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HomeMy WebLinkAbout05-1907 . , BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (/5> /q07 6:JJ LL Attorneys for Plaintiff CAROLINA BUILDERS CORPORATION t/dIb/a CHARLES C. LOOSE AND SON, COURT OF COMMON PLEAS OF LEBANON COUNTY, PENNSYL V ANlA CIVIL ACTION - LAW Plaintiff v. 05 -:.3{)() ,/ No. 2003-01774 !., ~" HARRY L. SMITH & SONS, INC. and HARRY L. SMITH, Individually, Defendants '" ^ -,- l r:.;l u) .0 RAGHU T ADA V ARTHY and JYOTHIP. TADAVARTHY, Garnishees WRIT OF EXECUTION This paper is a Writ of Execution. It has been issued because there is ajudgment ag inst you. It may cause your property to be held or taken to pay the judgment. You may have Ie! al rights to prevent your property frorn being taken. A lawyer can advise you more specificall of these rights. If you wish to exercise your rights, you must act promptly. The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of $300. There are other exemptions which may be applicable to you. Attached is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following promptly: (I) Fill out the aU ched claim form and demand for a prompt hearing. (2) Deliver the form or mail it to the Sheriff Office at the address noted. 1374574-1 1 ,......- ~ .;; , ., .J , "' --,., r- !~ c:;; You should come to court ready to explain your exemption. If you do not come to urt and prove your exemption, you may lose some of your property. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 0 NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELO THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LA ER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCmS THAT MAY OFFER LE SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 1374574-1 2 " .. BARLEY SNYDER LLC Sbawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff CAROLINA BUILDERS CORPORATION tJdlb/a CHARLES C. LOOSE AND SON, COURT OF COMMON PLEAS OF LEBANON COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff v. os - .j7)[)I( No. 2003-01774 HARRY L. SMITH & SONS, INC. and HARRY L SMITH, Individually, Defendants RAGHUTADAVARTHYand JYOTHIP. TADAVARTHY, Garnishees WRIT OF EXECUTION - (Money Judgment) (Pa. R.C.P. 3101 to 3149 and 3252) COMMONWEALTIl OF PENNSYLVANIA COUNTY OF LEBANON TO TIlE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and cost against Harry L. Smith & Sons. Inc. and Harry L. Smith. Individuallv, Defendants (I) You are directed to levy upon the property of the defendants and to sell their interest therein; (2) You are directed also to attach the property of the defendants not levied npon in the possession ofB, Jl!! Tadavarthv and Jvothi P. Tadavarthy, as garnishees and to notify the garnishees (a) that an attachment has been issued; and (b) that the garnishees are etUoined from paying any debt to or for the account of the defendan and from delivering any property of the defendants or otherwise disposing thereo[ (3) If property of the defendants not levied upon and subject to attachment is found in the possession of anyone other than the named garnishees, you are directed to notify him that he has been added as a garnishe and is enjoined as above stated. XX Affidavit of Non-Military Service Filed. Dated: 1174'\74_1 1 M. Lone: Es uire Attorneys for Plaintiff Court ID. No. 83774 126 East King Street Lancaster. P A 17602-2893 (717) 299-5201 Judgment Amount remaining Judgment Costs Interest from 2/28/05 to 3/15/05 at 1.5% per month ($21.4 I per diem) Prothonotary Costs Sheriff's Cost $43,418,01 . ll1.5G 32I.I5 $ $ ;20) DeL.!"", Prothonotary, Court of Common Peas . 3,. Tl - M l-- ~:thonotary o$: trtttn;lt;t. / t1/J Y, r '---!1 ~ ~ &!JrP foth~t; . MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW I. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirernent funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as rnay be provided by law 1374574-1 1 . BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff CAROLINA BUILDERS CORPORATION t/d/b/a CHARLES C. LOOSE AND SON, COURT OF COMMON PLEAS OF LEBANON COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff v. No. 2003-01774 HARRY L. SMITH & SONS, INC. and HARRY L. SMITH, Individually, Defendants RAGHU T ADA V ARTHY and JYOTHIP. TADAVARTHY, Garnishees CLAIM FOR EXEMPTION To the Sheriff: I, the above-named defendant, claim exemption of property from levy or attachment: (1) From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be (i) set aside in kind (specify property to be set aside in kind): ............................................. .............................................., (ii) paid in cash following the sale of the property levied upon; r (b) I claim the following exemption (specify property and basis of exempti n: ............................................................................................, (2) From my property which is in the possession of a third party, I claim the following exemptions: 1374574-1 I ~ (a) my $300 statutory exemption _ in cash; _ in kind (specify property): ................................................ ............................................. (b) Social Security benefits on deposit in the amount of $. . . . . . . . . . . . . . . . .. . (c) other (specify amount and basis of exemption):.......... .. ......." "....... I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at ... ................... ........... ..................... ..........................., (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 49 4 relating to unsworn falsification of authorities. Date:................................... (Defendant) THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY Cumberland County Sheriff's Office Cumberland County Courthouse One Courthouse Square Carlisle,PA 17013-3387 1374574-1 2 Z~ :0\ ~ ~ ~ !A -'0 0<\ . "'\ c') ...1 ~:i - i.....Jj .1'-' ~ \'i ..J _" _" -' ;.,..... ..J_,oJ 0-" \ ~ ~ ~ l -.c\ <:.l\ ~ ~ r c...: ~ ~ s ~ (' '---" ~ j?~; -< r-> \:::;:~ c.-' (.',-,""1 or- ~) ,p -c' :;:J: i)? f'.) -' f R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pdne Sale Certified Mail Postage Garnishee TOTAL So Answers; 2006 AD. 18.00 2.46 Advance Costs: 225.00 Sheriffs Costs 125.06 99.94 25.50 11.10 Refunded to Atty on 01106/06 30.00 20.00 18.00 125.06 Sworn and Subscribed to before me ~~~~ R. Thomas Kline, Sheriff ,/ BC~Qll~~b~ D '" "'- -..() '" --...\ UOLUO ~ ~ ~.1j) ~ U FlU ~~:b1 ~O hJU)OUOLU~: '11 - <1'f" S1!~d UOUIUlO;) JO l-ffiO;) 'A..I11l0UOl{jOld c:f})9 . (0<::: - $ \SO:) S JJf1~qS $ SjSO:) AreIOUOl\+Old (UI~!p rod I t'l Z$) l:\>UOUI lod %,'1 I~ ,01, lit 01 ,0ISZlZ wOJ]: IS~101ur Sjso:) ltI:luUlpn[ ilUfU!mll'lIUllOWY lu.uUlpn[ ,I'lcE 1OZ,-66Z \L lL! t6SZ-Z09L I V d 'l'IS~ou~l 1"lIS c1I!)!lSB3: 9Z1 PUtS 'oN 'ill jlllo:J., JJ!)urnld 10J sAowollX(' ;;lnTI sg rro'l. .~~. .,,;-AM :.",;'jf OS'll! , [O'S It'tt$ . ., BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 f'4(')')/ I 9D 7 Attorneys for Plaintiff / CAROLINA BUILDERS CORPORATION tJdIb/a CHARLES C. LOOSE AND SON, COURTOFCO~ONPLEASOF LEBANON COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff v. 05 -.J'{Jo-r I No. 2003-01774 HARRY L. SMITH & SONS, INC. and HARRY L. SMITH, Individually, Defendants RAGHU TADAVARTHY and JYOTHI P. TADA V ARTHY, Garnishees WRIT OF EXECUTION - (Money Judgmeut) (pa. R.C.P. 310 I to 3149 and 3252) COMMONWEALTII OF PENNSYLVANIA COUNTY OF LEBANON TO TIlE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and cost against Harry L. Smith & Sons. Inc. and Harry L. Smith. Individuallv. Defendants (I) You are directed to levy upon the property of the defendants and to sell their interest therein; (2) You are directed also to attach the property of the defendants not levied upon in the possession of Raehu Tadavarthv and Jvothi P. Tadavarthv. as garnishees and to notify the garnishees (a) that an attachment bas been issued; and (b) that the garnishees are enjoined from paying any debt to or for the account of the defendants and from delivering any property of the defendants or otherwise disposing thereof. (3) If property of the defendants not levied upon and subject to attachment is found in the possession of anyone other than the named garnishees, you are directed to notify him that he has been added as a garnishee and is enjoined as above stated. XX Affidavit of Non-Military Service Filed. Dated: . 1374574-] .-, I BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.399.1512 t~ fr i5~ .,. fi,~ { ,- ,t , jf ~~~y 2010 ,.~;~' 22 ~~ I r 4 S ~ ~-`i.`I ~F~ ~~ ~ <~ ~ L„ ,, ~r .,fry. Attorneys for Plaintiff CAROLINA BUILDERS CORPORATION t/d/b/a CHARLES C. LOOSE AND SON, Plaintiff v. HARRY L. SMITH & SONS, INC. and HARRY L. SMITH, Individually, Defendants and RAGHU TADAVARTHY and JYOTHI P. TADAVARTHY, Garnishees COURT OF COMMON PLEAS OF ~ ~u n i.Tni.r rnr nr•ry~ pENNSYLVANIA CIVIL ACTION -LAW No. 2003-01774 Cumberland County Docket No. 05-1907 v PRAECIPE TO DISSOLVE ATTACHMENT/GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment/garnishment against Raghu Tadavarthy and Jyothi P. Tadavarthy in the above-captioned matter. BARLEY SNYDER ~ By: fawn M. Long, Esquire Attorneys for Plaintiff Court I.D. No. 83774 126 East King Street ~. ~ p p Amy Lancaster, PA 17602-2893 c* r}~,y ~o't.'7 (717) 299-5201 E'~o'iy5(c~(oa aa63oo9. ~