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
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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
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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.
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Date1424)11
Cumberland County Bar Association
34 S. Bedford Street
Carlisle, Pennsylvania -
telephone number 717-249-3166
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(Name of Prothonotary Clerk)
(Deputy)
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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,
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(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
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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
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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
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THE CFT OBTAINED 7'0 THE PROPERTY AS FOLLQ
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State of Pennsylvania:
County of Cumberland
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above list in the property claim are co ct and true.
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being duly sworn according to law; deposes and says that the
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CLAUDIA A. BRBVBAKEIVIIIITAIIY PUBLIC
Carlisle Boro, Cumberland County
My Commission Expires April 4, 2017
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