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Home My WebLink About14-3397 COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND ,- Case Mag. Dist. No: MDJ-09-1-01 Lower Allen Township Authority MDJ Name: Honorable Charles A. Clement Jr. V. Address: 920 Linda Lane Jeffrey L Frymoyer Camp Hill, PA 17011 Telephone: 717-737-3434 Steven Paul Miner, Esq. Docket No: MJ-09101-CV-0000089-2014 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-0000089-2014 Lower Allen Township Authority Jeffrey L Frymoyer Default Judgment for Plaintiff 04/25/2014 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Jeffrey L Frymoyer $0.00 $2,250.83 $2,250.83 Lower Allen Township Authority $0.00 $0.00 $0.00 Judgment Finding ("Post Judgment) In the matter of Lower Allen Township Authority vs. Jeffrey L Frymoyer on MJ-09101-CV-0000089-2014, on 4/25/2014 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $1,648.80 $1,648.80 Attorney Fees $0.00 $500.00 $500.00 Costs $0.00 $102.03 $102.03 Grand Total: $2,250.83 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. 4/25/2014 Date Magisterial District Judge Charles A.Clement Jr. certify that this is a true and correct copy of the reco ofl t ee procee rags co aining the judgment. Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed:04/28/2014 11:53:46AM Lower Allen Township Authority Docket No.: MJ-09101-CV-0000089-2014 V. Jeffrey L Frymoyer A Participant List Plaintiff(s) Lower Allen Township Authority 120 Limekiln Road New Cumberland, PA 17070 Defendant(s) Jeffrey L Frymoyer 312'Pirift6od Drive Camp Hill, PA 17011 err+ Complainant's Attorney(s) N Steven Paul Miner, Esq. Daley Zucker Meilton ET AL y 0 C-- 635 N 12TH St Ste 101 VG (: Lemoyne, PA 17043-1225 W , N c) MDJS 315 Page 2 of 2 Printed:04/28/2014 11:53:46AM PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 TO 3149 Lower Allen Township Authority, 120 Limekiln Road New Cumberland, PA 17070 vs. Jeffrey Frymoyer 312 Pinewood Drive Shiremanstown, PA 17011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2014-3397 Amount Due $2,250.83 Interest $20.72 Atty's Comm. $500.00 and Costs $178.50 • _ rn a' cn —+n • cD -ri tv `err •---4 N.) 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 Jeffrey Frymoyer, 312 Pinewood Drive, Shiremanstown, PA 17011, Defendant and (3) against Metro Bank, 3201 Trindle Road, Camp Hill, PA 17011 , Garnishee; (4) and index this writ (a) against Jeffrey Frymoyer, 312 Pinewood Drive, Shiremanstown, PA 17011, Defendant and (b) Metro Bank, 3201 Trindle Road, Camp Hill, PA 17011, Garnishee, As a lis pendens against the real property of the Defendant in the name of Garnishee as follows: (5) Exemption has not been waived Dated: 7 (vJ( 4 aq.o0 pp f -rry' 31. a5 CBF �p a5 pry a.as flue°% 5o LL aft-733rioicia4A E 309 ,F30 ,Uri+0 -oQ Steven P finer, Esquire DALEY UCKER 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 JEFFREY FRYMOYER 312 Pinewood Drive Shiremanstown, PA 17011 WRIT OF EXECUTION (Pa R.C.P. 3252) NO 2014-3397 Civil CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against JEFFREY FRYMOYER, 312 Pinewood Drive, Shiremanstown, PA 17011, 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 METRO BANK, 3201 Trindle Road, Camp Hlll, 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. 1 (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 $2,250.83 Plaintiff Paid Interest -- $20.72 Law Library $.50 Attorney's Comm. $500.00 Due Prothonotary $2.25 Attorney Paid $60.25 Other Costs $178.50 Date: 8/5/14 David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : STEVEN P. MINER, ESQUIRE Address: DALEY ZUCKER MEILTON & MINER, LLC 635 N. 12TH STREET, SUITE 101 LEMOYNE, PA 17043 Attorney for: PLAINTIFF Telephone: 717-724-9821 Supreme Court 1D 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 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OF THE PROTHONOTARY KIR AUG f4 Alif1:146 CUMBERLAND COUNTY PENNSYLVANIA CII111tot OFF i„ E OF THE, "„ HERIFF Lower Allen Township Authority vs. Jeffrey L. Frymoyer Case Number 2014-3397 SHERIFF'S RETURN OF SERVICE 08/12/2014 02:45 PM - 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, Metro Bank, 20 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Terry Glass, Customer Service, personally three copies of interrogatories together with three 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 13, 2014 to Jeffrey L. Frymoyer at 312 Pinewood Drive, Shiremanstown, PA 17011. August 13, 2014 (c) County: uito Sheriff, Tcl=_osoft, Inc. LIAM CLINE, DE SO ANSWERS, RONNY R ANDERSON, SHERIFF Steven P. Miner, Esquire DALEY ZUCKER MEILTON 8:1V1INER, LLC Attorney LD, No. 3001 635 N. 1.21Street, Suite 101 Lemoyne, PA 17043 (717) 74-9821 sininer@cizimulnw.eom HLE0- PROTHONO 2t1tt SEP 12 1D'il 12: jL CUMBERLAND COUNT'( PENNSYLVANIA Lower Allen Township Authority Plaintiff, V. Jeffrey Fryinoyer Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 2014-3397 •ANYCZeia /C.) INTERROGATORIES TO GARNISHEE TO: Metro Bank 3201 Trindle 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 80 inay result iii 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 instrunient, or did the defendant claim that you .wed the defendant any money or were liable to the defendant for anyreason? Defendant has a balance of $10 , 069 . 52 2, At the time you Were scry., d 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.clid 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 atiy person or place pursuant to your direction or consent and if so what was the consideration. therefore? no 6. At any time after you wereserved did you pay, transfer or deliver any money or property to the defendant or to any person or place piirsuaiit 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 tunic 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. 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. (a) Identify all documents that were given to the Bank or signed for the Bank establishing the account. 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, (e) State all addresses:given for the Bank's customer and all addresses to which. the account statements were to be sent. Respectfully Submitted, DALEY ZUCK MEILTON & M ER, LLC Steven e , Mi lei, Esquirer Attor • y I,D..N.o. 38901 635 N, 12"' Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 =finer rr,dzmnnlaw.com Attorney.fin: Plaintiff VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. • ; . 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 O THE PRS i�O N�.' TT--rr �n i fl`� 71w 201 4 SEP 25 Pi,/ ,. CUMBERLAND COUNTY PENNSYLVANIA Lower Allen Township Authority Plaintiff, v. Jeffrey Frymoyer Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : Docket No. 2014-3397 PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROTHONOTARY: Please mark the judgment in the above -captioned matter SATISFIED of record and DISCONTINUE and END the above -captioned case. Dated: By: Respectfully submitted, DALEY ZUCKER MEILTON & MINER, LLC Steven P i her, Esquire Attorne I.D. No. 38901 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 sminer@dzmmlaw.com Attorney for Plaintiff Lower Allen Township Authority Plaintiff, v. Jeffrey Frymoyer Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : Docket No. 2014-3397 CERTIFICATE OF SERVICE I, Steven P. Miner, Esquire, hereby certify that on the date indicated below, I served a true and correct copy of the foregoing Praecipe for Satisfaction of Judgment via United States, First Class Mail, postage prepaid, upon the following: Dated: Melanie L. Vanderau, Esquire Mette, Evans & Woodside 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110 Attorney for Garnishee Jeffrey Frymoyer 312 Pinewood Drive Shiremanstown, PA 17011 Defendant By: Steven P. M. er, Esquire Attorney I. D . No. 38901 635 N. 12tStreet, Suite 101 Lemoyne, PA 17043 (717) 724-9821 sminer@dzmmlaw.com 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 1 PRO TIl` 0TA 1Glt,S C'(,,R, EP ZS P1�1 'TEFLA PENNSYLVANIA Lower Allen Township Authority Plaintiff, v. Jeffrey Frymoyer Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : Docket No. 2014-3397 PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Please mark the attachment against the Garnishee, Metro Bank, in the above -captioned matter as discontinued. Dated: By: Respectfully submitted, DALEY ZUCKER MEILTON & 1 ! ER, LLC Steven P Miner, Esquire Attorne I.D. No. 38901 635 N. 2th Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 sminer@dzmmlaw.com Attorney for Plaintiff Lower Allen Township Authority : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. Jeffrey Frymoyer Defendant : Docket No. 2014-3397 CERTIFICATE OF SERVICE I, Steven P. Miner, Esquire, hereby certify that on the date indicated below, I served a true and correct copy of the foregoing Praecipe to Discontinue Attachment Execution via United States, First Class Mail, postage prepaid, upon the following: Dated: Melanie L. Vanderau, Esquire Mette, Evans & Woodside 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110 Attorney for Garnishee Jeffrey Frymoyer 312 Pinewood Drive Shiremanstown, PA 17011 Defendant By: TyVL Steven P. iner, Esquire Attune I.D. No. 38901 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 sminer@dzmmlaw.com