HomeMy WebLinkAbout05-2538
Gordon & Weinberg, P.C.
By: Frederic 1. Weinberg, Esquire
ID:41360
By: Paul M. Schofield, Jr., Esquire
ID:81894
21 South 21st Street
Philadelphia, PA 19103
215-988-9600
ATTORNEYS FOR PLAINTIFF
KEY LEASING & RENTAL, LLC.
717 YORK ROAD
TOWSON, MD 21204
: COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY
v.
GEORGE D. BRYSON
129 REGENCY WOOD NORTH
CARLISLE, P A 17013
AND
YVONNE M. BRYSON
129 REGENCY WOOD NORTH
CARLOSLE, PA 17013
:NO. OS- -;}SJP (3ull'UL~
ENTRY OF APPEARANCE, ORDER FOR JUDGMENT
AND ASSESSMENT OF DAMAGES
(FOREIGN JUDGMENT PROCEEDINGS)
TO THE PROTHONOTARY:
Kindly enter my appearance for the plaintiff in the above matter, enter judgment in favor of
the plaintiff and against the Defendants, on the foreign judgment entered in the District Court of
Maryland for the County of Baltimore for monetary damages, a duly authenticated copy of the
judgment being filed herewith, and assess damages as follows:
Amount of Foreign Judgment
Costs
Attomey's Fees
Real Debt
$ 4,773.32
$
$
$ 4,773.32 _-----
...----
-----
ERIC 1. WEINBERG, ESQUIRE
Attorney for Plaintiff
Prothonotary
Gordon & Weinberg, P.C.
By: Frederic 1. Weinberg, Esquire
10: 41360
By: Paul M. Schofield, Jr., Esquire
10:81894
21 South 21 ~ Street
Philadelphia, PA 19103
215-988-9600
ATTORNEYSFORPLMNTIFF
KEY LEASING & RENTAL, LLC.
717 YORK ROAD
TOWSON, MD 21204
: COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY
v.
GOERGE D. BRYSON
129 REGENCY WOOD NORTH
CARLOSLE, P A 17013
AND
YVONNE M. BRYSON
129 REGENCY WOOD NORTH
CARLOSLE, PA 17013
:NO. oS _ ~S 3;
C/u ~[~f)L.""L
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF CUMBERLAND
AFFIDAVIT
FREDERIC I. WEINBERG, ESQUIRE, being duly sworn according to law, deposes and says that he is the
Attorney for the Plaintiff in the ahove captioned matter; that the defendants and their last known address is 129 Regency
Wood North, Caris Ie, P A 17013 and the plaintiffs last known address is 717 York Road, Towson, MD 21204 that the
foreign judgment entered by the plaintiff against the defendant in the District Court of Maryland, County of Baltimore
in the sum of$4.812,26 no part of which has been paid, is valid, enforceable, and unsatisfied,
(
-.----.-
FRED EINBERG, ESQUIRE
A ey for Plaintiff
OMMON EALTHOFPENNSYLVANIA
NOTARIAL SEAL
JOHN V McBRIDE. III, Notary Public
City of Philadelphia, ?hila, County
,~Q!1)I.fli~~O.f,pires August 4.2008
Gordon & Weinberg, P.C.
By: Frederic L Weinberg, Esquire
10: 41360
By: Paul M. Schofield, Jr., Esquire
10:81894
21 South 21'" Street
Philadelphia, PA 19103
215-988-9600
ATTORNEYS FOR PLAINTIFF
KEY LEASING & RENTAL, LLC.
717 YORK ROAD
TOWSON, MD 21204
: COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY
v.
GEORGE D. BRYSON
129 REGENCY WOOD NORTH
CARLISLE, P A 17013
AND
YVONNE M. BRYSON
129 REGENCY WOOD NORTH
CARLISLE, PA 17013
:NO. OS' - cJS2P C.lC.)->~ ~
TO: GEORGE D. BRYSON
NOTICE
PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED
THAT A JUDGMENT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEED.
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL FREDERIC I. WEINBERG,
ESQUIRE AT 215-988-9600,
Gordon & Weinberg, P.C.
By: Frederic L Weinberg, Esquire
ID: 41360
By: Paul M. Schofield, Jr., Esquire
ID:81894
21 South 21 ~ Street
Philadelphia, PA 19103
215-988-9600
ATTORNEYS FOR PLAINTIFF
KEY LEASING & RENTAL, LLC.
717 YORK ROAD
TOWSON, MD 21204
: COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY
:
v.
GEORGE D. BRYSON
129 REGENCY WOOD NORTH
CARLISLE, PA 17013
AND
YVONNE M. BRYSON
129 REGENCY WOOD NORTH
CARLISLE, PA 17013
:NO. oS-:J.nf C?l~i~~
TO: YVONNE M. BRYSON
NOTICE
PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE
HEREBY NOTIFIED THAT A JUDGMENT HAS BEEN ENTERED AGAINST YOU IN THE
ABOVE PROCEED.
IF YOU HA VEANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL FREDERIC
I. WEINBERG, ESQUIRE AT 215-988-9600.
.- ,
@,9l"'DISTRICTCOURTOF MARYLAND FOR...,B.a.~~,i~(lr:e....c.(lllI1y..,."..,',..,..........................,'
n Cit)'ICounty
- ::: - 120 E. Chesapeake Av.Towson,Md.21286 18589-2001
.' Located at",...."...."" ........."....,..,..'....,..'........, ....,......,'..",.......... ,Case No, "..,..,..'",..,..,..,......'".."......, .........."..".."
Court Address
.,." .1<e.Y.. I,e.<!f!~!1g,,~., ge.!1~<!,I, ~,.I-,I-,C;"..".",..",...",..".., ..,.,. qe.()r:ge." 0.,..., Ilr:Y.~()~."".."."."" ,.".",'.""", .....'"",.
Name Name
717 York Road
'Addr~~~ .................................................. '............,. '..........
Towson, MD. 21204
......................................pi;i~tlff......................................
YS.
129 Regency Wood North
'Add;;s~"""'" '..,..,'..,.. ,_.................................... cci~~ij.:""""
Carlisle, PA. 17013
....................,......,..........D~f~;ld.a.u"l.........................,...........
CERTIFICATION OF JUDGMENT UNDER ACT OF CONGRESS
I HEREBY CERTIFY that the attached is a true and exact copy of the docket entries ofthis Court in this case. In witness
whereof I hereto set my hand and affix the seal of the District Court of Maryland,
It.,/j /?/I '
/7f!/U/<.,~L,{dV,."...".."..,",.."..,'
Clerk
.,.".".,..,...,',.".c;..~/9..~~.f), ,'I..,..,.",....",.."..",.,
Dale
Baltimore County , ,
STATE OF MARYLAND, ...'"..'..'..'"..,....,......,......................,......,.......,..'..'..........,...."..,',......,......, to WIt:
I HEREBY CERTIFY that the foregoing attestation of ......,J:IClr:~a....R.~...f~(O,l.cl~........................., ..................
Clerk of the District Court of Maryland is in due form and by the proper officer.
.,.,..,..""..""...,.".......".0Lfil9Y,..,..,.."....",...,....,..
-." -.-......... -,..",
~J<'~~mmm.
STATE OF MARYLAND, .....~Cl~t.~tn():r,~..(;()'.lIl~y.......................,................."..,..,..........."', to wit:
I HEREBY CERTIFY that the Honorable.......)~D..,l.1.....Ah~?\iJ.P9.~x:............................................,' who has certified and
signed the above attestation, was at the time of so doing a judge of the District Court of Maryland, duly commissioned and
qualified, and that as to all acts done by the judge in that capacity, full faith and credit are due and ought to be given, and that
the signature of the judge thereto is genuine,
In witness whereof, I hereunto subscribe my name and affix the seal of the District Court of Maryland,
'.".'""",."",,'..., ,(-1 ~,~. 9, i.."...,..,.",..",..., ........,
Date
DC/CV 50 (Rev, 112002)
~'4J/"~,&)....m
0'6D32~04
DISTRICT COURT OF MARYLAND
CIVIL SYSTEM JUDGMENT UPDATE
DIST: 08
DIST/LOC: 08 04 CASE NUMBER VER: 0018589 - 2001 CASE ACTIVITY DATE: 06032004
STATUS: A 07122001 CLAIM TYPE: CONT FILING DATE: 07052001 JUDGE-ID: 9H7
TRIAL DATE: DISP: JUDG
COMP FILN DATE: 07052001 COMP ACTIV DATE: 06032004 COMP STATUS: JUDG 03262002
COMPLAINT NUMBER: 001 COMPLAINT TYPE: REGL
KEY LEASING & RENTAL, LLC
JUDGMENT TYPE: AFDV
AMOUNT: 4,773.32
ATTORNEY FEE: 0.00
JOINTLY AND SEVERALLY:
POSS OF PROP VALUED AT:
0.00 VALUE OF
RECORDED LIEN DATE:
JUDGMENT RENEWED DATE:
NEXT PAGE
,
VS. BRYSON, GEORGE D
LP/LJ: DATE: 03252002 DIST/LOC: 08 04 JUDGE 10: 9H7
INTEREST: 0.00 COST: 38.94 OTHER: 0.00
POST INTEREST LEGAL RATE: X CONTRACTUAL RATE:
IN FAVOR OF DEF: DISMISSED WITH PREJUDICE:
0.00 AWARDED TO: DAMAGES: 0.00
PROPERTY AND DAMAGES OF: 0.00 AWARDED TO:
RENEWED LIEN DATE: MMDDCCYY SEND NO NOTICES:
MMDDCCYY SATISFACTION DATE: MMDDCCYY
p/ N
PAGE: 001
1'ne T.. (4,
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DISTRICT COURT OF MARYLAND FOR BALTIMORE COUNTY 0804
120 E. CHESAPEAKE AVENUE (V)
TOWSON, MD 21286-5307
II~~I~III ~IIIII~I ~III~ II~ ~I~IIIII~ IIIIIII~IIIIIIIIIIIII~III~ I~I
CIVIL CASE NO,: 0804 - 0018589 - 2001
COMPLAINT NO,: 001
004248
TO: BALENSON, JERI LYNN
KEY LEASING & RENTAL
POBOX 1002
TIMONIUM, MD 21094
KEY LEASING & RENTAL, {,Le
VS.
BRYSON, GEORGE D
DA TE: 03/26/2002
AFFIDAVIT JUDGMENT ENTERED
ON MARCH 25, 2002 THIS COURT ENTERED AN AFFIDAVIT
JUDGMENT IN FAVOR OF THE PLAINTIFF IN THE ABOVE CASE IN THE
AMOUNT OF $4773.32 PLUS ATTORNEY'S FEES OF $0.00,
COSTS OF $38.94, PRE-JUDGMENT INTEREST OF $0.00 AND
OTHER AMOUNT OF $0.00. PLUS POST-JUDGMENT INTEREST AT LEGAL RATE.
THE DEFENDANT HAS UNTIL APRIL 24, 2002 TO FILE A MOTION TO
VACATE THIS JUDGMENT, STATING A FACTUAL AND LEGAL BASIS FOR A
DEFENSE.
THE PLAINTIFF TO ENFORCE THIS JUDGMENT MAY FILE FOR A LIEN ON
ANY REAL PROPERTY OWNED BY THE DEFENDANT.
FOR QUESTIONS CONCERNING THIS DOCUMENT TELEPHONE (410) 512-2000.
HEARl NG/SPEECH IMPAI RED CALLERS ONLY, TELEPHONE TTY /TT 1-800-925-9690
OR THROUGH MARYLAND RELAY SERVICE AT 1-800-735-2258 OR 711.
Rl
003969A
MAR 2, 8 ZOO'L
@
DiSTRICT COURT OF MARYLAND FOR......,.."~"ll,~~rn?J:',e,.~?~l1y.."....,..,....,"',..,....,,......"..,..,
City/CO(lllty
Located at.. ~~9" ,E.:.., <::h.e.1lClP'",a.k.e. ,.i\':'~.T.()w.:>()??,l'1<l~.2.1~~~"" ,Case No, ",....,.. ~,85.8.9.::~??~,.."",.., '..','......, "..,.,
Court Address
",lZ,"Y.. ,~~~I1g, ,II::. ,~~I1~1'l~ 7.. P:~,.".".,.",."",.".,..".,
Nan\C
717 York Road
'Addr'e's~""""""""""""""""""""""""............................
Towson MD. 21204
".,...,",..,~".,.,",.".,',.,...,...,.......".,".,.".',."..,.,...'.,...,."
Plaintiff
Yvonne M. Bryson
.Na~l;...................,......................,..................................
VS.
129 Regency Wood North
.A'dfuis.s..................'. .... ,-.................................. CO;lflt5.:...'..-.
Carlisle, PA. 17013
...................,..................D~f~~d.a;;t.....................................
CERTIFICATION OF JUDGMENT UNDER ACT OF CONGRESS
I HEREBY CERTIFY that the attached is a true and exact copy ofthe docket entnes of this Court in this case, In witness
whereofI hereto set my hand and affix the seal of the District Court of Maryland,
~4J,E~mmm
b~/O-Od
.......................................,...............,.../.......................
Date
Baltimore County ,
STATE OF MARYLAND, ..,............",......,.."..".........,..,..,.."..,........"........,''',..........'..,..".....,..,..,", to Wlt:
I HEREBY CERTIFY that the foregoing attestation of ..."....M.a.r.~1'l..,~~".F..i',~~ci:>.................................."...............,
Clerk of the District Court of Maryland is in due fonn and by the proper officer.
.,..".,."..,.....,.",...,...,.."..C;:/&./6..y..,..,..,.....,.',..".".
. ,". ,-...... ",
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STATE OF MARYLAND, ,.."...~1'l,l,t.~l1l()J:'e."~()LJIl,tX........"............"......,,..,......,......,' to wit:
] HEREBY CERTIFY that the Honorable........:!ClI1..l'1,~..,i\~~~,a,n.cl~J:....................."......................, who has certified and
signed the above attestation, was at the time of so doing a judge of the District Court of Maryland, duly commissioned and
qualified, and that as to all acts done by the judge in that capacity, full faith and credit are due and ought to be given, and that
the signature of the judge thereto is genuine.
In witness whereof, I hereunto subscribe my name and affix the seal of the District Court of Maryland,
(iq~()(fmk~...l:,~,<;., ' " , ,
O.t, e Cl"k" ....., , ,........
DCICV 50 (Rev, 1/2002)
06032004
- ,.
DISTRICT COURT OF MARYLAND
CIVIL SYSTEM JUDGMENT UPDATE
DIST: 08
DIST/LOC: 08 04 CASE NUMBER VER: 0018589 - 2001 CASE ACTIVITY DATE: 06032004
STATUS: A 07122001 CLAIM TYPE: CONT FILING DATE: 07052001 JUDGE-ID: 9H7
TRIAL DATE: DISP: JUDG
COMP FILN DATE: 07052001 COMP ACTIV DATE: 06032004 COMP STATUS: JUDG 03262002
COMPLAINT NUMBER: 002 COMPLAINT TYPE: REGL
KEY LEASING & RENTAL, LLC
VS. BRYSON, YVONNE M
JUDGMENT TYPE: AFDV
AMOUNT: 4,773.32
ATTORNEY FEE: 0.00
JOINTLY AND SEVERALLY:
POSS OF PROP VALUED AT:
0.00 VALUE OF
RECORDED LIEN DATE:
JUDGMENT RENEWED DATE:
LP/LJ: DATE: 03252002 DIST/LOC: 08 04 JUDGE ID: 9H7
INTEREST: 0.00 COST: 38.94 OTHER: 0.00
POST INTEREST LEGAL RATE: X CONTRACTUAL RATE:
IN FAVOR OF DEF: DISMISSED WITH PREJUDICE:
0.00 AWARDED TO: DAMAGES: 0.00
PROPERTY AND DAMAGES OF: 0.00 AWARDED TO:
RENEWED LIEN DATE: MMDDCCYY SEND NO NOTICES:
MMDDCCYY SATISFACTION DATE: MMDDCCYY
END OF DATA
pi 01
PAGE: 002
..... ....c...,
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,
DISTRICT COURT OF MARYLAND FOR BALTIMORE COUNTY 0804
120 E. CHESAPEAKE AVENUE (V)
TOWSON, MD 21286-5307
TO: BALENSON, JERI LYNN
KEY LEASING & RENiAL
POBOX 1002
TIMONIUM, MD 21094
I ~I~IIIIIIII~IIIIII~IIIIIIIIIIII~ Illmll~~~1 ~~I~mllll~1 ~IIIIII
CIVIL CASE NO.: 0804 - 0018589 - 2001
COMPLAINT NO.: 002
004248
KEY LEASING & RENTAL, LLC
VS.
BRYSON, YVONNE M
DATE: 03/26/2002
AFFIDAVIT JUDGMENT ENTERED
ON MARCH 25, 2002 THIS COURT ENTERED AN AFFIDAVIT
JUDGMENT IN FAVOR OF THE PLAINTIFF IN THE ABOVE CASE IN THE
AMOUNT OF $4773.32 PLUS ATTORNEY'S FEES OF $0.00,
COSTS OF $38.94, PRE-JUDGMENT INTEREST OF $0.00 AND
OTHER AMOUNT OF $0.00. PLUS POST-JUDGMENT INTEREST AT LEGAL RATE.
THE DEFENDANT HAS UNTIL APRIL 24, 2002 TO FILE A MOTION TO
VACATE THIS JUDGMENT. STATING A FACTUAL AND LEGAL BASIS FOR A
DEFENSE.
THE PLAINTIFF TO ENFORCE THIS JUDGMENT MAY FILE FOR A LIEN ON
ANY REAL PROPERTY OWNED BY THE DEFENDANT.
FOR QUESTIONS CONCERNING THIS DOCUMENT TELEPHONE (410) 512-2000,
HEARING/SPEECH IMPAIRED CALLERS ONLY, TELEPHONE TTY/TT 1-800-925-9690
OR THROUGH MARYLAND RELAY SERVICE AT 1-800-735-2258 OR 711.
R1
003964A
MAR 2 8 2002
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GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
KEY LEASING & RENTAL
P.O. Box 1002
Timonium, MD 21094
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
DOCKET NO.
05-2538
George D. Bryson
129 Regency Wood North
Carlisle PA 17013
and
Yvonne M. Bryson
129 Regency Wood North
Carlisle PA 17013
and
Soveriegn Bank
6520 Carlisle Pike
Mechanicsburg, PA 17050
GARNISHEE
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue writ of execution in the above matter,
directed to the Sheriff of Cumberland County;
(1) against
George D. Bryson
defendant (s)and
(2) against
Soveriegn Bank
garnishee(s)
(3) AMOUNT DUE
INTEREST
from May 17, 2005
COSTS
Prothonotary fee
Sheriff fee
$4,773.32
$176.23
$15.00
$150.00
TOTAL
$5 114.55
FREDERIC I. W
PAUL M. SCHOF
Attorney for
E
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-2538 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due KEY LEASING & RENTAL, Plaintiff (,)
From GEORGE D. BRYSON, YVONNE B. BRYSON, 129 REGENCY WOOD NORTH,
CARLISLE, PA 17013
(I) You are directed to levy upon the property of the defendant (.)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
ofSOVERIEGN BANK, 6520 CARLISLE PIKE, MECHANICSBURG, PA 17050
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) 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $4,773.32
Interest FROM 5/17/05 - $176.23
L.L. $.50
Atty's Comm %
Atty Paid $37.50
Plaintiff Paid
Date: OCTOBER 5, 2005
Due Prothy $1.00
Other Costs
(Seal)
By:
Deputy
REQUESTING PARTY:
Name FREDERIC I. WEINBERG, ESQUIRE
Address: GORDON & WEINBERG, ESQUIRE
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-988-9600
Supreme Court ID No, 41360
~
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
KEY LEASING & RENTAL
P.O. Box 1002
Timonium, MD 21094
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
DOCKET NO.
05-2538
George D. Bryson
129 Regency Wood North
Carlisle PA 17013
and
Yvonne M. Bryson
129 Regency Wood North
Carlisle PA 17013
and
Soveriegn Bank
6520 Carlisle Pike
Mechanicsburg, PA 17050
GARNISHEE
INTERROGATORIES IN ATTACHMENT
TO: Soveriegn Bank - GARNISHEE
1. You are required to file answers to the following
Interrogatories within twenty (20) days after
service upon you. Failure to do so my result in
judgment against you.
2. At the time you were served or at any subsequent
time did you owe the defendant(s) any money or
were you liable to him (her, them) on any
negotiable or other written instrument, or did he
(she, they) claim that you owed him (her, them)
any money or were liable to him (her, them) for
any reason?
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
r
DATED:
4. At the time you were served or at any subsequent
time did you hold a fiduciary any property in
which the defendant(s) had any interest?
No
5. At any time before or after you were served did
the defendant(s) transfer or deliver any property
to you or to any person or place pursuant to your
direction or consent and what was the
consideration thereof?
No
6. At any time after you were served did you pay,
transfer or deliver any money or property to the
defendant(s) or to any person or place pursuant to
his (her, their) direction or otherwise discharge
any claim of the defendant(s) against you?
No
7. How much is the value of any property in your
possession belonging to the defendant(s)?
See Attached
FREDERIC I.
PAUL M. SCH
Attorney for
NBERG, ESQUIRE
ELD, JR., ESQUIRE
Plaintiff
ANSWER TO INTERROGATORIES
Account #
2471713378
Balance:
$1,600.67
Account Holder:
Yvonne M. Bryson
George D. Bryson
129 Regency Wood North
Carlisle, PA 17013-9085
VERIFICATION
I, Timothy J. Cooney, OAG Team Leader of Sovereign Bank, hereby verify that the information
contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of
my knowledge, information and belief. 1 understand that false statements herein are made subject to
the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities.
Sovereign Bank
By:
Timothy J. Cooney
OAG Team Leader
,
-'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
INRE:
Key Leasing & Rental
vs.
George D. Bryson and Yvonne M. Bryson
CERTIFICATE OF SERVICE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner indicated below:
Service by first class mail addressed as follows:
Frederic L Weinberg, Esquire
Gordon & Weinberg, P.c.
21 South 21 st Street
Philadelphia, P A 19103
Service by certified mail addressed as follows:
Yvonne M. Bryson
George D. Bryson
129 Regency Wood North
Carlisle, P A 17013-9085
SignatUre 0 Person Filing
Timothy J. Cooney, OAG Team Leader
Sovereign Bank
MAl MB3-02-1O
2 Morrissey Boulevard
Boston, MA 02125
October 31, 2005
""
/
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
INRE:
Key Leasing & Rental
vs.
George D. Bryson and Yvonne M. Bryson
CERTIFICATE OF SERVICE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner indicated below:
Service by first class mail addressed as follows:
Frederic I. Weinberg, Esquire
Gordon & Weinberg, P.C.
21 South 21st Street
Philadelphia, P A 19103
Service by certified mail addressed as follows:
Yvonne M. Bryson
George D. Bryson
129 Regency Wood North
Carlisle, PA 17013-9085
Signat re 0 Person Filing
Timothy J. Cooney, OAG Team Leader
Sovereign Bank
MAl MB3-02-1O
2 Morrissey Boulevard
Boston, MA 02125
October 31, 2005
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SHERIFF'S RETURN - GARNISHEE
.
CASE NO: 2005-02538 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
KEY LEASING & RENTAL LLC
VS
BRYSON GEORGE D ET AL
And now SHANNON SHERTZER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0010:50 Hours, on the 13th day of October
2005, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
BRYSON GEORGE D
, in the
hands, possession, or control of the within named Garnishee
SOVEREIGN BANK 6520 CARLISLE PIKE
MECHANICSBURG, PA 17055
Cumberland County, Pennsylvania, by handing to
JESSICA NOTZ (PERSONAL BANKING REP)
personally three copies of interogatories together with 3
true
and attested copies of the within WRIT OF EXECUTION
and made
the contents there of known to Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
.00
.00
.00
.00
.00
.00
So ans~ .'
~ -~~e
R. Thomas Kline'
Sheriff of cumberland County
10/17/2005
Sworn and subscribed to before me
this l/P~ day of 7t,,-ve..'^,~
<l~<' AD ~
prottJ:~
By
.
SHERIFF'S RETURN - GARNISHEE
.
CASE NO: 2005-02538 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
KEY LEASING & RENTAL LLC
VS
BRYSON GEORGE D ET AL
And now SHANNON SHERTZER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0010:50 Hours, on the 13th day of October ,2005, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
BRYSON YVONNE M
in the
hands, possession, or control of the within named Garnishee
SOVEREIGN BANK 6520 CARLISLE PIKE
MECHANICSBURG, PA 17055
Cumberland County, Pennsylvania, by handing to
JESSICA NOTZ (PERSONAL BANKING REP)
personally three copies of interogatories together with 3
true
and attested copies of the within WRIT OF EXECUTION
and made
the contents there of known to Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
.00
.00
.00
.00
.00
.00
So ans"f.Eir~ //
rJAJ(, _. "I ~t.: -r ___"- -'&l'
R. Thomas Klin~
Sheriff of Curr~erland County
10/17/2005
"" I'
Ch'" J':~ tl~'Y O~"k-
Proth not~'
By
~ 1J-
. / 0/ ,.
/ V1",,-_ If. 6
eputy Sher f
Sworn and subscribed to before me
,.
.
2010286
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No. : 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
KEY LEASING & RENTAL
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
DOCKET NO.
05-2538
George D. Bryson
and
Yvonne M. Bryson
and
Sovereign Bank
Garnishee
NOTICE
PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE
HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED AGAINST
YOU IN THE ABOVE PROCEEDING.
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL
FREDERIC I. WEINBERG, ESQUIRE AT 215-988-9600.
,
,
2010286
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
KEY LEASING & RENTAL
P.O. Box 1002
Timonium, MD 21094
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
DOCKET NO.
05-2538
George D. Bryson
129 Regency Wood North
Carlisle PA 17013
and
Yvonne M. Bryson
129 Regency Wood North
Carlisle PA 17013
PRAECIPE FOR JUDGMENT UPON ADMISSION
TO THE PROTHONOTARY:
Please enter judgment in favor of the Plaintiff, KEY LEASING
& RENTAL and against the Garnishee, Sovereign Bank, in the amount
of $1,600.67, admitted in the Answer to Interrogatories to be in
the Garnishee's possession, together with interest and costs. The
amount of the judgment of the Plaintiff against the Defendant
together with post judgment costs and post judg~ent interest is
$5,393.07.
! r( 3.) 0 (
GORDON & WEINBERG, P.C.
Date:
BY:
FREDERIC I
.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
KEY LEASING & RENTAL
P.O. Box 1002
Timonium, MD 21094
vs.
DOCKET NO.
05-2538
George D. Bryson
129 Regency Wood North
Carlisle PA 17013
and
Yvonne M. Bryson
129 Regency Wood North
Carlisle PA 17013
and
Soveriegn Bank
6520 Carlisle Pike
Mechanicsburg, PA 17050
GARNISHEE
INTERROGATORIES IN ATTACHMENT
TO: Soverieqn Bank - GARNISHEE
1. You are required to file answers to the following
Interrogatories within twenty (20) days after
service upon you. Failure to do so my result in
judgment against you.
2. At the time you were served or at any subsequent
time did you owe the defendant(s) any money or
were you liable to him (her, them) on any
negotiable or other written instrument, or did he
(she, they) claim that you owed him (her, them)
any money or were liable to him (her, them) for
any reason?
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
t-
DATED:
4. At the time you were served or at any subsequent
time did you hold a fiduciary any property in
which the defendant(s) had any interest?
No
5. At any time before or after you were served did
the defendant(s) transfer or deliver any property
to you or to any person or place pursuant to your
direction or consent and what was the
consideration thereof?
No
6. At any time after you were served did you pay,
transfer or deliver any money or property to the
defendant(s) or to any person or place pursuant to
his (her, their) direction or otherwise discharge
any claim of the defendant(s) against you?
No
7. How much is the value of any property in your
possession belonging to the defendant(s)?
See Attached
FREDERIC I.
PAUL M. SCH
Attorney for
NBERG, ESQUIRE
ELD, JR., ESQUIRE
Plaintiff
ANSWER TO INTERROGATORIES
Account #
2471713378
Balance:
$1,600.67
Account Holder:
Yvonne M. Bryson
George D. Bryson
129 Regency Wood North
Carlisle, P A 17013-9085
VERIFICATION
I, Timothy J. Cooney, OAG Team Leader of Sovereign Bank, hereby verify that the information
contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of
my knowledge, information and belief. 1 understand that false statements herein are made subject to
the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities.
Sovereign Bank
By:
Timothy J. Cooney
OAG Team Leader
. '
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
INRE:
Key Leasing & Rental
vs.
George D. Bryson and Yvonne M. Bryson
CERTIFICATE OF SERVICE
I hereby certilY that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner indicated below:
Service by first class mail addressed as follows:
Frederic L Weinberg, Esquire
Gordon & Weinberg, P.c.
21 South 21 st Street
Philadelphia, PA 19103
Service by certified mail addressed as follows:
Yvonne M. Bryson
George D. Bryson
129 Regency Wood North
Carlisle, PA 17013-9085
Signat re 0 Person Filing
Timothy J. Cooney, OAG Team Leader
Sovereign Bank
MAl MB3-02-1O
2 Morrissey Boulevard
Boston, MA 02125
October 31, 2005
C 7CJ D ~
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
TOTAL
18.00
1.97
Advance Costs: 150.00
Sheriff's Costs 100.07
49.93
.50
1.00
9.60
Refunded to Atty on 5/12/06
40.00
20.00
9.00
100.07
~ {, - ()I" 0 6) Sworn and Subscribed to before me
f'"~4f!e
R. Thomas Kline, Sheriff ,
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-2538 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due KEY LEASING & RENTAL, Plaintiff (8)
From GEORGE D. BRYSON, YVONNE B. BRYSON, 129 REGENCY WOOD NORTH,
CARLISLE, P A 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of SOVERIEGN BANK, 6520 CARLISLE PIKE, MECHANICSBURG, P A 17050
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) 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $4,773.32
Interest FROM 5/17/05 - $176.23
L.L. $.50
Atty's Corom %
Atty Paid $37.50
Plaintiff Paid
Date: OCTOBER 5, 2005
Due Prothy $1.00
Other Costs
(Seal)
By:
Deputy
REQUESTING PARTY:
Name FREDERIC I. WEINBERG, ESQUIRE
Address: GORDON & WEINBERG, ESQUIRE
21 SOUTH 21sT STREET
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-988-9600
Supreme Court ID No. 41360
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 81894
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
'WE PROTHONg'
2-b 16286
2812 DEC 19 PM 2: 3 0
CUMBERLAND C LINTY
PENNSYLVA tp
KEY LEASING & RENTAL
VS.
George D. Bryson
and
Yvonne M. Bryson
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-2538
SUGGESTION OF BANKRUPTCY OF DEFENDANT
TO THE PROTHONOTARY:
AND NOW, this llDec12, it is suggested of record that
Defendant, George D. Bryson, filed a petition in bankruptcy under
Chapter 13 of the Bankruptcy Code on or about April 27, 2012, in
the United States Bankruptcy Court for the Middle District of
Pennsylvania, docke-? number 1202568. Therefore, this matter
should be stayed un-il further notice.
GORDON & WEINBERG, P.C.
BY:
FREDERICK WEINBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff