014 (c) CountySuite Sheriff: Teleosoft, inc. RONNY R ANDERSON, SHERIFF .•• COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FEDERATED FINANCIAL, Plaintiff VS. Kimberly HILL Theodore Productions Defendant And Members' 1st Federal Credit Union, Garnishee .s000 Lim it 1)f, Vm6x. ?rt Judgment Amount Post Judgment Interest Costs Poundage (2%) Total : No.: 14-2833 131221.001 PRAECIPE FOR WRIT OF EXECUTION TO THE CLERK OF COURTS: Issue a writ of execution or attachment upon a judgment in the above matter, (1) direct the Sheriff of Cumberland County: (2) against Kimberly HILL Theodore Productions (Name of Defendant) Following described property of the defendant(s) $24,538.14 $10,193.08 $0.00 $0.00 $34,731.22 all personal property and all Business property located at 162 Ken -Lin Drive, Carlisle PA 17015. (3) (Supply four copies of lengthy personality list) (if real property supply six copies of the description) against Members' 1st Federal Credit union, garnishee(s) for the following property: Attach any and all funds and assets of the Defendant found in the possession of Garnishee, Members' 1st Federal Credit Union, OA 60N th a ?t?.?ell3P 34 IS `",`, 469 46.45)`re It, CILV 2,3114 12_4- aocilak (A)r--[ J&r3L (4) and enter this writ in the judgment index (a) against Kimberly HILL Theodore Productions and (b) against Members' 1st Federal Credit Union, as garnishee(s) as a lis pendens against real property of the defendant in name of garnishee as follows: (Specifically described property) Respectfully Submitted, TSAROUHIS LAW GROUP DEMETRIOS H. TSAROUHIS Attorney for Plaintiff Attorney ID # 88513 21 S. 9th Street Allentown, PA 18102 610-439-1500 DATE: June 4, 2014 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net FEDERATED FINANCIAL Vs. KIMBERLY HILL, THEODORE PRODUCTIONS WRIT OF EXECUTION (Pa R.C.P. 3252) NO 14-2833 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against KIMBERLY HILL, THEODORE PRODUCTIONS, 162 KEN -LIN DRIVE, CARLISLE, PA 17015 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; ALL PERSONAL PROPERTY AND ALL BUSINESS PROPERTY LOCATED AT 162 KEN -LIN DRIVE, CARLISLE, PA 17015. (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of MEMBERS 1ST FEDERAL CREDIT UNION, 5000 LOUISE DRIVE, MECHANICSBURG, PAGARNISHEE(S), as garnishee, ATTACH ANY AND ALL FUNDS AND ASSETS OF THE DEFENDANT FOUND IN THE POSSESSION OF GARNISHEE. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as 1 determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $24,538.14 Interest POST JUDGMENT INTEREST - $10,193.08 Plaintiff Paid Attorney's Comm. % Attorney Paid $409.50 Date: 7/28/14 Law Library $.50 Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary REQUESTING PARTY: Name : DEMETRIOS H. TSAROUHIS, ESQUIRE Address: TSAROUHIS LAW GROUP 21 S. 9T11 STREET ALLENTOWN, PA 18102 Attorney for: PLAINTIFF Telephone: 610-439-1500 Supreme Court ID No. 88513 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OF THE PRO -II -Whig -TAR 7 aoutr of Climbr lobo 2014 AUG -.6 4H 9: 50 CUMBERLAND COUNTY PENNSYLVANIA OFFICE OF THE SHERIFF Federated Financial vs. Kimberly Hill (et al.) Case Number 2014-2833 SHERIFF'S RETURN OF SERVICE 08/04/2014 11:27 AM - William. Cline, 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, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Nicole Martin, Manager, personally six copies of interrogatories together with six true and attested copies of the Writ of Execution and made the contents there of known to her. August 05, 2014 (c) CounlySuito Sheriff, Toleosoft, Inc. WILLIAM CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy To Whom It May Concern: tv .ot Cuitibett OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 RICHARD W. STEWART Solicitor -0 rrl C/) J rri r_ September 08, 2014 -<> < c., Federated Financial vs Kimberly Hill, Theodore Productions Writ No. 2014-2833 Property Claim Deteimination Reference is made to Property Claim filed August 28, 2014, entered by Theodore Hill, Cumberland County Writ No. 2014-4-2833, Federated Financial vs Kimberly Hill, and Theodore Productions. Ronny R. Anderson, Sheriff, has detemlined that the claimant, Theodore Hill, in the above mentioned property claim, is the owner of the property set forth in the claim. cc Theodore Hill, Claimant Kimberly Hill, Defendant Demetrios Tsarouhis, Attorney for Plaintiff So Answers: . Afi.gn, Shen - By CO NOTICE OF PROPERTY CLAIM Federated Financial VS Kimberly Hill, Theodore Productions In the Court of Common Pleas Cumberland County, Pennsylvania Writ of Execution No. 2014-2833 TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Theodore Hill, claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 08-28-14 Cc Theodore Hill, Claimant Kimberly Hill, Defendant Demetrios Tsarouhis, Attorney for Plaintiff of Cumberland County By ' PROPERTY CLAIM , r1 €iQdC\cctqyu A-\\ 6ikeEco TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 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 r a- D\1K (VklOY)- b119_ 0 Red (-Om da((- - c_66d 10,bo ?) emk Qkcilio ky) dwcA ao,a0 \Qh\ek Eir.ii io.00 S,(\\(\ck,itmon 0 0 qp1,4-f4 v\ -2 -JD --oW( Pm 00 r( THE CFT OBTAINED 7'0 THE PROPERTY AS FOLLQ QWS: , p tIkc- 0 \\PC419 \DAT.10i ) PUS1411_ /44° 11(\604ect ck.i\a& eiNA1 putO p ex -hi Date State of Pennsylvania: County of Cumberland cloohke above list in the property claim are co ct and true. 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