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HomeMy WebLinkAbout06-5593WRIT OF EXECUTION IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA PRAMCO III LLC CASE NO. 2006-NO-002/2?15-Y30 YK VERSUS Z mu \t1 Ll TIMOTHY J WILBUR D/B/A TIM WILBUR MECHANICAL CONTRACTING MICHELLE L WILBUR TO THE SHERIFF OF CUMBERLAND COUNTY: TO SATISFY THE JUDGMENT, INTEREST AND COSTS AGAINST: DEFENDANT (S): TIMOTHY J WILBUR D/B/A TIM WILBUR MECHANICAL CONTRACTING & MICHELLE L WILBUR (1) YOU ARE DIRECTED TO LEVY UPON THE PROPERTY OF THE SAID DEFENDANT (S) AND TO SELL ANY INTEREST THERIN: (2) YOU ARE ALSO DIRECTED TO ATTACH THE PROPERTY OF THE DEFENDANT (S) NOT LEVIED UPON IN THE POSSESSION OF ADAMS COUNTY NATIONAL BANK LOCATED AT 1 BIG SPRING AVE, NEWVILLE, PA 17241 & MANUFACTURERS & TRADERS TRUST COMPANY LOCATED AT ONE WEST HIGH ST, CARLISLE, PA 17013 & ORRSTOWN BANK LOCATED AT 22 SOUTH HANOVER ST, CARLISLE, PA 17013 GARNISHEE (S) (SPECIFICALLY DESCRIBE PROPERTY) ALL PERSONAL PROPERTY CAPABLE OF ATTACHMENT UNDER THE RULES OF CIVIL POCEDURE, OWNED BY ANY DEFENDANT, OR IN WHICH ANY DEFENDANT CLAIMS AN INTEREST, AND WHICH IS IN THE POSSESSION, CUSTODY OF CONTROL OF ANY GARNISHEE, INCLUDING WITHOUT LIMITATION DEBTS OWED OR TO BE OWED TO ANY DEFENDANT BY ANY GARNISHEE, ANY DEPOSIT ACCOUNTS OF ANY DEFENDANT HELD BY ANY GARNISHEE, AND ANY SAFETY DEPOSIT BOXES LEASED TO ANY DEFENDANT. DEFENDANT OR OTHERWISE DISPOSING THEREOF; (3) IF PROPERTY OF THE DEFENDANT NOT LEVIED UPON AND SUBJECT TO ATTACHMENT IS FOUND IN THE POSSESSION OF ANYONE OTHER THAN A NAMED GARNISHEE, YOU ARE DIRECTED TO NOTIFY HIM THAT HE HAS BEEN ADDED AS A GARNISHEE AND IS ENJOINED AS ABOVE STATED. AMOUNT OF JUDGMENT: $131,293.92 DOCKET COSTS: $176.97 AMOUNT OF INTEREST: $7,562.17 ATTORNEY FEES/COMMISSION: SEAL OF COURT DATE: SEPTEMBER 15, 2006 ?J PROTHO TARY Atty for Pltff: Kaplin Stewart (610) 941-2543 EPUTY oq ?\ lai a v.? w h l? l l d b i d ?S 9GQl eo 4 + , n ?a \ (z , c 01 WRIT OF EXECUTION _ is-?D-OG IN-THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA PRAMCO III LLC CASE NO. 2006-NO-002215-Y30 YK VERSUS Zcc,U ?O-Tq TIMOTHY J WILBUR D/B/A TIM WILBUR MECHANICAL CONTRACTING MICHELLE L WILBUR TO THE SHERIFF OF CUMBERLAND COUNTY: TO SATISFY THE JUDGMENT, INTEREST AND COSTS AGAINST: DEFENDANT (S): TIMOTHY J WILBUR D/B/A TIM WILBUR MECHANICAL CONTRACTING & MICHELLE L WILBUR (1) YOU ARE DIRECTED TO LEVY UPON THE PROPERTY OF THE SAID DEFENDANT (S) AND TO SELL ANY INTEREST THERIN: (2) YOU ARE ALSO DIRECTED TO ATTACH THE PROPERTY OF THE DEFENDANT (S) NOT LEVIED UPON IN THE POSSESSION OF ADAMS COUNTY NATIONAL BANK LOCATED AT 1 BIG SPRING AVE, NEWVILLE, PA 17241 & MANUFACTURERS & TRADERS TRUST COMPANY LOCATED AT ONE WEST HIGH ST, CARLISLE, PA 17013 & ORRSTOWN BANK LOCATED AT 22 SOUTH HANOVER ST, CARLISLE, PA 17013 GARNISHEE (S) (SPECIFICALLY DESCRIBE PROPERTY) ALL PERSONAL PROPERTY CAPABLE OF ATTACHMENT UNDER THE RULES OF CIVIL POCEDURE, OWNED BY ANY DEFENDANT, OR IN WHICH ANY DEFENDANT CLAIMS AN INTEREST, AND WHICH IS IN THE POSSESSION, CUSTODY OF CONTROL OF ANY GARNISHEE, INCLUDING WITHOUT LIMITATION DEBTS OWED OR TO BE OWED TO ANY DEFENDANT BY ANY GARNISHEE, ANY DEPOSIT ACCOUNTS OF ANY DEFENDANT HELD BY ANY GARNISHEE, AND ANY SAFETY DEPOSIT BOXES LEASED TO ANY DEFENDANT. DEFENDANT OR OTHERWISE DISPOSING THEREOF; (3) IF PROPERTY OF THE DEFENDANT NOT LEVIED UPON AND SUBJECT TO ATTACHMENT IS FOUND IN THE POSSESSION OF ANYONE OTHER THAN A NAMED GARNISHEE, YOU ARE DIRECTED TO NOTIFY HIM THAT HE HAS BEEN ADDED AS A GARNISHEE AND IS ENJOINED AS ABOVE STATED. AMOUNT OF JUDGMENT: $131,293.92 DOCKET COSTS: $176.97 AMOUNT OF INTEREST: $7,562.17 ATTORNEY FEES/COMMISSION: SEAL OF COURT DATE: SEPTEMBER 15, 2006 TRUE COPY FROM RECORD Testhmy whereof, i here ume set my hap, od the seW ot said Cou at (fig. A. his?a C. y uv?? prnthnnntan, J PROTHO TARY Atty for Pltff: Kaplin Stewart (610) 941-2543 c EPUTY V, KAPLIN STEWART MELOFF REITER & STEIN, P.C. BY: William J. Levant, Esquire I.D. No..54286' Union Meeting Corporate Center 910 Harvest Drive, P.O. Box 3037 Oto-5593 Blue Bell, PA 19422 (610) 260-6000 Attorneys for Plaintiff -< PRAMCO III, LLC Plaintiff VS. TIMOTHY J. WILBUR, individually and: dba Tim Wilbur Mechanical Contracting and MICHELE L. WILBUR Defendants and ADAMS COUNTY NATIONAL BANK and MANUFACTURERS AND TRADERS TRUST COMPANY : and ORRSTOWN BANK Garnishees 4n-5u)eC5 -V IN TO: Adams County National Bank 1 Big Spring Ave. Newville, PA 17241 THE COURT OF COMMON PLI -, YORK COUNTY, PA -. =-> No. 2006-SU-2215-Y30 ' T' CIVIL ACTION - LAW c,7 Ln Ln TO : BELOW-NAMED GARNISHEES You are hereby notified to plead to the below Interrogatories to Garnishee(s) withWttwenty yo3'Y2 r. i5d days of service upon W be red against Manufactuers and Traders Trust Company One West High Street Carlisle, PA 17013 Esquire :r Orrstown Bank 22 South Hanover St. Carlisle, PA 17013 You are required to answer the following Interrogatories, as to Defendants Timothy J. Wilbur, individually and d/b/a Tim Wilbur Mechanical Contracting and Michele L. Wilbur. 1. At the time you were served or at any subsequent time, did you owe the Defendant any money or were you liable to the Defendant on any negotiable or other written agreement or did the Defendant claim that you owed it any money or were liable to it for any reason? -?S (a) If the answer to (1) is affirmative, state the amount claimed or owed. IMANBB /nca/661 1 /48/877196 1 09132006110:00 2. At the time you were served or any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and others any property of any nature owned solely or in part by the Defendant? NO (a) If the answer to (2) is affirmative, state the nature of such property. 3. At the time you were served or any subsequent time, did you hold legal title to any property in which the Defendant has, had or claimed an interest? 11 0 (a) If the answer to (3) is affirmative, state nature of such property and its value. 4. At the time you were served or any subsequent time, did you hold as fiduciary any property in which the Defendant had or claimed an interest? Na (a) If the answer to (4) is affirmative, state the nature and value of such property and the extent of the Defendant's interest. 5. At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and what was the consideration therefor? 00 (a) If the answer to (5) is affirmative, state what type of property was delivered, to whom it was delivered and when it was delivered. 6. At any time after you were served, did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to the Defendant's direction or otherwise discharge any claim of Defendant against you? N 0 (a) If the answer to (6) is affirmative, state what was delivered, to whom and when. IMANBB /=a/661 1/48/877 1 96_1 09132006/10:00 7. At the time you were served or any subsequent time, did you hold on account for the Defendant any money or credits arising from credit card transactions of any type?o (a) If the answer to (7) is affirmative, state the amounts you held for Defendants. 8. At the time you were served or at any subsequent time, did Defendant lease a safety deposit box at any branch of your bank (if applicable) ? , r D (a) If the answer to (8) is affirmative, state the location and identifying number of such box. 9. If you claim a right of set-off with regard to property of the Defendant you possess, please state the following: NJ A (a) The nature of the obligation the set-off funds are to be applied against (revolving loan, term loan, demand loan, etc.); (b) The relationship of the Defendant to the loan (maker, guarantor, surety, etc.); (c) The loan balance on the date on which you were served with the Writ of Execution); (d) Whether or not the loan(s) was/were in default immediately prior to service of the Writ of Execution; (e) If the loan(s) was/were a revolving loan, would the loan still be open and available for draw-down if there were no writ outstanding; (f) Please provide a copy of the loan documentation establishing your right to set off. IMANBB /nca/6611/48/877196_1 09132006/10:00 . y 10. List all accounts or obligations owned by or owed to the Defendant, by number, title and balance in which the defendant has any interest if not disclosed in response to another question herein. I hereby certify that the are true and correct, to the best of my knowledge, information and belief, under penalty of 18 P.S. § 4904, relating to unsworn falsification to authorities. Date : 01,75-106 Name : o n of r'a? k. M 0l i n ; Title : Corhpi;&tlee- ()??? ctr for Garnishee (Name): IMANBB /nca/6611/48/877196_I 09132006/10:00 CJ C [ l c " ? it err, cr> , C h I :I I V 61 d3S 9041 PRAMCO III, LLC COURT of COMMON PLEAS Plaintiff YORK COUNTY, PA V. TIMOTHY J. WILBUR, individually and : dba Tim Wilbur Mechanical Contracting and MICHELE L. WILBUR Defendants No. 2006-NO-2215-Y30 and ORRSTOWN BANK and ADAMS COUNTY NATIONAL BANK and MANUFACTURERS AND TRADERS TRUST COMPANY Garnishees WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of $300. There are other exemptions which may be applicable to you. Attached is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following promptly: (1) Fill out the attached claim form and demand for a prompt hearing. (2) Deliver the form or mail it to the Sheriff s Office at the address noted. You should come to court ready to explain your exemption. If you do not come to court and prove your exemption, you may lose some of your property. 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 BELOW to FIND OUT WHERE YOU CAN GET LEGAL HELP. YORK COUNTY BAR ASSOCIATION 137 East Market Street York, PA 17401 (717)854-8755 [CONTINUED on NEXT PAGE] IMANN /nca/6611 /48/676401_1 09132006116:28 [CONTINUED from PREVIOUS PAGE] MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law IMANBB /nca/6611/481876401_1 09132006/16:28 PRAMCO III, LLC COURT of COMMON PLEAS Plaintiff YORK COUNTY, PA V. TIMOTHY J. WILBUR, individually and : dba Tim Wilbur Mechanical Contracting and MICHELE L. WILBUR Defendants ORRSTOWN BANK : and : ADAMS COUNTY NATIONAL BANK and MANUFACTURERS AND TRADERS TRUST COMPANY No. 2006-NO-2215-Y30 Garnishees CLAIM FOR EXEMPTION TO THE SHERIFF: I, the defendant, claim exemption of property from levy or attachment: (1) From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be [ ] (1) set aside in kind (specify property to be set aside in kind): [ ] (11) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption (specify property and basis of exemption: (2) From my property which is in the possession of a third party, I claim the following exemptions: (a) my $300 statutory exemption: [ ] in cash; [ J in kind (specify property): (b) Social Security benefits on deposit in the amount of: (c) other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption. [CONTINUED on NEXT PAGE] IMANBB /nea/6611 /48/876401 1 09132006116:28 [CONTINUED from PREVIOUS PAGE] Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: Defendant: THIS CLAIM TO BE FILED WITH: Office of the Sheriff of Cumberland County 1 Courthouse Square, Carlisle, PA 17013 Telephone Number : (717)240-6390 IMANBB /nce/661 1 /4 8/87 64 01_1 09132006/16:28 SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00674 T 3 COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PRAMCO III LLC VS WILBUR TIMOTHY J ET AL And now SHARON LANTZ ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:50 Hours, on the 4th day of October 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , WILBUR TIMOTHY J D/B/A TIM WILBUR MECHANICAL CONTRACTING , in the hands, possession, or control of the within named Garnishee ADAMS COUNTY NATIONAL BANK 1 BIG SPRING AVE NEWVILLE, PA 17241 Cumberland County, Pennsylvania, by handing to TRINA KULP (TELLER) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTTON and made the contents there of known to Her Sheriff's Costs: So a Docketing .00 ,er• Service .00 Affidavit .00 R. Thomas Kline surcharge .00 Sheriff of Cumberland County .00 00 10/05/2006 Sworn and Subscribed to before me this day of By A.D Deputy Sherif I SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00674 T // (p1 ~9 COMMONWEALTH OF PENNSLYVA17IA COUNTY OF CUMBERLAND PRAMCO III LLC VS WILBUR TIMOTHY J ET AL And now SHARON T.ANT7 ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:50 Hours, on the 4th day of October 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT WILBUR MICHELE L hands, possession, or control of the within named Garnishee ADAMS COUNTY NATIONAL BANK 1 BIG SPRING AVE NEWVILLE, PA 17241 Cumberland County, Pennsylvania, by handing to TRINA KULP (TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTTON the contents there of known to Her Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscribed to before me this day of , in the true and made So answers: .00 .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 00 10/05/2006 e By Deputy Sherif A.D t SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00674 T/O?.P--SS q3 COMMONWEALTH OF PENNSf?YVANIA COUNTY OF CUMBERLAND PRAMCO III LLC VS WILBUR TIMOTHY J ET AL And now SHARON LANTZ ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:51 Hours, on the 4th day of October , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT WILBUR TIMOTHY J D/B/A TIM WILBUR MECHANICAL CONTRACTING , in the hands, possession, or control of the within named Garnishee MANUFACTURERS & TRADERS TRUST COMPANY 1 WEST HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BRENT SMITH (SELECT BANKER) 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 Service Affidavit Surcharge Sworn and Subscribed to before me this So answe .00 .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County 00 0 0 11/1-71e6 10/05/2006 day of By v Deputy S eri f A.D SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00674 T / 0 6 .-,55g3 COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PRAMCO III LLC VS WILBUR TIMOTHY J ET AL And now SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:51 Hours, on the 4th day of October , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , WILBUR MICHELE L in the hands, possession, or control of the within named Garnishee MANUFACTURERS & TRADERS TRUST COMPANY 1 WEST HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BRENT SMITH (SELECT BANKER) , 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: So answers: Docketing .00 ?` `? Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 0 0 ? //?f JO4 10/05/206 Sworn and Subscribed to before me this day of By epu y Sheri A.D SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00674 T / Qk -SS ?,2 COMMONWEALTH OF PENNSLYV A C OUNTY OF CUMBERLAND PRAMCO III LLC VS WILBUR TIMOTHY J ET AL And now SHARON LANTZ ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:57 Hours, on the 4th day of October , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT WILBUR TIMOTHY J D/B/A TIM WILBUR MECHANICAL CONTRACTING , in the hands, possession, or control of the within named Garnishee ORRSTOWN BANK 225 S. HANOVER ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to CARRIE MCGEE (TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her true and made Sheriff's Costs: So answers- Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 .00 ? Il?0 g? o 10/05/20 6 Sworn and Subscribed to before me this day of By -?X46 J-t 0? eputy heri A.D SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00674 T/ 6& -S'S93 COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PRAMCO III LLC VS WILBUR TIMOTHY J ET AL And now SHARON LANTZ ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:57 Hours, on the 4th day of October , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT WILBUR MICHELE L hands, possession, or control of the within named Garnishee ORRSTOWN BANK 22 S. HANOVER ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to CARRIE MCGEE (TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscribed to before me this , in the true and made So answers- .00 .00 " ?,455!? .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 .00 ?//jbZlb-? 10/05/2006 day of By Deputy Sher 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: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL Advance Costs: 1.50.00 Sheriffs Costs 234.46 18.00 15.54 4.60 25.50 Refunded to Atty on 10/24/07 19.36 80.00 60.00 27.00 234.46 Ih Il"f&t So Answers, R. 7 a/' By. s U t BARRY LONG : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. : NO. 06-5393 CIVIL LISA A. LONG DEFENDANT : IN DIVORCE ANSWER TO PETITION TO ENFORCE MARITAL SETTLEMENT AGREEMENT COMES, NOW, Lisa A. Long, by and through her counsel, Sally J. Winder, Esquire, and does by way of Answer represent as follows: 1. Admitted. ._ G, 2. Admitted. s- rrr r?Fn •_T l C3 3. Admitted.` N c. 4. Admitted. i 5. Denied as stated. On the contrary, Defendant requested the bill and any collect?n no*ces in connection with the $919.00 medical bill at the time of agreeing to the Settlement. To date, Plaintiff has failed to provide the information necessary to make payment of this account. Plaintiff has failed to provide an address or phone number to Defendant and Defendant is unfamiliar with the Hamilton Law Group, and has no knowledge of the address, phone number, claim number or any other information necessary to make payment of the account despite requests for Plaintiff to provide this information. 6. Denied. Defendant has not incurred any debts for which Plaintiff may be held liable after the date of the Marital Agreement dated March 10, 2008. Defendant has no knowledge of any medical debts incurred by her in March 2009, notice for which would have been received by Plaintiff. No copies of such notice are attached to the Petition and Defendant has no ability to investigate the truth of the allegation, therefore strict proof of the averment at hearing of this matter is demanded. 7. Admitted. 8. Denied. On the contrary, Defendant did not remove wicker chairs, an AB lounger, a metal table, two black chairs or slide projector pictures from Husband's property. Further denied that such items were, or are, worth $500.00. By way of further response, Defendant was questioned about the whereabouts of these items by Pennsylvania State Police and told them she did not take the items, had no knowledge of their whereabouts, and that when she went with her son to the property approximately May 30, 2008, the garage doors were open and the front door was open and not locked leading her to believe that anyone could have taken items from the house without Plaintiff's knowledge as he was not living at the house at that time. 9. Admitted. 10. Denied as stated. Defendant will pay and settle the claim for the $919.00 medical debt when provided the information to do so by Plaintiff. Plaintiffs failure to provide the necessary documents has caused him to receive any notices he may have gotten. Defendant believes and therefore, avers that Plaintiff's credit rating is determined by many more factors than this particular debt. Plaintiff has the right and duty to protest or dispute the debts and obligations listed on his credit rating report and Defendant has no right to attempt to influence credit reporting agencies concerning Plaintiff. 11. Denied. On the contrary, Defendant has none of Plaintiff's personal property and owes Plaintiff no sums of money. 12. Denied. Plaintiff's bad faith in failing to provide the notice or bill in order for Defendant to fulfill the terms of the agreement vis-a-vis the $919.00 medical debt prevents him from having any right to an award of attorney fees as claimed. Further, Plaintiff's claim for personal property is unfounded and without merit and Plaintiff has failed to plead a specific amount of attorney fees or legal services which would support an award of fees under the terms of the Marital Agreement. An award of attorney fees in this matter would be unfounded as Defendant has not by her actions caused Plaintiff to incur any expense. WHEREFORE, this Honorable Court should enter an order in favor of Defendant and against Plaintiff for failing to show proof of any of his claims and finding that the filing of this Petition is spurious and lacking in any factual basis. Date: Respectfully submitted, j Sally J. Iffinder, Esquire ID 27405 P.O. Box 341 Newville, PA 17241 Attorney for Defendant VERIFICATION Lisa A. Long, states that she is the Defendant in this action and the foregoing Answer is true and correct as to her own knowledge, except as to matters therein stated to be alleged on information and belief, and as to those matters she believes it to be true. This statement is made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsifications to authorities, which provides that if I make knowingly false statements I may be subject to criminal penalties. Date: L4 10 - 6? /S:? Lisa A. Long