HomeMy WebLinkAbout05-5823
(
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Gates, Halbruner & Hatch, P.C.
By: Albert N. Peterlin, Esquire
PA Attorney 10 No. 84180
1013 Mumma Road, Suite 100
Lemoyne, P A 17043-1144
(717) 731-9600
(717) 731-9627 facsimile
a. oeterlin@aateslawfirm.com
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
------------------------------------------------------)[
GATES, HALBRUNER & HATCH, P.C.,:
Civil Action
Plaintiff,
Case No. OS- .sg;;13
v.
VICTOR B. & REBECCA E. SNYDER,
Defendants.
------------------------------------------------------)[
PRAECIPE TO ENTER JUDGMENT
TO THE PROTHONOTARY:
Please enter the attached money judgment in the amount of $2490.25. The
undersigned certifies that a copy of this Praecipe has been mailed to the defendant
Respectfully Submitted,
GATES, HALBRUNER & HATCH, P.C.
Dated: November 7,2005 By:
f
COMMONWEALTH OF PEN A- VANIA
Cl'iUNl'Y OF: CUMBBIlLAlIP'
09-1-02
NOTICE. JUDGMENTfTRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME artd ADDRESS
'GATES, HALBRURBR & BATCH, P.C I
1013 MUMMA ROAD APTlSTE 100
LEMOYRE, PA 17043
L ~
Mag. Dist No
MDJ Name: Han
ROBBRT V. MARLOVE
Add"". 1901 STATB ST
CAMP HILL, PA
VS.
T"'phoo,. (717 )761-0583
17011-0000
DEFENDANT:
'sNYDBR, VICTOR B,
29 E COOVER ST
MBCIlAlfICSBtJRG,
L
NAME and ADDRESS
ET AL.
I
PA 17055-4218
GATBS, HALBRURBR & BATCH, P.C.
1013 MUMMA ROAD APT/STE 100
LEMOYRE, PA 17043
Docket No.: CV-0000134-05
Date Filed: 3/23/05
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THIS IS TO NOTIFY YOU THAT:
Judgment' .
DI!:I!'AULT JUDimRllT PLTP
[i]
[i]
Judgment was entered for:
(Name)
aa.T''IlA a.a.T.R'RTT'N"'R'R" 'R.
a.T~'R'T p
Judgment was entered against: (Name)
AJlYDRR, VT(!TOR R
in the amount of $
2,4QO 2!i on:
(Date of Judgment)
4/1Q/0",
. .
D Defendants are jointly and severally liable.
D Damages will be assessed on:
D This case dismissed without prejudice.
(Date & Time)
D Amount of Judgment Subject to
AttachmenV42 Pa.C.S. S 8127 $
o Portion of Judgment for physical
damages arising out of residential
lease $
Amount of Judgment $ 2,375.15
Judgment Costs $ 115.10
Interest on Judgment $ .00
Attorney Fees $ .00
Total $ 2,490.25
.
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 FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT 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.
rc;.(" Date
It
, Magisterial Di$lrict Judge
ify r2~~ a tru
o Date
e proceedings containing the judgment.
~
, Magisterial District Judge
My commission expires first Monday of January, 2006
SEAL
AOPC 315.05
DATB PRINTED:
4/19/05
2:14:47 PM
1
COMMONWEALTH OF PE~VANIA
c.oltNr~ OF: COJIBBVT."
r
09-1-02
NOTICE 6J JUDGMENTrrRANSCRIPT
CIVIL CASE
PLAINTIFF. . NAME and ADDRESS
~ATBS, HALBRuRBR & BATCH, P.C I
1013 MUMMA ROAD APT/STB 100
LBMOYBB, PA 17043
Mag. Disl. No'
MDJ Name: Hon
Addr,)ss:
ROBBRT V. KAlIILOVE
1901 STATB ST
CAMP HILL, PA
L
-.J
VS.
T""hO", (71'7) 761...0583
17011-0000
DEFENDANT: NAME and ADDRESS
IsRYDBR, VICTOR B, BT AL.
29 B COOVER ST
HBCHARICSBURG, PA 17055-4218
I
GATBS, HALBRURBR & BATCH, P.C.
1013 MUMMA ROAD APT/STB 100
LBMOYBB, PA 17043
L
Docket No.: CV-0000134-05
Date Filed: 3/23/05
-.J
-
THIS IS TO NOTIFY YOU THAT:
J4dgment: '~.=~.M
. DK~AULT .'TTJ1lmnn1'\'. PLTI!'
[!]
[!]
Judgment was entered for:
(Name)
t:!.....1l~ 'A'aT.'AVTT'N"'IlV a:. R_
aTC'lI. 1>
Judgment was entered against: (Name)
RRYDRR, VR~R~~" R
in the amount of $
2 4Cln 2" on:
(Date of Judgment)
4/1Cl/n<;
o Defendants are jointly and severally liable.
o Damages will be assessed on:
o This case dismissed without prejudice.
(Date & Time)
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
$ 2,375.15
$ 115.10
$ .00
$ .00
$ 2.490.25
O Amount of Judgment Subject to
Attachment/42 Pa.C.S. 9 8127 $ _
D Portion of Judgment for physical
damages arising out of residential
lease $
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 FILING A NOTICE
OF APPEAL WITH THE~ROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION: YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT 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 "NfRY OF SATiSFACTiON WITh ThE MAGii:;"1 EH.AL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
I
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
41 j Q/05 . Date , Magisterial District Judge
I certify that this is a true the proceedings containing the judgment.
~ Date , Magisterial District Judge
I
My commission expires first Monday of January, 2006 SEAL
AOPC 315.05
DATB PRINTED:
4/2S/05
9:07:39 Ml
, ~
CERTIFICATE OF SERVICE
I, Jeffrey L Shaffer, Legal Assistant, hereby certify that a true and correct
copy of the foregoing Praecipe to Enter Judgment has been served this day upon the
following parties by United States first class mail, postage prepaid, addressed as
follows:
Victor B. & Rebecca E. Snyder
29 East Coover St.
Mechanicsburg, PA 17055-4218
pro se
GATES, HALBRUNER & HATCH, P.C.
Date: November 7, 2005
By:
--~ ~
ey . Shaffer, . egal Assistant
meys for Plain Off
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Gates, Halbruner & Hatch, P.C.
By: Albert N. Peterlin, Esquire
PA Attorney 10 No. 84180
1013 Mumma Road, Suite 100
Lemoyne, PA 17043-1144
(717) 731-9600
(717) 731-9627 facsimile
a. peterlinlalaateslawfirm. com
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
------------------------------------------------------)(
GATES, HALBRUNER & HATCH, P.C.,:
Civil Action
Plaintiff,
Case No. (y) - -:fa '3
v.
VICTOR B. & REBECCA E. SNYDER,
Defendants.
------------------------------------------------------)(
PRAECIPE FOR WRIT OF E)(ECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter,
(1) directed to the Sheriff of CUMBERLAND County;
(2) against Victor B. & Rebecca E. Snyder, defendants; and
(3) against Commerce Bank, garnishee;
(4) and index this writ
(a) against Victor B. & Rebecca E. Snyder, defendants and
(b) against
, as garnishee as a lis pendens against real
property of the defendant in name of garnishee as follows:
.
Interest from 4/19/05
$2490.25
$ 82.69
(5) Amount Due
[Costs to be added]
$ 2M.!:),
Respectfully Submitted,
GATES, HALBRUNER & HATCH, P.C.
Dated:November 7,2005 By:
. Pe rlin, Esq
Attorneys for Plaintiff
-.
CERTIFICATE OF SERVICE
I, Jeffrey L. Shaffer, Legal Assistant, hereby certify that a true and correct
copy of the foregoing Praecipe for Writ of Execution has been served this day upon the
following parties by United States first class mail, postage prepaid, addressed as
follows:
Victor B. & Rebecca E. Snyder
29 East Coover St.
Mechanicsburg, PA 17055-4218
pro se
GATES, HALBRUNER & HATCH, PoCo
Date: November 7,2005
By: L.
Je y L. Shaffer, Leg' Assistant
Aft eys for Plaintiff
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IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
------------------------------------------------------)(
GATES, HALBRUNER & HATCH, PoCo,:
Civil Action
Plaintiff,
Case Noo 0)-. scJ3
Vo
VICTOR B. & REBECCA Eo SNYDER,
Defendantso
------------------------------------------------------)(
WRIT OF E)(ECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY
To satisfy judgment, interest, and costs against Victor B. & Rebecca E. Snyder,
defendants,
(1) You are directed to levy upon the property of the defendant and to sell
defendant's interest therein, including, but not limited to, any and all personal property
located at defendant's residence, commonly identified as 29 East Coover St.,
Mechanicsburg, PA 17055-4218.
(2) You are also directed to attach the property of the defendant not levied
upon in the possession of Commerce Bank, garnishee, all sums due defendant from
garnishee all property of defendant possessed by garnishee. All accounts including all
savings, checking and other accounts, certificates of deposit, notes receivable,
collateral, pledges, documents of title, securities, coupons and safe deposit boxes,
especially account no. 513173294 and to notify the garnishee that:
(a) an attachment has been issued;
/ ~
(b) the garnishee is enjoined from paying any debt to or for the
account of the defendant and from delivering any property of the defendant or
otherwise disposing thereof.
(3) If property of the defendant not levied upon and subject to attachment is
found in the possession of anyone other than a named garnishee, you are directed to
notify them that they have been added as garnishee and are enjoined as above stated.
REAL DEBT
INTEREST
From 04/19/2005
COST PAID: ~ 205.23 '
PROTHONOTARY $ 38.2&
SHERIFF $ IdO.OO
STATUTORY $
COSTS DUE ~.25
,
$2490.25
$ 82.69
Prothonotary
BY
DATE
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IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
------------------------------------------------------)(
GATES, HALBRUNER & HATCH, PoCo,:
Civil Action
Plaintiff,
Case Noo 0') - 5Y;13
Vo
VICTOR Bo & REBECCA Eo SNYDER,
Defendantso
------------------------------------------------------)(
WRIT OF E)(ECUTION - NOTICE
This paper is a writ of execution. It has been issued because there is a judgment
against you. It may cause your property to be held or taken to pay the judgment. You
may have rights to prevent your property from being taken. A lawyer can advise you
more specifically of these rights. If you wish to exercise your rights, you must act
promptly.
The law provides that certain property cannot be taken. Such property is said to
be exempt. There is a debtor's exemption of $300.00. There are other exemptions that
may be applicable to you. Attached is a summary of some of the major exemptions.
You may have other exemptions or other rights.
If you have an exemption, you should do the following promptly:
(1) Fill out the claim form and demand a prompt hearing.
(2) Deliver the form or mail it to the sheriff's office at the address noted.
You should come to court ready to explain your exemption. If you do not come to
court and prove your exemption, you may lose some of your property.
This and any future communication from our debt collection firm are attempts to
collect a debt, and information obtained will be used for that purpose.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW 0
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYERo
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEEo
Cumberland County Bar Association Lawyer Referral Service
32 South Bedford St.
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
------------------------------------------------------)(
GATES, HALBRUNER & HATCH, P.Co, :
Civil Action
Plaintiff,
Case No.
v.
VICTOR B. & REBECCA E. SNYDER,
Defendantso
------------------------------------------------------)(
WRIT OF E)(ECUTION - NOTICE
This paper is a writ of execution. It has been issued because there is a judgment
against you. It may cause your property to be held or taken to pay the judgment. You
may have rights to prevent your property from being taken. A lawyer can advise you
more specifically of these rights. If you wish to exercise your rights, you must act
promptly.
The law provides that certain property cannot be taken. Such property is said to
be exempt. There is a debtor's exemption of $300.00. There are other exemptions that
may be applicable to you. Attached is a summary of some of the major exemptions.
You may have other exemptions or other rights.
If you have an exemption, you should do the following promptly:
(1) Fill out the claim form and demand a prompt hearing.
(2) Deliver the form or mail it to the sheriff's office at the address noted.
You should come to court ready to explain your exemption. If you do not come to
court and prove your exemption, you may lose some of your property.
This and any future communication from our debt collection firm are attempts to
collect a debt, and information obtained will be used for that purpose.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCEo IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW 0
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEEo
Cumberland County Bar Association Lawyer Referral Service
32 South Bedford St.
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
-------------------------------.----------------------)(
GATES, HALBRUNER & HATCH, P.C.,:
Civil Action
Plaintiff,
Case Noo
Vo
VICTOR B. & REBECCA Eo SNYDER,
Defendants.
.-.-..---.--.-..--..--.---..------.........-----------)(
WRIT OF E)(ECUTION - NOTICE
This paper is a writ of execution. It has been issued because there is a judgment
against you. It may cause your property to be held or taken to pay the judgment. You
may have rights to prevent your property from being taken. A lawyer can advise you
more specifically of these rights. If you wish to exercise your rights, you must act
promptly.
The law provides that certain property cannot be taken. Such property is said to
be exempt. There is a debtor's exemption of $300.00. There are other exemptions that
may be applicable to you. Attached is a summary of some of the major exemptions.
You may have other exemptions or other rights.
If you have an exemption, you should do the following promptly:
(1) Fill out the claim form and demand a prompt hearing.
(2) Deliver the form or mail it to the sheriff's office at the address noted.
You should come to court ready to explain your exemption. If you do not come to
court and prove your exemption, you may lose some of your property.
This and any future communication from our debt collection firm are attempts to
collect a debt, and information obtained will be used for that purpose.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW 0
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association Lawyer Referral Service
32 South Bedford St.
Carlisle, PA 17013
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N 005-5823 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GATES HALBRUNER & HATCH, P.c. Plaintiff (s)
From VICTOR B. AND REBECCA E SNYDER, 29 EAST COOVER STREET,
MECHANICSBURG, PA 17055-4218
(1) You are directed to levy upon the property of the defendant (s)and to sell Any and all personal
property located at defendant's residence commonly identified as 29 East Coover Street,
Mechanicsburg, PA 17055-4218
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of Commerce Bank (any branch), all accounts including all savings, checking and other accounts,
certificates of deposit~ notes receivable, collateral, pledges documents of title, securities, coupons and
safe deposit boxes, especially account no. 513173294,
GARNlSHEE(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 himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due$2490.25
Interest from 4/19/05 $82069
Atty's Comm %
Ally Paid
Plaintiff Paid $37.50
L.L.$.50
Due Prothy $1.00
Other Costs
Date: November 9, 2005
.-- !J
Prothonotary /----
(Seal) By:
Deputy
REQUESTING PARTY:
Name Albert N. Peterlin, Esq.
Address: 1013 Mumma Road, Suite 100
Lemoyne, P A 17043-1144
Attorney for: Plaintiff
Telephone: 717-731-9600
Supreme Court ID No. 84180
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Rx DatelTime NOV-c8-c005(MDN) 17: 13
NO~-28-2005 16:11 GRTES,HRLBRNR,HRTCH
717 731 %c7
P ODe
717 731 9627 P.02/11
Gates, Halbruner & Hatch, P.C.
By: Albert N. Peterlin, Esquire
PA Attorney ID No. 84180
1013 Mumma Road, Suite 100
Lemoyne, PA 17043-1144
(717) 731-9600
(717) 731-9627 facsimile
a. peterlin@aateslawfirm.com
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
..-----------..---.........--.........................)(
GATES, HALBRUNER & HATCH, P.C., :
Civil Action
Plaintiff,
Case No. 05-05823, Civil Term
v.
VICTOR B. & REBECCA E. SNYDER,
Defendants.
...........................------------------------...)(
flVl~i.Je0 Iv INTERROGATORIES IN ATTACHMENT
TO: Commerce Bank
YOU MUST FILE WITH THE COURT VERIFIED ANSWERS TO THE FOLLOWING
INTERROGATORIES IN ATTACHMENT WITHIN TWENTY (20) DAYS AFTER
SERVICE UPON YOU. FAILURE TO DO SO MAY RESULT IN A DEFAULT
JUDGMENT BEING ENTERED AGAINST YOU. A COpy OF THE ANSWERS MUST
BE SERVED ON THE UNDERSIGNED. IF YOUR ANSWER TO ANY OF THE
INTERROGATORIES IS AFFIRMATIVE, SPECIFY THE AMOUNT AND VALUE
AND/OR COMPLETELY DESCRIBE THE NATURE OF THE SUBJECT PROPERTY.
IF YOUR ANSWER DEPENDS UPON THE REVIEW OF ANY DOCUMENTS,
ACCOUNT RECORDS, OR OTHER PAPERS OR ELECTRONIC DATA,
COMPLETELY DESCRIBE THE SAME IN E>tACT DETAIL (OR ATTACH A COpy OF
THE SAME).
Interrogatories In Attachment, 1 of 10
Rx Oate/Time NOV.28-2005(MON) If: 13
NO~-28-2005 16:11 GRTES,HRLBRNR,HRTCH
{If B1 %2{
P 003
717 731 9627 P.03/11
1. a. At the time you were served or at any subsequent time, did you owe the
defendant(s] any money or were you liable to defendant(s] on any negotiable or other
written instrument, or did defendant[s] claim that you owed any money or were liable to
defendant[s] for any reason?
b. To the extent that your above answer depends in whole or part on
documents, account records, other papers, or electronic data, describe each in exact
detail (or attach a copy of the same).
tf\ft\chCUl+-S "ewe aCCollnf 31611()'af\4- \\Il:H\ C\
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oQ\GIf\Ct' Of
bl~ \lQ0i
C\ JIGGOO \J\()ce~l~ \b: \\\\\\ ell \/,-.]L\ \ bt' OCClJ~tc\ CtI-
-the. -time i"Y'Dl'iEj kS ~iltc\ for plC\\ltlfF.
Interrogatories In Attachment, 2 of 10
Rx Date/Time NOV-cB-cOOS(MON) 17: 13
NO~-28-2005 16:12 GATE5,HALBRNR,HATCH
7\7 13\ 9027
717 731 9627
P ooa
P.04/11
2. a. 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 property of any nature owned solely or in part by
the defendant[s]?
b. To the extent that your above answer depends in whole or part on
documents, account records, or other papers or electronic data, describe each in exact
detail (or attach a copy of the same).
,See O--X\:w~er~o %illhh)() I.
Interrogatories In Attachment. 3 of 10
Rx oate/Time NoV-28-200S(MON) 1?: 13
NDU-28-2005 15:12 GATES,HALBRNR,HATCH
II? 731 90(1
P 005
717 731 9527 P.05/11
3. a. At the time you were served or at any subsequent time, did you
hold legal title to property of any nature owned solely or in part by the defendant[s] or in
which defendsnt[s] held or claimed any interest?
b. To the extent that your above answer depends in whole or part on
documents, account records, or other papers or electronic data, describe each in exact
detail (or attach a copy of the same).
:)te (L\\S\\ltY' ~O ~Ut\StI0 II I.
Interrogatories In Attachment, 4 of 10
Rx Date/TIme NOV-28-200S(MON) \ (: \ 3
NO~-28-2005 16:12 GATES,HALBRNR,HATCH
(17 131 %27
717 731 9627
P 005
P.06/11
4. a. At the time you were served or at any subsequent time, did you
hold as a fiduciary property in which the defendant[s] had an interest?
b. To the extent that your above answer depends in whole or part on
documents, account records. or other papers or electronic data, describe each in exact
detail (or attach a copy of the same).
~~.
Interrogatories In Attachment, 5 of 10
Rx Date/TIme NDV-28-2DD5(MDN) 17: 13
NO~-28-2005 16:12 GATE5,HALBRNR,HATCH
ili 131 9021
P 007
717 731 9627 P.07/11
5. a. At any time before or after you were served, did the defendant[s]
transfer or deliver property of any nature to you or to any person or place pursuant to
your direction or consent and, if so, what was the consideration therefor?
b. To the extent that your above answer depends in whole or part on
documents, account records, or other papers or electronic data, describe each in exact
detail (or attach a copy ofthe same).
ttTf\\dCH\10 mucle C\tPG~Lt0 lfUO --me (1 00 \/C
feftreilced OCCOLllIj lx\ .file Ord\na~ cour..se
j:)nor +0 S.'r\Jlcf) mne. or ~\)\\IC\\ \/VCTt OJ
t'1~ d\rah,Jn Of (jJl'Vlmerce bOIuc.
Interrogatories In Attachment, 6 of 10
Rx DatelTlme NOV-28-2005(MON) 17: 13
NO~-28-2005 15:12 GRTES,HRLBRNR,HRTCH
711 731 9021
717 731 9527
P 008
P.08/11
6. a. At the time you were served or at any subsequent time did you pay,
transfer, or deliver any money or property of any nature to the defendant[s]?
b. To the extent that your above answer depends in whole or part on
documents, account records, or other papers or electronic data, describe each in exact
detail (or attach a copy of the same).
No.
Interrogatories In Attachment, 7 of 10
Rx OatelTlme NOV-2B-2005(MON) 17: 13
NOV-28-2005 16:12 GRTES,HRLBRNR,HRTCH
717 731 9027
717 731 9627
P 009
P.09/11
7. a. At the time you were served or at any subsequent time did you pay,
transfer, or deliver any money or property of any nature, to any person, entity, or place
pursuant to the direction of, or undertaking for, the defendant[s), e.g., lease payments,
loan payments?
b. To the extent that your above answer depends in whole or part on
documents, account records, or other papers or electronic data, describe each in exact
detail (or attach a copy of the same).
No.
Interrogatories In Attachment, 8 of 10
Rx DatelTime NDV-28-2DD5(MDN) 17: 13
NOV-28-2005 16:12 GRTES,HRLBRNR,HRTCH
ili 131 9021
717 731 9627
POlO
P.10/11
8. a. At the time you were served or at any subsequent time, did you
have, share, or utilize any safe deposit boxes, pledges, documents of title, securities,
notes, coupons, receivable, license, or collateral in which there was an interest claimed
by defendant[s]?
b. To the extent that your above answer depends in whole or part on
documents, account records, or other papers or electronic data, describe each in exact
detail (or attach a copy of the same).
NO.
Interrogatories In Attachment, 9 of 10
Rx Date/Time NDV-r8-rD05(MON) II: 13
NGV-2B-2005 16;12 GATE5,HALBRNR,HATCH
ili 131 9521
717 731 9627
POll
P.11/11
9. a. Identify every account <not previously noted) titled in the name of
defendant[sJ in which you believe defendant[s] have an interest in whole or part,
whether or not styled as a payroll account, individual retirement account, tax account,
lottery account, partnership account, joint or tenants by entirety account, insurance
account, trust or escrow account, attorney's account, or otherwise.
b. To the extent that your above answer depends in whole or part on
documents, account records, or other papers or electronic data, describe each in exact
detail (or attach a copy of the same).
~() (J\-\,Ct ace 0\;ll\tS
Oated:November 26, 2005 By:
COMMERCE BANK/HARRISBURG
lfl )~latD
Interrogatories In Attachment, 10 of 10
TOTAL P. 11
, r-,)
,1
I
C
C'_'
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.-
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2005-05823 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
GATES HALBRUNER & HATCH PC
VS
SNYDER VICTOR ET AL
And now BRIAN BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, 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
SNYDER VICTOR B
in the
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND AVE
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
REBECCA BONAWITZ (TSM)
personally 3 true and attested copies of t~e within
WRIT OF EXECUTION and made the contents thereof known to Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers:
.00
.00
.00
.00
.00
.00
r~~e
Sworn and subscribed to before me
this l- e day of hflue~
JOVS ,~A'D'
{!IJJ,_~_
Pr6thono
Deputy Sheriff
11/23/2005
By
R. Thomas Kline
Sheriff of Cumberland County,
,~aA
.
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2005-05823 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
GATES HALBRUNER & HATCH PC
VS
SNYDER VICTOR ET AL
And now BRIAN BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, 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
SNYDER REBECCA E
, in the
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
REBECCA BONAWITZ (TSM)
personally 3 true and attested copies of the within
WRIT OF EXECUTION and made the contents thereof known to Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers:
.00
.00
.00
.00
.00
.00
:7""'K- ~ -~ ~ e
R. Thomas Kline
Sheriff of C,umberlandCo/fJnty
11/22/2005 1/'/1''\ Ji1
By r;,~ {/f'r
Deputy Sheriff
Sworn and subscribed to before me
this ~ ~
of ~_~
Gates. Halbruner & Hatch, P.C.
By: Matthew J. Eshelman, Esquire
PA Attorney 10 No. 72655
1013 Mumma Road, Suite 100
Lemoyne, PA 17043-1144
(717) 731-9600
(717) 731-9627 facsimile
M. Eshelman@GatesLawFirm.com
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
------------------------------------------------------)(
GATES, HALBRUNER & HATCH, P.Co,:
Civil Action
Plaintiff,
Case Noo 05-05823, Civil Term
Vo
VICTOR B. & REBECCA E. SNYDER,
Defendantso
------------------------------------------------------)(
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Please mark the judgment entered against Defendants, Victor B. Snyder and
Rebecca E. Snyder, and against Garnishee, Commerce Bank, in the above.captioned
action satisfied, thereby releasing the attachment issued in the matter against the
Garnishee, Commerce Bank.
Date: February 27, 2006
By:
lb!b!J
~
=
I!:!b6
I!:!b,
~
Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STA YEDo
Sheriff s Costs:
Advance Costs: 173.79
Sheriffs Costs: 173.79
$ 000.00
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Surcharge
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage
TOTAL $
18.00
49.81
.50
1.00
14.00
40.00
40.00
Refunded to Atty on 02/28/06
9.00
1.48
173.79
Sworn and Subscribed to before me
~, ~,
~~r~'~.
This /'I~ day of '7'k~
2006 A.D.
R. Thomas Kline, Sheriff
(, n~~ ~I
~laudia A. Brewbaker
h 0 :f ci III ;\ON SDOI
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'::":j CI
~
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I.~ CJe. ~-3;2 '/0
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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 GATES HALBRUNER & HATCH, PoCo Plaintiff (s)
NOO5-5823 Civil
CIVIL ACTION - LAW
From VICTOR B. AND REBECCA E SNYDER, 29 EAST COOVER STREET,
MECHANICSBURG, P A 17055-4218
(I) You are directed to levy upon the property of the defendant (s)and to sell Any and all personal
property located at defendant's residence commonly identified as 29 East Coover Street,
Mechanicsburg, PA 17055-4218
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of Commerce Bank (any brancb), all acconnts including all savings, checking and other accounts,
certificates of deposit, notes receivable, collateral, pledges documents of title, securities, coupons and
safe deposit boxes, especially account noo 5131732940
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 himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due$2490025
Interest from 4/19/05 $82069
Arty's Comm %
Arty Paid
Plaintiff Paid $37050
Date: November 9, 2005
L.L.$.50
Due Prothy $1.00
Other Costs
(Seal)
By:
Deputy
REQUESTING PARTY:
Name Albert N. Peterlin, Esqo
Address: 1013 Mumma Road, Suite 100
Lemoyne, P A 17043-1144
Attorney for: Plaintiff
Telephone: 717-731-9600
Supreme Court ID No. 84180