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Home My WebLink About14-4925 WRIT OF EXECUTION (MONEY JUDGMENTS) & ATTACHMENT P.R.C.P. 3101 TO 3149 rP ILI, Home for the Friendless d/b/a Writ No. 2014-CV-00474-CV,-., Homeland Center cz vs. Amount Due: $12,636.28 Sylvia J.Pfaff and Kenneth C.Pfaff,Jr. M C-- --U =�o (7) r- -C—� VS. INTERROGATORIES Cn r— r") C:) Debra K.Pfaff- Garnishee > F5 WRIT OF EXECUTION NOTICE This VaRer is a writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the iudgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these.rights. If you wish to exercise your rightsyou must act promptly. The law provides that certain property cannot betaken. Such,property is said to be exempt. There is a debtor's exemption of$300.00. There are other exeml2tions, which maybe applicable to you. Attached is a summary of some of the ,maior exemptions. You may have other exemptions or other rights. MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 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 If you have an exemption,you should do the following promptly: (1)Fill out the attached claim form and demand for a prompt hearing. (2)Deliver the form or mail it to the Sheriffs Office at the address noted. You should come to court ready to explain your exemption. If you do not come to court and prove your exemption, you may lose some of your property. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17101 V (717)232-7536 WRIT OF EXECUTION (MONEY JUDGMENTS) & ATTACHMENT . P.R.C.P, 3101 TO 3149 COMMONWEALTH OF PENNSYLVANIA,.COUNTY OF DAUPHIN CIVIL ACTION—LAW Home forAhe Friendless d/b/a Writ No. 2014-CV-00474-CV Homeland Center VS. Amount Due: $12,636.28 Sylvia J.Pfaff and Kenneth C.Pfaff,Jr. 5210 Meadowbrook Dr. COSTS Mechanicsburg,PA_17050 Plaintiff Paid: $223.00 VS. Interest: unliquidated Debra K.Pfaff Garnishee Sheriffs Costs: $125.79 5210 Meadowbrook Dr. Attorney: $3.00 Mechanicsburg,PA 17050 This Writ: $37.75 Attorneys Commission: unliquidated Costs: $487.75 INTERROGATORIES TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs against Kenneth C. Pfaff,Jr. and Sylvia J. Pfaff, Defendant(s). (1) You are directed to levy upon the property of the defendants) and to sell his, her(or their) interest therein. (2) You are also directed to attach the property of the defendant not levied upon in the possession of Debra K. Pfaff- 5210 Meadowbrook Drive, Mechanicsburg, PA 17050 as Garnishee(s) as follows: SEE ATTACHED INSTRUCTIONS TO CUMBERLAND COUNTY PROTHONOTARIES AND SHERIFFS. and to notify the Gamishee(s)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 and from delivering any property of the Defendant or otherwise disposing thereof, (c) the attachment shall not include any funds in an account of the Defendant with a bank or other financial institution (i) in which 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, or(i) the first $10,000 of each account of the Defendant 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 execution, levy or attachment under Pennsylvania or Federal law. (ii) each account of the Defendant with a bank or other financial institution in which funds on deposit exceed $10,000 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, lev or attachment under Pennsylvania or Federal law. y (ill) any funds in an account of the Defendant 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. Sect. 8123. (3) if property of Defendant 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. WITNESS, the Honorable Todd A. Hoover, President Judge of the Court of Common Pleas Dauphin County at the City of Harrisburg, Tuesday,August 19,2014. of Stephen E. Farina, Prothonotary By: . Requesting Party Bradford Dorrance, Esquire 417 Walnut St., 4th fl. PO Box 11963 Harrisburg, PA 17108 (717) 255-8014 AND NOW, Writ Re-Issued Stephen E. Farina, Prothonotary t HOME FOR THE FRIENDLESS IN THE COURT OF COMMON PLEAS d/b/a HOMELAND CENTER, OF DAUPHIN COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION--LAW SYLVIA J. PFAFF and KENNETH C. PFAFF, JR. , Defendants No. 2014-CV-474-CV and M & T BANK and DEBRA K. PFAFF, Garnishees INSTRUCTIONS TO PROTHONOTARIES AND DAUPHIN COUNTY AND CUMBERLAND COUNTY SHERIFFS The Prothonotary is requested to list on the Writ of Attachment, and the Sheriff is instructed to attach and garnish the following: 1. All money due either defendant from either garnishee. 2. All accounts of either defendant in either garnishee's possession including savings, checking, and other accounts, certificates of deposit, notes receivable, collateral, pledges, documents of title, securities, coupons, and safe deposit boxes. The Dauphin County Sheriff is requested to: 1, Serve the accompanying Interrogatories in Attachment on Garnishee, M & T Bank, 213 Market Street, Harrisburg, PA 17101; and 2. Deputize the Cumberland County Sheriff to serve the accompanying Interrogatories in Attachment on Garnishee, Debra K. Pfaff, 5210 Meadowbrook Drive, Mechanicsburg, PA 17050, and the accompanying Plaintiff' s Post- Judgment Interrogatories Addressed to Defendants and Plaintiff's Post-Judgment Request for Production of Documents Addressed to Defendants, Sylvia J. Pfaff and Kenneth C. Pfaff, Jr. , c/o Kenneth C. Pfaff, Jr. , 5210 Meadowbrook Drive, Mechanicsburg, PA 17050 (individually and as power of attorney/agent for Sylvia J. Pfaff) . KEEFER WOOD ALLEN & RAHAL, LLP DATE: �Ol radford Dorrance ID# 32147 417 Walnut St. 4th Floor Rear P.O. Box 11963 Harrisburg, PA 17108-1963 Phone (717) 255-8014 Fax (717) 255-8042 Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FLED -OF F i Sheriff `, t THE f R O! H O N E? i A l` tiE�ttr tit Coolforr1 Jody S Smith Chief Deputy 2014 AUG 27 PM 3: 5 Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA OFF CF., OF THE S'MERIFF it/ - Y9a-S Home for the Friendless d/b/a Homeland Center vs. Case Number Sylvia Pfaff (et al.) 2014 -CV -00474 -CV SHERIFF'S RETURN OF SERVICE 08/26/2014 07:24 PM - Shawn Gutshall, 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, Debra K. Pfaff, 5210 Meadowbrook Drive, Hampden Township, Mechanicsburg, PA 17050, Cumberland County, by handing to Kenneth Pfaff, Jr., husband, 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 him. The writ of execution and notice to defendant was mailed on August 27, 2014 to Kenneth Pfaff Jr., at 5210 Meadowbrook Drive, Mechanicsburg, PA 17050; and to Sylvia Pfaff c/o Kenneth C. Pfaff, Power of Attorney at 5210 Meadowbrook Drive, Mechanicsburg, PA 17050. • August 27, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. SO ANSWERS, RONNY R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLANDtOUN MIS 21 FP3 3' 59 OFFICE OF THE $IERIFF Home for the Friendless d/b/a Homeland Center vs. Sylvia Pfaff (et al.) Case Number 2014 -CV -00474 -CV SHERIFF'S RETURN OF SERVICE 08/26/2014 07:24 PM - Shawn Gutshall, Deputy, being duly sworn according to law, states that on August 26, 2014 at 7:24 PM hours, served the requested Writ of Execution; Claim for Exemption Form; two (2) copies of Plaintiffs Post -Judgment Request for Production of Documents Addressed to Defendants; and two (2) copies of Plaintiffs Post -Judgment Interrogatories Addressed to Defendants by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Kenneth C Pfaff, Jr at 5210 Meadowbrook Drive, Hampden Township, Mechanicsburg, PA 17050, and informed Defendant of contents of same. August 27, 2014 (c) CQ^untySui e Sheriff, Teleosoft, Inc. fl s 'GUTS DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF THE SME'i,',IFF THE r RO HONOTAR 2014 AUG 27 PM 3: 59 CUMBERLAND COUNTY PENNSYLVANIA Home for the Friendless d/b/a Homeland Center vs. Case Number Sylvia Pfaff (et al.) 2014 -CV -00474 -CV SHERIFF'S RETURN OF SERVICE 08/26/2014 07:24 PM - Shawn Gutshall, Deputy, being duly sworn according to law, states that on August 26, 2014 at 7:24 PM hours, served the requested Writ of Execution; Claim for Exemption Form; two (2) copies of Plaintiffs Post -Judgment Request for Production of Documents Addressed to Defendants; and two (2) copies of Plaintiffs Post -Judgment Interrogatories Addressed to Defendants by "personally" handing a true and attested copy to a person representing themselves to be the Power of Attorney for Sylvia Pfaff, to wit: Kenneth C Pfaff, Jr at 5210 Meadowbrook Drive, Hampden Township, Mechanicsburg, PA 17050, and informed Defendant of contents of same. UTS , DEPUTY SHERIFF COST: $135.28 SO ANSWERS, August 27, 2014 (C) CountySulto Sheriff, Teieosoft, Inc. RONR ANDERSON, SHERIFF