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HomeMy WebLinkAbout06-5934'of ed"ll c?c eft A PROFESSIONAL CORPORATION ??&O'Wfow at-raw BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215) 564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Philadelphia, PA 19104 Plaintiff I hereby certify that I have served ozertified of this paper upon all other s or their attorneys by: ular mail mail ? oth !?t? By: CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION V. ALAN D. MANWARING 146 West Park Street d G S 13 y;.( 71- Carlisle, PA 17013 Defendant PRAECIPE TO TRANSFER JUDGMENT TO THE PROTHONOTARY: Please enter judgment against the above captioned Defendant in accordance with Pennsylvania Rules of Civil Procedure 3002 as follows: Amount of Judgment entered in the Philadelphia Court of Common Pleas $44,204.13 Court Costs Interest at 6% from 02/21 /01 to 09/21/06 Less Payments AMOUNT OF JUDGMENT + 130.20 +14,157.16 - 1,500.00 $56,991.49 O ? Dated: ED ERGER, E IRE Attorneys for Plaintiff i R REPORT : ZDRDOCT USER ID: COS First Judicial District CIVIL DOCKET REPORT CASE ID 001000019 PAGE 1 RUN DATE 09/27/06 RUN TIME 09:29 AM -------------------------------------------------------------------------------- CASE NUMBER CASE CAPTION 001000019 UNIVERSITY OF PA VS MANWARING FILING DATE COURT LOCATION JURY 02-OCT-2000 AR AC N CASE TYPE: CONTRACTS (GOODS), ENFORCE STATUS: JUDGMENT BY DEFAULT/FINAL DISP Seg # Assoc Expn Date 1 2 3 Date Entered 02-OCT-00 10:00:14 ACTIVE CASE 02-OCT-00 02-OCT- 00 10:07:00 COMMENCEMENT OF CIVIL ACTION 03-OCT-00 BERGER, EDWARD L 02-OCT- 00 10:07:00 SHERIFF'S SURCHARGE 1 DEFT 03-OCT-00 BERGER, EDWARD L 02-OCT- 00 10:07:00 COMPLAINT FILED NOTICE GIVEN 03-OCT-00 BERGER, EDWARD L COMPLAINT WITH NOTICE TO DEFEND WITHIN TWENTY (20) DAYS AFTER SERVICE IN ACCORDANCE WITH RULE 1018.1 FILED.ASSESSMENT NOT REQUIRE.D 03-OCT-00 14:49:25 ARBITRATION HEARING SCHEDULED 03-OCT-00 01-NOV- 00 10:38:50 ATTEMPTED SERVICE - NOT FOUND 08-NOV-00 OF COMPLAINT BY PERSONAL SERVICE UPON ALAN D. MANWARING ON 10/19/00 1 Type ID Party Name / Address & Phone No. APLF A34116 BERGER, EDWARD L 1760 MARKET ST. SUITE 600 PHILADELPHIA PA 19103 (000)564-2031 PLF 112474 UNIVERSITY OF PA 3451 WALNUT ST PHILADELPHIA PA 19104 DFT 04163427 MANWARING, ALAN D FOUR COUNT RD 0335 LAFAYETTE MS 38655 Filing Date / Time Docket Entry ? s REPORT : ZDRDOCT First Judicial District USER ID: COS CIVIL DOCKET REPORT CASE ID 001000019 Filing Date / Time Docket Ent PAGE 2 RUN DATE 09/27/06 RUN TIME 09:29 AM Date Entered 21-NOV-00 13:32:49 PETITION - ALTERNATIVE SERVICE 24-NOV-00 UNIVERSITY OF PA, 45-00111045 PETITION FOR ALTERNATIVE SERVICE 24-NOV-00 14:04:20 MOTION ASSIGNED 24-NOV-00 45-00111045 PETITION FOR ALTERNATIVE SERVICE ASSIGNED TO JUDGE MCINERNEY ON 11-27-00 29-NOV-00 11:23:57 ORDER ENTERED/236 NOTICE GIVEN 29-NOV-00 MCINERNEY, PATRICIA A 45-00111045 - AND NOW, THIS 27TH DAY OF NOVEMBER, 2000, UPON CONSIDERATION OF PLAINTIFF'S AFFIDAVIT IN SUPPORT OF REQUEST FOR LATERNATIVE SERVICE PURSUANT TO PHILADELPHIA R.C.P.141, IT IS HEREBY ORDERED AND DECREED THAT PLAINTIFF BE ALLOWED TO SERVE A COPY OF ITS COMPLAINT ON DEFENDANT BY REGULAR MAIL, CERTIFIED MAIL, RETURN RECEIPT REQUESTED, AND BY POSTING THE PREMISES WITH A COPY OF THE COMPLAINT BY B & R SERVICES FOR PROFESSIONALS, INC. AT DEFENDANT'S RESIDENCE, 4 COUNTY ROAD, #335, OXFORD, MISSISSIPPI, 38655..... BY THE COURT: PATRICIA MCINERNEY J. 05-DEC-00 10:10:00 REINSTATE/REISSUE CIVIL ACTION 05-DEC-00 COMPLAINT WITH NOTICE TO DEFEND WITHIN TWENTY (20) DAYS AFTER SERVICE IN ACCORDANCE WITH RULE 1018.1 REINSTATED. 23-JAN-01 09:48:00 AFFIDAVIT OF SERVICE FILED 23-JAN-01 SERVICE OF COMPLAINT UPON DFT ALAN MANWARING VIA POSTING ON JANUARY 17, 2001. 26-JAN-01 13:41:36 AFFIDAVIT OF SERVICE FILED 29-JAN-01 BERGER, EDWARD L OF COMPLAINT BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED UPON DEFT AS PER COURT ORDER REGULAR MAIL &POSTED THE PREMISES ON 01-17-01 21-FEB-01 10:11:00 JUDGMENT BY DEFAULT/FINAL DISP 44,204.13 21-FEB-01 PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT FILED. JUDGMENT FOR PLAINTIFF(S) AGAINST DEFENDANT(S) FOR FAILURE TO FILE ANSWER WITHIN REQUIRED TIME. PRO-PROTHONOTARY NOTICE UNDER RULE 236. NOTICE UNDER 237.5. AFFIDAVIT OF NON-MILITARY SERVICE FILED . DAMAGES ASSESSED $ 44,204.13 * * * End of Docket Judgment certified in the amount of $44,204.13 CERTIFIED FROM THE RECORD Ong S E 2 200" JOSEPH H. EVERS PR OTARY OF PHILA LPHIA COUNTY BY• ic) "Of-dzff & ?lJ efcY?,ef? A PROFESSIONAL CORPORATION ./LGl,O/YLClW a&?&zV BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Philadelphia, PA 19104 Plaintiff V. ALAN D. MANWARING 146 West Park Street Carlisle, PA 17013 Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION ASSESSMENT OF DAMAGES AND NOW, to wit, this // E day of 067_,- e _, , 2006 Judgment is entered in favor of the above referenced Plaintiff, and against ALAN MANWARING above referenced Defendant, for failure to file an Answer and Plaintiffs damages are assessed in the sum of $56,991.49. Prothonotary A PROFESSIONAL CORPORATION ltto/yte f? aG_ %w BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania. 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Philadelphia, PA 19104 Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION V. ALAN D. MANWARING 146 West Park Street Carlisle, PA 17013 Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA . ss EDWARD L. BERGER, ESQUIRE, being duly sworn according to law, hereby deposes and says that I am the attorney for the Plaintiff in the above captioned action, and that the following Defendant is not in the Military Service of the United States of America or any State or Territory thereof, or its allies, and that the Defendant is not in any manner subject to the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended: Alan D. Manwaring 146 West Park Street Carlisle, PA 17013 SWORN TO AND SUBSCRIBED BEFORE ME THIS 5TH DAY OF OC OBER 2006. c?c des ; EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff NOTARY PUBLIC vmmairowtAL It1UF PENNSYLVANIA NOTARIAL SEAL DIANA BURTON, Notary Public City of Philadelphia, Phila. County M Commission Expires Jul 14, 2009 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS To: Alan D. Manwaring 146 West Park Street Carlisle, PA 17013 UNIVERSITY OF PENNSYLVANIA Plaintiff V. COMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION ALAN MANWARING Defendant Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. ? Judgment by Default Money Judgment ? Judgment in Replevin ? Judgment for Possession ? Judgment on Award of Arbitrators ? Judgment on Verdict ? Judgment on Court Findings If you have any questions concerning this notice, please call: ATTORNEY EDWARD L. BERGER Esquire (Insert Attorney's Name) at this telephone number: 215-564-2031 16-232 (Rev. 2100) ? ? `"' s fry t Nz 1 1 1 c A. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION UNIVERSITY OF PENNSYLVANIA V. ALAN D. MANWARING -and CITIZENS BANK, COMMERCE BANK, PNC BANK, : WACHOVIA BANK, SOVEREIGN BANK & M&T BANK, Garnishees File No. 06-5934 Amount Due $56,991.49 Interest 10/11/06 Atty's Comm Costs $57.80 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the Defendant(s) ALAN D. MANWARING PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) All contents of Defendant's residence, including but not limited to all furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, televisions, stereo equipment, tools and any other property subject to levy located at 146 WEST PARK STREET, CARLISLE, PA 17013. Checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty, which may be in the possession of the Garnishee belonging to the Defendant. and all other property of the Defendant(s) in the possession, custody or control of the said Garnishee(s). (Indicate) Index this writ against the Garnishee(s) as a lis pendens against real estate of the Defend antO described in the attached exhibit. DATE: \ Signature: Print Name: Edward L. Berger, Esquire Address: Gordin & Berger, P.C. 1760 Market Street, Suite 600 Philadelphia, PA 19103 Attorney for: Plaintiff Telephone: 215-564-2031 Supreme Court ID No. 34116 Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (Pa. R.C.P No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. 1? t n O ? b ? a . o a c o ?? ?J OD WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF. PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5934 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIVERSITY OF PENNSYLVANIA, Plaintiff (s) From ALAN D. MANWARING, 146 PARK STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE, INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, KITCHEN UTENSILS, SILVERWARE, TELEVISIONS, STEREO EQUIPMENT, TOOLS AND ANY OTHER PROPERTY SUBJECT TO LEVY LOCATED AT 146 WEST PARK STREET, CARLISLE, PA 17013. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of CITIZENS BANK, 665 NORTHEAST CIRCLE, CARLISLE, PA 17013 - COMMERCE BANK, 20 NOBLE BOULEVARD, BUILDING II, CARLISLE, PA 17013 - PNC BANK, 105 NOBLE BOULEVARD, CARLISLE, PA 17013 - WACHOVIA BANK, 604 EAST HIGH STREET, CARLISLE, PA 17013 - SOVEREIGN BANK, 17 WEST HIGH STREET, CARLISLE, PA 17013 - M&T BANK, 812 1/2 WEST HIGH STREET, CARLISLE, PA 17013 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 $56,991.49 Interest 10/11/06 Atty's Comm % Atty Paid $38.00 Plaintiff Paid Date: DECEMBER 18, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs $57.80 Curt' . Long, P notary By: Deputy REQUESTING PARTY: Name EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, P.C. 1760 MARKET STREET, SUITE 600 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-2031 Supreme Court ID No. 34116 c?Pf4 ??li CMG ^?efc? A Pr4essional Corporation .?f/oirrP? agar BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street - Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA Plaintiff V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION ALAN D. MANWARING NO. 06-5934 Defendant /fin Swdfr? INTERROGATORIES IN ATTACHMENT TO: SOVEREIGN BANK 17 West High Street Carlisle, PA 17013 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 a default judgment being entered against you. 1. At the time you were served or at any subsequent time, did you owe the Defendant any money, exclusive of exempt Social Security benefits, or were you liable to him/her on any negotiable or other written instrument, or did he/sh claim that you owed him/her any money or were liable to him/her for any reason? ANSWER HAS " & T BANK OR ABp EACCpUNts NAIN® 2. At the time you were served or at any subsequent time, was -t ere in your possession, custody or control or in the joint possession, custody or control of yourself or one or more other persons any property of any nature owned solely or in part by the Defendant? ANSWER 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? ANSWER J0 4, At the time you were served or at any subsequent time, did you hold as fiduciary any propdr-ty in which the defendant had an interest? ANSWER 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? ANSWER 6. At the 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 his/her direction or otherwise discharge any claim of the Defendant against you? ANSWER 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, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? ANSWER AofY&T & Bety"-, 0.6 W4 6, ??? BpMK M & T BANK LEGAL DOCUMENT PROCESSING P.O. BOX 844 BUFFALO, W 14240 EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff 0 .? ci 1 Z 03Q 9DDt A Professional Corporation ?floiviP? nl?o?rr BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA Plaintiff V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION ALAN D. MANWARING NO. 06-5934 Defendant 45WCrS 4V INTERROGATORIES IN ATTACHMENT TO: COMMERCE BANK 20 Noble Boulevard, Building II Carlisle, PA 17013 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 a default judgment being entered against you. 1. At the time you were served or at any subsequent time, did you owe the Defendant any money, exclusive of exempt Social Security benefits, or were you liable to him/her on any negotiable or other written instrument, or did he/she claim that you owed him/her any money or were liable to him/her for any reason? ANSWER No 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 or one or more other persons any property of any nature owned solely or in part by the Defendant? ANSWER No 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? ANSWER No 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? ANSWER No 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? ANSWER No 6. At the 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 his/her direction or otherwise discharge any claim of the Defendant against you? ANSWER No 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, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? ANSWER No A sY 4; T & A(Befw, e.-; ? 0 EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff Comme.,e Bank 3801 Paxton Street Harrisburg, PA 17111 -412-6134 f /1 >--... _ Date -' rTl rn r=i CD _ c`1Ofyhw & A PROFESSIONAL CORPORATION -'f& /S2Cl?B at-a I' BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. CIVIL DIVISION ALAN D. MANWARING Defendant -and- SOVEREIGN BANK NO. 06-5934 Garnishee ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against Garnishee, SOVEREIGN BANK, discontinued, upon payment of your costs only. &o^ -"efze-, 0.6) EDW RGER, ESQUIRE Atto evs for Plaintiff &of4h/L & ef? ef? A PROFESSIONAL CORPORATION /?OIYLCl? BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA Plaintiff V. ALAN D. MANWARING PNC BANK -and- Defendant Garnishee CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 06-5934 ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against Garnishee, PNC BANK, discontinued, upon payment of your costs only. QeWM BERGER, ESQUIRE Attorneys for Plaintiff c101-whT & A PROFESSIONAL CORPORATION . ltl? ab-riuo BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA V. ALAN D. MANWARING -and- COMMERCE BANK Plaintiff Defendant Garnishee CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 06-5934 ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against Garnishee, COMMERCE BANK, discontinued, upon payment of your costs only. 1 EDWARD L. BERGER, E IRE Attorneys for Plaintiff T &o/(& V Vim/ VVV e A PROFESSIONAL CORPORATION C -'(&Orn?lc f`v aG-?%w BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street - Suite 600 Philadelphia, Pennsylvania 19103 (215) 564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. CIVIL DIVISION ALAN D. MANWARING CITIZENS BANK -and- Defendant NO. 06-5934 Garnishee ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against Garnishee, CITIZENS BANK, discontinued, upon payment of your costs only. EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff ? "?, t"? ?a C ? _ ? ? ? ? .,... ? ?t` ???? © ?a w L ? `? w^` V ??1 UNIVERSITY OF PENNSYLVANIA COURT OF COMMON PLEAS COUNTY OF CUMBERLAND VS. ALAN D. MANWARING : NO. 06-5934 and WACHOVIA BANK, N.A. : GARNISHEE ATTORNEY I.D.# ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, Wachovia Bank, N.A. discontinued, upon payment of your costs only. EDWARD L. BER E Attorney for Plaintiff JON C. SIRLIN Attorney for Gai NR a - p 'Ll v ` 1 ? two C) R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Advance Costs: 450.00 Sheriff's Costs: 374.28 Docketing 18.00 $ 75.72 Poundage 7.34 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 01/30/07 Mileage 8.80 Surcharge 140.00 Levy 140.00 Certified Mail 4.64 Post Pone Sale Garnishee 54.00 Postage TOTAL $ 374.28 ? ,V"'16 7 So Answers . r R. Thomas Kline, S eriff y Claudia A. Brewbaker c*Z.6'7 ?y WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5934 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIVERSITY OF PENNSYLVANIA, Plaintiff (s) From ALAN D. MANWARING, 146 PARK STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE, INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, KITCHEN UTENSILS, SILVERWARE, TELEVISIONS, STEREO EQUIPMENT, TOOLS AND ANY OTHER PROPERTY SUBJECT TO LEVY LOCATED AT 146 WEST PARK STREET, CARLISLE, PA 17013. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 'CITIZENS BANK, 665 NORTHEAST CIRCLE, CARLISLE, PA 17013 COMMERCE BANK, 20 NOBLE BOULEVARD, BUILDING III,, CARLISLE, PA 17013 -4NC BANK, 105 NOBLE BOULEVARD, CARLISLE PA 17013 - WACHOVIA BANK, 604 EAST HIGH STREET, CARLISLE, PA 17013 - ZVEREIGN BANK, 17 WEST HIGH STREET, CARLISLE, PA 17013 - M&T BANK, 812 1/2 WEST HIGH STREET, CARLISLE, PA 17013 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 $56,991.49 Interest 10/11/06 Atty's Comm % Atty Paid $38.00 Plaintiff Paid Date: DECEMBER 18, 2006 L.L. $.50 Due Prothy $1.00 Other Costs $57.80 Curti. Long notary(Seal) By: Deputy REQUESTING PARTY: Name EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, P.C. 1760 MARKET STREET, SUITE 600 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION UNIVERSITY OF PENNSYLVANIA File No. 06-05934 Plaintiff Amount Due $56,991.49 V. Interest ALAN D. MANWARING Atty's Comm Defendant Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the Defendant(s) including but not limited to all furniture, clothing, jewelry, electronic equipment, electrical appliances kitchen utensils silverware, television, stereo equipment, tools, and anv other property subiect to lees located at 623 GLENDALE STREET, CARLISLE, PA 17013. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment ;o the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the Defendant(s) in the possession, custody or control of the said Garnishee(s). (Indicate) Index this writ against the Garnishee(s) as a lis pendens against real estate of the Defendants described in the attached exhibit. LATE: Signature: Print Name: Edward L. Berger, Esquire Address: Gordin & Berger, P.C. 1760 Market Street, Suite 600 Philadelphia, PA 19103 Attorney for: Plaintiff Telephone: 215-564-2031 Supreme Court ID No. 34116 Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (Pa. R.C.P No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. Q 4 ,r, "" JN 1= j no AB .484.00 C g?4. as 5 ao. o0 8.0° « V•oO '18 ,pp ?-ccY 4J.oo buP C6 Ce jpyyA q RYA a05t'08 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5934 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIVERSITY OF PENNSYLVANIA, Plaintiff (s) From ALAN D. MANWARING, 623 Glendale Street, Carlisle PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell property of defendant including but not limited to all furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, television, stereo equipment, tools, and any other property subject to levy. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 $56,991.49 Interest Atty's Comm % Atty Paid $449.78 Plaintiff Paid Date: 7/29/09 L.L. Due Prothy $2.00 Other Costs P. L R. Long, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, P.C. 1760 MARKET STREET, SUITE 600 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-2031 Supreme Court ID No. 34116 R. THOMAS KLINE Sheriff EDWARD L.SCHORPP Solicitor °0tv of ?Cunt?Prt? OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 October 26, 2009 F11 FD--Q`:F1CE OF THE PRC,71; ntti'C:TARY 2009 OCT 28 AM 9: 4 l RONNY R. ANDERSON PEr JODY ' NMI' Nil, Real Estate Sergeant University of Pennsylvania `X vs Alan D. Manwaring Writ No. 2006-5934 Property Claim Determination To Whom It May Concern: Reference is made to Property Claim dated October 16, 2009, entered by Max Manwaring, Writ of Execution No. 2006-5934, Civil Term, University of Pennsylvania VS Alan D. Manwaring. R. Thomas Kline, Sheriff, has determined that the claimant, Max Manwaring, in the above mentioned property claim, is the owner of the property set forth in the claim. cc Edward L. Berger, Atty for Plaintiff Alan D. Manwaring, Defendant Max Manwaring, Claimant So Answers: R. I liomas Kline, Sheriff i By A?Z? NOTICE OF PROPERTY CLAIM University of Pennsylvania In the Court of Common Pleas Cumberland County, Pennsylvania VS Alan D. Manwaring No. 2006-5934 Civil Term Writ of Execution TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Max Manwaring claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 10-16-09 Cc Edward L. Berger, Atty for Pltff Alan D. Manwaring, Defendant Max Manwaring, Claimant rye Sheriff of Cumberland County By 5 PROPERTY CLAIM University of Pennsvlvania VS Alan D. Manwaring TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE '?3O, ,n) .xn flu THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: Date State of Pennsylvania: County of Cumberland above list in the property claim are correct and true. Sworn and subscribed-to before me of -':-'7 NOTARIAL SEAL CLAUDIA A. BREWBAKER, NOTARY PUBLIC Carlisle Boro, Cumberland County My Commission Expir¢c Anr" ° A In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-5934 being duly sworn according to law, deposes and says that the ?.dou ?r 01-61 I Wo A-) n b,w ao-.o _. SHERIFF'S OFFICE OF CUMBERLA !p`}Q NTY R Thomas Kline rlr THE + P1. ?TAR Sheriff 4 qtr t l€?trbrrft? ZQQ9 NN -9 Ph 3: Ou Ronny R Anderson Chief Deputy z' Jody S Smith but `' r Civil Process Sergeant C FI,;E t t r p : rr?RIFF 1 Edward L Schorpp Solicitor ( University of Pennsylvania vs. Case Number . Alan D Manwaring 2006-5934 SHERIFF'S RETURN OF SERVICE 08/19/2009 08:20 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he attempted to serve a true copy of the within writ of execution, upon the defendant, to wit: Alan D. Manwaring at 623 Glendale Street, Carlisle, Cumberland County, Pennsylvania 17013. At that time it was learned from the defendant's father that the defendant had moved to Washington DC approximately 6 months ago and he has no forwarding address. A post office check revealed that mail is still delivered to this address. 09/29/2009 09:25 PM - Timothy R. Black, Deputy Sheriff, who being duly sworn according to law, states that on September 29, 2009 at 2100 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Alan D. Manwaring, by making known unto Max Manwaring, Adult in Charge and father of defendant, at 623 Glendale Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on 10-02-09. Max Manwaring advised that his son does not reside there, but lives in Washington DC. Mr. Manwaring was unable to provide a mailing address but did provide a cell phone # of 202-294-2650. 10/16/2009 On Friday, October 16, 2009, at 1049 hours, a property claim was filed by Max Manwaring. All parties notified by mail this date. 10/26/2009 Reference is made to Property Claim dated October 16, 2009, entered by Max Manwaring, Writ of Execution No. 2006-5934 Civil Term, University of Pennsylvania vs Alan D. Manwaring. R. Thomas Kline, Sheriff, has determined that the claimant, Max Manwaring, in the above mentioned property claim, is the owner of the property set forth in the claim. 11/09/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that this writ of execution is returned STAYED per Pennsylvania Rules of Court 3206(c). SHERIFF COST:' 69.40 SO ANSWERS ! ds November 09, 2009 ? vv? i 3/09 R THOMAS KLINE, SHERIFF By?? Sharon R. Lantz CA- 7,2 9J4? (c) CountySulte Sherift, TeleoSoft, Inc. le', ;? 3 3 5-1 S WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5934 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIVERSITY OF PENNSYLVANIA, Plaintiff (s) From ALAN D. MANWARING, 623 Glendale Street, Carlisle PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell property of defendant including but not limited to all furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, television, stereo equipment, tools, and any other property subject to levy. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 $56,991.49 Interest Atty's Comm % Atty Paid $449.78 Plaintiff Paid Date: 7/29/09 L.L. Due Prothy $2.00 Other Costs (Seal) REQUESTING PARTY: Name EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, P.C. 1760 MARKET STREET, SUITE 600 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-2031 Deputy Supreme Court ID No. 34116