HomeMy WebLinkAbout06-0283
OLD DOMINION FREIGHT LINE, INC.
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. D~ ->>~ C.l~~l~82.hj
: CIVIL DIVISION - LAW
JACOB GARBER, III,
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 an 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 requested by the plaintiff. You may lose money or property or other rights important
to you.
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. 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
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
AVISO
USTED HA 5100 DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se
presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias
despues de la notificacion de esta Demanda y Aviso radicando personal mente 0 por medio de un abogado una
comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas
presentadas aqui en contra suya. Se Ie advierte de que si usted falla de tomar accion como se describe
anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la
demanda 0 cualquier otra reclamacion 0 remedio solicitado por el demandante puede ser dictado en contra suya
por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos importantes para
usted.
USTED DE BE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. 51 USTED NO
TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OF/CINA. ESTA OFICINA PUEDE PROVEERLE
INFORMACION A CERCA DE COMO CONSEGU/R UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA
OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES
SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALlFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
(717) 249-3166
OLD DOMINION FREIGHT LINE, INC.
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Gu~L~~
NO. 0 l.. - ~.P..3
JACOB GARBER, III,
CIVIL DIVISION - LAW
Defendant
COMPLAINT
The Plaintiff, OLD DOMINION FREIGHT LINE, INC., by its attorneys, KNUPP, KODAK & IMBLUM, P.C.,
brings this action of Assumpsit against the Defendant to recover the sum of FOUR THOUSAND TWENTY-FIVE
DOLLARS ($4,025.00), together with interest thereon at the statutory rate from February 24, 2005, of which the
following is a statement:
1. The Plaintiff, OLD DOMINION FREIGHT LINE, INC., is a corporation organized and existing under
the laws of the State of North Carolina, having its principal office and place of business at 500 Old Dominion Way,
Thomasville, North Carolina 27360.
2. The Defendant, JACOB GARBER, III, is an adult individual residing at 82 Linda Drive #35,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. On May 24,2004, Defendant signed a Truck Driver Training Program Agreement with Plaintiff which
provided, in pertinent part, that should Defendant leave Plaintiff's employ for any reason or voluntarily transfer to
a non-driving position with Plaintiff prior to 1 year after graduation from the driver training program, Defendant
would pay to Plaintiff the sum of $3,500.00 in consideration for such Truck Driver Training Program. A true and
correct copy of said Truck Driver Training Program Agreement is attached hereto, marked Exhibit "A" and made
a part hereof.
F:\USERIROBIN\CCP&DJ CMPS\CCP COMPLAINTS\OLD DOM FREIGHT 31900.wpd:20Dec05
4. Defendant completed the Old Dominion Truck Driver Training Program and received a Certificate
of Achievement on or about June 28, 2004. A true and correct copy of said Certificate of Achievement is attached
hereto, marked Exhibit "B" and made a part hereof.
5. Defendant began his employment with Plaintiff on April 21 , 2004, and ended on or about February
24, 2005, the last date Defendant worked. On or about February 24, 2005, Defendant resigned his position with
Plaintiff without giving notice by failing to report to work. A true and correct copy of Plaintiff's Payroll Change
Request evidencing date of hire and last date worked is attached hereto, marked Exhibit "e" and made a part
hereof.
6. The price charged for said training and services provided were just and reasonable, were the legal
and market prices therefor and were the prices which the Defendant contractually promised and agreed to pay
to Plaintiff.
7. The balance due and owing by Defendants to Plaintiff is the sum of Three Thousand Five Hundred
Dollars ($3,500.00) as more fully set forth on Plaintiff's May 9, 2005 Jetter to Defendant, marked Exhibit "0"
attached hereto and made a part hereof.
8. Due to the default of Defendant, and pursuant to the terms and conditions of the Truck Driver
Training Program Agreement executed by Defendant hereto attached as Exhibit "A", attorney's fees in the total
amount of Five Hundred Twenty Five Dollars ($525.00) have been added to said account.
9. Plaintiff frequently demanded paymentfrom Defendant of said amount due and owing as aforesaid,
but Defendant refused and neglected and still refuses and neglects to pay said amount of any part thereof.
F;IUSERIROBINICCP&DJ CMPSICCP COMPLAINTSIOLD DOM FREIGHT 31900.wpd;20Dec05
2
WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of FOUR THOUSAND
TWENTY-FIVE DOLLARS ($4,025.00), together with interest thereon at the statutory rate from February 24,
2005.
Respectfully submitted,
KNUPP'O;BLUM. P.C'/ .
#~~
~h
Robert D. Kodak, Esquire
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7151
Attorney ID No. 18041
Attorney for Plaintiff
F:IUSERIROBINICCP&DJ CMPSICCP COMPLAINTSIOLD DOM FREIGHT 31900.wpd:20Dec05
3
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OLD DOMINION FREIGHT LINE. INC.
TRUCK DRIVER TRAINING PROGRAM AGREEMEKI
For and in consideration of Old Dominion Freight Line, Inc. allowing me to participate in the Old Dominion Truck Driver
Training Program for the purpose of becoming trained as a professionallruck driver and agree as follows:
L That I meet the qualifications of the program.
2. That I understand the requirements of the program, the type of training to be given and what shall be required of
me should I receive my CDL
3. That I have read the attached infoonation sheet and agree with i(s content (Truck Driver Training Infoonation
Sheet - "Earn While You Leam".)
4, That in the event I withdraw from the program, or deliberately delay my continued training/completion, after
having completed the classroom:
[ hereby agree to pay to Old Dominion any compensation I have received during the program, including meal
reimbursement, lodging, classroom and on the job training.
5. That in the event that [complete the training program and receive my CDL:
If I should leave Old Dominion Freight Line, [nc.'s employment for any reason and/or voluntarily transfer to a
non driving position prior to I year (12 month,) after graduation from the Old Dominion Freight Line, Inc.
Truck Driver Training Program, I hereby agree to pay to the order of Old Dominion Freight Line, Inc. the sum of
$3500.00 as consideration for such training, same to be due and payable in full on the date of my teonination.
I further agree that any wages or other monies not yet paid to me by Old Dominion Freight Line, Inc. shall be withheld
and will be applied toward the sum which I may owe at the time of teonination and [ authorize old Dominion Freight
Line. Inc. to deduct said sums from wages or other monies due me at the time of said termination. I consider this to be a
voluntary repayment of any amount which I owe as provided by Chapter 95-25.10 of the General Statutes of North
Carolina.
[n the event [ default in the payment of such sum, when due, then in such event interest on the unpaid balance at the
highest legal interest rate at the time of teOllination shall be due and payable and shall accrue until said is fully paid.
In the event it becomes necessary for Old Dominion Freight Line, Inc. to employ an attorney to collect said sum, then in
such eveOl. Old Dominion Freight Line, Inc. shall be entitled to recover an additional 15% of the balance due and interest
as attorney's fees.
Nothing herein shall be considered to be a contract of employment with Old Dominion Freight Line, Inc. and I understand
that either old Dominion Freight Line, Inc. or I can teOllinate my employment at wilL
Executed this C)l( day of (VlC\.~_, 20 OY.
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OLD DOMINION FREIGHT LINE, INC. 500 Old Dominion Way
.........'.;
..... ',>
. ,
Thomasville. NC27360
FOAM A.2
PAYROLL CHANGE REQUEST-
LOCATION
HAP
No. G 7 0
DEPARTMENT LTNFHMJT.
PLEASE TYPE
(STATUS)
(1)
NawHire
Rehire
Transfer I Job Change
Wage Change
Resigned
Y1rY~)( Discharged (Explain in 41)
Fam. Med. Leave
Temp. Mod. Duty
(Explain in 41)
CorractedA-2
Other (Explain in 41)
(2) ErTl\'t?Y-~~!t
~""J..J L.OL
(3) Employee Name
GP.HBER III
'-'>,
Jl..COB
(4) Sex
First
Midllle
. ('M;;F)
(5) Address (House Number, Street. Apt.#)
8? LINI:.J\ D.P #' 35
City
hEC"HANICSBURG
(6) Date of Birth
(7) Sociai Security No.
Zip Code Phone No.
170~;0 (717 )795 -9474
(8) Marital Status (9) Emergency Contact Name
o Married 0 Single
(11) Date Employed (First Day Worked) Omportant: In.event date employed
and/or first day worked changes, a
4/2 1/04 corrected A2 must be submitted.)
State
Pl'
. .(10) Phone No.
(.12) Empl. Status F = Full Time
F' P= Part Time
(13) Full Time Date
(14) Effective Date of Change
3/4/05
(19) EXisting Job Class
* Items (15) through (18): See Shaded area at bottom of this form
(20) New Job Class (21) New Service Center No. . (22) Department
(23) Veteran (Y or N)
(24) Disability
(25) Ethnic
(26) EEO
(27) Job Title
(Yor N)
(28) State Tax Subject to
(29) City Tax subject to
(30) Other Tax Subject to
(3.1) Drivers license Number
(32) State
(33) CDL Endorsements (H N T M P X I
(34) Issue Date
(35) Expiration Date
(36) Type
"-
(37) Last Date Worked
2/24/D5
(38) Termination Date
-::'/4/ns
(39) Eligible For Rehire If NO, Explain
1'J ~ Y = Yes N:; No Reason On Une (41).
(40) Reason For Separation
c:;orn
(See Separation Codes on Back of Pink Copy) .
(41) Comments:
Fl\lLED
(42)
Requested By
Approved By
Approved By
~'O R,FPOR'" mo t,W.RK - >.10
4~~4/~~' .
No'rICE GIVEN - ~c REHIRE
Title
Title
e:::h'
r1't1iZ-
Date 3' If /bs-
Date
By
I
EXHIBIT
c-
Date
I Forwarded to Benefits
By . . Date
(17) Date Last Rate Change
ir~onne'21g /{'r-
/J --'Dati J
Pro
(15) Pay Status (Circle O?e) H ~ Hourly
.-['Vi ==~,^,eekly
OLD DOMINION FREIGHT LINE, INC.
500 OLD DOMINION WAY
THOMASVILLE, N.C. 27360
336-822-5368
May 9, 2005
JACOB GARBER III
82 LINDA DR #35
MECHANICSBURG, PA 17050
Dear Mr. Garber:
In regard to your recent termination with Old Dominion Freight Line, Inc., our records indicate that
there is stili a $3500.00 balance owed for Driving School Agreement. A copy of documentation is
enclosed.
Please remit the balance due within thirty days of the date of this letter to the payroll department
attention Laura Williams or contact us to make appropriate arrangements. Thank you for your
prompt attention to this matter.
Sincerely,
OLD DOMINION FREIGHT LINE, INC.
Laura O. Williams
Payroli Manager
Attachments
IJ:L
I,
VERIFICATION
I, Laura O. Williams, Director of Payroll of OLD DOMINION
FREIGHT LINE, INC., verify that the statements made in the
aforegoing document are true and correct.
I understand that false
statements herein are made subject to the penalties of 18 Pa. C. S.
S4904, relating to unsworn falsification to authorities.
OLD DOMINION FREIGHT LINE, INC,
~~e~~CJ
Title: Director of Payroll
Dated:
January 3, 2006
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-00283 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
OLD DOMINION FREIGHT LINE INC
VS
GARBER JACOB III
MICHAEL BARRICK
Sheriff or Deputy Sheriff of
cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
GARBER JACOB III
the
DEFENDANT
, at 1853:00 HOURS, on the 2nd day of February
2006
at 82 LINDA DRIVE #35
MECHANICSBURG, PA 17050
by handing to
JACOB GARBER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
So Answers:
18.00
8.80
.39
10.00
.00
37.19
r~~-P
R. Thomas Kline
me this
""
'1~
day of
02/03/2006
KNUPP KODAK .IMBLUM ~
BY:_--??~ -
. Deputy Sri r' ff
Sworn and Subscribed to before
;J
A.D.
OLD DOMINION FREIGID LINE, INC.
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2006-00283
JACOB GARBER, III,
CIVIL DNISION - LAW
Defendant
TO: PROTHONOTARY, COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PRAECIPE FOR DEFAULT JUDGMENT
Enter judgment in favor of Plaintiff and against Defendant(s) JACOB GARBER, III, named for
failure to file within the required time an Answer to the Complaint in the above-captioned case and
assess the Plaintiffs damages as follows:
Amount claimed in Plaintiffs Complaint
$4,025.00
Interest from February 24, 2005 at the Statutory rate of 6% per annum
$256.59
Total
$4,281.59
It is hereby certified that a written notice of intention to file this Praecipe was mailed to the
Defendant(s) and his attorney of record, after the default occurred and at least ten (10) days prior
to the date of the filing of this Praecipe. See Exhibits A & B attached.
KNUPP'~AjZ?~
BY~>~~~
Robert D. Kodak, Attorney for Plaintiff
DATED:~!7 dDob
I
Judgment entered and damages assessed as above.
N- ti~j;, "f);i:
Prothonotary ~
Robert L Knupp
Robert D. Kodak
Gary J. ImbIum
LAW OFFICES OF
KNUPP, KODAK & IMBLUM, P.C.
CAMERON MANSION
407 NORTH FRONT STREET
POST OFFICE BOX 11848
HARRISBURG, PA 17108-1848
Telephone: 7171238-7159
Facsimile: 717/238-7158
email: kki.law@verizon.net
FilE C~~LKnupp
(1900-1976)
Robert H. Maurer
(1923-1998)
February 28, 2006
JACOB GARBER, III
82 LINDA DRIVE #35
MECHANICSBURG PA 17050
RE: Old Dominion Freight Line, Inc.
VS: Jacob Garber, III
No. 2006-00283, Court of Common Pleas
Cumberland County, Commonwealth of Pennsylvania
Our File No. 31900
Dear Mr. Garber:
In accordance with Pennsylvania Rules of Civil Procedure 237.1 (a)(2), we are
enclosing herewith a Notice of a Praecipe for Entry o~ Default Judgment According to the
records as they are found in the Office of the Prothonotary of Cumberland County, you
have not filed responsive pleadings to the Complaint filed against you to the above term
and number, nor has any attorney entered an appearance on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that if
you do not take action as set forth in this Notice, we, at the expiration of time indicated
therein, will request the Office of the Prothonotary of Cumberland County to enter
Judgment against you in the amount as set forth in said Complaint
Very truly yours,
KNUPP, KODAK & IMBLUM, P.C.
Robert D. Kodak, Esq.
THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE
RDK/kqb
enclosure
cc: ANDREW S LASINE ESQUIRE
KEZIAH GATES & SAMET LLP
POST OFFICE BOX 2608
HIGH POINT NC 27261-2608
-A--
#05-977
. , .
OLD DOMINION FREIGlIT LINE, INe.
Plaintiff
f~! ~' , jV
U_ ~.,' "
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: NO, 2006-00283
JACOB GARBER, III,
: CIVIL DMSION - LAW
Defendant
IMPORTANT NOTICE
TO: JACOB GARBER. III, Defendant(s)
DATE OF NOTICE: FEBRUARY 28. 2006
YOU ARE IN DEF AUL T BECAUSE YOU HA VB 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 (10) DAYS FROM THE DATE OF TIDS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS,
YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HA VB ALAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TIDS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT IDRING A LAWYER
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIESTHAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE P A 17013
(717) 249-3166
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OLD DOMINION FREIGHT LINE, INC.
Plaintiff
: IN 1HE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2006-00283
JACOB GARBER, III,
: CIVIL DIVISION - LAW
Defendant
TO: JACOB GARBER. III, Defendant(s)
You are hereby notified that on (Yl ';:J/Lc.l / 7
(Judgment) has been entered against you in the above-captioned case.
, 2~the following
Judgment entered in the amount of $4.281.59. ()\ rJI
fYl.';Jo rJ /7 dJX>/o ~) I (~A;;iL; -' k. 0~
' rothonotary V
I hereby certify that the name and address of the proper person(s) to receive this notice is:
DATE:
JACOB GARBER III
82 LINDA DRIVE #35
MECHANICSBURG PA 17050
N JACOB GARBER. III , Defendido/a Defendidoslas
Por este medio se Ie esta notificando que el de del 2005,
el/la siguiente(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Protonotario
Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de
residencia:
JACOB GARBER III
82 LINDA DRIVE #35
MECHANICSBURG PA 17050
Abogado del Demandante
..
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
OLD DOMINION FREIGHT
LINE, INC.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Writ No.
Term 20
Plaintiff
NO. 2006-00283 CIVIL J'ERM J'erm 20!lE-
vs
Amount due
$ 4,281. 59
JACOB GARBER, III
82 LINDA DRIVE # 35
MECHANICSBURG Pi), 17050
Interest FROM DAJ'E OF JUDG. 03/17/06
Atty's Cown. $ 214.08
and CostsJ'O BE DEJ'ERMINED$
Defendant (s)
TO THE PROTHONOtARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of
CUMBERLAND
County, Pennsylvania;
(2) against JACOB GARBER, III
(3) and against
Defendant (s)
Garnishee (5)
(4) and index this writ
(a) against JACOB GARBER, III
Defendant (s)
and
(b) against
Garnishee (s) I
as a lis pendens against the real property of the defendant{s) in the name of the Garnishee(s)
as follows:
(Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for
real estate levy)
LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING
BUT NOT LIMITED TO FURNITURE, ELECTRONICS, APPLIANCES, ETC. INSIDE~TSI E ON PROPERTY.
(5) Exemption has (not) been waived. ~ /
Robert D. Kodak, Esquire
PO Box 11848
Harrisburg, PA 17108
(717) 238-7159
Attorney For P1aintiff(s)
Dated 04/04/06
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NOTE:
Under pori'lgraph (1) wr,en the writ .is directed to the sheriff of another county ilOJ authorized by Rul~~ 310:)(b), the
county should be indicated.
Under Rule JI03(c) a writ issued on a transferr-ed judgment may be directed onLy 1-,0 the sheriff of the county ~n
\-In ien issued.
Pi'lraqraph {J) (above shQuld be completed only in a named C)arnlshee is to bto ifl,;l': led in the w::-it).
Paragraph (4) (a) s~lOuld be completed only if inde)cing of the executiollS in lhe co ~ty of lssuralle:e, L:; desj_re a:';
authorized by Rule JI04(a). When the writ i:'lsues to anothLl- county indE!x.ing is reqtlic,,j "IS of CQurse to lhat coun'y b}'
the prothonotary. See Rule 3104(b).
Paragraph (4) (b) should be completed only if real property in the name of th(, 'jdrn15h8e is attached iH)d indexLnq
as a lis pendens 15 desirE!d. See Rule 3104(c).
WRIT OF EXECUTION and/or ATTACHMENT
"
...
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-283 Civil
CIVIL ACTION - LA W
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due OLD DOMINION FREIGHT LINE, INC., Plaintiff (s)
From JACOB GARBER, III, 82 LINDA DRIVE # 35, MECHANICSBURG, P A 17050
(I) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED
ADDRESS INCLUDING BUT NOT LIMITED TO FURNITURE, ELECTRONICS,
APPLIANCES, ETC. INSIDE OR OUTSIDE ON PROPERTY.
(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 gamishee(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 $4,281.59
Interest FROM DATE OF JUDG 3/17/06
Atty's Comm % $214.08
Atty Paid $1I9.19
Plaintiff Paid
Date: APRIL 13, 2006
1.1. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
prothonz 7e
~: . a-, r P 'I2/J<1A;-'
Deputy
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 1I848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 18041
.
OLD DOMINION FREIGHT LINE, INC.
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2006-00283
JACOB GARBER, III,
: CIVIL DIVISION - LAW
DEFENDANT
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-captioned Judgment as settled and satisfied in full.
TO: Cumberland County
Prothonotary
Dated: August 29, 2006
Robert D. Kodak
Attorney LD. No. 18041
Attorney for Plaintiff
31900
l"'--:l
c:"':'.J.
(0"")
-"f;
(....:>
v::
Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff s Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Surcharge
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage
TOTAL $
18.00
85.66
Advance Costs: 153.96
Sheriffs Costs: 153.96
$ 000.00
.50
1.00
8.80
20.00
20.00
Refunded to Atty on 08/09/06
153.96'1' 't -/J ~ () (, ~
so~;
'~~.~.~~
R. Thomas Kline, Sheriff
Cfc,t '~ "
" , "/ o..uJ.-t -- bctk (
y Claudia A. Brewba er
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-283 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due OLD DOMINION FREIGHT LINE, INC., Plaintiff (s)
From JACOB GARBER, III, 82 LINDA DRIVE # 35, MECHANICSBURG, P A 17050
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED
ADDRESS INCLUDING BUT NOT LIMITED TO FURNITURE, ELECTRONICS,
APPLIANCES, ETC- INSIDE OR OUTSIDE ON PROPERTY.
(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 $4,281.59
Interest FROM DATE OF JUDG 3/17/06
Atty's Comm % $214.08
Atty Paid $119.19
Plaintiff Paid
Date: APRIL 13, 2006
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
proth02
~y: l'2t 0
P . 7f!/2./?-<- 'l". /-
Deputy
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 18041