The URL can be used to link to this page

Home My WebLink About05-2451 oaMMQ~WEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of QvrY1.bu-!GU)d NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. DS -~4S"' dDl-~"-1 NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. o KET No MAG. 0151. NO C'(-S-03> CITY UlI (JrcuY1 e(' ~nor-o.bk.l SUSCln STATE PA f(Dcz ZIP DE Ol~ N~AMJ OF APPELLANT IVI . 6. TafG ADDRESS OF APPELLANT /5(0 M u r-e.-S: C: DATE OF JUDGMENT A "II Iq 2.00S C.N'- OOOOO~2-05 v{ This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.G.P.D.J. No. 1001(6) in action R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL. Signalura of Prvlhooolary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appellant was DEFENDANT (see Pa.R.CPD.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon KOJ)d ~ lfOJY\U appellee(s), to file a complaint in this appeal ' -.--,vameofappellee(S) (Common Pleas No. --OS -;:)4 S; I (]t ~ ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. J82-Wj jlJl~ /f~~- Signature of appellant Of attorney or agent RULE: To ROJ\d~ Cfu,rne.r___, appellee(s) Name of appel/ea(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal seNice or by certified or registered mail. (2) if you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. p Cft2 ?r)~ Date('fL'J.-j J~. ,200S ~ 0--- n -~ ~f~fo~~ YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 COURT FILE TO BE FILED WITH PROTHONOTARY MUST BE PILED wrrf1IN TE;rv (10) DAYS AFTER filinfj ofille notice PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT Check COMMONVVLAL OF PENNSYLVANIA COUNTY OF ,33 AFFIDAVIT: thai i cory tho Notice of AppeaL Cornnlon Pleas No upon the DIstrict justlce by (certiHedJ (reglstered) mail, of by persona! service attached uDOn U10 appellee, (nwrm) bY personal service by AND SUBSCH!BEG 8EFORE DAY . 20 THIS tf -kj. ~ -- ~ r-- Lv ....0 ~ ~, t My CQmrT1iSS;On expires en 20 312/\ lhorein on (regiswred) mali, o c r--> = t.? eJ" ::rr: :L,.;.~ -- (~ .~ -- ~ boxes.) SiqnaiUJ"O of <Jffiant N o -n ...-\ ::]:-" fl1f:.7.; -,Jm -,r)O 7J(~' -rJ :fi~ ~~)1 .::\ ."..,.... ~D -< -,,"' -"\> r:? 0.) c:> COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBBRLABD NOTICE OF JUDGMENTfTRANSCRIPT CIVIL CASE 09-3-03 PLAINTIFF: ~II, URDY L 170 IlBD TAB RD BOXLXWG SPRIRGS, L NAME and ADDRESS I Mag. Disl. No.: MDJ Name: Hon SUSAJI' 1[. DAY Add'e" 229 KJ:LL ST, BOlt 167 ft. BOLLY SPRXWGS, PA PA 17007 -l VS. 17065 DEFENDANT: ITATE, MBRL E 156 KCCLUllBS GAP RD CARLXSLE, PA 17013 L NAME and ADDRESS Telephoce' (717) 486-7672 I MBIlL E. TATE 156 KCCLUllBS GAP RD CARLXSLE, PA 17013 Docket No.: CV-0000062-05 Date Filed: 3/08/05 -l 1& THIS IS TO NOTIFY YOU THAT: Judgment: l!'Oll. PT.ATII'l':J:l!'l!' [i] [i] Judgment was entered for: (Name) ~'D.II"II!D r D.a.1ft\V T. Judgment was entered against: (Name) TAT., _liT. . in the amount of $ 4.&:\9 411 on: (Date of Judgment) 411Q/05 . . o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice. (Date & Time) O Amount of Judgment Subject to Attachment/42 Pa.C.S. 98127 $ O Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 4.500.00 Judgment Costs $ 138.43 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 4.638.43 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY ALING A NonCE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NonCE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DlsmlCT JUDGES, IF THE JUDGEMENT 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 MAYBE 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. 1--/ ?-tJ5 Date , Magisterial District Judge Date proceedings containing the judgment. , Magisterial District Judge I certify that this is a true My commission expires first Monday of January, 2010 . SEAL AOPC 315-05 DATE PRXRTBD: 4/20/05 8:04:51 All U.S. Postal Service," CERTIFIED MAil,,, RECEIPT (DomeBfJc _ Only; No Insurance pnwld8dJ c~ s-:; .-.> = = <f' :r: ~:;. -J o -n .... ::I:-n mp -am ~?-]CJ (2(:> :r~"Jd ':-~} f~4 ~:1 -'0 :< Certilied Fee Return ReciepJ Fffe (Endorsement ReqLdred) Cl Aeslrj(.,'ted Delivery Fee M {Endorsement RHQuired} r'l rn $0.00 TOlal fJosfage & j~ees $...:.-~ ,. [l' g S.ntT:.sC{,SCVl j(' I-JCi.:/ ". ......7"-- r- ~;";/,Z:::~;i<j IJl)/ 5f~':~ ox '/21 , Cil~ ,'jIAe 2'iP~4,. / ~ \ 01.-)// ,I ,'" \- ) 1/0' 1..' ........)..)I/.":.j , ... / L-(Lj / <f! w ...J (This pi PROOF OF SERVICE OF NOnCE OF APPEAL AND RULE f::'tF:: FiLED W/THiN I i:,,:::rf';<' CCfMMONWEAi.TH OF PENNSYL VANIA 'UNTY OF C J(Y)W\o..nd ~"S AFFIDAVIT: i hemby (swear) (affirm) that l st:rved a <>JPY of the- Notice of Appeal, Common Picas No.O!5;"' -~'7t/,SI_ (,1ele of Sf!0/!Ce) ~ /7 ' :20 lJS . sender's recejpl attached hereto, ;:md upon the IX. KO.f:l;J {'vcl1'ile.r- ....l:?Q (tY ~~j;t r:'~)r l1[ached hero;~) D 5 0'1 pare".,,, !!;'iJORN) (i\FrIEMED) AND ;i,~8SCRIBED 8EFORF NIl, TH'2!71b. DiWOF If/a.-<j .20 Cr S!(:,,~~~,~!''i:~!H rc" '- /"c . ;ilK C'.: ......;1tr22- -~~~~-~.,~-~~*~"_.~~-**-~_._- T:>:0tofficia! AOPC :) 12A D r'l r'l m rn Cl SsntTo K _. ::2 Siii8i'A;;~,fr]C}~J:;'C9!!].~.Cu..........um. m'mm. orpo'BaxNO.' 170 Rc:.d Tc.nl( I'\d city:'Siais,-ZIP+4_"" .mO.._h... .,.h..., o. \ I Ii.e' SDY'inCS pH I7G07 U.S. Postal Service,. CERTIFIED MAil,,, RECEIPT (Domestic Meil Only; No Insurance Collersge ProVided) Mv commission expires on . Of PENNS NoIIri8I Sad Anpll F. U_. ~ Public ('Jfrilown 8orO P....k1in Count)' M elllllmlulon EXJlire' Oct. 1. 1008 Mtlmllllf. ~1l,,".vIY.n\. I\Osoc;;ll\IOn of - COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. NOTICE OF APPEAL Notice IS given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. NAME Of APPELLANT MAG OIST. NO. NAME OF D.J :.. I (i ADDRESS Of APPELLANT I I,;' l,. DATE OF JUDGMENT 1': i 1 'J ! i_c o KET No. CITY STATE ZIP aom' (DefeManl)' " SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT \J ,." I", f,:c i ,( This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.GP.D.J. No. 1001(6) in action R.C.P.D.J. No. 1008B. This Notice of Appeal, when receIved by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days alter filing the NOTICE of APPEAL. Signature of Prolflonolary or Deputy PRAECIPE TO ENTER RULE TO FilE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appellant was DEFENDANT (see Pa.R.CPD.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enterrule upon \-C..., I:'; (\ ' i ---",- -------t-- ,. appellee(s), to file a complaint in this appeal Name of appel/ee(s) (Common Pleas No. _~...2.i:l'::"_L-__:,=--ciL:L_ ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. ,-_I ",r~ Signature of appellant or attorney or agent ;.---J ,f r / .',.c;;,'( ~ _, I {' RULE: To J$a.nd \j ~(CU'Y 1 U"_ __ _ ___ I Name of appel/ee(s) , appellee{s) (1) You afe notified that a rule is hereby entered upon you to file a complaint (n this appeal within twenty (20) days after the date of service of this rule upon you bY.i='e~nal service,,?!': by certified or registered mail. (2) If you do notfrle a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The dat~:~_,service of this rule if service was by mail is the date of the mailing. Da;e }li::J. 'lj;;k ,20 OD .../ Sigf)8t~re of ~~tho~otaftl15rtiep~:~ YOU MUST INC\.U06 A COPY OF TIiE'NOTlCE OF JUDGMENTrrRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312,02 COURT FILE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-2451 Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW NOTICE TO DEFEND Pursuant to PA RCP No. 1018.1 You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief quested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOUW TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT BA VE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT BlRING 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 ELIGmLE PERSON AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 TELEPHONE (717) 249-3166 OR (800) 990-9108 Effective September 1, 2003 Complaint A visa PARA DEFENDER Conforme a P A RCP Num. 1018.1 USTED HA SIDO EEMANDADO/A EN LA CORTE. Si usted desea defender conta Ia demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (2) dias despues que esta Demanda y Avillo es servido, con entrando por escrito una aparencia personalmente 0 por un abodgado y archivando por escrito con Ia Corte sus defenses 0 objeciones alas demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un jazgamiento puede ser entrado contra usted por la Corte sin mas aviso por cualquier dinero reciamado en la Demanda 0 por cualquier otro reciamo 0 alivio solicitado por Demandante. Usted puede perder dinero o propiedad 0 otros derechos importante para usted. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO T1ENE UN ABOGADO, VA Y A 0 LLAME POR TELEFONO LA OFICINA FlJADA AQUI ABAJO. EST A OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADQ. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVlCIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARlO REDUCIDO 0 GRATIS. SERVICIO DE REFERIDO A ABOGADO COLEGIO DE ABOGADOS DEL CONDADO DE YORK ABOGACIA DEL CONDADO DE YORK CALLE MARKET #137 ESTE YORK,PENNSYLVANIA 17401 TELEFONO: (717) 854-8755 Efectivo I de septiembre, 2003 Queja 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-2451 Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW COMPLAINT AND NOW comes the Plaintiff, by and through his attorneys, Blakey, Yost, Bupp & Rausch, LLP, and files this Civil Complaint against Meryl Tate, and in support thereof, avers the following: I. Plaintiff, Randy L. Cramer is an adult individual residing at 170 Red Tank Road, Boiling Springs, PA 17007. 2. Defendant, Meryl Tate is an adult individual residing at 1560 McClures Gap Road, Carlisle, PA 17013. 3. In or around November of2003 the parties discussed the sale and purchase of a four-wheel recreational vehicle. 4. The discussion between the parties took place at Plaintiffs residence. 5. The vehicle in question is a 1998 Kawasaki four-wheeler, Vehicle Identification Number JKALFKB 18WB528535 6. Plaintiffs asking price for the vehicle was $4,500.00. 7. Plaintiff told Defendant that a third party was interested in purchasing the vehicle. 3 8. Defendant told Plaintiff that if third party decided not to purchase the vehicle, the Defendant was interested in purchasing it. 9. The third party contacted Plaintiff and stated that he was not interested in purchasing the vehicle. 10. Plaintiff contacted Defendant and said that the vehicle was available for purchase if Defendant was still interested. II. Defendant agreed to Plaintiff's purchase price for the vehicle and took possession of the vehicle on November 15,2003. 12. Defendant did not have the money to purchase the vehicle at time of possession. 13. Defendant stated that he was selling land, would settle no later than January 2004, and could pay the money for the vehicle at that time. 14. Plaintiff and Defendant orally agreed to the sale by Plaintiffto Defendant of the vehicle for $4500.00 and to Defendant's immediate possession ofthe vehicle. 15. The parties further agreed that payment for the vehicle would be made from Defendant to Plaintiff at the end of January 2004 for $4500.00. 16. Defendant still has possession of the vehicle. 17. Despite repeated demands, Defendants still have not paid Plaintiff the agreed upon purchase price and refuses to do so. 18. While in Defendant's possession, the vehicle was damaged by Defendant. 19. On several occasions between January 2004 and October of 2004, Defendant made statements to third parties admitting he and Plaintiff agreed upon the purchase price. 2 20. The amount claimed by Plaintiff is below the jurisdiction limits in Cumberland County requiring arbitration. WHEREFORE, Plaintiff demands judgment against the Defendant in the amount of $4,500.00 plus interests, costs of suit, and any other damages this Honorable Court deems just and proper. COUNT I BREACH OF CONTRACT 21. Plaintiff incorporates paragraphs] -20 herein as if set forth in their entirety. 22. Defendant and Plaintiff had a valid and enforceable contract for $4,500.00. 23. Defendant took possession and Plaintiff allowed Defendant to take possession of the vehicle in reliance on that contract. 24. Defendant retained possession and continues to retain possession of the vehicle. 25. Defendant breached the parties' contract by failing to make the agreed upon payment to Plaintiff by January 2004, entitling Plaintiff to damages for the breach. WHEREFORE, Plaintiff demands judgment against the Defendant in the amount of $4,500.00 plus interests, costs of suit, and any other damages this Honorable Court deems just and proper. COUNT II UNJUST ENRICHMENT 26. Plaintiff incorporates paragraphs I -25 herein as if set forth in their entirety. 27. Defendant has enjoyed possession of the vehicle since November ]5, 2003. 28. Defendant has ridden and damaged the vehicle in his possession. 3 29. To allow Defendant to retain possession and the benefits adherent therefrom without payment to Plaintiff would result in unjust enrichment of Defendant. WHEREFORE, Plaintiff demands judgment against the Defendant in the amount of $4,500.00 plus interests, costs of suit, and any other damages this Honorable Court deems just and proper. Respectfully Submitted, BLAKEY, YOST, BUPP & RAUSCH, LLP --7 ,,/ By: n . Baranski, Jr., Esquire Attorney for Plaintiff Supreme Ct. 1.0. No. 82585 17 East Market Street York, Pennsylvania 17401 (717) 845-3674 4 VI.RII'IC'\TI()~ I verify that the foregoing facts arc true, Uplll1 m>" pl..'rsonal knowkdge nr i\lr\.lnl1~llll)]) ~l]hi belief. This verification is made subject to the pCllaltie:.; ~)( 1 X Pel. C.S. ~-:l){)4 n.:lc!1111~:~ [0 llll.'i\\lln, falsification to authorities. < L Dated: 00~. 5 CERTIFICATE OF SERVICE I hereby certify that I am this day causing a copy of the foregoing document to be served by First Class United States Mail, postage prepaid, on the following person: Meryl Tate 1560 McClures Gap Road Carlisle, PA 17013 Dated; {!~~ BLAKEY, YOST, BUPP & RAUSCH, LLP //) / ~7 / B1'- - / \. ~,aM.Do '---lLE et Street York, PA 17401 8 -' ~ 3, ~ >:> ....,. 9-> c:-. ~ S> 8 -- -- , , C.J - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-2451 Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT Enter judgment in favor of the Plaintiff, RANDY L. CRAMER, and against the Defendant, MERYL TATE, for failure to file an Answer to Plaintiff s Complaint. Assess damages as follows: Debt $ 4,500.00 Interest @ 6% (05/25/05 to 07/21/05) 42.16 TOTAL $ 4,542,16 Plus costs I certify that the foregoing assessment of damages is for specified amounts alleged in the Complaint and is calculable as a sum certain from the Complaint. Pursuant to Pa. R.C.P. 237, I certify that a copy of this Praecipe is being mailed to the Defendant. Pursuant to Pa. R.C.P. 237.1, I certify that written notice of the intention to file this Praecipe was mailed to the party against whom the judgment is to be entered after default occurred and at least ten days prior to the date of the filing of this Praecipe and a copy of the notice is attached. P By: . amaski, Jr., Esquire Supreme Ct. ill No. 82585 17 East Market Street York, PA 17401 Telephone (717) 845-3674 Fax No. (717) 854-7839 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-2451 Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW To: Meryl Tate Date of Notice: July 7, 2005 IMPORT ANT NOTICE Pursuant to PA R.C.P. 237.5 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE Lawyer Referral Service of the York County Bar Association York County Bar Center 137 East Market Street York, Pennsylvania 17401 Telephone No. (717) 854-8755 :~ John J. Baranski, Jr., Esquire S. Ct. I.D. #82585 17 East Market Street Telephone (717) 845-3674 Fax No. (717) 854-7839 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-2451 Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE I hereby certify that I am this day causing a copy of the foregoing document to be served by First Class United States Mail, postage prepaid on the following person: Meryl Tate 1560 McClures Gap Road Carlisle, P A 17013 BLAKEY, YOST, BUPP & RAUSCH, LLP Dated: July 7, 2005 By: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA RANDY L. CRAMER, Plaintiff No. 05-245] Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE Before me, a Notary Public in and for York County, Pennsylvania, personally appeared John J. Barnaski, Jr., Esquire, attorney for Plaintiff in the above entitled case, who being duly sworn or affirmed according to law deposes and says, that the he is advised and therefore believes that Defendant, Meryl Tate, is not in the military service of the United States of America; that said Defendant is now living at 1560 McClures Gap Road' ]7013, is a resident of Cumberland County, Pennsylvania, and his 10 status is Sworn and subscribed before me this 2]'t day of July, 2005. DilO)0~P .J NotatY Public C:OMMONW'" Ii "I' NN II IA NOTARIAL SEAL ILEEN S. KRONE, Notary Public City of York. York County My Commission Expires March 28, 2009 t A:J (:J ~ \ :;:, - F ~ ~ ~ 0"'- ~ ~ 60 '\v - R c----- ~ :-0 () C> -0 F ~ ---L... ~ ~ 2 ~ ::;l r ~ ~~ ~, C 1" rn ~'1\ G"> :gQ ~C~. , QtJ Z.l~ cP _....,....::.;. U1 >'-~" ::r: 1) ~\~~i -'0 q~ ~Ci % (5. ',Z'O (.,) _:0., 5c::: .' ?r! ~ ~ 0< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-2451 Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW NOTICE OF FILING JUDGMENT ( x) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of Four Thousand Five Hundred Forty-Two and 16/100 ($4,542.16) Dollars, plus costs of suit. ( x) A copy of all documents filed with the Prothonotary in support of the within judgment are enclosed. If you have any questions regarding this Notice, please contact the filing party: John J. Baranski, Jr., Esquire S. Ct. \.D. #82585 BLAKEY, YOST, BUPP & RAUSCH, LLP 17 East Market Street York, PA 17401 Telephone (717) 845-3674 Fax No. (717) 854-7839 (This Notice is given in accordance with Pa.R.C.P. 236.) Notice sent to: Mr. Meryl Tate 1560 McClures Gap Road Carlisle, P A 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-2451 Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Issue Writ of Execution in the above matter, Directed to the Sheriff of Cumberland County, Pennsylvania, against MERYL TATE, Defendant To levy upon any and all personal property of the Defendant located in and about the premises known and numbered as 1560 McClures Gap Road, Carlisle, PA 17013. Amount due $ 4,542.16 Interest from 7/21/05 to 10/3/05 55.25 TOTAL $ 4,597041 Dated: October 3, 2005 ,LLP ~------ By: John J. Barans i, Jr., Esquire S. Ct. J.D. #82585 17 East Market Street York, PA 17401 Telephone (717) 845-3674 Fax No. (717) 854-7839 Attorney for Plaintiff t: ?A)9- +- .~ 1l -k;t .../q, :-- t 6 r& -- ~ ~ Vv -Pre~ cY~ ~ fl t C' ~ ~ ~ -"1- ~~ "<;;) ..c~ vt V) '..:z . 'II? ."" () \.f1 C' \I) C> , -) \ I -v ~p- = ~' ~ t: - .- ;./'1- - ~ 't1-L. ....> 0 ~ .-n ~ .-t C> ~:.q " r" -I ::~S) ~ ~~C-' -1::=\") :r'!I> ~;:.:~(::; -C" /~. rn ...;.."" 0 cP .-\ . ~ ~J.o U1 "" c..> WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-2451 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due RANDY L. CRAMER, Plaintiff (s) From MERYL TATE, 1560 MCCLURES GAP ROAD, CARLISLE, PA 17013 (I) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ANY AND ALL PERSONAL PROPERTY OF THE DEFENDANT LOCATED IN AND ABOUT THE PREMISES KNOWN AND NUMBERED AS 1560 MCCLURES GAP ROAD, CARLISLE, PA 17013. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) 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; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,542.16 Interest FROM 7/21/05 TO 10/3/50 - $55.25 L. L. $.50 Atty's Comm Atty Paid $81.75 Plaintiff Paid Date: OCTOBER 4, 2005 % Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name JOHN J. BARNASKI, JR., ESQUIRE Address: BLAKEY, YOST, BUPP & RAUSCH, LLP 17 EAST MARKET STREET YORK, PA 17401 Attorney for: PLAINTIFF Telephone: 717-845-3674 Supreme Court ID No. 82585 . RANDY L. CRAMER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. MERYL TATE : NO. 2005 -2451 CIVIL TERM ORDER OF COURT AND NOW, this 7TH day of NOVEMBER, 2005, a hearing on the Claim for Exemption is scheduled for THURSDAY, NOVEMBER 17, 2005, at 8:30 a.m. in Courtroom # 5. Edward E. Guido, J. ~hn J. Baranski, Jr., Esquire For the Plaintiff vIGndy L. Cramer 170 Red Tank Road Boiling Springs, Pa. 17007 .J. ~eryl Tate 1560 McClures Gap Road Carlisle, Pa. 17013 Sheriff :sld V:i'.i\!/\L\~;;:';J\: jd kU.::Y' -, -"'-..,'^'t'l" '<<IV s S : I lid L - ;\ON SOUZ AU\ilC!>,:Ul-':.'.i~idd 31-11 .:JO "C,(:'(IJlI:I . ,.. ~ .... 6% \r1lV~L ~ IRECEI~EDI 0 nrT 3 1 ,01,5 > 1 ~v 'c-.- 3 '''v : IN THE COURT OF COMMO ~EA;:'. Ul< : CUMBERLAND COUNTY, PENNSYL VANIA ; WRIT NO. 0 5' - 2 Y S I CIVIL TERM CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy, or attachment: I. 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 proP/rty to be set aside in kind): Jl..lRif-t fJehtL I &-..., flex. (ii) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption (specifY property and basis of exemption): 1llJ.. eRoffi.Rl ~ 1.-1 S -reD 0 N e-x f;.cvTI ON - LEV '1 FOR /v1 ) T /Vol M'1-PR6PJ;R 1:; - OIVJvEiO ELf EX-WFE 2. From my property which is in the possession of a third party, I claim the following # I exemptions: (a) my $300 statutory exemption: 0 in cash 0 in kind ( specify property): l'.. (b) Social Security benefits on deposit in the amount of $ (c) l~~s~;OounLr ~a;;J~~x;r~k WI'l/ U-I J J I f<EAr;oI'J f::(}f?. ,yf)fJIrMbI1JT /16-t4llvsT f4E "S} J../ ptJ_<:;S S S) 1c.~~1 oJ::- Mil CfllJ.MEl?; :J:. OlUE JI/fi1 -- NOTjJ/luG- ! / 0/7 [L ('....; --... , U-', c'-:." c.'" N -- ,. , " I request a prompt court hearing to determine the exemption. Notice of the hearing ofthe hearing should be given to me a!~ eR I e ~ 1-t2.- /50D rWClDve) ?"p @ Address (>> I /7() 13 (AV IS t' fA (2t!ler 249- 5 J 77 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. 4904 relating to unsworn falsification to authorities. Date: iO}31/0) TIDS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYL VANIA 17013 (717) 240-6390 SIJl^"j) " '" , MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 Statutory exemption 2. Bibles, school books, sewing machines, unifonns and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement fimds and accounts 6. Certain veteran and armed forces benefits 7. Certain Insurance proceeds 8. Such other exemptions as may be provided by law v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2005-2451 CIVIL TERM RANDY L. CRAMER, Plaintiff MERYL TATE, Defendant MOTION FOR CONTINUANCE TO THE HONORABLE JUDGES OF SAID COURT: AND NOW this 16th day of November, 2005, comes the Defendant, Meryl Tate, by and through his Attorney Paul Bradford Orr, Esquire, and moves this Court to grant his request, and in support thereof respectfully represents the following: 1. Defendant is scheduled for a hearing on the Claim for Exemption on Thursday, November 17, 2005.(Sce (C,"'''' tI\\.o.Lr.ed <""c\ lV'c&'tJu.~ ('5 E,\'1..i.b)...t "A'~) 2. Defense Counsel is requesting a continuance due to counsel being hired on November 15, 2005 and having already been scheduled in another county for unrelated hearings. fV\ Paul Bradford Orr, Esquire Attorney for Defendant ID # 71786 50 East High Street Carlisle, PA 17013 (717) 258-8558 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2005-2451 CIVIL TERM RANDY L CRAMER, Plaintiff MERYL TATE, Defendant CERTIFICATE OF SERVICE I, Paul Bradford Orr, Esquire, attorney for Defendant, do hereby certify that a true and correct copy of the within MOTION TO CONTINUANCE was served upon the following individuals on the below date, by US First Class Mail as follows: Randy L. Cramer 170 Red Tank Rd. Boiling Springs, P Date: H \ \ La \ a~ BY: 11 aul Bradford Orr, squire Attorney for Defendant ID # 71786 50 East High Street Carlisle, PA 17013 (717) 258-8558 RANDY L. CRAMER fN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ~'---'"--., t\6TAT~ --_._~ NO. 2005 - 2451 CIVIL TERM ORDER OF COURT AND NOW, this 7TH day of NOVEMBER, 2005, a hearing on the Claim for Exemption is scheduled for THURSDAY. NOVEMBER 17. 2005. at 8:30 a.m. in Courtroom # 5. ~~ ~ Edward E. Guido, J. john J. Baranski, Jr., Esquire For the Plaintiff Randy L. Cramer 170 Red Tank Road Boiling Springs, Pa. 17007 Meryl Tate 1560 McClures Gap Road Carlisle, Pa. 17013 Sheriff :sld DEFENDANT'S EXHIBIT R C) C r-' ~:=-~, ~:fl ------ --- -- (:~:i o -.1 .--\ .1: -n h1?~ -~'\ t:.:' .'.~ , '<',(. 0" ~;~J ~;.... J.-) ::...:., o - RANDY L. CRAMER, Plaintiff v. MERYL TATE, Defendant AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2005-2451 CIVIL TERM ORDER OF COURT I (,J1\. day of N~ , 2005, upon consideration of the Defendant's Motion for Continuance, it is hereby ORDERED that the Motion for Continuance is GRANTED and the Defendant is directed to appear for a hearing on the Claim for Exemption on the Jg~ day of tJ ~ ,2005, at J(,'()().4 ~~Iock _.m in the Cumberland County Court of Common Pleas. ~I Bradford Orr, Esquire vAtt~rney for Defendant ID # 71786 50 East High Street Carlisle, PA 17013 (717) 258-8558 ~ndy L. Cramer V,70 Red Tank Rd. Boiling Springs, PA 17007 BY J. :\i\no "r' '111)"} :J~ 'I 1".'-.. 91 ACN SuciZ AbV1G-<:} ~;_;>f)~,';d 3Hl ~o :j~!I::~::V:}{'j3'lj:l v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2005-2451 CIVIL TERM RANDY L. CRAMER, Plaintiff MERYL TATE, Defendant PRAECIPE TO ENTER APPEARANCE Prothonotary of Cumberland County: Please enter my appearance on behalf of the Defendant in the above captioned matter. Respectfully Submitted, Date: /Illb)of \ By: Paul Bradford Orr, Esquire Attorney for Defendant 50 East High Street Carlisle, PA 17013 (717) 258-8558 ID # 71786 ...., ,::;::'~) <:.1"1 o ~fi ::;j ;<1 -.l -".., -',., -- '":'? Cr', ~n)-23-2005 10: 56 BLAKEY YOST BUPP RAUSCH 717 854 7839 P.02 .. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-2451 Civil Term vs. MERYL TATE. Defendant CIVIL ACTION - LAW ORDER NOW, this ;;-~ day of 7)'al\'~ ,2005, upon consideration ofPlaintiirs request, a continuance is hereby granted in this matter and the new date and time for the hearing on Defendant's Claim for Exemption is set for ~ I' ,2005 at ;. :66 -I m, in Court Room # <'of the Cumberland COWlty CourthousF 9' Cc. Judge John Baranski, Jr., Esquire, for Plaintiff] /J - J- - Of) /11 . Paul Orr, Esquire, for Defendant . C~ Cumberland County Sheriff /Y1~ :}t;' 0\ TOTAL P.02 "", t),) ." 'j!:] !11 ;.:':; os SDGZ I\(j';" NOI)-23-2005 10: 56 BLRKEY YOST BUPP RRUSCH 717 854 7839 P.Ol A"fr,ert G. Blakey / , Donald B. Hoyt Charles A, Rausch Bradley J. Leber David A. Mills Stacey R. MacNeal Penny V. Ayers John J. Baranski, Jr. Michael C. Anderson Nicole M. Ehrbarr ~ of counsel Donald H. Yost David Wm. Bupp B....,..V..._._W At1On.~.at t... FACSIMILE TRANSMITI AL COVER LETTER DATE: 11/23/05 TO: Honorable Judse Guido. c/o Sandy TOTAL NUMBER OF PAGES: 2 FAX NUMBER: 717240..{;460 (including this page) FROM: John Baranski RE: Cramer v, Tate ~~... MESSAGE: Sandy, could you please fax me a copy of the signed order. Thanks, If you have any problem receiving thill, please call (717) 845-3674. THIS MESSAGE IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MA Y CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination or copying of this communication is prohibited. If you have received this communication in error, please notify us immediately by telephone (collect), and return the original message to us at the above address via U.S. Postal Service. Thank you. 17 East Market Street, York PA 17401 717-845-3674 Fax 717-854-7839 RANDY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-2451 CIVIL TERM MERYL TATE, Defendant CIVIL ACTION -- LAW ORDER OF COURT AND NOW, this 19th day of December, 2005, this matter has been resolved by agreement of the parties, which we shall incorporate into an Order of Court as follows: 1. The items listed in Defendant's Exhibit No.1 are the only items which are exempt from the Sheriff's levy since they are items that do not belong to him. 2. The 1998 Kawasaki four-wheeler, VIN Number JKALFKB18WB528535, shall be included as part of any eventual Sheriff's sale unless it is otherwise sold by the Defendant privately prior to the Sheriff's sale. 3. Plaintiff has agreed not to list this matter for a Sheriff's sale for 30 days. ~hn J. Baranski, Jr., Esquire For the Plaintiff ~aul B. Orr, Esquire For the Defendant ~1~d Sheriff srs BS :6 WI I Z :l30 SOOZ AUV.LCi\J: ;;.UJJd 3!-ll :30 :!')i.!.in-n711IJ .-1,,,1....._..... ,-,:1 .:.l . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-245 I Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW :rD R. 8 S$'uL.. PRAECIPE__ WRIT OF EXECUTION -.!f.:- To the Prothonotary: Issue Writ of Execution in the above matter, Directed to the Sheriff of Cumberland County, Pennsylvania, against MERYL TATE, Defendant To levy upon the 1998 Kawasaki four-wheeler, VIN JKALFKB18WB528535 per Court Order attached, 2 jet skis, aU firearms and livestock consisting of approximately 60 head of deer, of the Defendant located in and about the premises known and numbered 88 1560 McClures Gap Road, Carlisle, PA 17013. Amount due $ 4,542.16 Interest from 7/21/05 to 01/30106 143.82 TOTAL $ 4,685.98 Dated: January 27,2006 By: Jo . aranski, Jr., Esquire S. Ct. LD. #82585 17 East Market Street York, PA 17401 Telephone (717) 845-3674 Fax No. (717) 854-7839 Attorney for Plaintiff ~ + ~ %~t '- --- ~ ..J:::- ~~() !'..J ~ tv ~ ~ D t [ Y R ~ 11) () 0- ~ 3? --< ~ .::;:! ~:: :~-il 'c,:, -<,-- (..'"; - ....,., --' C:;;., +- ~~ ~ ~~~ ~ - \' -..c. f::.-o ~. b r i-J J:-} " ~ t r # .. RANDY L. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-2451 CIVIL TERM MERYL TATE, Defendant' CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 19th day of December, 2005, this matter has been resolved by agreement of the parties, which we shall incorporate into an Order of Court as follows: 1. The items listed in Defendant's Exhibit No.1 are the only items which are exempt from the Sheriff's levy since they are items that do not belong to him. 2. The 1998 Kawasaki four-wheeler, VIN Number JKALFKB18WB528535, shall be included as part of any eventual Sheriff's sale unless it is otherwise sold by the Defendant privately prior to the Sheriff's sale. 3. Plaintiff has agreed not to list this matter for a Sheriff's sale for 30 days. B~)J1e-c~ Edward E. Guido, J. ,~n J. Baranski, Jr., Esquire For the Plaintiff Paul B. Orr, Esquire For the Defendant Sheriff srs 06 \ .---~----, ~~_. .' TO WHOM IT MA Y CONCERN: REGARDING A TT ACHMENT "A" THE FOLLOWING LISTED ITEMS, (MARKED IN RED), DO NOT BELONG TO MR. MERL TATE. THE MARKED ITEMS BELONG TO MR TATE'S FIRST WIFE MS. CRYSTAL WILSON. THESE ITEMS, ARE BEING HELD, PER A VERBAL AGREEMENT BETWEEN MR. TATE AND MS. WILSON, UNTIL THE END OF JANUARY 2006. THE FOLLOWING LIST, IS A BREAKDOWN OF "A TT ACHMENT "A" WHICH PERSONALL Y BELONG'S TO MS. WILSON: KITCHEN: DINETTE TABLE HUTCH DRY SINK BEDROOMS: BEDROOM #2 (DAUGHTER'S ROOM) BEDROOM #3 (MS. WILSON'S ROOM) BASEMENT: WOODEN BENCH COUCH AND LOVE SEA T DESK BEDIFRAME HUTCH MISCELLANOUS: 2 CHAIRS 2 COUCH'S TABLE/4 CHAIRS 2 TELEVISIONS COFFEEIEND TABLES 2 LAMPS GUN CASE).BELONG'S TO SON OF MS. WILSON (HAND MADE)) LIVING ROOM: LAMPS TELEVISION VCR STEREO GUN CABINE DVDIVCR COMBO I HEREBY CLAIM, THE FOREMENTIONED ITEMS, AS MY PERSONAL ITEMS WHICH, MR. MERL TATE HAS ABSOLUTELY NO CLAIM. THESE ARE MY PERSONAL ITEMS WHICH MR. TATE AND I HAVE A VERBAL AGREEMENT TO STORAGE UNTIL THE END OF JANUARY 2006. ' " \ , I GREA TL Y APPRECIATE YOUR A ITENTlON TO THIS MATTER, AS MY PERSONAL ITEMS ARE NOT AND SHOULDNOTBEA PART OF THlS LEGAL ACTION, AS MR. TATE AND I HAVE BEEN DIVORCED FOR 14 YEARS, BUT SHARE 2 VERY LOVED CHILDREN TOGETHER AND HAVE A VERY ADULT FRIENDSHIP TOGETHER AS WELL AS THE VERBAL AGREEMENT ON THE STORAGE OF ITEMS SINCE MY SECOND DIVORCE. ANY QUESTIONS REGARDING THIS MA ITER CAN BE DIRECTED TO THE BELOW LISTED NUMBERS PLEASE FEEL FREE TO CONTACT ME REGARDING THIS MA TIER SINCERELY,;! , ,-1 . ;:1 l' / 1'1., {~-!' i't. .' ! ,~ L , MS. CRYSTAL WILSON ,., 1/ /' / " l'-'t"" --.- ---- " 'DA YTlME CONTACT # 243-0055 (SA TURDA Y - SUNDA Y - MONDA Y AND TUESDA Y UNTIL 3:00 PM) "HOME CONTACT # 486-5561 .- REISSUED WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-2451 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due RANDY L. CRAMER, Plaintiff (s) From MERYL TATE, 1560 MCCLURES GAP ROAD, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON THE 1998 KAWASAKI FOUR-WHEELER, VIN JKALFKB18WB528535 PER COURT ORDER ATTACHED, 2 JET SKIS, ALL FIREARMS AND LIVESOTCK CONSISTING OF APPROXIMATELY 60 HEAD OF DEER, OF THE DEFENDANT LOCA1ED IN AND ABOUT THE PREMISES KNOWN AND NUMBERED AS 1560 MCCLURES GAP ROAD, CARLISlE, PA 17013 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) 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; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,542.16 Interest FROM 7/21/05 TO 10/3/50 - $55.25 1.1. $.50 Atty's Corom Atty Paid $81.75 Plaintiff Paid Date: OCTOBER 4, 2005 % Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name JOHN J. BARNASKI, JR., ESQUIRE Address: BLAKEY, YOST, BUPP & RAUSCH, LLP 17 EAST MARKET STREET YORK, PA 17401 Attorney for: PLAINTIFF Telephone: 717-845-3674 Supreme Court ID No. 82585 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2451 CIVIL TERM RANDY L. CRAMER, Plaintiff MERYL TATE, Defendant' CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 19th day of December, 2005, this matter has been resolved by agreement of the parties, which we shall incorporate into an Order of Court as follows: 1. The items listed in Defendant's Exhibit No.1 are the only items which are exempt from the Sheriff's levy since they are items that do not belong to him. 2. The 1998 Kawasaki four-wheeler, VIN Number JKALFKB18WB528535, shall be included as part of any eventual Sheriff's sale unless it is otherwise sold by the Defendant privately prior to the Sheriff's sale. 3. Plaintiff has agreed not to list this matter for a Sheriff's sale for 30 days. Edward E. Guido, J. ,~hn J. Baranski, Jr., 'For the Plaintiff Esquire srs '.~ ''>v .(,y'V,. ,\ ~Lr "t) \ .v ~~~\~/)~ / r:! I \ .~\-/ . ~ \ \.- , - /- \f~ ~au1 B. Orr, Esquire For the Defendant \ ....,~.- yO Sheriff ...""~, .,;JJ (}..l , , , ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-2451 Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW PRAECIPE TO RE-ISSUE WRIT OF EXECUTION To the Prothonotary: Please re-issue the Writ of Execution in the above case. Dated: May 23, 2006 . Baranski, Jr., Esquire S. Ct. l.D. #82585 17 East Market Street York, PA 17401 Telephone (717) 845-3674 Fax No. (717) 854-7839 Attorney for Plaintiff By: , F o c ,...., c::> c;:.::,) "'" (.- ~ r I c::> ~ .-l -c.,., ft,? -Orn -nO ,',0:.' \ ':J1() .,,," " ,___-T"'j "'~;!:~ 1:2\ '" <0 :..<: ~ --- \9 Cl CO . RANDY L. CRAMER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. MERYL TATE : NO. 2005 - 2451 CIVIL TERM ORDER OF COURT AND NOW, this 1ST day of AUGUST, 2006, a hearing on the Claim for Exemption is scheduled for FRIDAY, AUGUST 4. 2006, at 3:30 p.m, in Courtroom # 3. Edward E. Guido, J. ~dY L. Cramer 170 Red Tank Road Boiling Springs, Pa. 17007 \4 Sheriff w )0 E,\)'\ o .)deryl Tate 1560 McClures Gap Road Carlisle, Pa. 17013 :sld 'I,' -:h'711)..j ~ ,,",. l~lt .! JHL r]TIH Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL $ "~~ :~~~~>~ . f':"" "-\.' C\r< ,~\) , .... ;;~> 18.00 90.85 .50 1.00 9.60 20.00 40.00 .78 /J 180.73 y 't -/J . &' [, '-1""'" Z 0 :t: CJ 11';" , \ ~'" ~ ':"j':" \ ':'.1~'- Ctt$S051 ,.tr"~. ~ fI.../iJ.. jO {p" (, Jj . Advance Costs: 350.00 Sheriffs Costs: 180.73 $ 119.27 ,. Refunded to Atty on 08/07/06 So Answers; () ~~~ ~ R. T~. omas Kline, She'riff.. .~ (:1 . /:...~ " M--- ~uJh(~/c'r y Claudia A. Brewbaker K\~ ~ . ~C0 ~~ ~ r'l ~ f") fj A (nn7 J~U~ r- ~ ~ f1J'~ Q:J ~R~ ~r-l ~. & ~ Xn 1'~ REISSUED WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due RANDY L. CRAMER, Plaintiff (s) NO 05-2451 Civil CIVIL ACTION - LAW From MER'l TATE, 1560 MCCLURES GAP ROAD, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON THE 1998 KAWASAKI FOUR-WHEELER, VIN JKALFKB18WB528535 PER COURT ORDER A'ITACHED, 2 JET SKIS, ALL FIREARMS AND LIVESTOCK CONSISTING OF APPROXIMATELY 60 HEAD OF DEER, OF THE DEFENDANT LOCATED IN AND ABOUT THE PREMISES KNavN AND NUMBERED AS 1560 MCCLURES GAP ROAD, CARLISLE, PA 17013 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) 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; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,542.16 Interest FROM 7/21/05 TO 10/3/50 - $55.25 L.L. $.50 Arty's Corom % Arty Paid $81.75 Plaintiff Paid Date: OCTOBER 4, 2005 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name JOHN J. BARNASKI, ,JR" ESQUIRE Address: BLAKEY, YOST, BUPP & RAUSCH, LLP 17 EAST MARKET STREET YORK, P A 17401 Attorney for: PLAINTIFF Telephone: 717-845-3674 Supreme Court ID No. 82585 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDY L. CRAMER, Plaintiff No. 05-2451 Civil Term vs. MERYL TATE, Defendant CIVIL ACTION - LAW PRAECIPE TO SETTLE AND DISCONTINE TO THE PROTHONOTARY: Please mark the above-captioned matter settled and discontinued and the Judgment obtained thereunder as satisfied. By: Date: ..Jdh&\ bb Jo 1, Jr., Esquire Supreme Ct. ID No. 82585 17 East Market Street York, PA 17401 Telephone (717) 845-3674 Fax No, (717) 854-7839 Attorneys for Plaintiff ~ 2 a"" o rfi n r" co o "'T1 -H ::i r<) .r- (j".