HomeMy WebLinkAbout06-2765
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD REALTY
CORPORATION
Plaintiff,
CIVIL DIVISION
No. CL. -.7ft.S c;u ~f'T~
Vs.
JAMES W. KIRKPATRICK
and
GAYLE 1. KIRKPATRICK
Defendant(s)
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT.
If you wish to defend against the claims set forth in the following pages, you must
take action within twenty (20) days after this complaint and notice are served, by
entering a written appearance personally or by attorney and filing in writing with
the court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment
may be entered against you by the court without further notice for any money
claimed in the complaint or for any other claim or relief 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 OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIA nON
2 LIBERTY AVENUE
CARLISLE, P A 17013
717-249-3166 OR 800-990-9108
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD REALTY
CORPORATION,
CIVIL DIVISION
No. 0(", -;J1/.;S (];u~L 't-02...h---t
Plaintiff,
vs.
TYPE OF PLEADING:
Complaint
JAMES W. KIRKPATRICK
and
GAYLE L. KIRKPATRICK
TYPE OF CASE:
Defendants.
Civil Action
FILED ON BEHALF OF:
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
HOUSEHOLD REALTY
CORPORATION
COUNSEL OF RECORD:
Defendant's Address:
164 SOUTH ENOLA DRIVE
ENOLA, PA 17025
CATHY ANN CHROMULAK, ESQ.
P A ill NO. 42067
NANCY C. WILKINS, ESQ.
PA ill NO. 94178
JESSA C. MARTIN, ESQ.
PA ill NO. 201169
AMY L. SABOLCmCK, ESQ.
PAillNO.94653
CHROMULAK & ASSOCIATES, LLC
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD REALTY
CORPORATION,
Plaintiff,
CIVIL DIVISION
No. ()~ - 'J..r-tt..S
C!fo~LY~
vs.
JAMES W. KIRKPATRiCK
and
GAYLE 1. KIRKPATRiCK,
Defendants.
COMPLAINT
AND NOW COMES, the Plaintiff, HOUSEHOLD REALTY CORPORATION, by its
Attorneys, Chromulak & Associates, LLC, with its Civil Action Complaint, the following of
which is a statement thereof:
1. HOUSEHOLD REALTY CORPORATION is a Corporation, duly authorized to
conduct business in the Commonwealth of Pennsylvania, with its principal office situated at
2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred to as "Plaintiff'.
2. JAMES W. KIRKPATRICK and GAYLE 1. KIRKPATRICK are adult
individuals residing at 164 SOUTH ENOLA DRiVE, ENOLA, PA 17025.
3. On or about MARCH 20, 2002, Defendants entered into a written Loan
Agreement with the Plaintiff, a copy of which is attached hereto as "Exhibit A" and incorporated
herein.
4. Pursuant to the Loan Agreement with the Defendants, Plaintiff advanced funds to
the Defendants.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
5. Defendants are in default under the terms and conditions of the aforementioned
Loan Agreement for failing to make payments when due, with the last payment having been
made on or about NOVEMBER 1,2005.
6. Pursuant to the terms of the Loan Agreement, Plaintiff has the right to require
payment of the entire amount owed upon default. The total amount due, including principal and
interest, and owing by the Defendants is in the sum of EIGHT THOUSAND FOUR HUNDRED
FIFTY NiNE AND 13/100 ($8,459.13) DOLLARS as of MARCH 29, 2005.
7. Numerous demands have been made upon the Defendants by Plaintiff, but the
Defendants have failed or refused to pay.
8. Pursuant to the Loan Agreement, Plaintiff is entitled to recover costs of collection
and reasonable attorney's fees.
WHEREFORE, Plaintiff claims damages in the sum of EIGHT THOUSAND FOUR
HUNDRED FIFTY NiNE AND 13/100 ($8,459.13) DOLLARS, with interest thereon at the rate
of 13,99% from MARCH 29, 2005, plus court costs and attorney's fees.
Respectfully submitted,
Chromulak & Associates, LLC
By: !J ~ /J I J1 {~ ~'
CATHY ANN C~OMULAK, ESQ.
PA!D NO. 42067
NANCY C. WILKINS, ESQ.
PA !DNO. 94178
JESSA C. MARTIN, ESQ.
PAIDNO.201169
AMY L. SABOLCHlCK, ESQ.
PA!D NO. 94653
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Attorneys for Plaintiff
375 Southpointe Boulevard
4th Floor
Canonsburg,PA 15317
. '. _ " LOAN REPAVMENT AND SECURITV AGREEMENT (Page I or 3)
LENDER (called "We", "Us", "Our") "
HOUSEHOLD REALTY CORPORATION
P.O. BOX 438
WOOD DALE IL 60191
BORROWERS (called "Vou", "Vour")
KIRKPATRICK, GAYLE L
SS# 206387909
KIRKPATRICK, JAMES W
SS# 208345406
164 S ENOLA DR
ENOLA PA 17025
LOAN NO:
'/I>"
710997-106'161
DA Tt Of tDAI
SECONDARV MORTGAGE LOAN
THIS AGREEMENT IS SUBJECT TO THE PROVISIONS Of THE SECONDARY MORTGAGB LOAN ACT
YOU ARE GIVING US A SECURITY INTEREST IN THE REAL ESTATE LOCATED AT THE ABOVE ADDRESS.
RBQUIRED INSURANCE. You mUlt obtaio i.....raoce for torm ot 1000 _orine .ecurity for this 1004 .. iAdicatod by tho
word .YES" below, namiDg us as LOll Payee:
Title insuranco aD real estate security.
Fire and extended coverap insurance OD. real estate lecuri\l.
Physical damage insurance on vehicle listed UDder "Security" above if "Y" appear. uncleI' "Itulured".
Physical dam.. insurance On other propert} listed unc10r "Security" above if frY" appean under "Insured-,
You may obtain any required insurance from anyono you choose and may ..sign any other policy of wuraftQO
you own to cover tho security for this loan.
(See "Security" paragraph abovo for desCriptiOD of security to bo inauredJ
E: THE F LO ING PA ES C ITI AL C ERMS.
(( Q I)
PA855931
03-29-00
2ND MTG PHI.
S, .3 !<{,Ot..
R, ~.Iq."t.
F, !!>.~.Oz..-
EXHIBIT
ORIGIfol'l
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111.11111111
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LOANREP A VMENT AND SECURiTV AGREEMENT (Page 2 or 3)
PAYMENT. In return ror your loan described below, you agree to pay us, the Principal and Interest computed at the
Contract Rate (as stated on page one). Principal is AmoOnt Financed, plus the Fee. You shall pay US monthly
payments, at our business address or other address giveO YOb. If more than one Borrower is named on page one, we
may enforce this Contract against all. or any Borrowers, bilt !lot in a combined amount greater than the amount owed.
Each payment will be first applied to any Late Charges, tl)en to Interest at the Contract Rate for the actual time
outstanding, and the remainder to your unpaid Principal.
DATE ON WHICH INTEREST BEGINS. If you do not cancel this loan, the date on which Interest begins, payment
dates, and effective date of insurance purchased are postponed by the number or days from this contract's date to date
you receive this loan. '
PAY-QUTS. You agree to pay-outs or Amount Financed asl shown on Truth-In-Lending disclosure rorm. Ir pay-outs
change because loan closing is delayed, (a) you shall pay additional amounts due at closing, or (b) your cash or check
will be reduced to COVer additional pay-outs.
PREPAYMENT. You may prepay your lOan at any time. Iryou rully prepay before the final due date, the Points are
fully earned when this loan is made, and you will not receiv~ a rerund of that part or the Finance Charge consisting or
Points.
,
LATE CHARGE. We will charge you a late charge ir you &n't pay any payment in full within 15 days after it's due
date. The Late Charge is equal to 10% of the Monthly Installg.ent or $20.00, whichever is greater.
.
BAD CHECK CHARGE. We will charge you a ree or S20lif any payment check is returned because or insufficient
funds or is otherwise dishonored. You agree that we may deduct this charge from a monthly payment.
SECURITY. If disclosed on page one, you also agree to giV~ us a security in~ in the property identified on page
one. You agree to give us a security interest in the real estat~ as described in the MortgagelDeed of Trust.
PROPERTYINSURANCR
A. YOUR OBLIGATION TO INSURE. You shall keep thejstructures located on the real property securing this loan
insured against damage caused by fire and other physical h!lzards, name us as a loss payee and deliver to us a loss
payable endorsement. If insurance covering the real property is cancelled or expires while the loan is outstanding and
you do not reinstate the coverage, we may obtain, at our option, hazard insurance coverage protecting our interest in
the real property as outlined below.
B. LENDER'S RIGHf TO PLACE HAZARD INSURANCE. You authorize us, at our option, to obtain coverage on
the Property in an amount not greater than the outstanding ,balance of principal and interest on the loan or, ir known
to be less, the replacement value or the Property, in the event that you fail to maintain the required hazard insurance
outlined above or fail to provide adequate proof or its existence. You authorize us to charge you ror the costs of this
insurance and add the insurance charges to your loan. The Iri,surance charges will be added to the unpaid balance or the
loan which accrues interest at the Contract Rate. The additicir or the insurance charges due might increase the amount
of your final installment. The cost of Lender placed hazard insurance might be higher than the cost of standard
insurance protecting the property. The Lender placed insural!ce will not insure the contents of the property or provide
liability coverage. The insurance might not be the lowest ~ coverage or its type available and you agree that we have
no obligation to obtain the lowest cost coverage. We or' an arfiliated company might receive some benefit (i.e.
commission, service fee, expense reimbursement, etc.) rrom the placement of this insurance and you will be charged
for the full cost of the premium without reduction ror any: such benefit. If at any time after we have obtained this
insurance, you provide adequate proof that you have subseqUently purchased the required coverage, we will cancel the
coverage we obtained and credit any unearned premiums to your loan.
,
NOTICE: THE FOLLOWING PAGE CONT~NS ADDITIONAL CONTRACT TERMS.
03-29-00
2ND MTG PHl
PAB55932
ORIGI~
1.11.'1111111.11111111
. , ' .
;', . ,';;' ~.~;,~ ~i_~ ~~
LOAN REPA YMENT AND SECl:)'RITy,AGREEMENT (Page 3 or 3)
"~..,' ~':.~ '.',
DEFAULT, If you don't pay on time or tail to keep any required insurance in force, or ir permitted in the event of default
under the Mortgage, (I) all your payments may become due at once and, (2) without notifying you before bringing suit, we
may sue you for the entire unpaid balance of Principal and accrued Interest and (3) any judgment in our ravor may include
our reasonable attorney's fee and court costs as determined by the court. You agree that, should we obtain judgment
against you, a portion of your disposable earnings may be attached or garnished (paid to US by your employer), as provided
by Pederallaw. You agree to pay interest on any judgment at the Contract Rate.
EXCHANGE OF INFORMATION. You understand that rrom time to time we may receive credit information
concerning you from others, such as stores, other lenders, and credit reporting agencies. You authorize \IS to share any
information, on a regular basis, we obtain related to your Account, including but not limited to credit reports and
insurance information, with any or our affiliated corporations, subsidiaries or other third parties. The uses or this
information may include an inquiry to determine if you qualify for additional offers of credit. You also authorize \IS to
share any information regarding your Account with any of our arriliated corporations, subsidiaries or other third parties.
You may prohibit tbe sharing or such information (except ror tbe sharing or inrormation about transactions or
experiences between us and you) by sending a written request which contains your rull name, Social Security
Number and Address to us at P.O. Box 1547, Chesapeake, VA 23320.
If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be submitted
to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent of such
department) may release your residence address to us, should it become necessary to locate you. You agree that our
supervisory personnel may listen to telephone calls between you and our representatives in order to evaluate the quality of
our service to you.
.. ". ~ '.
INSURANCE. Optional credit insurance and any required insurance disclosures are attached to this Agreement and are
incorporated herein by reference. '
ALTERNATIVE DISPUTE RESOLUTION AND OTHER RIDERS. The terms of the Arbitration Agreement and any
other Riders signed as part of this loan transaction are incorporated into this Agreement by reference.
APPLICABLE LAW, This loan is made under the Pennsylvania Secondary Mortgage Loan Act, Title 7, Purdon's
Pennsylvania Statutes.
If you do not pay the rull amount of an instalment when it is due, and we intend to foreclose on the Mortgage, we must
comply with the provisions of Section 403 and 404 or the Act of January 30, 1974, which is known as Act No.6, and the
provisions of the Homeowner's Emergency Mortgage Assistance Act (Act NO.9] of 1983).
ANY ADVANCE OF FUNDS PURSUANT TO THIS LOAN REPAVMENT AND SECURITV AGREEMENT
AND THE MORTGAGE WHICH SECURES THE AGREEMENT MAY, IN THE EVENT OF ANY
DEFAULT, RESULT IN THE LOSS OF VOUR HOME OR OTHER REAL PROPERTY PLEDGED AS
SECURITV FOR VOUR LOAN.
YOU HA VB RECEIVED A COMPLETE
COPV OF THIS AGREEMENT AND. THE
TRUTH-IN-LENDING DISCLOSURES.
-'WITtJ);!;lll
(SEAL)
(SEAL)
(SEAL)
'/~+.~ad
03-29-00
2ND MTG PHl.
PA855933
011 I GIIlAL
'.1111..11111.11111111
-
~_llrM.
~..,...,.
VERIFICATION
Linda Szudora, Recover Specialist for
HOUSEHOLD REALTY CORPORATION
Deposes and says subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn
falsification to authorities, that the facts set forth in the forgoing Complaint are true and
correct to the best of her knowledge, information and belief.
,~L
,b~~
,f/
Linda Szudora
p ~ e
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD REALTY
CORPORATION,
CIVIL DIVISION
No. 06-2765 - CIVIL TERM
Plaintiff,
TYPE OF PLEADING:
vs.
Praecipe for Default Judgment
JAMES W. KIRKPATRICK
and GAYLE L. KIRKPATRICK,
TYPE OF CASE:
Civil Action
Defendants.
FILED ON BEHALF OF:
HOUSEHOLD REALTY
CORPORATION
Plaintiffs Address:
2700 Sanders Road
Prospect Heights, IL 60070
COUNSEL OF RECORD:
Defendants' Address:
164 SOUTH ENOLA DRIVE
ENOLA, P A 17025
CATHY ANN CHROMULAK, ESQUIRE
PA ill NO. 42067
LORI M, DIRENZO, ESQUIRE
PA ill NO. 201843
NANCY C. WILKINS, ESQUIRE
PA ill NO. 94178
JESSA C. MARTIN, ESQUIRE
PA ill NO. 201169
AMY L. SABOLCHICK, ESQUIRE
PA ill NO. 94653
Dated: JUNE 23, 2006
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, Pennsylvania 15317
(724) 916-2400
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE,
~
TO: PROTHONOTARY
Please enter judgment by default against the within-named defendants, JAMES W.
KIRKPATRICK and GAYLE L. KIRKPATRICK, for failure to file an Answer as follows:
Amount Claimed in Complaint: $8,459.13
Less Payment Received 6/01/06: -300.00
Amount Owed: $8,159.13
Interest from 3/30/06 through 6/23/06: 545.33
Costs of Collection through 6/23/06: 505.70
TOTAL $9,210,16
With interest accruing on the total balance of$9.210,16 at the rate of6% per annum, together
with additional costs OfSUi~y AA~ ~
CATHY ANN CHROMULAK, ESQUIRE
LORI M. DIRENZO, ESQUIRE
NANCY C. WILKINS, ESQUIRE
JESSA C. MARTIN, ESQUIRE
AMY L. SABOLCHICK, ESQUIRE
Attorneys for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATION OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
)
)
)
SS:
COUNTY OF WASHINGTON
Before me, the ~ed authority, a Notary Public in and for said County and State,
personally appeared, \. (J C (Y7 f1 (-h fl , ESQUIRE, attorney for and
authorized representative 0 plaintiff who, being duly sworn according to law, deposes and says
that the defendant is not in the military service of the United States of America to the best of her
knowledge, information and belief and certifies that the Notice of Intent to take Default
Judgment was mailed to defendants on JUNE 12, 2006 by certificate of mailing in accordance
withPa.R.C.P. 237.1, as evidenced by the attachedCOPY~ . tf!IIO-1~
CATHY A~ CHROMULAK, ESQUIRE
LORI M. DIRENZO, ESQUIRE
NANCY C. WILKINS, ESQUIRE
JESSA C. MARTIN, ESQUIRE
AMY L. SABOLCHICK, ESQUIRE
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
U IC
Mc:heIe L WdoIa. NcllIy NlIIc
CecIITwp.. wasl1ir(jllln~
MyQ"""liI8Icll, ElcpIr8SJUy 7, 200lI
Member, Pennsylvonla Association 01 No\IIIIS
" .
"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD REALTY
CORPORATION,
CIVIL DIVISION
Plaintiff,
No. 06-2765 CIVIL TERM
Vs.
JAMES W. KIRKPATRICK and
GAYLE L. KIRKPATRICK,
Defendants.
TO: JAMES W, KIRKPATRICK
164 SOUTH ENOLA DRIVE
ENOLA, PA 17025
DATE OF NOTICE: JUNE 12,2006
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF TIDS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, P A 170 I3
717-249-3166 OR 800-990-9108
By:
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
C/\ ANN CHRO
NANCY C. WILKINS, ESQ.
JESSA C. MARTIN, ESQ.
AMY L. SABOLCHICK, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
,
u
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD REALTY
CORPORATION,
CIVIL DIVISION
Plaintiff, .
No. 06-2765 CIVIL TERM
vs.
JAMES W. KIRKPATRICK and
GAYLE L. KIRKPATRICK,
Defendants.
TO: GAYLE L. KIRKPATRICK
164 SOUTH ENOLA DRIVE
ENOLA, PA 17025
DATE OF NOTICE: JUNE 12,2006
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LffiERTY AVENUE
CARLISLE, PA 17013
717-249-3166 OR 800-990-9108
By:
JuJa1~
CATHY ANN CHROMULAK, ESQ.
NANCY C. WILKINS, ESQ.
JESSA C. MARTIN, ESQ.
AMY L. SABOLCHICK., ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4111 Floor
Canonsburg, PA 15317
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INfORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD REALTY
CORPORATION,
CIVIL DIVISION
No. 06-2765 - CIVIL TERM
Plaintiff,
vs.
JAMES W. KIRKPATRICK
and GAYLE L. KIRKPATRICK,
Defendants.
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: JAMES W, KIRKPATRICK
164 SOUTH ENOLA DRIVE
ENOLA, PA 17025
(X) Defendant
You are hereby notified that1an Order, Decree or Judgment was entered in the above
captioned proceeding on.... '-' I . \ p_ ;;J L. ( :;). (Y')f.. .
() A copy of the Order or Decree is enclosed, or
(X) The judgment is as follows: $9.210.16 plus interest at the rate of6% per
annum and additional costs of suit.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE,
. . . ~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
HOUSEHOLD REALTY
CORPORATION,
CIVIL DIVISION
No. 06-2765 - CNIL TERM
Plaintiff,
vs.
JAMES W. KIRKPATRICK
and GAYLE L. KIRKPATRICK,
Defendants.
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: GAYLE L, KIRKPATRICK
164 SOUTH ENOLA DRIVE
ENOLA, PA 17025
(X) Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the above
captioned proceeding on ...], J . '12_ :2L { :JN~.
( ) A copy of the Order or Decree is enclosed, or
(X) The judgment is as follows: $9.210,16 plus interest at the rate of6% per
annum and additional costs of suit.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
...
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD REALTY CORPORATION,
Plaintiff,
CIVIL DIVISION
No, 06-2765-CIVll.,
vs,
TYPE OF PLEADING:
JAMES W. KIRKPATRICK and
GAYLE L. KIRKPATRICK,
Praecipe to Discontinue
Against Garnishee ONLY
Defendant,
and
TYPE OF CASE:
COMMERCE BANK,
Civil Action
Garnishee,
FILED ON BEHALF OF:
HOUSEHOLD REALTY CORPORATION
Plaintiffs Address:
2700 Sanders Road
Prospect Heights, ll., 60070
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PAID NO. 42067
MAUREEN A. DOWD, ESQ.
PAID NO. 90549
LORI M. DIRENZO, ESQ.
PA ID NO. 201843
AMY L. SABOLCHICK, ESQ.
PAID NO. 94653
ANNA M. BONARRIGO, ESQ.
PAID NO, 202070
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, P A 15317
(724) 916-2400
THIS IS AN AlTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
. .~
"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
HOUSEHOLD REALTY CORPORATION,
Plaintiff,
CIVIL DIVISION
No. 06-2765-CNIL
vs.
JAMES W, KIRKPATRICK and
GAYLE L. KIRKPATRICK,
Defendants,
and
COMMERCE BANK,
Garnishee.
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO PROTHONOTARY:
Please discontinue this action against the above garnishee, COMMERCE BANK and
mark the docket accordingly.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.c.
By:~dxt~
CATHY C MULA}{, ESQUIRE
MAUREEN 1\. DOWD, ESQUIRE
LORI M. DIRENZO, ESQUIRE
AMY L. SABOLCHICK, ESQUIRE
ANNA M. BONARRIGO, ESQUIRE
Attorneys for Plaintiff
375 Southpointe Boulevard
4th Floor
Canonsburg, P A 15317
Sworn to and subscpbed
Be~e this I day
of ~' ,2006.
:J
ot libVolota. NotarY
QdTwp" Was~CclJty .
MyOOmmissio(l ExPires J~7. 2008
Member, Pennsytvarl!a Association Of Notaries
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
'1"4... ..
CERTIFICATE OF SERVICE
I, counsel for HOUSEHOLD REALTY CORPORATION, hereby certify that a true and correct
copy of the foregoing Praecipe to Discontinue Against Garnishee Only was served upon the
following by First Class Mail, postage prepaid on this 1 st day of September, 2006.
COMMERCE BANK
742 WERTZVILLE ROAD
ENOLA, P A 17025
JAMES W. KIRKPATRICK
GAYLE L. KIRKPATRICK
164 SOUTH ENOLA DRIVE
ENOLA, P A 17025
Cathy
Maureen . Dowd, Esq.
Lori M. DiRenzo, Esq.
Amy L. Sabolchick, Esq.
Anna M. Bonarrigo, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
HOUSEHOLD REALTY CORPORATION,
CIVIL DIVISION
Plaintiff,
No. 06-2765-CNIL TERM
vs.
TYPE OF PLEADING:
JAMES W. KIRKPATRICK
and GAYLE L. KIRKPATRICK,
Defendants,
PRAECIPE FOR A WRIT OF
EXECUTION
and
FILED ON BEHALF OF:
COMMERCE BANK,
HOUSEHOLD REALTY CORPORATION
Garnishee.
COUNSEL OF RECORD:
Plaintiffs Address:
2700 Sanders Road
Prospect Heights, IL 60070
CATHY ANN CHROMULAK, ESQ.
P A ill NO, 42067
LORI M. DIRENZO, ESQ.
PA ill NO. 201843
AMY L. SABOLCHICK, ESQ.
P A ill NO, 94653
ANNA M. BONARRIGO, ESQ.
PA ill NO. 202070
Defendants' Address:
164 SOUTH ENOLA DRIVE
ENOLA, P A 17025
Garnishee's Address:
742 WERTZVILLE ROAD
ENOLA, P A 17025
CHROMULAK & ASSOCIATES, L.L.C.
Date: AUGUST 7, 2006
375 Southpointe Boulevard
4th Floor
Canonsburg, P A 15317
(724) 916-2400
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
I,....
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
HOUSEHOLD REALTY CORPORATION,
CIVIL DIVISION
Plaintiff,
No. 06-2765-CNIL TERM
vs,
JAMES W. KIRKPATRICK
and GAYLE L. KIRKPATRICK,
Defendants,
and
COMMERCE BANK,
Garnishee,
PRAECIPE FOR WRIT OF EXECUTION
TO: The Prothonotary
Please issue a Writ of Execution in the above matter,
1, directed to the Sheriff of CUMBERLAND County;
2. against JAMES W. KIRKPATRICK, defendant, and
3, against GAYLE L. KIRKPATRICK, defendant, and
4, against COMMERCE BANK, garnishee,
5, and index this writ
a, against JAMES W. KIRKPATRICK, defendant, and
b. against GAYLE L. KIRKPATRICK, defendant, and
c. against COMMERCE BANK, garnishee, and any property of the defendant in
the name of Garnishee:
Said Writ of Execution is pursuant to all monies due defendants in any accounts. individual
and ioint. personal and business.
6.
Amount of Judgment
Additional Interest to Date
(Costs to be added)
$9,210.16
$ 64.68
$
Pursuant to Writ of Execution
And Service of Writ
$9,274.84
~13? ..
YTIIY ANNCHROMUL~
LORI M. DIRENZO, ESQ.
AMY L. SABOLCHICK,ESQ,
ANNA M. BONARRIGO, ESQ,
[THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-2765 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD REALTY CORPORATION,
Plaintiff (s)
From JAMES W. KIRKPATRICK AND GAYLE L. KIRKPATRICK, 164 SOUTH ENOLA
DRIVE, ENOLA, P A 17025
(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, 724 WERTZVILLE ROAD, ENOLA, PA 17025 - ALL MONIES DUE
DEFENDANTS IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS.
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) If property 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $9,210.16
Interest TO DATE - $64.68
Atty's Comm %
Atty Paid $139.20
Plaintiff Paid
Date: AUGUST 9, 2006
L.L. $.50
Due Prothy $1.00
Other Costs
~
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name ANNA M. BONARRIGO, ESQUIRE
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 DOUTHPOINTE BOULEVARD
4TH FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court In No. 202070
r - ,_
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD REALTY
CORPORATION,
CIVIL DIVISION
Plaintiff,
No. 06-2765-CIVIL TERM
vs.
TYPE OF PLEADING:
JAMES W. KIRKPATRICK and
GAYLE L. KIRKPATRICK,
Praecipe to Satisfy Judgment
Defendants.
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
Plaintiffs Address:
2700 Sanders Road
Prospect Heights, IL 60070
HOUSEHOLD REAL TY CORPORATION
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ill NO. 42067
AMY L. SABOLCHICK, ESQ.
PA ill NO, 94653
ANNA M. BONARRIGO, ESQ.
PA ill NO, 202070
CHROMULAK & ASSOCIATES, L.L.c.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD REALTY
CORPORA nON,
CIVIL DIVISION
No, 06-2765-CIVIL TERM
Plaintiff,
vs.
JAMES W. KIRKPATRICK and
GAYLE L. KIRKPATRICK
Defendants.
PRAECIPE TO SATISFY JUDGMENT
TO PROTHONOTARY:
Please satisfy the judgment against JAMES W, KlRKP A TRICK and GAYLE L.
KIRKPATRICK, at No. 06-2765-CIVIL TERM, and mark the docket accordingly.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By:
CAT ANN CHR
PA ill NO, 42067
AMY L. SABOLCHICK, ESQ.
PAID NO, 94653
ANNA M. BONARRIGO, ESQ.
PA ill NO, 202070
Attorneys for Plaintiff
375 Southpointe Boulevard
4th Floor
Canonsburg, P A 15317
Sworn to and subscribed
Before me this ) elk-- day
of ~ ,2006.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Notary Public
OOMMONWEAlTH Off PENNSYLVANIA
Notarial Se8I
Hea1her L HatlIefd, Notary Public
CecIl Twp., wasIW1gton COU1ty
MyCorrmisSion Exp!rea June 29 2010
M '
ember, Pennsylvania Association of Notatles
CERTIFICATE OF SERVICE
I, counsel for HOUSEHOLD REALTY CORPORATION, hereby certify that a true and correct
copy of the foregoing Praecipe to Satisfy Judgment was served upon the following by First
Class Mail, postage prepaid on this 18TH day of SEPTEMBER, 2006.
JAMES W, KIRKPATRICK and
GAYLE L. KIRKPATRICK
164 SOUTH ENOLA DRNE
ENOLA, P A 17025
athy Ann Chrom ak, Esq.
Amy L. Sabolchick, Esq,
Anna M. Bonarrigo, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
~
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Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED,
Sheriffs Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Surcharge
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage
TOTAL $
18.00
1.84
.50
1.00
13.20
30.00
20.00
9.00
93.54 ./
'~~~~~~
Advance Costs: 150.00
Sheriffs Costs: 93.54
$ 56.46
Refunded to Atty on 09/12/06
q<:2JvOe,Ov
,..>~~
R. Thomas Kline, Sheriff
cjfl/lA,-_ ~}/
By C1ali'dTaX. Brewbaker
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R...v. 113)).1
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-2765 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD REALTY CORPORATION,
Plaintiff (s)
From JAMES W. KIRKPATRICK AND GAYLE L. KIRKPATRICK, 164 SOUTH ENOLA
DRIVE, ENOL A, P A 17025
(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, 724 WERTZVILLE ROAD, ENOLA, P A 17025 --- ALL MONIES DUE
DEFENDANTS IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS.
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 $9,210.16
Interest TO DATE - $64.68
Arty's Comm %
Arty Paid $139.20
Plaintiff Paid
Date: AUGUST 9, 2006
L.L. $.50
Due Prothy $1.00
Other Costs I ~A.A
(!~~- 0
CURTIS R. LONG
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name ANNA M. BONARRIGO, ESQUIRE
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 DOUTHPOINTE BOULEVARD
4TH FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 202070
"
SHERIFF'S RETURN - REGULAR
(
CASE NO: 2006-02765 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD REALTY CORPORATION
VS
KIRKPATRICK JAM~S W ET AL
STEPHEN BENDER
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the with~n COMPLAINT & NOTICE
was served upon
KIRKPATRICK JAMES W
the
DEFENDANT
, at 1430:00 HOURS, on the 22nd day of May
2006
at 164 SOUTH ENOLA DRIVE
I
ENOLA, PA 1702$
GAYLE L KIRKPAtRICK, WIFE
by handing to
a true and att~sted copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
13.20
.00
10.00
.00
41.20/
r"~~~
R. Thomas Kline
OS/23/2006
CHROMULAK & ASSOCIATES
~
1-/7'Ol,
By, Zitt, U
Deputy Sheriff
'I.
..
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-02765 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD REALTY CORPORATION
VS
KIRKPATRICK JAMES W ET AL
STEPHEN BENDER
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
KIRKPATRICK GAYLE L
the
DEFENDANT
, at 1430:00 HOURS/ on the 22nd day of May
2006
at 164 SOUTH E~OLA DRIVE
ENOLA, PA 17025
by handing to
GAYLE L KIRKPAtRICK
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
,00
10.00
.00
16.00/
Qv. '1/1")/0(,
So Answers:
.~~<-:!<, ~.ld~-f'"
R. Thomas Kline
OS/23/2006
CHROMULAK & ASSOCIATES
By, ~ 6L
- Duty Sheriff
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-02765 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD REALTY CORPORATION
VS
KIRKPATRICK JAMES W ET AL
And now CPL. TIMOTHY REITZ
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0015:52 Hours, on the 17th day of August
, 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
KIRKPATRICK JAMES W
, In the
hands, possession, or control of the within named Garnishee
COMMERCE BANK 724 WERTZVILLE ROAD
ENOLA, PA 17025
Cumberland County, Pennsylvania, by handing to
STEPHEN SILCOX (TELLER)
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 His .
.00
.00
.00
.00
.00
.00,/
Sworn and SUbscribe;!~~&~' 08/18/200~ ?ft----
before me this day of By _~:~ ~
- - D7uiy Sher' ff
A.D
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So :ns~
~~~~~.~
R. Thomas KI ine .
Sheriff of Cumberland County
SHERIFF'S RETURN - GARNISHEE
..
CASE NO: 2006-02765 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD REALTY CORPORATION
VS
KIRKPATRICK JAMES W ET AL
And now CPL. TIMOTHY REITZ
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0007:24 Hours, on the 17th day of August
, 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
KIRKPATRICK GAYLE L
ln the
hands, possession, or control of the within named Garnishee
COMMERCE BANK 724 WERTZVILLE ROAD
ENOLA, PA 17025
Cumberland County, Pennsylvania, by handing to
STEPHEN SILCOX (TELLER)
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 His .
.00
.00
.00
.00
.00
.00v
08/17/2006
So?~~p
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
R. Thomas Kline
Sheriff of Cumberland County
9, ,!:5.btr
Sworn and Subscribed to
L~
day of
By
~' - ;:~-
~y ~he ff
before me this
A.D