HomeMy WebLinkAbout06-5230UC-728 REV. 1-06
IN THE COURT OF COMMON PLEAS OF
CUMnBERLAND COUNTY, PENNSYLVANIA
I'C Jr
Ck /L 3))
CERTIFIED COPY OF LIEN
TO THE PROTHONOTARY OF SAID COURT:
Pursuant to Section 308.1 of the
Pennsylvania Unemployment
Compensation Law, 43 P.S. § 788.1,
this is a Certified Copy of Lien for
unpaid unemployment compensation
contributions, interest and penalties to
be entered of record by you and
indexed as judgments are indexed.
ACCOUNT NUMBER:
AD Number: 319849
QTR/YR.
DUE
2-06IWE 182.47
2-06 12,152.20
DOCKET # o6_ S-2, g6
DATE ENTERED
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF LABOR AND INDUSTRY
TO THE USE OF THE
UNEMPLOYMENT COMPENSATION FUND
VS.
•CUMBERLAND SERVICES INC
3 SOUTH 40TH STREET
CAMP HILL PA 17011
•
.00 182.47
.00 12,152.20
11NALTY DUE
CONTRIBUTION AND / OR I. so reverse for
CONTRIBUTION PAID LATE. explanation],
. 01
92.51 ,01
co
"WE" refers to withholding for employee contributions, sub-total
Additional interest is to be computed on the above balance of unpaid unemployment
compensation contributions at the rate of one-twelfth (1/12) of the annual rate
determined by the Secretary of Revenue under Section 806 of the Fiscal Code, 72
P.S. § 806, per month or fraction of a month, or at the rate of three quarters of one
per centum (0.7596) per month or fraction of a month, whichever is greater, from the
date they become due until paid, from 08/31/2006.
12, 334 671 92 51 00?
:Total 12,427.18
Filing Fee(s) 14.00
Additional Legal Casts
Additional Interest
Satisfaction Amount
The undersigned, Assistant Director, Office of Unemployment Compensation Tax Services, Department of Labor and Industry, certifies that the above unemployment compensation
contributions, interest and penalties are due and payable by the above named defendant under the provisions the Pennsylvania Unemployment Compensation Law. Pursuant to Section
308.1 of said Law, 43 P.S. § 788.1, the above contributions, Interest and penalties are a Ilen upon the franchises e and property, both real and personal, Including after acquired property, of
the above named defendant and attach thereto from the date of entry of this Certified Copy of Llen.
0'w ey ;
SALLY L. PIATAK
Assistant Director, Office of Unemployment Compensation Tax Services
TO BE RETAINED BY RECORDING OFFICE
08/23/2006
DATE
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF LABOR AND INDUSTRY,
to the use of the
UNEMPLOYMENT COMPENSATION FUND
Plaintiff
V.
Cumberland Services, Inc.
3 South 40th Street
Camp Hill, PA 17011
Defendant(s)
and
Fulton Bank
1423 South Market Street
Mechanicsburg, PA 17055
Garnishee
: NO. 06-5230 Civil Term
AFFIDAVIT OF MAILING NOTICE OF ENTRY OF LIEN
Joyce A. Pierce, being duly sworn according to law, deposes and says that he/she
is an employee of the Commonwealth of Pennsylvania, Department of Labor and
Industry, and that as such makes the following affidavit.
That on October 18, 2007, he/she mailed by certified mail, return receipt requested
Notice of Entry of Lien, and Intent to Execute, as provided by Section 308.1 of the
Pennsylvania Unemployment Compensation Law, Act of December 5, 1936, P.L. (1937)
2897, as amended, addressed to Cumberland Services, Inc., 3 South 40th Street, Camp
Hill, PA, 17011 the last known post office address of the employer.
This affidavit is made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities.
Jo A. Pierce
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - LAW
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF LABOR AND INDUSTRY,
to the use of the
UNEMPLOYMENT COMPENSATION FUND
Plaintiff
V.
Cumberland Services, Inc.
3 South 40th Street
Camp Hill, PA 17011
and
Fulton Bank
1423 South Market Street
Mechanicsburg, PA 17055
Defendant(s)
Garnishee
NO. 06-5230 Civil Term
EXECUTION NO. TERM,
PRAECIPE FOR WRIT OF EXECUTION
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 Cumberland Services, Inc.,
3. against Fulton Bank,
4. Amount of Contributions, Interest and Penalty due
Lien Filing Fee(s)
Additional Legal Costs
Additional Interest due on $10,819.06
from 08/31/2006 to 11/02/2007 on
unpaid contributions to be computed at the annual
rates determined by the Secretary of Revenue under
Section 806 of the Fiscal Code, 43 P.S. § 788.1.
Less Payments
Total Amount Due
Dated:
Defendant(s)
Garnishee
$10,911.57
$+94)0--
$174.50
$1,147.37
$(0.00)
$12,252.44 plus costs
k-3,bjl
Arthur Selikoff (Attorn ID #43524)
Assistant Counsel
Commonwealth of Pennsylvania
Department of Labor and Industry
0? 10th Floor, Labor and Industry Building
Harrisburg, PA 17121
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N006-5230 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Commonwealth of Pennsylvania Department of Labor
and Industry to the use of the Unemployment Compensation Fund Plaintiff (s)
From Cumberland Services, Inc 3 South 40th Street, 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 Fulton Bank 1423 South Market Street, Mechanicsburg, Pa. 17055
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$10,911.57
L.L.$0.50
Interest Additional Interest due on $10,819.06 from 8/31/06 to 11/02/07 on unpaid contributions to be
computed at the annual rates determined by the Secretary of Revenue under Section 806 of the Fiscal
Code 43 ps 788.1 $1,147.37
Atty's Comm %
Atty Paid $41.00
Plaintiff Paid
Date: November 2, 2007
(Seal)
Due Prothy $2.00
Other CostsAdditioanl Legal Cost $174.50
Tax due $0.50
biu4rtis 4
R. Long, Prothono ry
By: L f?: ??Zc
Deputy
REQUESTING PARTY:
Name Arthur Selikoff Esq., Assistant Counsel
Address: Commonwealth of Pennsylvania, Department of Labor and Industry
10`h Fl Labor and Industry Building, Harrisburg, Pa 17121
Attorney for: Plaintiff
Telephone:
Supreme Court ID No. 43524
t. F
MOGEL, SPEIDEL, BOBB & KERSHNER, P.C.
A PROFESSIONAL CORPORATION
BY: Frederick R. Mogel, Esquire
Identification No. 32214
520 Walnut Street, P.O. Box 8581
Reading, PA 19603-8581
610-376-1515
Attorney for: Garnishee
COMMONWEALTH OF
PENNSYLVANIA, DEPARTMENT OF
LABOR & INDUSTRY, to the use of the
UNEMPLOYMENT COMPENSATION
FUND,
Plaintiff
-vs-
CUMBERLAND SERVICES, INC.,
Defendant
-and-
FULTON BANK,
Garnishee
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-5230
NOTICE
TO: COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF LABOR & INDUSTRY,
to the use of the UNEMPLOYMENT COMPENSATION FUND
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE
ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR
A JUDGMENT MAY BE ENTERED AGAINST YOU.
MOGEL, SPEIDEL, BOBB & KERSHNER
B
rederick R. Mogel, Esquire
Attorney I.D. No. 32214
520 Walnut Street, P.O. Box 8581
Reading, PA 19603-8581
(610) 376-1515
Attorneys for Garnishee
A
L
COMMONWEALTH OF : IN THE COURT OF COMMON PLEAS
PENNSYLVANIA, DEPARTMENT OF : OF CUMBERLAND COUNTY,
LABOR & INDUSTRY, to the use of the : PENNSYLVANIA
UNEMPLOYMENT COMPENSATION
FUND,
Plaintiff CIVIL ACTION - LAW
-vs- NO. 06-5230
CUMBERLAND SERVICES, INC.,
Defendant
-and-
FULTON BANK,
Garnishee
ANSWER AND NEW MATTER OF FULTON BANK. GARNISHEE.
TO INTERROGATORIES IN ATTACHMENT BY THE PLAINTIFF
1. Yes.
2. No.
3. No.
4. No.
5. No.
6. No.
7. No.
8. No.
9. Demand Deposit Account No. 3620-46084 in the name of Cumberland Services,
Inc., with a balance as of November 8, 2007 in the amount of $26,163.39.
NEW MATTER
10. Garnishee, Fulton Bank, is entitled to reasonable counsel fees as part of taxable
costs in this matter pursuant to 41 Pa. C.S. §2503(3).
11. Reasonable counsel fees on behalf of the Garnishee, Fulton Bank, are Two
Hundred Dollars ($200.00) for the review of the records, consultations with Plaintiff's counsel,
consultations with Garnishee, review of the pleadings and execution of documents and filing
these Answers to Interrogatories.
12. Garnishee, Fulton Bank, is entitled to its reasonable attorney's fees as set forth
above pursuant to law and Garnishee, Fulton Bank's contract with the Defendant, which fees
shall be a setoff against the debt owing to Defendant, which Plaintiff has garnished.
WHEREFORE, Garnishee, Fulton Bank, hereby demands judgment against the Plaintiff
in the amount of Two Hundred Dollars ($200.00) as reasonable counsel fees as provided for by
law.
MOGEL, SPEIDEL, BOBB & KERSHNER
2By51de `l C t/4-ct,,-( ?-
rederick R. Mogel
, Esquire
ntification No. 32214
4
520 Walnut Street, P.O. Box 8581
Reading, PA 19603-8581
(610) 376-1515
Attorney for Garnishee, Fulton Bank
w
VERIFICATION
Frederick R. Mogel, Esquire, hereby verifies that he is the attorney for Fulton Bank,
Garnishee, in the instant action, and that as such counsel, he is authorized to make, and
possesses sufficient information and belief to make, the within verification on its behalf; and
further, that the facts set forth in the foregoing Answers to Interrogatories are true and correct
to the best of his information and belief.
This verification is made pursuant to Pennsylvania Rule of Civil Procedure No. 1024(c),
inasmuch as verification of the Garnishee, on whose behalf the foregoing pleading is filed,
cannot be obtained within the time allowed for filing the pleading. The undersigned's
information regarding the facts set forth in the foregoing pleading has been derived from a review
of pleadings, correspondence and other documents in the attorneys' files, as well as from
conversations with the Garnishee concerning the subject matter of the instant action.
This verification is made subject to the penalties set forth in 18 Pa. C.S.A. §4904, relating
to unsworn falsifications to authorities.
c "-7/"xAc ft ?CiCv-f _
F ederick R. Mogel, Esquire
Dated: November 20, 2007
P %
COMMONWEALTH OF
PENNSYLVANIA, DEPARTMENT OF
LABOR & INDUSTRY, to the use of the
UNEMPLOYMENT COMPENSATION
FUND,
Plaintiff
-vs-
CUMBERLAND SERVICES, INC.,
Defendant
-and-
FULTON BANK,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-5230
Garnishee
CERTIFICATE OF SERVICE
I, Cheryl R. Zito, Legal Assistant to Frederick R. Mogel, Esquire, Attorney for
Garnishee, do hereby certify that I served the foregoing upon the following, by first class, United
States mail, postage prepaid, on the date listed below:
Arthur Selikoff, Esquire Cumberland Services, Inc.
Commonwealth of Pennsylvania 3 South 40th Street
Dept. of Labor & Industry Camp Hill, PA 17011
Labor & Industry Building, 10th Floor
Harrisburg, PA 17121
I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section
4904, relating to unsworn falsification to authorities.
Dated: November 20, 2007
Cl rv
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-05230 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
UNEMPLOYMENT COMPENSATION FUND
VS
CUMBERLAND SERVICES INC
And now KENNETH GOSSERT
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0015:25 Hours, on the 7th day of November-, 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
CUMBERLAND SERVICES INC in the
hands, possession, or control of the within named Garnishee
FULTON BANK 1423 SOUTH MARKET ST
MECHANICSBURG, PA 17055
Cumberland County, Pennsylvania, by handing to
MEGAN NORDSTROM (BRANCH 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: So ans
st
Docketing .00
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00 0 0 ? 11/07/01 4-1--
11/08/2007
Sworn and Subscribed to
before me this day of By
, A.D
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs: Advance Costs: 150.00
Sheriff's Costs 92.84
Docketing 18.00 57.16
Poundage 1.82
Advertising
Law Library .50
Prothonotary 2.00 Refunded on 07/29/08
Mileage 11.52
Misc.
Surcharge 30.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage
Garnishee 9.00
TOTAL 92.84 $ '13 '4 a So Answers,
C
cr,
' R. mas Kline
4
By
$2.So
-3 (f), I
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N006-5230 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Commonwealth of Pennsylvania Department of Labor
and Industry to the use of the Unemployment Compensation Fund Plaintiff (s)
From Cumberland Services, Inc 3 South 40th Street, 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 Fulton Bank 1423 South Market Street, Mechanicsburg, Pa. 17055
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$10,911.57
L.L.$0.50
Interest Additional Interest due on $10,819.06 from 8/31/06 to 11/02/07 on unpaid contributions to be
computed at the annual rates determined by the Secretary of Revenue under Section 806 of the Fiscal
Code 43 ps 788.1 $1,147.37
Atty's Comm %
Atty Paid $41.00
Plaintiff Paid
Date: November 2, 2007
(Seal)
Due Prothy $2.00
Other CostsAdditioanl Legal Cost $174.50
Tax due $0.50
w w
C is R. Long, Prothonota
By: hLc.?
Deputy
REQUESTING PARTY:
Name Arthur Selikoff Esq., Assistant Counsel
Address: Commonwealth of Pennsylvania, Department of Labor and Industry
10th Fl Labor and Industry Building, Harrisburg, Pa 17121
Attorney for: Plaintiff
Telephone:
Supreme Court ID No. 43524