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HomeMy WebLinkAbout02-2226BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. DALE R. BROOKHART Defendant : CIVIL ACTION - LAW PRAECIPE TO TRANSFER JUDGMENT PURSUANT TO PA R C P 3002 TO THE PROTHONOTARY: Please enter judgment on behalf of plaintiff, CITIBANK (SOUTH DAKOTA) N.A., and against defendant, DALE R. BROOKHART in the sum of $5,031.75 plus costs in accord with Pa.R.C.P. 3002 and attached are certified copies of the PERRY County Judgment. BURTON ASSOCIATES, P.C. BY: urton Neil, Esquire Attorney for Plaintiff AND NOW this 1+4N day of m? 2002, judgment is entered on behalf of plaintiff, CITIBANK (SOUTH DAKOTA) N.A. , and against defendant, DALE R. BROOKHART, in the sum of $5,031.75 plus costs. LA2?;-. T? , Prothonotary The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. In the Court of Common Pleas of Perry County; Pennsylvania CITIBANK (SOUTH DAKOTA)N.A. No. 2001-863 PO Box 356 c/o OLIN NEIL & HALTRECHT WEST CHESTER,PA.19381-0356 VS DALE BROOKHART RD#1,BOX 40 D LIVERPOOL,PA.17045 CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of Common Pleas of Perry County, Pennsylvania, do hereby certify that the following is a full, true and correct copy of the docket entries in the above captioned case. Judgment in favor of the Plaintiff CITIBANK,N.A. and against the Defendants DALE BROOKHART in the sum of $5,031.75 Dollars ($5,031.75 ) by virtue of authority contained in file dated SEPTEMBER 28 , 2001 XK payable with interest/costs, etc. -% for collection. Inquisition and Exemption ( )Waived. Entered^ ,19 at J.ALBRIGHT [SEAL] ` - Prothonotary Deputy CHARTES E MMMW I further certify that judgment was entered in favor and DALE BROOKHART on the 28th day of of $5,031.75 SEPTEMBER CITIBANK,N.A. 2001 A.D. _ in said case in the amount In Testimony Whereof, I have hereunto set my hand and affixed the seal of the Court, on the 24th day of APRIL 2002 A.D. 19 E' J.ALBRIGHT Q Prothonotary ?Q ? ,,v°? by A CHARLES E.MEEHAN Deputy 1 6 z v o ? p r es es z ?+ 'l G 7?5N Q ?. C ? vi e.9 ss u9 vi W U ? b d y 'O p ` ? a A A F a P rinted Dy : IMR Limltatl - F orm H - 102 E 00020636 Do r rob ?y E n b n • p . rn 0 o ? (n r-r (D rt F ' :d bd bi c Y O x M •J 1 ' O m T. rt z .. a I' ° d Im M%' l W. r ?• ? w N R co n N N w W rt z ? a o m g r n ? N w co W N N ID g rt H n vi w O O N ? V W l.tl a N W O R r• n D ( `Y 0 ?1 M - a w 0 I 0 ?O ? c W Date: 04/24/2002 41st Judicial District of PA, Perry County Branch Time: 03:53 PM ROA Report Page 1 of 1 Case: CV-MI-2001-00863 Current Judge: UNASSIGNED CITIBANK vs. DALE R BROOKHART Miscellaneous Date 04/22/2002 PRAECIPE FOR EXEMPLIFEID RECORD FILED. EXIT EXEMPLIFIED RECORD TO ATTY. Filing: Exemplified Record Paid by: OLIN, NEIL, & HALTRECHT Receipt number: 0000508 Dated: 4/22/2002 Amount: $10.00 (Check) UNASSIGNED UNASSIGNED User: OLD &IF11D n1011 DEPUTY PROTHONOTARY BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 E. 60" St. N, Sioux Falls, SD Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. DALE R. BROOKHART RR 1 POB 40, Liverpool, PA 17045-9801 Defendant NO. CIVIL ACTION - LAW Certification of Address and Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment creditor and debtor. 2. The said defendant is not in the Military Service of the United States or its Allies or otherwise within the coverage of the Soldiers' and Sailors' Relief Act of 1940, as amended, is over 18 years of age and has civilian occupation. BUR25n IL & ASSOCIATES, P.C. By: eil, Esquire Attorney for Plaintiff The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. c? C-) l Fil w $ Fi 7 -? V i'LD PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. DALE R. BROOKHART Defendant(s) MEMBERS FIRST FEDERAL CREDrr UNION Garnishee(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2226 CIVIL CIVIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. against DALE R. BROOKHART, Defendant(s) 3. and against MEMBERS FIRST FEDERAL CREDIT UNION Garnishee(s) 4. and index this writ (a) against (b) against Defendant(s) Gamishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) NO LEVY-GARNISHMENT ONLY Serve interrogatories on garnishee at: 5000 Louise Drive, Mechanicsburg, PA 17055 5. Amount Due $5,031.75 Interest from 6/26 /01 $ 261.76 Total $5,293.51* *Plus writ costs Dated: May 8, 2002 Burton Neil, Esquire Attorney for Plaintiff NOTE: Under paragraph I when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the count in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a Its pendens is desired. See Rule 3104(c). The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. p -4 l4l '` -k A *k r i w C C CO, c 0 1 M ' a o c „ % „ U) te 01 ?j r ' c -. J ? y n ?r co WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-2226 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK (SOUTH DAKOTA) NA, Plaintiff (s) From DALE R. BROOKHART, R R # 1, P.O.BOX 40, LIVERPOOL, PA 17045 (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 MEMBERS FIRST FEDERAL CREDIT UNION, 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055 - SERVE INTERROGATORIES ON GARNISHEE 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 $5,031.75 Interest FROM 6/26/01 - $261.76 Atty's Comm % Arty Paid $32.50 Plaintiff Paid Date: MAY 16, 2002 REQUESTING PARTY: Name BURTON NEIL, ESQUIRE Address: 26 SOUTH CHURCH STREET PO BOX 356 WEST CHESTER, PA 19381-0356 Attorney for: PLAINTIFF Telephone: 610-696-2120 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division r Supreme Court ID No. 11348 SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02226 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS BROOKHART DALE R And now CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:40 Hours, on the 20th day of May , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT BROOKHART DALE R in the hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UN 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to TODD SHIMKO (SUPPORT SERVICE ADMINISTRATOR) 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 . Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 00/00 Sworn and subscribed to before me this 3,u( day of jao,2 A.D. x.00.. Pr lonotary So ans R. Thomas Kline Sheriff of Cumberland County ..r ..r .w+ w? y B RTON NEIL & ASSOCIATES, P.C. B : Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff vs. DALE R. BROOKHART Defendant and MEMBERS FIRST FEDERAL CREDIT UNION Garnishee IN THE COURT OFICOMMON PLEAS CUMBERLAND , PENNSYLVANIA NO. 02-2226 CIVIL CIVIL ACTION - RULE OF CIVIL PROCEDURE NO. 236 Notice is given that a JUDGMENT in the above captioned on 13? X26& A- Prothonotary By: If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing 26 South Church Street West Chester, PA 19382 Phone: 610-696-3030 has been entered against you In making this communication, we advise that our firm is a debt collector. BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. vs. Plaintiff DALE R. BROOKHART Defendant and MEMBERS FIRST FEDERAL CREDIT UNION Garnishee TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2226 CIVIL CIVIL ACTION - LA Kindly enter judgment in favor of plaintiff, Citibank (South Dakota) N.A.I , and against garnishee, Members First Federal Credit Union, for the amount admitted in its possession in the attached Answers to Interrogatories in the total sum of $2,574.77. TES, P.C. AND NOW this I.'10-" day of -Horton Neil., Esquire Attorney for Plaintiff 2002, judgment ?s hereby entered in favor of plaintiff, Citibank (South Dakota) N.A. , and against garnishee, Members First accordance with the attached Answers to Interrogatories in the total sum of $2, Prothonotary 77. Credit Union, in In making this communication, we advise that our firm is a debt collector. 4 t c ° r ? r - mr -,m tea. -? co l7 ' r BURTON NEIL & ASSOCIATES, P.C. By:Burton Neil, Esquire - Id. No. 11348 26 South Church Street West Chester, PA 19382 - 610-696-2120 Attomev for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff vs. DALE R. BROOKHART Defendant(s) MEMBERS FIRST FEDERAL CREDIT UNION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2226 CIVIL CIVIL ACTION - LAW Garnishee(s) Interrogatories to Garnishee To: MEMBERS FIRST FEDERAL CREDIT UNION 5000 Louise Drive. Mechanicsburg, PA 17055 You are required to file answers to the following Interrogatories within tv enty (20) days after service upon you. Failure to do so may result in judgment against you. 1. At the time you were served or at any subsequent time, did you owe the defendants any money or where you liable to it by virtue of monies held by you on deposit or otherwise on any negotiable or written instrument or did defendants claim that you owed them money or were liable to them for any reason. ob 2. At the time you were served or at any subsequent time, was there in yo, control or in the joint possession, custody or control of yourself and one or more c any nature owned solely or in part by the defendants? \4 ?s 3. If the answer to 1 and/or 2 is yyes pplease spe u the nture of the rope SgViuC?S o CN?Guu? A,aouaT 18395q.'SAvou; ?t(LfU ta,go Aa.( 4. At the time you were served or at any subsequent time, did you hold leg nature owned solely or in part by the defendants or in which defendants held or eb N6 5. At the time you were served or at any subsequent time, did you hold fic the defendants had an interest? Nb 6. At the time before or after you were served, did the defendants transfer or to any person or place pursuant to your direction or consent and if so, what was N0 7. At any time after you were served, did you pay, transfer or deliver any n defendants or to any person or place pursuant to its direction or otherwise discharg against you? No BURTON NEIL & Burton Neil, Esquire possession, custody or ier persons any property of and, if money, the amount? _CKINC QA(AO '? -=-0)(6q,9&. title to any property of any tied interest? any property in which deliver any property to you consideration therefor? ney or property to the any claim of the defendants TES, P.C. The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-2226 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK (SOUTH DAKOTA) NA, Plaintiff (s) From DALE R. BROOKHART, R R # 1, P.O.BOX 40, LIVERPOOL, PA 1'045 (1) You are directed to levy upon the property of the defendant (s)and to sell IF (2) You are also directed to attach the property of the defendant(s) not levied ul{on in the possession of MEMBERS FIRST FEDERAL CREDIT UNION, 5000 LOUISE DM v E,IMECHANICSBURG, PA 17055 - SERVE INTERROGATORIES ON GARNISHEE GARNISHEE(S) as follows: and to notify the gamishee(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 an 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 $5,031.75 L.L. $.50 Interest FROM 6/26/01 - $261.76 Atty's Comm % Due Prothy $1.00 Atty Paid $32.50 Other Costs Plaintiff Paid Date: MAY 16, 2002 CURTIS R. LONG Prothonotary, Civil Divisio REQUESTING PARTY: Name BURTON NEIL, ESQUIRE. Address: 26 SOUTH CHURCH STREET PO BOX 356 WEST CHESTER, PA 19381-0356 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No. 11348 TRUE COP FROM RECORD jay W f, I here unto set my MW Th" !t(w sad Cuxlrt at Wow Pa. J/, d.. _ . M. 1 M embers1 FEDERAL CREDIT UNION May 24, 2002 Dale R. Brookhart R.R. #1, P.O. Box 40 Liverpool, PA. 17045 RE: Account #183959 Dear Member: ASSET RECOVERY P. O. BOX 40 MECHANICSBURG, PA 17055 1-800-283-2328 EXT 5132 or(717)795-5132 O\ Please be advised that Members 1st Federal Credit Union has received a Writ of Execution and Attachment from the Court of Common Pleas Cumberland County. As a result of this judgment, Members 1 st has placed an administrative hold on your checking and savings accounts. The total amount being held is $2,574.77. These accounts are not accessible until such time as we receive notification from the Court. If you have any questions, please contact the attorney as listed on the enclosed document and at the bottom of this letter. Sincerely, Mice Murphy, CFE Asset Recovery Specialist DM/cg Certified Mail Cc: Burton Neil, Esq. 4 C ?' C N l ?a r ; t_r; 3Z T _ , rr+ y ? m ?jrn ? A BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2226 CIVIL DALE R. BROOKHART Defendant and MEMBERS FIRST FEDERAL CREDIT UNION Garnishee CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly mark the judgment against garnishee Members First Federal Credit Union, in the above matter, SATISFIED on payment of your costs only. BURTON NEIL & ASSOCIAT S, P.C. V , BY: 9- J? Burton Neil, Esquire Attorney for Plaintiff In making this communication, we advise that our firm is a debt collector. T ..J ?i ka PATRICIA ANN HASLAM, Plaintiff V. MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO.02-2426 CIVIL TERM CIVIL ACTION - LAW MICHAEL F. HASLAWS REPLY TO PATRICIA ANN HASLAWS NEW MATTER IN THE FORM OF A CROSS-PETITION TO DEFENDANT'S PETITION FOR SPECIAL RELIEF REQUESTING EXCLUSIVE POSSESSION OF MARITAL RESIDENCE AND NOW, this day of August, 2002, Petitioner/Defendant, Michael F. Haslam, by and through his attorneys, McNees Wallace & Nurick LLC, files the within Reply to Respondent/Plaintiff Patricia Ann Haslam's New Matter in the Form of a Cross Petition for Exclusive Possession to Petitioner/Defendant's Petition for Interim Exclusive Possession of Marital Residence, and in support thereof, avers as follows: 18. Admitted in part, denied in part. Admitted that Plaintiff incorporated her averments set forth in her foregoing answer. The averments of the Defendant's averments in his Petition for Special Relief Requesting Exclusive Possession of Marital Residence are incorporated herein by reference. 19. Admitted in part, denied in part. Defendant's averments in his Petition for Special Relief Requesting Exclusive Possession of Marital Residence are incorporated herein by reference. Admitted that Plaintiff has not worked outside of the home on a full- time basis throughout the lives of the children. Denied that Plaintiff has been the primary care provider for the children or that she has arranged her work and other schedules so that she is available to be with and care for the children. Since 1997, Defendant has been the primary caregiver for the children and continues to be the primary caregiver for the children at this time. Plaintiff repeatedly fails at her duties as a parent and Defendant is constantly making up for Plaintiffs failures to fulfill her duties as a parent and a spouse. Plaintiff often is more interested in going out and going away with her friends than being a parent to her children or a spouse to Defendant. 20. Denied. Defendant's averments in his Petition for Special Relief Requesting Exclusive Possession of Marital Residence are incorporated herein by reference. Defendant was an at least equal caregiver with Plaintiff to the children up until 1997. Since 1997, Defendant has been the primary caregiver. Although Defendant works full time and Plaintiff works part-time at best, Defendant has become the primary caretaker of the children because Plaintiff neglects her parental duties and obligations. 21. Denied. Defendant's averments in his Petition for Special Relief Requesting Exclusive Possession of Marital Residence are incorporated herein by reference. Defendant is working hard at maintaining some sort of normalcy for the children in the marital home. A. Denied. Plaintiff has equal access to the accounts that hold the children's money gifted to them by their grandfather. Both Plaintiffs and Defendant's names are on the accounts. Plaintiff has never taken an interest in the financial matters of the household. Defendant has been forced to be responsible for all of the financial dealings of the household and the marriage. B. Denied. Defendant did not refuse to cooperate in the enrollment of the parties' second child at Trinity High School. In fact, Defendant's counsel wrote a letter to Plaintiffs counsel expressing Defendant's cooperation and willingness to find a way to pay for the tuition. The letter from Pamela Purdy to Sam Andes, dated July 29, 2002, is attached hereto as "Exhibit A" and is incorporated herein. -2- C. Denied. Defendant has controlled the financial matters for the family by necessity. Plaintiff consistently ignores her parental and marital duties and has never expressed any interest in helping with the finances. D. Denied. Defendant has reacted towards Plaintiff in a manner that is consistent with the behavior of a spouse of an alcoholic. Defendant makes an effort to protect the children from Plaintiffs behavior and to maintain some sort of normalcy in a household that is constantly disrupted by Plaintiffs alcoholism and marital misconduct. 22. Denied. Defendant's averments in his Petition for Special Relief Requesting Exclusive Possession of Marital Residence are incorporated herein by reference. Any tension and anxiety that is in the family home is a result of Plaintiffs alcoholism, her failure to perform her parental and marital duties and her disappearances during the day and overnight. 23. Denied. The allegation contained in Paragraph 23 of Plaintiff/Respondent's New Matter is a legal conclusion to which no responsive pleading is required. To the extent that a response is required, Defendant believes that the safety and well-being of the children would be endangered if they were placed in the primary physical custody of Plaintiff. Defendant believes that it is in the best interest of the children to remain in the primary physical custody of Defendant. 24. Denied. The allegation contained in Paragraph 24 of Plaintiff/Respondent's New Matter is a legal conclusion to which no responsive pleading is required. To the extent that a response is required, Defendant believes that the children's safety and well-being would be endangered if Plaintiff was awarded exclusive possession of the marital home. Defendant believes that it is in the best interest of the children that he be awarded exclusive -3- possession of the marital home and that Plaintiff be excluded from the residence so that Defendant can continue as the primary caregiver to the children and so that the safety and well-being of the children will be preserved. WHEREFORE, Petitioner Michael F. Haslam respectfully requests this Honorable Court grant him and the parties' children interim exclusive possession of the marital home until the conclusion of the divorce proceedings. Respectfully Submitted, MCNEES WALLACE & NURICK, LLC BY Pamela L. Purdy ID No. 85783 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Petitioner Michael F. Haslam Date: August 16, 2002 -4- /O McNeeWNs Wallace & Nurick LLC attorneys at law PAMELA L. PURDY DIRECT DIAL: (717) 237-5479 E-MAIL ADDRESS: PPURDY@U MWN.COM July 29, 2002 Samuel L. Andes, Esq. P. O. Box 168 Lemoyne, PA 17043 Re: Michael F. Haslam and Patricia Ann Haslam Dear Mr. Andes: This letter is to confirm our conversation from last week regarding the Haslams' E-Trade account and plans for payment of Carly's tuition to Trinity High School. I was able to speak with Dennis Brewer at E-Trade last week and obtained documents identifying the parties' two E-Trade accounts, their balances and interest earned in 2001 and 2002. 1 have forwarded these documents to you with our other discovery responses. In regard to Carly's attendance at Trinity High School, Mr. Haslam has no objection to sending Carly to Trinity High School as long as the parties are able to afford it. The most prudent financial plan regarding payment of the tuition would be to earmark the dividend checks coming from the E-Trade and American Express accounts as funds for the children's education. Mr. Haslam proposes that a separate account be established in joint names for that purpose and that E-Trade and American Express will automatically deposit the monthly checks into that account. That account will be used solely for the purposes of paying for the children's educational needs. We are confident that Mrs. Haslam will agree that this is the best use of those funds. Please discuss this proposal with Mrs. Haslam and let me know your thoughts at your earliest convenience, so that we are able to establish the new account and affirm direct deposit as soon as possible. I look forward to hearing from you. Very truly yours, McNEES WALLACE & NURICK LLC By G? 2-/ PLP:jIp amela L. Purdy c: Michael F. Haslam PO BOX 1166 • 100 PINE STREET • HARRISBURG, PA 17108-1166 • TEL: 717.232.8000 • FAX: 717.237.5300 • WWW_MWN.COM COLUMBUS, OH • HAZLETON, PA • WASHINGTON, DC VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. 'NN .0 ? _v Michael F. Haslam Dated: PATRICIA ANN HASLAM, Plaintiff V. MICHAEL F. HASLAM, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO.02-2426 CIVIL TERM CIVIL ACTION - LAW CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 16'h day of August, 2002, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Samuel L. Andes, Esq. P. O. Box 168 Lemoyne, PA 17043 Pamela L. Purdy Of Counsel for Defendant Michael F. Haslam L / t-? f\ l ?-_, ? ?'? I l a? { r ?: ? ? ?--? : y v j • ' ?' '. _ _ __ ?•i ? ;.? ( .fl IX? ? 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: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Garnishee 18.00 1.74 .50 1.00 9.66 20.00 20.00 is-.00 -$8.90 Sworn and Subscribed to before me this .& uk day of ` 2003 A.D. nAt pro onotary Advance Costs: 150.00 Sheriffs Costs: 88.90 61.10 Refunded to Atty on 3/ 2 5/ 0 3 So Answers; ?. 0%ewwwe.,jo?,', : R. Thomas Kline, Sheriff BY --> a yti t CL ? =y IN .-I I J Ayy3 h 40 ?D U PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 CITIBANK (SOUTH DAKOTA) N.A. Plaintiff Vs. DALE R. BROOKHART Defendant(s) MEMBERS FIRST FEDERAL CREDIT UNION Garnishee(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2226 CIVIL CIVIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER L Directed to the Sheriff of Cumberland County, Pennsylvania 2. against DALE R. BROOKHART , Defendant(s) 3. and against MEMBERS FIRST FEDERAL CREDIT UNION , Garnishee(s) 4. and index this writ (a) against Defendant(s) (b) against Garnishee(s) as a lis pendens against the real property- of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property). NO LEVY-GARNISIUVIENT ONLY Serve interrogatories on garnishee at: 5000 Louise Drive, Mechanicsburg, PA 17055 5. Amount Due $5,031.75 Interest from 6/26/01 $ 521.38 Credit $2,574.77 Total $2,978.36*? *Plus writ costs Dated: October 27, 2003 Burton Neil, Es ire Attorney for Plaintiff NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the count in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. r v qA? 1 r rZI 0 0 0 O ' cv C 1 ? (?1l l ", :? Z1 =C O „ . q ui .c ?;rn 110 w -< WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-2226 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK (SOUTH DAKOTA) N.A., Plaintiff (s) From DALE R. BROOKHART (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 MEMBERS FIRST FEDERAL CREDIT UNION - SERVE INTERROGATORIES ON GARNISHEE AT: 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055 GARNISHEE(S) as follows: and to notify the gamishee(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 $5,031.75 L.L. Interest FROM 6/26101 - $521.38 Arty's Comm % Due Prothy $1.00 Arty Paid $148.40 Other Costs Plaintiff Paid Date: NOVEMBER 4, 2003 CURTIS R. LONG ?- Prothonotary >r : J& P (Sea)) ,X v . Deputy REQUESTING PARTY: Name BURTON NEIL, ESQUIRE Address: BURTON NEIL & ASSOCIATES, P.C. 26 SOUTH CHURCH STREET WEST CHESTER, PA 19382 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No. 11348 SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02226 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) N A VS BROOKHART DALE R And now DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:26 Hours, on the 7th day of November , 2003, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , BROOKHART DALE R , in the hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CRDT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to DELUCE MURPHY (FRAUD INVESTIGATION) 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: S7 answeLp: Docketing .00 ? Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 00 00/00/0000 Sworn and subscribed to before me this day of7Zt ? o9i7o 3 A.D. Pro honotary By Deputy Sherif '2/y BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff IN THE COURT OF COMMON PLEAS VS. DALE R. BROOKHART Defendant and MEMBERS FIRST FEDERAL CREDIT UNION Garnishee CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2226 CIVIL CIVIL ACTION - LAW Praecipe to Dissolve Attachment To the Prothonotary: Dissolve the attachment against MEMBERS FIRST FEDERAL CREDIT UNION, garnishee. & ASSOCIATES, P.C. :BY: JON N ei l, Esquire Attorney for Plaintiff C N_ T C o "D CY O 1 CrJ -a C:U om 7T1 _ `? y^ t}, ifs -! cl? Citibank (South Dakota) N.A. VS Dale R. Brookhart Writ of Execution Docket No. 2002-2226 Civil Term FILED-0. ! ri:.E OF THE P,= , ) . , I?qO i Y 2009 AUG 3 f ;Pi H: 16 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. No action has been taken in the last six months. Sheriff's Costs: Docketing Surcharge Garnishee Prothonotary Mileage Levy Poundage So Answers: $82.11 j j9 `' $18.00 20.00 9.00 1.50 12.00 20.00 1.61 R. Thomas Kline, Sheriff BY Sergea t s 1. 06 Co s SO ?- -7 l 579 X300 3 s IC) a? S'