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COMMONWEALTH OF PENNSYLVANIA Notice of Judgmenrnscript Civil
06UNTY OF CUMBERLAND
Case
Mag. Dist. No: MDJ-09-1-01 Lower Alleri Township Authority
MDJ Name: Honorable Charles A. Clement Jr.
V.
Address: 920 Linda Lane Chang & Sun Yi. Chon
Camp Hill, PA 17011
Telephone: 717-737-3434
Steven Paul Miner, Esq. Docket No: MJ-09101-CV-0000085-2014
Daley Zucker Meilton ET AL Case Filed: 3/14/2014
635 N 12TH St Ste 101
Lemoyne, PA 17043-1225
Disposition Summary (cc-Cross Complaint)
Docket No Plaintiff Defendant Disposition Disposition Date
MJ-09101-CV-0000085-2014 Lower Allen Township Authority Chang&Sun Yi Chon Default Judgment for Plaintiff 04/25/2014
Judgment Summary
Participant Joint/Several Liability Individual Liability Amount
Chang&Sun Yi Chon $0.00 $5,693.96 $5,693.96
Lower Allen Township Authority $0.00 $0.00 $0.00
Judgment Finding (*Post Judgment)
In the matter of Lower Allen Township Authority vs. Chang & Sun Yi Chon on MJ-09101-CV-0000085-2014, on 4/25/2014 the
judgment was awarded as follows:
Judament Component Joint/Several Liability Individual Liability Deposit Applied Amount
Civil Judgment $0.00 $5,033.93 $5,033.93
Attorney Fees $0.00 $500.00 $500.00
Costs $0.00 $160.03 $160.03
Grand Total: $5,693.96
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH
THE PROTHONOTARYICLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF
JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES,IF THE JUDGMENT
HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE
COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A
REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
pun o�^n
Date' Magisterial District Judge Charles A.Clement Jr. :;
certify that this is a true and correct copy of the record of the proceedings conta.n g t e lu gment.
Date Magisterial District Judge
MDJS 315 Page 1 of 2 Printed:04/28/2014 11:48:49AM
f " Lower Allen Township Authority Docket No.: MJ-09101-CV-0000085-2014
a V
Chang & Sun Yi Chon
Participant List
Plaintiff(s)
Lower Allen Township Authority
120 Limekiln Road
New Cumberland, PA 17070
Defendant(s)
Chang&-Sun Yi Chon
4943 Gettysburg Road
Mechanicsburg, PA 17055
Complainant's Attorneys)
Steven Paul Miner, Esq.
Daley Zucker Meilton ET AL
635 N 12TH St Ste 101
Lemoyne, PA 17043-1225 ^`
ins
c31,asCt
a
MDJS 315 Page 2 of 2 Printed:04/28/2014 11:48:49AM
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. 3101 TO 3149
IN THE COURT OF COMMON PLEAS OF c:�
CUMBERLAND COUNTY, PENNSYLVANIA 2 -7;
Lower Allen Township Authority, No. 2014-3395Imi-
s� -T1
120 Limekiln Road =--or•:1
New Cumberland, PA 17070 Amount Due $5,693.96
(pr.'
D u1 c'�
vs. Interest$52.42 CD
Chang and Sun Yi Chon Atty's Comm. $1,000.00 3} c " ^t r=a
_..44 ......4 .31'
4943 Gettysburg Road ...t, ra
Mechanicsburg, PA 17055 and Costs $178.50
TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MANNER,
(1) Directed to the Sheriff of Cumberland County, Pennsylvania;
(2") against Chang and Sun Yi Chon, 4943 Gettysburg Road, Mechanicsburg, PA 17055, Defendants and
(3) against Susquehanna Bank, 3599 Gettysburg Road, Camp Hill, PA 17011, Garnishee;
(4) and index this writ
(a) against Chang and Sun Yi Chon, 4943 Gettysburg Road, Mechanicsburg, PA 17055,
Defendants and
(b) Susquehanna Bank, 3599 Gettysburg Road, Camp Hill, PA 17011, Garnishee,
As a lis pendens against the real property of the Defendants in the name of Garnishee as follows:
(5)
Dated:
Exemption has not been waived
$aq.00 Pp Am/
3P.0.5 CBF
190.95 -PD 11111
.50 LL
cif 1337ag8 9105
r2* 309'428
Steven P. 'ner, Esquire
DALEY Z CKER
MEILTON & MINER, LLC
Attorney I.D. No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer@dzmmlaw.com
Attorney for Plaintiffs
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
LOWER ALLEN TOWNSHIP AUTHORITY
120 Limekiln Road
New Cumberland, PA 17070
Vs.
Term
CHANG and SUN YI CHON
4943 Gettysburg Road
Mechanicsburg, PA 17055
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 2014-3395 Civil
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against CHANG and SUN YI CHON, 4943 Gettysburg Road,
Mechanicsburg, PA 17055, Defendant (s)
(1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein;
(2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of
SUSQUEHANNA BANK, 3599 Gettysburg Road, Camp Hill, PA 17011, GARNISHEE(S), as garnishee,
(Specifically describe property) and to notify the garnishee that as a lis pendens against the real property of the
Defendants in the name of Garnishee
(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
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 $5,693.96
Interest -- $52.42
Attorney's Comm. $1,000.00
Attorney Paid $60.25
Date: 8/5/14:.
Plaintiff Paid
Law Library $.50
Due Prothonotary $2.25
Other Costs $ 178.50
David D. Buell, Prothonotary
REQUESTING PARTY:
Name : STEVEN P. MINER, ESQUIRE
Address: DALEY ZUCKER MEILTON & MINER, LLC
635 N. 12T11 STREET, SUITE 101
LEMOYNE, PA 17043
Attorney for: PLAINTIFF
Telephone: 717-724-9821
Supreme Court ID No. 38901
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
Deputy
2
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
THE PRO T HONOTAR'r
2014 AUG 25 AM 1,3: 0 3
CUMBERLAND COUNTY
PENNSYLVANIA
Lower Allen Township Authority
vs.
Chang Mun Chon (et al.)
Case Number
2014-3395
SHERIFF'S RETURN OF SERVICE
08/15/2014 03:00 PM - Dennis Fry, Deputy, who being duly sworn according to law, attached as herein commanded all
goods, chattels, rights, debts, credits, and monies of the Defendants, in the hands, possession, or control
of the within named garnishee, Susquehanna Bank, 1196 Walnut Bottom Road, South Middleton
Township, Carlisle, PA 17013, Cumberland County, by handing to Rachel L. Boore, Customer and
Financial service representative, 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.
The writ of execution and notice to defendant was mailed on August 18, 2014 to Chang Chon at 4943
Gettysburg Road, Mechanicsburg, PA 17055 and to Sun Yi Chon at 4943 Gettysburg Road,
Mechanicsburg, PA 17055.
August 18, 2014
(c) CountySuite Sheriff, Teleosoft, inc.
DENNIS FRY, D
SO ANSWERS,
RONK'? R ANDERSON, SHERIFF
Steven P. Miner, Esquire
DALEY ZUCKER
MEILTON & MINER, LLC
Attorney I.D. No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer@dzmmlaw.com
HO,•GT,1,
Uf'fBFn'LhFi
PEN'NSYL ANIAN1
Lower Allen Township Authority
Plaintiff,
v.
Chang and Sun Yi Chon
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: Docket No. 2014-3395
Ser
INTERROGATORIES TO GARNISHEE
TO: Susquehanna Bank
3599 Gettysburg Road
Camp Hill, PA 17011
You are required to file answers to the following interrogatories within twenty (20) days
after service upon you. Failure to go so may result in judgment against you:
1. At the time you were served or at any subsequent time did you owe the defendant any
money or were you liable to the defendant on any negotiable or other written instrument, or did
the defendant claim that you owed the defendant any money or were liable to the defendant for
any reason?
No.
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 and one or more other
persons any property or any nature owned solely or in part by the defendant?
No.
3. At the 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 or in which defendant held or
claimed any interest?
No.
4. At the time you were served or at any subsequent time did you hold as fiduciary any
property in which the defendant had an interest?
No.
5. At any time before or after you were served did the defendant 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 therefore?
Prior to service, the defendants received a loan from the bank.
The loan is secured by liens against real estate in Cumberland
County, Pennsylvania, 'all inventory, chattel, papers, accounts
equipment, general intangibles and fixtures. The loan remains
outstanding. One payment of $27,303.56 was received since service
which was applied as a regular payment.
6. At any time after you were served did you pay, transfer or deliver any money or property
to the defendant or to any person or place pursuant to the defendant's direction or otherwise
discharge any claim of the defendant against you?
No.
•
7. If you are a bank or other financial institution, at the time you were served or at any
subsequent time did the defendant have funds on deposit in an account in which funds are
deposited electronically on a recurring basis and which are identified as being funds that upon
deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so,
identify each account and state the reason for the exemption, the amount being withheld under
each exemption and the entity electronically depositing those funds on a recurring basis.
No.
8. If you are a bank or other financial institution, at the time you were served or at any
subsequent time did the defendant have funds on deposit in an account in which the funds on
deposit, not including any otherwise exempt funds, did not exceed the amount of the general
monetary exemption under 42 Pa. C.S. § 8123? If so, identify each account.
No.
(a) Identify all documents that were given to the Bank or signed for the Bank
establishing the account.
N/A
Dated:
(b) State the Bank's understanding of the legal composition of its customer and
identify all documents the Bank has that showed that legal composition.
N/A
(c) State all addresses given for the Bank's customer and all addresses to which the
account statements were to be sent.
N/A
Respectfully Submitted,
DALEY ZUCK
MEILTON &
ER, LLC
Steven ' . Miner, Esquire
Attorn y I.D. No. 38901
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
sminer@dzmmlaw.com
Attorney for Plaintiff
VERIFICATION
I, William H. Finlay, verify that the facts set forth in these Garnishee's Answers to
Interrogatories are true and correct to the best of my knowledge, information, and belief. This
statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. §
4904) related to unsworn falsification to authorities.
Dated: August 21, 2014
H. Finlay,
Associate Counsel
Susquehanna Bank
26 North Cedar Street
Lititz, Pa 17543
(717) 625-6554