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HomeMy WebLinkAbout06-5799Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070 (717)938-6929 PAUL RUTH and IN THE COURT OF COMMON PLEAS LILLIAN RUTH CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. NO.: 1. (C' L MICHAEL MILLIKAN ` DEFENDANT CIVIL ACTION -LAW NOTICE TO DEFEND AND CLAIM RIGHTS THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE ATTEMPTIING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 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 claims 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR (800) 990-9108 PAUL RUTH and IN THE COURT OF COMMON PLEAS LILLIAN RUTH CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. : NO.: MICHAEL MILLIKAN DEFENDANT : CIVIL ACTION -LAW NOTICIA Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objectiones a las demandas en contra suya. Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 or 1-800-990-9108 Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 PAUL RUTH and LILLIAN RUTH PLAINTIFF Vs. MICHAEL MILLIKAN DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: (Xp-9"y44 tv CIVIL ACTION-LAW COMPLAINT AND NOW, comes Paul Ruth and Lillian Ruth, the Plaintiffs in the above captioned matter, by and through their attorney Karl M. Ledebohm, Esquire, and makes the following complaint: 1. Plaintiff, Paul Ruth and Lillian Ruth ("Plaintiffs"), are adult individuals having an address of 1113 Charles Street, Mechanicsburg, PA 17055. 2. Michael Millikan ("Defendant"), is an adult individual having a last known address of 56 Hellam Drive, Mechanicsburg, PA 17055 1 3. On or about the dates set forth below, Plaintiffs made the following advances totaling $22,703.38 to Defendant or payments on Defendant's behalf and at the request of Defendant, which amounts Defendant agreed to repay to Plaintiff by way of periodic payments: a. Advance to Defendant: March 24, 1991 $900.00 b. Advance to Defendant: August 14, 1991 1,295.00 c. Payment to Van & Storage August 14, 1991 2,205.00 d. Payment to Van & Storage August 15, 1991 1,959.00 e. Advance to Defendant: December 21, 1991 500.00 f. Advance to Defendant: June 17, 1993 1,000.00 g. Advance to Defendant: August 18, 1993 2,500.00 h. Payment to Union Trust: May 9, 1994 4,068.48 i. Advance to Defendant: May 9, 1994 500.00 j. Payment to Cumberland Tax Claim Bureau: July 3, 1995 1,775.00 k. Payment to 1St FID Jay Flavin October 3, 1995 1,022.00 1. Advance to Defendant: November 6, 1995 3,000.00 m. Advance to Defendant: September 30, 1996 146.93 n. Advance to Defendant: March 31, 1997 331.97 o. Advance to Defendant: June 14, 1997 500.00 p. Advance to Defendant: July 13, 1997 1,000.00 q. Total Advances and payments $22,703.38 2 4. On or about April 2000, Defendant again verbally agreed to repay the balance of the indebtedness due to Plaintiffs as set forth above (the "Loan") by way of regular, periodic payments. 5. On or about November 17, 2005, Defendant acknowledged his obligation to repay the amounts due to Plaintiffs as set forth above in the written divorce settlement agreement between Defendant and his wife, Barbara Millikan. A copy of the relevant provisions of the said divorce settlement agreement are attached hereto as exhibit "A" and made part hereof by reference. 6. Since on or about September 2004, Plaintiff did not receive any payments from Defendant on account of the above indebtedness and Defendant is in default of Defendant's obligations under the Agreement as a result of Defendant's failure to make the payments due to Plaintiffs as agreed. 7. By letters dated December 16, 2005 and March 13, 2006, (collectively referred to herein as the "Demand") addressed to Defendant, Plaintiff accelerated all amounts due and demanded the payment of all amounts due under the Loan. A copy of the Demand is attached hereto collectively as Exhibit "B" and made part hereof. 8. Since the date of the Demand, Defendant delivered two payments in the aggregate amount of $804.24 which Plaintiff accepted as a partial payment upon the express understanding that such acceptance would not waive any demand for payment in full of all the amounts due and owing by Defendant to Plaintiff. 3 9. As of the date of this complaint, Defendant is indebted to Plaintiffs under the Agreement in the amount of $8,754.90. 10. As set forth above, Plaintiffs have made demand upon Defendant to make payment of all amounts due to Plaintiffs under the Agreement and, as of the date hereof, Defendant has failed and refused to make payment of all such amounts due to Plaintiff. WHEREFORE, Plaintiffs, Paul Ruth and Lillian Ruth, demand judgment against Defendant, Michael Millikan, in the amount of EIGHT THOUSAND SEVEN HUNDRED FIFTY-FOUR AND 90/100 DOLLARS ($8,754.90) together with interest at the legal rate from the date of judgment on this complaint and costs of suit. Respectfully submitted, 4 Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff THIS ADDENDUM to the parties' May, 199 Property Settlement Agreement, is entered into and becomes effective this L%ay of VV 2005, by and between MICHAEL P. MILLIKAN, of Cumberland County, Pennsylvania, and BARBARA R. MILLIKAN, of Cumberland County, Pennsylvania; WITNESSETH: WHEREAS, Michael P. Millikan (hereinafter referred to as "Husband") and Barbara R. Milliken (hereinafter referred to as "Wife"), married July 31, 1981, entered into a Property Settlement Agreement in May of 1998 (hereinafter referred to as "Agreement" at a time when the parties were not contemplating separation or divorce; WHEREAS, said Agreement fully and finally resolves the parties' respective financial and property rights and obligations as between each other, including, without limitation the settling of all matters between them relating to the ownership of real and personal property, the support and maintenance of one another and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates, irrespective of the parties' continued cohabitation and marriage; WHEREAS, the parties are the biological parents of one minor child, Kate W. Miilik born July 15, 1988; an, medical expenses. Husband's and Wife's intent is to limit Husband's obligation to approximately Four Hundred Dollars ($400.00) per month in reimbursements starting November 1, 2005. The parties expressly agree to a "carryover" concept such that, in any months that Wife incurs less than Four Hundred Dollars ($400.00) per month in unreimbursed medical expenses, any shortfalls can be carried over to other months where Wife incurs in excess of Four Hundred Dollars ($400.00) per month in unreimbursed medical expenses. Husband's total obligation for any calendar year shall not exceed Four Thousand Eight Hundred Dollars (S4,800.00) in reimbursements. Wife shall send to Husband each month, via certified mail or by regular, original documentation evidencing the expenses she incurred for which she seeks reimbursement. Husband shall provide reimbursements to Wife within seven (7) business days of receipt of the letter unless an objection is made to the expenses in writing by Husband's counsel to Wife's counsel within seven (7) business days of Husband's receipt of the mail. If the parties cannot resolve any disagreements as to reimbursements amicably, the parties agree that the matter shall be submitted to the court for adjudication. 5. Paragraph 8 of the parties' Agreement is modified to provide that Husband shall be solely responsible for all joint debts due and owing as of the date of execution of this .Agreement including the debt owed to Wife's parents. Wife shall be solely responsible for all debts arising out of her over drafting the parties' bank account as well as any and all debts she : Ti, urs on or after the date of this Agreement. Husband agrees to indemnify and hold Wife ':armless from any and all liability, cost or expense, including actual attorneys fees, incurred as a It of the obligations he is assuming under this paragraph. Likewise, Wife agrees to ::idemnify and hold Husband harmless from any and all liability, cost or expense, including .:ial attorneys' fees incurred as a result of the obligations Wife is assuming under this ::ra-graph. IN WITNESS WHEREOF, the parties hereto set their hands and seals on the dates of their acknowledgments, 1 HESS '.I \ESS MICHAEL P. MILLIKAN BARBARA R. MILLIKAN II KARL M. LEDEBOHM ATTORNEY-AT LAW P.O. BOX 173 New Cumberland, PA 17070-0173 Phone: 717-938-6929 Fax: 717-932-0317 December 16, 2005 (Via Certified and regular mail) Michael Millikan 56 Hellam Drive Mechanicsburg, PA 17055 Dear Mr. Millikan: THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE FROM THIS OFFICE IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. AN IMPORTANT STATEMENT OF RIGHTS IS INCLUDED ON THE REVERSE OF THE SECOND PAGE OF THIS LETTER. Paul and Lillian Ruth have retained my office to collect the amounts due to them in connection with amounts which they lent to you and your wife. Specifically, on or about April, 2000, you agreed to repay to Mr. and Mrs. Ruth $10,949.34 by way of regular monthly payments in the amount of $150.00 each (the "Agreement"). As you know, you are in default of your obligations under the above Agreement due to your failure to make the payments required, the last payment having been received by Mr. and Mrs. Ruth on or about September 2004. As a result of your default, Mr. and Mrs. Ruth hereby accelerate all remaining amounts due to them under the Agreement and demand the payment of the balance due in the amount of $8,692.34. If you fail to deliver payment of the $8,692.34 to Mr. and Mrs. Ruth within thirty (30) days of the date of this letter, Mr. and Mrs. Ruth will have no choice but to file a legal action against you to collect all of the amounts due under the Agreement without further notice. In such event, in addition to the above amounts, you may also be responsible for the payment of Mr. and Mrs. Ruth's costs of suit. Nothing herein shall constitute or be construed as an agreement on behalf of Mr. and Mrs. Ruth to accept any terms and conditions in exchange for payment of the amounts due under the Agreement except for the immediate payment of all amounts due to Mr. and Mrs. Ruth. Nothing herein shall constitute a waiver of any rights or remedies which Mr. and Mrs. Ruth may have under any written agreement or at law or in equity to collect the balance of the indebtedness due under the Agreement without further notice, including, without limitation, the right to accept and apply any partial payments made on the Agreement without waiver of any demand for payment in full of all amounts due under the Agreement. Mr. and Mrs. Ruth look forward to the payment of the $8,692.34 on or before January 16, 2006. Very truVyours, 'X-arl M.Ted6bohd v CC: Paul Ruth NOTICE This letter is an attempt to collect a debt. It you dispute the validity of this debt, or any portion thereof, and you contact the undersigned within thirty (30) days after receipt of this Notice, you will be furnished with written verification of the debt; provided, that if a lawsuit has been filed against you to collect this debt before the expiration of the thirty (30) days, the complaint filed in said lawsuit will constitute written verification of the debt. If you do not dispute the debt or any portion thereof as stated above, the undersigned will assume the debt is valid. If the original creditor of this debt is different from the creditor stated on the front page of this letter, the undersigned will provide you with the name and address of the original creditor upon written request from you within thirty (30) days of receipt of this notice. The undersigned means the name signed at the end of this letter appearing in print at the top of this letter. ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Signature X /' f J J ? Agent ? Addressee B. Received by (Printed Name) I C. Date of Delivery D. Is delivery address different from item 17 ? Yes If YES, enter delivery address below; 0 NO' .... L-A pe Mail red ptfor Marchandlse Mail ? C.O.D Delivery? (Extra Fee) ? Yes 2. Article Number - from service -fabeq 7004 2890 0 002 84722401 PS Form 3811, February 2004 Domestic Retum Receipt _ 102595-02-M-1540 r-l C3 A ru • ru w ~ ru Postage $ ' a Certified Fee C3 ?, 471 p Return Receipt Fee (Endorsement R equired) Restricted Delivery Fee 0^ (indorsement R ¢ j . fri C3 ^ .' tm riff equired) CO N •!7, lllj A ? 4 'rota[ Postage $ Fees „? (( Ij J ab ?? ent o M1 st ° . v 12,11 ?. reet, A,t"No: or PO Box No. ------------- ------ KARL M. LEDEBOHM ATTORNEY-AT LAW P.O. BOX 173 New Cumberland, PA 17070-0173 Phone: 717-938-6929 Fax: 717-932-0317 March 13, 2006 (Via Certified and regular mail) Michael Millikan 56 Hellam Drive Mechanicsburg, PA 17055 Dear Mr. Millikan: THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE FROM THIS OFFICE IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. As you are aware, Paul and Lillian Ruth have retained my office to collect the amounts due to them in connection with amounts which they lent to you and your wife. Upon further investigation and discussions with Mr. and Mrs. Ruth, I have determined that the amount due to Mr. and Mrs. Ruth as set forth in the initial demand letter sent to you dated December 16, 2005 was in error. Specifically, Mr. and Mrs. Ruth advanced to you and your wife during the period of approximately March 24, 1991 through July 31, 1997 approximately $22,703.38, which amounts you and your wife agreed to repay (the "Agreement"). As set forth in my previous letter to you dated December 16, 2005, you are in default of your obligations under the Agreement due to your failure to make payment of the amounts due to Mr. and Mrs. Ruth, the last payment having been received by Mr. and Mrs. Ruth on or about September 2004. As a result of your default, by my letter dated December 16, 2005, Mr. and Mrs. Ruth have accelerated all remaining amounts due to them under the Agreement and demanded the payment of all amounts due. Upon closer examination of the amounts advanced to you and your wife and the payment history the amount which you actually owe to Mr. and Mrs. Ruth as of the date of this letter is in the amount of $9,559.14. 1. Total of advances through July 31, 1997 $22,703.38 2. Total payments received by Ruth's $13,144.24 3. Balance due as of the date hereof $9,559.14 If you fail to deliver payment of the $9,559.14 to Mr. and Mrs. Ruth within ten (10) days of the date of this letter, Mr. and Mrs. Ruth will have no choice but to file a legal action against you to collect all of the amounts due under the Agreement without further notice. In such event, in addition to the above amounts, you may also be responsible for the payment of Mr. and Mrs. Ruth's costs of suit. Nothing herein shall constitute or be construed as an agreement on behalf of Mr. and Mrs. Ruth to accept any terms and conditions in exchange for payment of the amounts due under the Agreement except for the immediate payment of all amounts due to Mr. and Mrs. Ruth. Nothing herein shall constitute a waiver of any rights or remedies which Mr. and Mrs. Ruth may have under any written agreement or at law or in equity to collect the balance of the indebtedness due under the Agreement without further notice, including, without limitation, the right to accept and apply any partial payments made on the Agreement without waiver of any demand for payment in full of all amounts due under the Agreement. Mr. and Mrs. Ruth look forward to the payment of the $9,559.14 on or before ten (10) days from the date of this letter. Very truly yours, P Karl M. Ledebohm 4(c CC: Paul Ruth ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the cans to you. ¦ Attach this card to the back of the mailplece, of on the front If space permits. 1. Article Addressed to: l? lri f;V!? /i e J? j 'J 'j A. Signature 9 ? Agent X!/7j'// OFIA Addressee B. Received by (Printed Name) C. Date of Delivery D. Is delivery address different from item:J O Yes If YES, enter delivery address below: A No 3. Service Type Certified Mail ? Express Mail ? Registered IV Return Receipt for Merchandise ? Insured Mail ? C O D 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number - --- - ----- --- -- -- (rmnsler from service,aW 7004 2890 0002 8 4 7 3 3 315 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 VERIFICATION I/we, Paul Ruth and Lillian Ruth, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my/our information knowledge and belief. I/we understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. t Paul Ruth (Plaintiff) 1 a cn y ca TI Y? l rn _i SHERIFF'S RETURN - REGULAR CASE NO: 2006-05799 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RUTH PAUL ET AL VS MILLIKAN MICHAEL JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon the DEFENDANT , at 1920:00 HOURS, on the 24th day of October , 2006 at 56 HELLAM DRIVE MECHANICSBURG, PA 17055 by handing to MICHAEL MILLIKAN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.80 Postage .39 So Answers: Surcharge 10.00 R. Thomas Kline .00 37.19,/ 10/25/2006 =1 KARL LEDEBOHM Sworn and Subscibed to By: before me this day Deputy Sheriff of A. D. Karl M. Ledebobxn, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 PAUL RUTH and IN THE COURT OF COMMON PLEA LILLIAN RUTH CUMBERLAND COUNTY, PLAINTIFFS PENNSYLVANIA, Vs. NO.: 06-5799 Civil Term MICHAEL MILLU<AN DEPENDANT : CIVIL ACTION-LAW PRAECIPE TO THE PROTHONOTARY: Please enter judgment in the above captioned proceeding in favor of Paul Ruth and Lillian Ruth, Plaintiffs; and against the Defendant, Michael Millikan, in the amount of Eight Thousand Seven Hundred Fifty-four and 901100 Dollars ($8,75490), together with, interest at the legal :rate from the date of judgment on the complaint and costs of suit. Judgment is entered pursuant to Pa. R.C.P. 3031 for failure to file an Answer on behalf of Michael Millikan to :Plaintiffs' Complaint within twenty (20) days of service thereof and after a I0-day Notice was sent, 'K7 oox?Ar/4?'iill?r c1,m?t+or1 Date: November 29, 2006 ?- ,?{.arl M. Ledebohm, Esquire %Supreme Court ID #59012 P.O. Box 173 New Cumberland, P.A, 17070-0173 (717)935-6929 Attorney for Plaintiffs I hereby c:crtify that notice of intent to take a default judgment was forwarded to Michael Millikan by United States Mail, first class, postage prepaid on November 16, 2006. The aforesaid notice was contained within an envelope beai~ na the return address of the undersigned. The notice has not been returned to the undersigned as undeliverable or otherwise. A copy of the notice and Postal Form 3817 is attached hereto and marred Exhibit "A,". M. Ledebohm, Esquire PAUL RUTH and 1N THE COURT Or COMMON PLEAS LILLIAN RUTH CUMBERLAND COUNTY, PLAINTIFFS PENNSYLVANIA Vs. : NO.: Q6-5799 Civil Term MICHAEL MILLIIS.AN DEFENDANT : CIVIL ACTION-LAW II1? AT-ANT NOTICE TO Michael Miilikan 56 Hellam Drive Mechanicsburg, PA 17055 PURSUANT TO THE PAIR DEBT COLLECTION PRACTICES ACT, I Am REQUIRED 10 INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE OWCOMN"ICATION IS AN ATTEMPT TO COLLECT A, DEBT AND ANY INFORMATION OBTAINED WILL BE USFA POR THAT PURPOSE. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN 00) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE PROPERTY OR OTHER IMPORTANT KICHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVF A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT W) TMRE YOU CAN C3ET LFGAL HELP. Cumberland County Bar .Association 2 Liberty Aveniuc Carlisle, PA 17013 (717) 249-3166 or(800)990-9108 Datc: November 15 -)nO4 Respectful) submitted, ,? ; i •.? ttv <>Tt--c rrr ,.?--mot ,.arl 1A. Ladebohni, Esq. Supreme Court ID 059012 P.O. Box 173 New Cumberland; PA 17070-0173 (717) 938-6929 Attorney for Plaintiffs vs. W01, 1A1- SERVICE CERTIFICATE OF MAILING MAY EE USED FOR DDM6S'nG AND INTERNATIONAL M1AgIL. DOES NOT 777777777 I'S0,0C 0C'0. ikaawNCe-pO$T,•AbTert lM1 ,;,•- a? f? s?, _ Karl M. Ledebohm, ESq. P.O. Box 173 New Cumberland, PA. 1 7070-0 1 7 K"° ? O'e wece a. an airy Moo .aa..aa.. ta. A"I i * -, t-1!?u/ 1 4/1 I7jl g`.L. JZ C2 .I?t uqi? 04 /T-AJ?v pS Fo- 3817. Jerwcry 2001 r L0P V ,.g ?Tj '?lyk SY EXHIBIT "A" -4s g ?z PAUL RUTH and lei THE COURT OF COMMON PLEAS LILLIAN RUTH CUMBERLAND COUNTY, PLAINTIFFS PENNSYLVANIA Vs. NO.: 06-5799 Civil Term < 6 .,,., , -, :VllVll('1LL _V11LLlll.-11V - ry T1L'L'L'T TTI A TTT CTN rl T A nTTfITT T A [T T f ?C j' l I . ? NOTICE OF JUDGMENT PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE TO: Michael Millikan 56 Hellam Drive Mechanicsburg, PA 17055 You are hereby notified that on 2006 the following judgment has been entered against you in the above captioned case: Judgment in the above captioned proceeding in favor of Paul Ruth and Lillian Ruth, Plaintiffs, and against the Defendant, Michael Millikan, in the amount of Eight Thousand Seven Hundred Fifty-four and 90/100 Dollars ($8,754.90), together with interest at the legal rate from the date of judgment on the complaint and costs of suit. Judgment is entered pursuant to Pa. R.C.Y. 3031 for failure to we art :Lnswer on oetiair oC Mzahael Mil.likan to l?iaintitts" C ,mmnlsint within twenty (20) days of service thereof and after a 10-day Notioe was sent. Dated: / s? 1 16 (a I'x onotary 4 r are: I hereby certify that the proper persons to receive this notice under Pa.1Z.C.P. 236 Michael Millikan 56 Hellam Drive Mechanicsburg,, PA 17055 A: Michael Millikan For este medio se le esta notificando clue el de 2006, el/la siguiente (Orden), (Decreto), (Fallo), ha silo anotado en contra suya en el caso mencionado en el eoxgrafe. Fccha: Protonotario Certifico que la siguiente direccion as la del def'endido/a segun indicada en el certifiicado d-: ; csiu.kalwa: Michael Millikan 56 Hellann Drive Mechanicsburg, PA. 17055 R etnectfi i l l v.. finhm i ttari M Date: November 29, 2006 l M. Lede ohm, Esc'ui uureme Court ID ##59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938,6929 Attorney for Plaintiffs W Karl M. Ledebob n, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 PAUL RUTH and : IN THE COURT OF COMMON PLEAS LILLIAN RUTH : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiffs Vs. NO.: 06-5799 Civil Term MICHAEL MILLIKAN Defendant : CIVIL ACTION-LAW AKS'wCrs -{> INTERROGATORIES TO GARNISHEE TO: MEMBERS 1sT FEDERAL CREDIT UNION, AS GARNISHEE You are required to file answers to the following interrogatories within twenty (20) days after service upon you. The answers must be in writing and under oath. You are warned that if you fail to do so, a Judgment may be entered against you by the Court without further notice for any money claimed by the Plaintiff against the Defendant. 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 CAN NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 04 Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 PAUL RUTH and : IN THE COURT OF COMMON PLEAS LILLIAN RUTH : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiffs Vs. NO.: 06-5799 Civil Term MICHAEL MILLIKAN Defendant : CIVIL ACTION-LAW INTERROGATORIES To: MEMBERS 1 ST FEDERAL CREDIT UNION, as Garnishee You are required to file answers to the following interrogatories within twenty (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 Defendant any money or were you liable to them or any of them on any negotiable or other written instrument, or did they or any of them claim that you owed them or any of them any money or were liable to them or any of them for any reason? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer property. 0-0 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. N 0 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. K U 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. N D 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 if so what was the consideration therefore? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. N 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 direction of them or any of them or otherwise discharge any claim of the Defendant against you? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. N 0 7. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, certificates, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of ` N\ A X VAA property. " , ` ??N\Wo^ ?th hove s?rv? c?ddv?ss 5lv H6kwv\be. W\RoA . QN I Kc-6 , a5G?aq - sm-AN aN, -A 5CA,3 3 C ?lcrinf? ? ? J? These Interrogatories shall be deemed to be continuing Interrogatories. If after the time of your answer, you or anyone acting in your behalf learn or obtain additional information requested, but not supplied in your answers, you shall promptly furnish supplemental answer under oath containing same. submitted, Date: 1:0-0 For signature by Garnishee: fu arl M Ldebohm, sq. preme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff states subject to the penalties of 18 Pa. C.S. t eft VV94 r g to unsworn falsification to authorities, that he/she is authorized by Garnishee M We this affidavit, and that the facts set forth herein are true and correct to the best of his/her knowledge, information and belief. l Date: fob r1 ? c '?l Fr. - _?i e Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 935-6929 PAUL RUTH and : IN THE COURT OF COMMON PLEAS LILLIAN RUTH CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs Vs. ; NO.: 06-5799 Civil Term MICHAEL MILLIKAN Defendant : CIVIL ACTION-LAW 45werg -A INTERROGATORIES TO GARNISHEE TO: MEMBERS 1ST FEDERAL CREDIT UNION, AS GARNISHEE You are required to file answers to the following interrogatories within twenty (20) days after service upon you. The answers must be in writing and under oath. You are warned that if you fail to do so, a Judgment may be entered against you by the Court without further notice for any money claimed by the Plaintiff against the Defendant. 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 CAN NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 PAUL RUTH and IN THE COURT OF COMMON PLEAS LILLIAN RUTH CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs Vs. NO.: 06-5799 Civil Term MICHAEL MILLIKAN Defendant CIVIL ACTION-LAW INTERROGATORIES To: MEMBERS I ST FEDERAL CREDIT UNION, as Garnishee You are required to file answers to the following interrogatories within twenty (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 Defendant any money or were you liable to them or any of them on any negotiable or other written instrument, or did they or any of them claim that you owed them or any of them any money or were liable to them or any of them for any reason? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer property. • 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. N10 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. N z 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. 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 if so what was the consideration therefore? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. 0 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 direction of them or any of them or otherwise discharge any claim of the Defendant against you? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. 7. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, certificates, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? If so, explain in detail including, without limitation, the names and addresses of all persons or entities taking part in any transaction, the specific amount of the debt, the value and location of any property and the amount of consideration given for any transfer of property. a. Y k v kMf, W% Kay, ?R - CU I1'Viil k(ntr 0 16o+h )IMe- stkwu aMasS - SU Hellaro bf. MIchanic,bo.vn, g?? 17055 kck' 9591 a9 -SAwn 3 C*?u(u 39 These Interrogatories shall be deemed to be continuing Interrogatories. If after the time of your answer, you or anyone acting in your behalf learn or obtain additional information requested, but not supplied in your answers, you shall promptly furnish supplemental answer under oath containing same. Respectfu!ky submitted, Date: 3 arl A Ledebohm, Esq. Supreme Court ID # : 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff For signature by Garnishee: states subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is authorized by Garnishee to make this affidavit, and that the facts set forth herein are true and correct to the best of his/her knowledge, information and belief. Date t°> r-`_ ? -'_ ` t'i`t -n ?.'? ?? - -? i -i .. -._?- ? ? . . __ _ -atl ^' ?? ? ?? `' - _ ,??? Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. SECTION 101 TO SECTION 149 ETC. PAUL RUTH and LILLIAN RUTH Plaintiffs vs. MICHAEL MILLIKAN Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA 06-5799 Civil Term Amount Due: $8,754.90 Interest from: 12/1/06 at legal rate Atty's Com. N/A COSTS TO BE ADDED TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Michael Millikan, 56 Hellam Drive, Mechanicsburg, PA 17055, Defendant; and (3) against Members 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA 17055, Garnishee; (4) and index this writ (a) against Michael Millikan, 56 Hellam Drive, Mechanicsburg, PA 17055, Defendant; and (b) against Members 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA 17055, Garnishee; and levy upon any and all personal property of the defendant (s) as follows: a , ?.l Any and all personal property of Defendant in the possession of Members 1 s' Federal Credit Union located at 5000 Louise Drive, Mechanicsburg, PA 17055, as Garnishee, including, without limitation, any and all funds on deposit. (c) Exemption has (not) been waived. Dated: Marl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff -b. w qz? V 07 IA '} { i w WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5799 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PAUL RUTH AND LILLIAN RUTH, Plaintiff (s) From MICHAEL MILLIKAN, 56 HELLAM DRIVE, MECHANICSBURG, PA 17055 (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 ANY AND ALL PERSONAL PROPERTY OF DEFENDANT IN THE POSSESSION OF MEMBERS 1sT FEDERAL CREDIT UNION LOCATED AT 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055, AS GARNISHEE, INCLUDING, WITHOUT LIMITATION, ANY AND ALL FUNDS ON DEPOSIT. 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 $8,754.90 Interest FROM 12/1/06 AT LEGAL RATE Atty's Comm % Atty Paid $119.19 Plaintiff Paid Date: JANUARY 30, 2007 (Seal) REQUESTING PARTY: L.L. $.50 Due Prothy $1.00 Other Costs $.50 DUE GARNISHEE 1- GUFUIy Name KARL M. LEDEBOHM, ESQUIRE Address: P.O.BOX 173 NEW CUMBERLAND, PA 17070-0173 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 PAUL RUTH and LILLIAN RUTH PLAINTIFF Vs. MICHAEL MILLIKAN DEFENDANT. MEMBERS 1sT FEDERAL CREDIT UNION GARNISHEE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2006-5799 Civil Term CIVIL ACTION-LAW PRAECIPE Please enter judgment in the above captioned proceeding in favor of Paul Ruth and Lillian Ruth, Plaintiffs, and against Members 1" Federal Credit Union, Garnishee, in the amount of FOUR THOUSAND FOUR HUNDRED AND 21/100 ($4,400.21) DOLLARS, being the property of Michael Millikan, the defendant in the above -- captioned matter (the "Defendant"), admitted to be in the possession of Members Is' Federal Credit Union, Garnishee, as set forth in the answer (The "Answer") to interrogatories filed by Members 1st Federal Credit Union in the above captioned matter. Judgment is entered pursuant to Pa. R.C.P. 3146(b) for property of the Defendant admitted to be in the possession of Members 1st Federal Credit Union as set forth in the Answer. Date: February 26, 2007 Ledebohm, Esquire Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiffs ` p ff?: t r ( r 4 r - .a- .Y, Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 PAUL RUTH and LILLIAN RUTH PLAINTIFF Vs. MICHAEL MILLIKAN DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2006-5799 Civil Term : CIVIL ACTION-LAW NOTICE OF JUDGMENT TO: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, I AM REQUIRED TO INFORM YOU THAT THIS DOCUMENT AND ANY SUBSEQUENT CORRESPONDENCE OR COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE Members 1st Federal Credit Union 5000 Louise Drive P.O. Box 40 Mechanicsburg, PA 17055 Michael Millikan 56 Hellam Drive Mechanicsburg, PA 17055 You are hereby notified that on Fe.'bruarv a 7 , 2007 the following judgment has been entered against you in the above captioned case: Judgment in favor of Paul Ruth and Lillian Ruth, Plaintiffs, and against Members 1st Federal Credit Union, Garnishee, in the amount of FOUR THOUSAND FOUR HUNDRED AND 21/100 ($4,400.21) DOLLARS, being the property of Michael Millikan, the defendant in the above captioned matter (the "Defendant"), admitted to be in the possession of Members 1st Federal Credit Union, Garnishee, as set forth in the answer (the "Answer") to interrogatories filed by Members 1st Federal Credit Union in the above captioned matter. Judgment is entered pursuant to Pa. R.C.P. 3146(b) for property of the Defendant admitted to be in the possession of Members 1st Federal Credit Union as set forth in the Answer. Dated: S C., 0?6 P thonotary I hereby certify that the proper persons to receive this notice under Pa. R.C.P. 236 are: Members 1st Federal Credit Union 5000 Louise Drive P.O. Box 40 Mechanicsburg, PA 17055 Michael Millikan 56 Hellam Drive Mechanicsburg, PA 17055 A: Kenneth L. Doll, Ann Marie Doll, Richard Koch, Esquire: Por este medio se le esta notificando que el de 2007, el/la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso mencionado en el epigrafe. Fecha: Protonotario Certifico que la siguiente direccion as la del defendido/a segun indicada en el certificado de residencia: Members 1st Federal Credit Union 5000 Louise Drive P.O. Box 40 Mechanicsburg, PA 17055 Michael Millikan 56 Hellam Drive Mechanicsburg, PA 17055 submitted, Dated: February 26, 2007 Farl M. tedebolim, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiffs C'a na i - r7 w rr y? O ? R> > _i r j yR W? SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-05799 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND RUTH PAUL ET AL VS MILLIKAN MICHAEL And now SHANNON SHERTZER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0008:50 Hours, on the 1st day of February , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT MILLIKAN MICHAEL hands, possession, or control of the within named Garnishee MEMBERS FIRST FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to . in the GRECHAN WOODWARD (SECURITY SPECIALIST) 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: Docketing Service Affidavit Surcharge Sworn and Subscribed to So ans er . .00 .00 ' .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 00 02/02/2007 before me this day of 11 By ; ,, Deputy She cif f 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 18.00 1.75 .50 1.00 8.80 30.00 20.00 9.00 89.05 ? gl?d?o'1 Advance Costs: 150.00 Sheriff s Costs 89.05 60.95 Refunded to Atty on 09/12/07 So Answers, R. Thomas Kline, Sheriff By CIQ 8 Z :ZI d 0 E NVP loot 10§4104?- JJW3NS sNl0JIdjS &N5° d c, J ?o -?.k Iaa°t' R.I MOO WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5799 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PAUL RUTH AND LILLIAN RUTH, Plaintiff (s) From MICHAEL MILLIKAN, 56 HELLAM DRIVE, MECHANICSBURG, PA 17055 (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 ANY AND ALL PERSONAL PROPERTY OF DEFENDANT IN THE POSSESSION OF MEMBERS 1sT FEDERAL CREDIT UNION LOCATED AT 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055, AS GARNISHEE, INCLUDING, WITHOUT LIMITATION, ANY AND ALL FUNDS ON DEPOSIT. 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 $8,754.90 Interest FROM 12/1/04 AT LEGAL RATE Atty's Comm % Atty Paid $119.19 Plaintiff Paid Date: JANUARY 30, 2007 L.L. $.50 Due Prothy $1.00 Other Costs $.50 DUE GARNISHEE (Seal). Deputy REQUESTING PARTY: Name KARL M. LEDEBOHM, ESQUIRE Address: P.O.BOX 173 NEW CUMBERLAND, PA 17070-0173 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 if •.. Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. SECTION 101 TO SECTION 149 ETC. PAUL RUTH and LILLIAN RUTH Plaintiffs VS. MICHAEL MILLIKAN Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA 06-5799 Civil Term Amount Due: $4,825.33 Interest from: 3/7/2007 at $0.79 per day Atty's Com. N/A COSTS TO BE ADDED TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Michael Millikan, 56 Hellam Drive, Mechanicsburg, PA 17055, Defendant; and (3) against Members lst Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA 17055, Garnishee; (4) and index this writ (a) against Michael Millikan, 56 Hellam Drive, Mechanicsburg, PA 17055, Defendant; and (b) against Members 1St Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA 17055, Garnishee; and levy upon any and all personal property of the defendant (s) as follows: 0 A1. Any and all personal property of Defendant in the possession of Members I" Federal Credit Union located at 5000 Louise Drive, Mechanicsburg, PA 17055, as Garnishee, including, without limitation, any and all funds on deposit. (c) Exemption has (not) been waived. Dated: January 3, 2008 Karl M. Ledebohm, Esquire Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff r"' 5 se t O t}? o,s,Q ? C? * h i oo 6 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5799 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PAUL RUTH and LILLIAN RUTH, Plaintiff (s) From MICHAEL MILLIKAN, 56 Hellam Drive, Mechanicsburg, PA 17055 (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 GARNISHEE(S) as follows: MEMBERS 1sT FEDERAL CREDIT UNION, 5000 Louise Drive, Mechanicsburg, PA 17055 Any and all personal property of Defendant in the possession of Members 1" Federal Credit Union located at 5000 Louise Drive, Mechanicsburg, PA 17055, as Garnishee, including, without limitation, any and all funds on deposit. 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 $4,825.33 Interest from 3/07/07 at $0.79 per day Atty's Comm % Atty Paid $150.74 Plaintiff Paid Date: 01/10/08 L.L. Due Prothy $2.00 Other Costs to be Added Cu R. Long, P not ry(Seal) By: Deputy REQUESTING PARTY: Name KARL M. LEDEBOHM, ESQUIRE Address: PO BOX 173 NEW CUMBERLAND, PA 17070-0173 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs: 61.02 Docketing 18.00 88.98 Poundage 1.20 Advertising Law Library Prothonotary 2.00 Refunded to Atty on 01/15/08 Mileage Surcharge 30.00 Levy Certified Mail Post Pone Sale Garnishee 9.00 Postage .82 TOTAL $ 61.02 ? So Answers; R. Thomas Kline,' heriff By Claudia A. Br wb er zz :o? d i i ?nr HU , Alb3Hs 3N1 30 33 330 z U, ?a WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5799 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PAUL RUTH and LILLIAN RUTH, Plaintiff (s) From MICHAEL MILLIKAN, 56 Hellam Drive, Mechanicsburg, PA 17055 (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 GARNISHEE(S) as follows: MEMBERS 1sT FEDERAL CREDIT UNION, 5000 Louise Drive, Mechanicsburg, PA 17055 Any and all personal property of Defendant in the possession of Members 1St Federal Credit Union located at 5000 Louise Drive, Mechanicsburg, PA 17055, as Garnishee, including, without limitation, any and all funds on deposit. 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 $4,825.33 Interest from 3/07/07 at $0.79 per day Atty's Comm % Atty Paid $150.74 Plaintiff Paid Date: 01/10/08 L.L. Due Prothy $2.00 Other Costs to be Added Cu . Long, P on ary(Seal) By: Deputy REQUESTING PARTY: Name KARL M. LEDEBOHM, ESQUIRE Address: PO BOX 173 NEW CUMBERLAND, PA 17070-0173 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAUL RUTH and LILLIAN RUTH, NO. 06-5799 CIVIL TERM Plaintiffs Amount Due: $4,825.33 V. Interest from: 3/7/2007 at $0.79 per day MICHAEL MILLIKAN, Atty's Com N/A Defendant COSTS TO BE ADDED PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS) - PA. R.C.P. 6101 TO 4149, ETC. TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, 1. Directed to the Sheriff of Cumberland County, Pennsylvania; 2. against Michael Millikan, 57 Partridge Circle, Carlisle, PA 17013, Defendant; and 3. against Orrstown Bank, 2250 Spring Road, Carlisle, PA 17013, Garnishee; 4. and index this Writ a. against Michael Millikan, 57 Partridge Circle, Carlisle, PA 17013, Defendant; and b. against Orrstown Bank, 2250 Spring Road, Carlisle, PA 17013, Garnishee; and levy upon any and all personal property of the Defendant as follows: Any and all personal property of Defendant in the possession of Orrstown Bank located at 2250 Spring Road, Carlisle, PA 17013, as Garnishee, including, without limitation, any and all funds on deposit. .A• C. Exemption has not been waived. LAW OFFICE OF CRAIG A. DIEHL Date: leaf By: Craig A. iehl, Esquire Attorney I.D. No. 52801 3464 Trindle Road Camp Hill, PA 17011 Tel: (717)763-7613 Fax: (717)763-8293 Counsel for Plaintiffs 2 F e r D yr f/`y ? r t IN TA ? a o C MD I ^F yl7 ?J' rrTr fT CI M w 'v C c? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N006-5799 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PAUL RUTH AND LILLIAN RUTH Plaintiff (s) From MICHAEL MILLIKAN, 57 PARTRIDGE CIRCLE, CARLISLE, PA 17013 (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 ORRSTOWN BANK, 2250 SPRING ROAD, CARLISLE, PA 17013 GARNISHEE(S) as follows: ANY AND ALL PERSONAL PROPERTY OF DEFENDANT IN THE POSSESSION OF ORRSTOWN BANK LOCATED AT 2250 SPRING ROAD, CARLISLE, PA 17013, AS GARNISHEE, INCLUDING, WITHOUT LIMITATION, ANY AND ALL FUNDS ON DEPOSIT. 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 duetedbo notify him/her that he/she has been added as a of anyone other than a named garnishee, you are garnishee and is enjoined as above stated. Amount Due$4825.33 Interest FROM 3/7/2007 AT $0.79 PER DAY Atty's Comm % Atty Paid $324.76 Plaintiff Paid Date: APRIL 09,2008 (Seal) L.L. Due Prothy $2.00 Other Costs C AR. ng, Pro By: Deputy REQUESTING PARTY: Name CRAIG A. DIEHL, ESQUIRE Address: 3464 TRINDLE ROAD, CAMP HILL, PA 17011 Attorney for: PLAINTIFFS Telephone: 717-763-7613 Supreme Court ID No. 52801 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. IL Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs: 75.48 Docketing 18.00 74.52 Poundage 1.48 Advertising Law Library Prothonotary 2.00 Refunded to Atty on 04/17/08 Mileage 5.00 Surcharge 20.00 Levy 20.00 Certified Mail Post Pone Sale Garnishee 9.00 Postage .? `? j lam i-Answers; TOTAL, $ 75.48 V L ' R. oma7s K I in e., Sheriff BY Claudia A. BrewbI?a e, q0 :1f ?? 01 tl&j NU n' r Nk RI1 OF EXE( t HON and!or -17 "1' ACHItII N x t`O_VIMONAt.111 OF PENNSYI_VANl,A, COUNTY OF CIJMBF.RLAND) ',,006-5799 ? i%o 19 At "I k TO THE SHERIFF OF CUMBERLAND COUN'IA: To satisfv the debt, interest and costs due PAUL RUTH AND LILLIAN RUTH Plaintiff (s) From MICHAEL MILLIKAN, 57 PARTRIDGE CIRCLE, CARLISLE, PA 17013 ( I ) 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 ut the possession of ORRSTOWN BANK, 2250 SPRING ROAD, CARLISLE, PA 17013 GARNISHEE(S) as follows: ANY AND ALL PERSONAL PROPERTY OF DEFENDANT IN THE POSSESSION OF ORRSTOWN BANK LOCATED AT 2250 SPRING ROAD, CARLISLE, PA 17013, AS GARNISHEE, INCLUDING, WITHOUT LIMITATION, ANY AND ALL FUNDS ON DEPOSIT and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined front 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$4825.33 Interest FROM 3/7/2007 AT $0.79 PER DAY Atty"s Conan Atty Paid $324.76 Plaintiff Paid Date: APRIL 09,2008 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs Curt R. Long, Pro ar By: Deputy Name CRAIG A. DIEHL, ESQUIRE Address: 3464 TRINDLE ROAD, CAMP HILL, PA 17011 Attorney for: PLAINTIFFS Telephone: 717-763-7613 Supreme Court ID No. 52801