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Home My WebLink About05-5538 WOLFF & SAMSON, PC By: Robert T. Carlton, Jr. Attorney No.: 25050 Two Penn Center, Suite 1310 ] 500 John F. Kennedy Boulevard Philadelphia, P A ] 9] 02 Attorneys for Plaintiff Arch Insurance Company ARCH INSURANCE COMPANY Three Parkway, Suite 1500 Philadelphia, PA 19102 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Df:- f:f:Y> (!,~~L y~ v. BARRETT COMPANY, INC. 429A South] 8th Street Camp Hill, PA 17001 MICHAEL BARRETT and KIMBERLY BARRETT 429A South 18th Street Camp Hill, P A ] 7001 Defendants PRAECIPE TO INDEX JUDGMENT TO THE PROTHONOTARY: Please index of record the attached judgment of the United States District Court for the Middle District of Pennsylvania, entered in Civil Action No. 05.01765 in the amount of $110, 043.93, on October 7, 2005 against defendants Barrett Company, Inc., Michael Barrett and Kimberly Barrett, jointly and severally, all is shown on the attached certified copy of the judgment and docket entries of the United States District Court for the Middle District of Pennsylvania. WOLFF & SAMSON, P.c. By: /;7 ~) d" T ~€C/4 j Robert T. Carlton, Jr., EsqJ\re' Attorneys for Plaintiff Arch Insurance Company 983411 .. IN THE UNITED STATES DISTRICT COURT fOR TIIEMIDDLEDISTRlCT OF PENNSYLVANIA ARCH INSURANCE COMPANY CIVIL ACTION Plaintiff BARRETT COMPA1\ry, INC. MICHAEL BARRETT and KIMBERLY BARRETT No. 05-01765 FILES HARRISBURG OCT (j '7 ZOO,) MARY e. C'ANORIiiA, CLERK P.~ CEPUTY CLERK Defendant.~ JUDGMENT AND NOW, this 1 ~ay of &i. 2005 upon consideration of Plaintiff Arch Insurance Company's motion for entry ofajudgment by default, it is hereby ORDERED that said motion is gt'dllted and JUDGMENT in the amount of$110,043.93 is ENTERED in favor ofPJaintiff Arch [nsurance -Co'mpliriy and agamsfDefendan'ts'Barri:tt Company, tnG: Michael Barreniuld Kimberly Barrett, jointly and severally. BY THE COURT 4~J~A (""""'-'0"" f((\nyth:..e~ A ':~.'''''''''' /-a~~-e.. n.! L .1.,. ,I .:-:~.~~!-'~;~~~ ;.;.:;::-;~~'..""-"-." '(~';l~~~'~: Pennsylvania Middle District Version 2.5. Docket Report Page I of2 CLOSED, HBG U.S. District Court Middle District of Pennsylvania (Harrisburg) CIVIL DOCKET FOR CASE #: I:05-cv-OI765-SHR Internal Use Only Arch Insurance Company v. Barrett Company, Inc. et al Assigned to: Honorable Sylvia H. Rambo Demand: $75,000 Cause: 28: 1332 Diversity.Other Contract Plaintiff Arch Insurance Company Date Filed: 08/30/2005 Jury Demand: None Nature of Suit: 190 Contract: Other Jurisdiction: Diversity represented by Robert T. Carlton Wolff & Samson PC Two Penn Center Suite 1310 1500 John F. Kennedy Boulevard Philadelphia, P A 19102 215.567-2877 Email: rcarlton@wolffsamson.com LEAD A ITORNEY A ITORNEY TO BE NOTICED V. Defendant Barrett Company, Inc. Defendant Michael Barrett r. ,..,. j ""i"'?'i'~h~~,,','rr('; .,":'f.~~ _, . . ~:, h;;- -,.... 'A// d:~!U~'" ~ --.-,-. 'or~az Defendant Kimberly Barrett Date Filed # Docket Text 08/30/2005 ~l COMPLAINT. N/C 10 cns!.; no jury trial demanded. ( Filing fee $250, Receipt Number III 143978) (Attachments: # I Civil Cover Sheet # 2 Receipt)(jc) (Enlered: 08/31/2005) 08/3112005 ~ SUMMONS ISSUED as to defendants. (jc) (Entered: 08/31/2005) 09/13/2005 ~2 ORDER Re: Case Assignment and Procedures Signed by Judge Sylvia H. Rambo on 09/13/05. (ma,) (Entered: 09/13/2005) 09/29/2005 ~:2 SUMMONS Returned Executed upon defendants on 9/8/2005, answer due 9/28/2005. (jc) (Entered: 09/30/2005) https://ecf.pamd.circ3.dcn/cgi.bin/DktRpt.pl?1 0 I 898476443624.L _ 280 _ 0.1 10/17/2005 Pennsylvania Middle District Version 2.5. Docket Report Page 2 of2 ,. . ... 01130/2005 1)1 First MOTION for Entry of Default As To All Defendants by Arch Insurance Company.(Carlton, Robert) (Entered: 09/30/2005) 10/03/2005 I)~ Clerk's ENTRY OF DEFAULT as to Barrett Company, Inc., Michael Barrett, Kimberly Barrett for failuire to plead or otherwise defend. Signed by Deputy Clerk on 10/3/05. (pw, ) (Entered: 10/03/2005) 10/06/2005 1)6 MOTION for Default Judgment as to Defendants with Memorandum of Law In Support by Arch Insurance Company.(Carlton, Robert) (Entered: 10/06/2005) 10/06/2005 I) COUNSEL is advised that document 6 filed 10/6/05 is to be refiled with the proposed order as an attachment to the Motion for Default Judgment and the Brief in Support docketed as a separate document. (jc) (Entered: 10/06/2005) 10/07/2005 ~7 ORDER granting pltfs Mtn for entry of Default Judgment 6 Signed by Judge Sylvia H. Rambo on 10/07/05 (ma,) (Entered: 10/07/2005) 10/07/2005 1)8 MOTION for Default Judgment as to Defendants with Memorandum of Law In Support of Motion and Statements with Order and Certificate of Service by Arch Insurance Company. (Attachments: # 1 # 2 # ,1 # 1) (Carlton, Robert) (Entered: 10/07/2005) 10/11/2005 MOTION for Default Judgment S as to Defendants filed by Arch Insurance Company. Default granted 10/7/05 (ma, ) (Entered: 10/11/2005) https://ecf.pamd.circ3.dcnlcgi.binlDktRpt.pl?1 0 18984 76443624.L _ 280 _ 0-1 10/17/2005 J ~<) ,::\ ~ ~ ~ tl\l~ 9- __ C> ~ ':3 ~ -J ~ C> - r - ,f=- ~ h r --t- '., v:' ~ ~ri~ ~ \_:g r ~ C:: \> L-, \" .t. E ( +f:~~ F'4-~ 3 I ~ c. '^ t ~ ~ \- ~ ~ ~~ ~ I> t- + '0 G ~ Us ~ i-t: c" r- t: "i:;, i- r' ---- WOLFF & SAMSON PC By: Robert T. Carlton, Jr. Attorney No.: 25050 Two Penn Center, Suite 1310 1500 John F. Kennedy Boulevard Philadelphia, PA 19102 Attorneys for Plaintiff Arch Insurance Company ARCH INSURANCE COMPANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. 05-5538 - Civil Term BARRETT COMPANY, INC., MICHAEL BARRETT and KIMBERLY BARRETT Defendants PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, (I) directed to the Sheriff of Cumberland County; (2) against Barrett Company, Inc., defendant; and (3) against Commerce Bank/Harrisburg NA, garnishee; (4) and enter this writ in the judgment index (a) against Barrett Company, defendant, and IlL l ---.. 1.fJ.9 Ii Sbu.--n,. IP-I-Z. 5;'.j.. e.a.n-.p 'kt' ,/4} /76 I / +- (b) against Commerce Bank/Harrisburg NA as garnishee I-S .L).t..Ld' -d. f)UWu-Lt c.iu>-Ltsl.., ?A /701:}, -t-- (5) Amount due $110,043.93 Interest from October 7, 2005 Costs to be added g8466g~ 1 . .. 984669.1 2 WOLFF & SAMSON PC By: 4:7I::di. ~~ Robert T. Carlton, Jr.,._ qUire Attorneys for Plaintiff Arch Insurance Company 0<./5- 331- "'-ID6 -- G 2' :r % 1- ~~ ~ ~~ ff\ \) ~ r\ ~ L <J B VI ~ r- .t.Q..u:l. -- c'rIJ \) G ~ (-fY' r v..., ~ 'b: "'\} }.) () V{ \) lr1 0 CJ C) \2. l;) \ I :U ~ ~F _ - VI --J...~ :ir <-' () ~~ .('- .:::'.J' -"'" C~~ ~ ..... :F:n \.1 r"- --"CD :':-)"'1') C) l.~~\S:, -:. '~.;i.~rl\ t'....') ".-",:\ -\:--,.. -' 'd .;;.. ~ lIJ.... Jt1 1( f --.f:. ~ '"t ~ ~ ~ , I WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 05.5538 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ARCH INSURANCE COMPANY, Plaintiff (s) From BARRETT COMPANY, INC., MICHAEL BARRETT AND KIMBERLY BARRETT, 429 A SOUTH 18TH ST., CAMP HILL, PA 17011 (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 COMMERCE BANK/HARRISBURG NA AS GARNISHEE, 65 ASHLAND AVENUE, CARLISLE, PA 17013 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attaclunent 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 hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $110,043.93 Interest FROM 10/7/05 L.L. $.50 Atty's Cornm Atty Paid $38.00 Plaintiff Paid Date: NOVEMBER 10, 2005 % Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name ROBERT T. CARL TON, JR., ESQUIRE Address: WOLFF & SAMSON PC TWO PENN CENTER, SUITE 1310 1500 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19102 Attorney for: PLAINTIFF Telephone: 215.337.4510 Supreme Court ID No. 25050 .' SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-05538 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND ARCH INSURANCE COMPANY VS BARRETT COMPANY INC ET AL And now BRIAN BARRICK ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:45 Hours, on the 17th day of November, 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT BARRETT COMPANY INC , in the hands, possession, or control of the within named Garnishee COMMERCE BANK/HARRISBURG NA 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to REBECCA BONAWITZ (TELLER SERVICE MANAGER 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 So ~~~ .00 .00 .00 .00 .00 .00 R. Thomas Kline Sheriff of Cumberland County t hi s ,)J,,^,^- da y 0 t'7Z(}=A<A-L-.- hv> ~/:~ Pro ono 7 By ~ 4th /-ea . Deputy Sheriff 11/18/2005 Sworn and subscribed to before me ./ SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-05538 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND ARCH INSURANCE COMPANY VS BARRETT COMPANY INC ET AL And now BRIAN BARRICK ,Sheriff or ~eputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:45 Hours, on the 17th day of November, 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT BARRETT MICHAEL , in the hands, possession, or control of the within named Garnishee COMMERCE BANK/HARRISBURG NA 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to REBECCA BONOWITZ (TELLER SERVICE MANAGER) 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~~ ~ ~". "l""~~~ R. Thomas Kline' Sheriff of Curr~erland County this ;?J~ day of7U'O-~",j,..,^-, .;Jtm~ A.D. ",o,~f1f!jfi ! By 11/18/2005 Sworn and subscribed to before me SHERIFF'S RETURN - GARNISHEE ./ CASE NO: 2005-05538 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND ARCH INSURANCE COMPANY VS BARRETT COMPANY INC ET AL And now BRIAN BARRICK ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:45 Hours, on the 17th day of November, 2005. attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT BARRETT KIMBERLY in the hands, possession, or control of the within named Garnishee COMMERCE BANK/HARRISBURG NA 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to REBECCA BONOWITZ (TELLER SERVICE MANAGER) 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~ . ~. 'l-~~I' R. Thomas Kline Sheriff of Cumberland County this ;U~ day of~ J"U; A~.D: . ~ih -~~ Prot onot, By I ffi;J JI) eputy Sheriff 11/18/2005 Sworn and subscribed to before me , . WOLFF & SAMSON PC By: Robert T. Carlton, Jf. Attorney No.: 25050 Two Penn Center, Suite 1310 1500 John F. Kennedy Boulevard Philadelphia, PA 19102 Attorneys for Plaintiff Arch Insurance Company ARCH INSURANCE COMPANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff v. 05-5538 . Civil Term BARRETT COMPANY, INC., MICHAEL BARRETT and KIMBERLY BARRETT Defendants t.J/151.UC'r) -10 INTERROGATORIES IN ATTACHMENT TO: Commerce Bank/Harrisburg NA, Garnishee You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you.: 1. At the time you were served or at any subsequent time did you owe the defendant Barrett Company, Inc. any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? Defendant has account 536734692 and 513209643 for the Barrett Company Inc. Account 536743692 has a balance of $97.21 and 513209643 has a blaance of $-12,947.82. Kimberly Barrett has accounts 513245720 and 616266899 at the time served and 513245720 has a balance of $71.69 and 616266899 has a balance of $74.66. Michael Barrett has account 513245613 with a balance of $37.93 at the time served. 985947 , ~ 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself or one or more other persons any property of any nature owned solely or in part by the defendant? See answer to question 1. 3. At the time you were served or a any subsequent time did you hold legal tide to any property of any nature owned solely or in part by th<: defend~nt or in which the defendant held or claimed any mterest? See answer to question 1. 4. At the time you were served or at any subsequent time did you hold as a fiduciary any property in which the defendant had an interest? No, 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefore? Defendant made deposits into the above referenced accounts in the ordinary course prior to service, none of which were at the direction of Commerce Bank. 2 985947 .. -. 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direclion or otherwise discharge any claim ofthe defendant against you? No, but there will be a $100.00 processing fee accessed at the time when judgement is entered. WOLFF & SAMSON PC By: ./. .. //) l /'c~ ~ / 0'Hf ,-- Robert T. Carlton, Jr. Attorneys for Plaintiff Arch Insurance Company COMMERCE BANK/HARRISBURG CV\\LLp$ Clv\~1J\\OJ\ \~)11()~ 3 985947 C) (.:l ,.... ) C'J WOLFF & SAMSON PC By: Robert T. Carlton, Jr. Attorney No: 25050 Two Penn Center, Suite 1310 1500 John F. Kennedy Boulevard Philadelphia, P A 19102 Attorneys for P1amtiff Arch Insurance Company IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANIA ARCH INSURANCE COMPANY Plaintiff Y. 05-5538 - Civil Tenn BARRETT COMPANY, INC, MICHAEL BARRETT and KIMBERLY BARRETT Defendants AI1'it-,)C'e; -k' INTERROGATORIES IN ATTACHMENT TO: Commerce Bank/Harrisburg NA, Garnishee You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you.: I. At the time you were served or at any subsequent time did you owe the defendant Barrett Company, ]nc~ any money or were you liable to the defendant on any negmiable or other written instmment, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? Defendant has account 536734602 and 513209643 for the Barrett Company Inc. Account 536743692 has a balance of $97.21 and 513209643 has a blaance of $-12,947.82. Kimberly Barrett has accounts 513245720 and 616266899 at the time served and 513245720 has a balance of $71.69 and 616266899 has a balance of $74.66. Michael Barrett "as 8ccount 5132/,5613 with a balance of $37.93 at tIle time served. Barrett Land and Cattle has account 513209601 with a balance of $343,580.23. Barrett Land and Cattle is a sole-proprietor using Michael Barrett's social security number. 985947 2~ At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself or one or more other persons any property of any nature owned solely or in part by the defendant? See answer to question 1. 3 At the time you were served or a any suhsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which the defendant held or claimed any interest? See answer to question 1. 4~ At the time you were served or at any subsequent time did you hold as a fiduciary any property in which the defendant had an interest? No, 5. At any time before or after you were served did the defendant transfer or deliver any propel1y to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefore? Defendant made deposits into the above referenced accounts in the ordinary course prior to service, none of which were at the direction of Commerce Bank. 2 985947 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? No, but there will be a $100.00 processing fee accessed at the time when judgement is entered. WOLFF & SAMSON PC ;;/.O/;? 'l" , BY_ct>-,/ 0", /' ~--~ Robert T. Carlton, Jr. Attorneys for Plaintiff Arch Insurance Company 3 98-"()47 ,~ "'1 ;";' "f C::" f' C', ... t - -. WOLFF & SAMSON PC By: Robert T. Carlton, Jr. Attorney No.: 25050 Two Penn Center, Suite 1310 1500 John F. Kennedy Boulevard Philadelphia, P A 19102 Attorneys for Plaintiff Arch Insurance Company IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ARCH INSURANCE COMPANY Plaintiff v. 05-5538 - Civil Term BARRETT COMPANY, INC., MICHAEL BARRETT and KIMBERLY BARRETT Defendants STIPULATION IT IS HEREBY STRIPULATED AND AGREED as of May 5, 2006 by and between Michael Barrett and Arch Insurance Company, by and through its counsel Wolff & Samson PC as follows: I. Barrett Land and Cattle is a sole proprietorship, owned by Michael Barrett, which has an account no. 513209601 with Commerce BanklHarrisburg NA ("the Account''). 2. The Account is subject to a writ of garnishment issued in this civil action at the request of Arch Insurance Company. 3. In order to have the garnishment released, Arch and Barrett agree that Commerce Bank shall issue its check, payable to the order of Arch Insurance Company, in the amount of $155,000, in exchange for which Arch shall file a Praecipe that dissolves the garnishment against the Account. t .. .. / . 4. Upon receipt of the Praecipe, Commerce Bank may deliver the balance of funds in the Account to Michael Barrett, or continue to hold the funds in the Account free and clear of any attachment by Arch Insurance Company, subject to the direction of Michael Barrett. 5. Upon receipt of the funds from Commerce Bank, Arch shall cause the judgment entered in this civil action and the judgment entered in civil action no. 05-05-1765 in the United States District Court for the Middle District of Pennsylvania to be marked satisfied of record. Arch Insurance Company by its counsel Wolff & Samson PC By:L~ Robert T. C ton, Jr. ~h~ IC ae arrett ~ Attorneys for Plaintiff Arch Insurance Company 2 ....... ~ i () "> c:.: = ~ "'" -,.,$: "" ",C'" ::Ji:: ~:o fTlr~:, :z-. ..~. :boo -;"'-;;;;-'- -< 1,- UJ ~~ :om r4',~ en -rJ6 ~.::::-" 0 J~" " ~-,~ ~,. ( :1: I !6:E' :Jl: 2iJ5 ;:....,: w Om ::;j <.0) 35 .,- -<; "./ ..... - WOLFF & SAMSON PC By: Robert T. Carlton, Jr. Attorney No.: 25050 Two Penn Center, Suite 1310 1500 John F. Kennedy Boulevard Philadelphia, P A 19102 Attorneys for Plaintiff Arch Insurance Company ARCH INSURANCE COMPANY Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-5538 - Civil Te.rm BARRETT COMPANY, INC., MICHAEL BARRETT and KIMBERLY BARRETT Defendants PREACIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve Plaintiff/Judgment Creditor Arch Insurance Company's garnishment/attachment against Garnishee Commerce BanklHarrisburg, N.A. in the above captioned civil action. 'Volff & Samson PC BY~~ Robert T. Carlton, . Attorneys for Plaintiff Arch Insurance Company - -'" ...", CERTIFICATE OF SERVICE I, Robert T. Carlton, Jr., certify that on May 22, 2006 I served a true and correct copy of the foregoing Praecipe to Dissolve by first class mail upon: Barrett Compan~, Inc. 429 A South 18t Street Camp Hill, PA 17011 Michael Barrett 429 A South 18th Street Camp Hill, PA 17011 Kimberly Barrett 429 A South 18th Street Camp Hill, PA 17011 d7 Robert T. Carlto , Jr. - N (J {q. \i '\ ~ 0 -... :::::: 0 ~ CI) p:J ~ "- lr' ~ -t- Q .;:'C '~':: . , '....""- ~-; ~ = ""... --l '-'" ::r: .,., Cc; rn e .~- -0 G.i 6, :"~lt) ~:= :r~ -u ~')-""'l :::: :..::: ~. h s~ ~ ~ =-< --.I - ...". . L? "n. . .. WOLFF & SAMSON PC By: Robert T. Carlton, Jr. Atlorney No.: 25050 Two Penn Center, Suite 1310 1500 John F. Kennedy Boulevard Philadelphia, PA 19102 Attorneys for Plaintiff Arch Insurance Company ARCH INSURANCE COMPANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. 05.5538 . Civil Term BARRETT COMPANY, INC., MICHAEL BARRETT and KIMBERLY BARRETT Defendants PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment in favor of Plaintiff Arch Insurance Company and against Defendants Barrett Company, Inc., Michael Barrett and Kimberly Barrett satisfied of record. Wolff & Samson PC By: -m.. obert T. Carlto Attorneys for Plainliff Arch Insurance Company . -. CERTIFICATE OF SERVICE I, Robert T. Carlton, Jr., certify that on June 16, 2006 I served a true and correct copy of the foregoing Praecipe 10 Satisfy Judgment by first class mail upon: Barrett Compan~, Inc. 429 A South 18' Streel Camp Hill, P A 17011 Michael Barrett 429 A South 18th Street Camp Hill, P A 17011 Kimberly Barrett 429 A South 18th Street Camp Hill, P A 17011 Robert T. Carlto Jr. 0 r-..) c,;:, C L~-:~ r~J"" ,~~ r.....' 0 -:'] :Jo" L) ,-~ C:. .JvJ ",-". -< ..- . . 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 Pone Sale Certified Mail Postage Garnishee TOTAL ~ 18.00 1.87 Advance Costs: 150.00 Sheriffs Costs 95.17 54.83 .50 1.00 4.80 Refunded to Atty on 5/12/06 40.00 20.00 9.00 95.17 ~ (, /1.1/ c6 ,~ ~ Sworn and Subscribed to before me Cr, V\ 0l "<7 f1!1r ~~ C!::::::::::-J ffftJ ~ ~~-~~ R. Thomas Kline, Slieriff BYCJ CL-u-JI~ ~LiJMl/ E E :8 \/ S I i\ON SOOZ .'1 ~LJ ~~ ~::- [YJ~ ll-[!~-. (C:""- ...-- , j'1l /. Ut <rlflOI i2u/ /1 q 0 ~ 0 .AI WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5538 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ARCH INSURANCE COMPANY, Plaintiff (s) From BARRETT COMPANY, INC., MICHAEL BARRETT AND KIMBERLY BARRETT, 429 A SOUTH 18TH ST., CAMP HILL, PA 17011 (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 COMMERCE BANK/HARRISBURG NA AS GARNISHEE, 65 ASHLAND AVENUE, CARLISLE, P A 17013 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 accoWlt 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 fOWld 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 $110,043.93 Interest FROM 10/7/05 L.L. $.50 Atty's Corom % Arty Paid $38.00 Plaintiff Paid Date: NOVEMBER 10, 2005 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name ROBERT T. CARLTON, JR., ESQUIRE Address: WOLFF & SAMSON PC TWO PENN CENTER, SUITE 1310 1500 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19102 Attorney for: PLAINTIFF Telephone: 215-337-4510 Supreme Court ID No. 25050