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HomeMy WebLinkAbout02-2665THE BOROUGH OF SHIREMANSTOWN, Plaintiff MATTHEW POWELL AND SANDRA POWELL, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : :NO. O,o:OW' : : CONFESSION OF JUDGMENT : CWIL ACTION - LAW CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of attomey, the original or a copy of which is attached to the complaint filed in this action, I appear for the Defendants and confess judgment in favor of the Plaintiff and against Defendants as follows: Principal Other authorized items: Interest to May 23, 2002 Attomey% Fees TOTAL $ 4,043.02 $ 189.71 $ 634.91 $ 4,867.64 plus additional interest, and costs from the date of the Complaint. Date: Respectfully submitted, SAIDIS, SHUFE., FLOWER & LINDSAY By: I~arl M. L~debohm, Esquire Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Defendants THE BOROUGH OF SHIREMANSTOWN, Plaintiff Vo MATTHEW POWELL AND SANDRA POWELL, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CONFESSION OF JUDGMENT CIVIL ACTION - LAW COMPLAINT FOR CONFESSION OF JUDGMENT UNDER RULE 2951 1. The name and address of the Plaintiff is the Borough of Shiremanstown, One Park Lane, Shiremamt,~wn, Pennsylvania 17011. .~ 2. The names and last known address of the Defendants are Matthew Powell and Sandra Powell, 799 Old Silver Spring Road, Mechanicsburg, Pennsylvania 17055. 3. Defendants executed and delivered to Plaintiff an Installme~it Judgment Note ("Note"), a tree and correct photostatic reproduction of the original of which is attached hereto as Exhibit "A" and made a part hereof. 4. Defendants are in default of Defendants' obligations to make payment to Plaintiff as required in the Note, and Plaintiff has demanded payment in full of all outstanding amounts as provided in the Note. A copy of Plaintiffs demand is attached hereto as Exhibit "B" and made a part hereof. 5. Cbntemporaneous to Defendants' execution of the Note, Defendants executed and delivered to Plaintiff a Disclosure for Confession and Execution of Judgment ("Disclosure for Confession"), a ~e and correct photostatic reproduction of the original of which is attached hereto as Exhibit "C" and made a part hereof. 6. Judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. 7. There has not been any assignment of the Note. 8. Judgment has not been entered on the Note in any jurisdiction. 9. The amount due to Plaintiff as a result of Defendants' default is as follows: Principal $ 4,043.02 Interest to May 23, 2002 $ 189.71 Attomey's Fees $ 634.91 TOTAL $ 4,867.64 10. Interest continues to accrue at the rate provided in the Note in the amount of $1.10767 per day. wHEREFoRE, Plaintiff demands judgment against Defendants, Matthew Powell and Sandra Powell, as authorized by the warrant of attorney contained in the Note for Four Thousand Eight Hundred ~iXty-Seven and 64/100 Dollars ($4,867.64), plus interest from and including the date of this Complaint and judgment entered hereon at the rate provided in the Note and costs of suit. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY BY: S~u~pre~e Co~xtbo~n~5E;0q~fi2re - 2109 Market Street . Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff INSTALLMENT JUDGMENT NOTE $4,043.02 geptemb~ ,2001 FOR VALUE RECEIVED, we promise to pay to the order of the Borough of Shir~manstown, the sum of S4,043.02, without offset, together with interest at thc rate of 10% per annum, in eight (g) racce~ive equal monthly installments of $$00.00 each, principal and interest, the first installment payable on November 1, 2001, and the remaining installments on the same day of each month thereafter with the full outstanding balance of principal and interest and any and all other charges as set forth in this Installment Judgement Note or in the Agrecment signed by the undersigned on even date herewith (the "Agreement") to be du~ and payable on or before Ju~y l, 2002 in thc form ora balloon payment. The Agreemen! is incorporated herein by rafcrence as if set for~ in full. On non-payment of any installment when due, all remaining ' installments shaJi become immediately due and payable at the option of the holder and without notice. If this no~e is placed in the hands of an attorney for collection, we agree to pay as a rea,~nable attorney's fee 15% of the amount due and owing on this note. To secure payment of this note, we authorize the Prothonotary, Clerk in such Court or any attorney of any Court of record to appear for us in such Court, at any time before or after maturity and coufess a judgement against us in favor of any holder of this note with or without stay of execution, and for such amount as may appear to be unpaid thereon, together with interest and with charges, attorney's fees and costs herein provided, and we hereby waive and release all benefit and relief from any and ail appraisement, stay, or exemption laws of any State, now in force or hereafter to be passed. FN WITNESS W~EREOF, we have hereunto set our hands and seals on the day and year first above written. Addt'ess: ~~- '~*Matthew Powoll ~~ Sandra Powell ~ JAMES D. FLOWER JOHN E. SLIKE ROBERT C. SAIDIS GEOFFREY S. SHUFF JAMES D. FLOWER, JR. CAROL J. LINDSAY JOHNNA J. KOPECKY KARL M. LEDEBOHM JOSEPH L. HITCHINGS THOMAS E. FLOWER FORREST N. TROUTMAN, II LAW OFFICES SAIDIS, SHUFF, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 2109 MARKET STREET CAMP HILL, PENNSYLVANIA 17011 TELEPHONE: (717) 737-3405 - FACSIMILE: (717) 737-3407 EMAIL: attorney~ssfl-law, com www.ssfl-law.com March 28, 2002 VIA CERTIFIED AND REGULAR MAIL CARLISLE OFFICE: 26 W. HIGH STREET CARLISLE, PA 17013 TELEPHONE: (717)243-~222 FACSIMILE: (71T)243-¢486 REPLY TO CAMP HILL 1 Matthew Powell P.O. Box 1333 729 Old Silver Spring Road Mechanicsburg, PA 17055 Sandra Powell P.O. Box 1333 729 Old Silver Spring Road Mechanicsburg, PA 17055 Repayment Agreement dated October 24, 2001 for the repayment of delinquency to the Borough of Shiremanstown for installation of curbs and sidewalks along Locust Street Property: 100 and 104 S. Locust Street Lien ~ings: Cumberland County Docket No's. 01-5409MLD and 01-5410MLD Dear Mr. & Mrs. Powell: Pursuant to the Fair Debt Collection Practices Act, I am required to inform you that this letter is an attempt to collect a debt and any information obtained will be used for that purpose. Since you have failed to bring current your obligations due to the Borough of Shiremanstown (the "Borough") under the Agreement dated October 24, 2001 (the "Agreement") as set forth in my previous letter dated January 25, 2002, a copy of which is again enclosed for your reference, the Borough hereby exercises its rights under the Agreement and corresponding documents and hereby accelerates all amounts due to the Borough under the Agreement and Installment Judgment Note also dated October 24, 2001 (theI "Note") and hereby demands immediate payment of $4,139.69 calculated as follows: ~ Outstanding Principal $4,043.02 Interest as of March 1, 2002 $ 96.67 Total due to the Borough as of March 1, 2002 $4,139.69 Please note that the Borough received a partial payment on or about March 1, 2002 in the amount of $350.00. The Borough has applied the $350.00 payment as a partial payment towards the outstanding balance of the indebtedness due to the Borough under the Agreement without waiver of demand or of any default under the Agreement or the Note and without prejudice to any rights the Borough may have to collect the full outstanding balance of the indebtedness without further notice. For your information the $350.00 partial payment has been applied to the indebtedness as follows: 1. Legal fees incurred as a result of your defaults $306.00 2. Interest as of March 1, 2002 $ 44.00 3. Total partial payment applied $350.00 ~ The $4,139.69 due as set forth above reflects the balance due after application of the $350.00 partlal payment. addition to the $4,139.69 due as set forth above, you are also responsible for certain sidewal,k,s ~tnd curbs installed by ~e Borough of Shiremanstown along Green Street in the amount of $3,825.00 (the' Green Street Assessment ). Additionally you are also obligated to the Borough for legal fees incurred as of March 26, 2002 in the amount of $621.00. Therefore, the total which you now owe to the Borough is $8,585.69. The Borough Council for the Borough of Shiremanstown considered your proposal to pay all of~e amounts due to the Borough under the Agreement and in connection with the Green Street Assessment ~ (collectively the "Indebtedness") dated March 13, 2002 at its regular meeting held on March 18, 2002. The Borough may be willing to entertain a proposal to repay the Indebtedness to the Borough under the follox~ ing terms and conditions (the "Repayment Plan"): 1. The amount to be repaid to the Borough is $8,945.69 calculated as follows: Principal outstanding balance $7,964.69 Legal fees incurred as of March 26, 2002 $ 621.00 Legal fees to prepare payment agreement and related documents $ 360.00 4. Total to be repaid $8,945.69 The $8,945.69 as set forth above shall be repaid as follows: $4,472.00 being approximately 50% of the total amount due shall be delivered to m office in the form of a certified or cashier's check within thirty (30) days of the dat~ hereof. The balance of $4,473.69 shall be repaid together with interest at a rate of 10% per annum by way of regular monthly payments of principal and interest in the ama of $350.00 each to commence May 1, 2002 and to continue on or before the first da of each month thereafter with the full outstanding balance of principal and interest any and all other amounts due to the Borough to be paid in full on or before Novem 1, 2002 in the form of a balloon payment. mit nd ~er 3. The Borough's willingness to entertain the above repayment plan is specifically contingent upon the following: Your delivery of this letter bearing your original signatures to my office within ten i (10) days of the date of this letter. Your delivery to my office within thirty (30) days of the date of this letter of the $4,472.00 representing one half of the amounts due to the Borough. Your deh, cry to my office within forty five (45) clays of the date of this letter of a written repayment agreement and installment judgment Note in form and content acceptable to the Borough and incorporating, inter alia, the above repayment terms bearing your original signatures. In the event you are in agreement with the above temis and conditions, please sign this letter where indicated at the end and remm this letter to my office within ten (10) days after the date of this letter so that I may prepare the necessary documents for your signature. Unless payment in full in the amount of $8,585.69 (being the principal balance of $7,964.69 plus legal fees as of March 26, 2002 in the amount of $621.00) or this letter bearing your original signatgres is delivered to my office on or before ten (10) days from the date of this letter, the Borough has 1 instructed me to pursue its rights and remedies against you under the Agreement and the Note and~n connection with the above referenced Municipal Liens and the Municipal Lien filed contemporaneously herewith for the Green Street Assessment and otherwise at law or in equity to collect the balance due to the Borough without further Notice. Nothing herein shall be construed as an offer on behalf of the Borough to compromise the debt or Cs a commitment on behalf of the Borough to accept any terms and conditions in exchange for the payment of all amounts due to the Borough except as specifically set forth herein, i This letter shall be without prejudice to and shall not be deemed a waiver or postponement o any rights or remedies available to the Borough, including, without limitation, the Borough's rights accept partial payments without waiving any defaults under the Agreement or the Note, in connecti with the Green Street Assessment or the above referenced Municipal Liens. Neither this letter nor ~' subsequent discussion shall be deemed offers to extend the maturity of the Agreement and the Note otherwise waive any defaults thereunder. I look forward to the receipt of this letter beating your original signatures or in the alternative, payment in the amount of $8,585.69 in the immediate future.. KMl_Jtmh Enclosure cc: William Runkle, III, Borough President c/o Janna Colechio Very truly yours, SAIDIS~HUFF. FLOV~ER.& LINDSAY I/we Matthew Powell and Sandra Powell, intending to be legally bound, hereby agree to the terms and conditions of the Repayment Plan set forth in this letter. f to my OF Matthew Powell Sandra Powell i'll[ I Sai~, Sh~ Flower & L~ay ~A~~? / C~ Hill, PA 17011 l~l~., D e.o.~ox ~ ~ / 729 Old Shyer ~pnng ~uuu . [~: · 17055 , ,x~ M~Y l~?e ~1~7 DISCLOSURE FOR CONFESSION AND EXECUTION OF JUDGMENT OWNERS: BOROUGH: Matthew Powell and Sandra Powell 729 Old Silver Spring Road Mechanicsburg, PA 17055 Borough of Shiremanstown One Park Lane Shiremanstown, PA 17011 The undersigned did execute, and/or is executing, on September ,2001, among other documents, the following documents under which the undersigned is obligated to repay monies to Borough. 1. Agreement 2. Installment Judgment Note A. THE UNDERSIGNED ACKNOWLEDGES AND AGREES THAT SUCH DOCUMENT CONTAINS PROVISIONS UNDER WHICH BOROUGH MAY ENTER JUDGEMENT BY CONFESSION AGAINST THE UNDERSIGNED. BEING FULLY AWARE OF UNDERSIGNED'S RIGHTS TO PRIOR NOTICE AND A HEARING ON THE VALIDITY OF ANY CLAIMS THAT MAY BE ASSERTED AGAINST THE UNDERSIGNED BY BOROUGH THEREUNDER BEFORE JUDGMENT IS ENTERED, THE UNDERSIGNED HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WAIVES THESE RIGHTS AND EXPRESSLY AGREES AND CONSENTS TO BOROUGH ENTERING JUDGMENT AGAINST THE UNDERSIGNED BY CONFESSION PURSUANT TO THE TERMS THEREOF. B. THE UNDERSIGNED ALSO ACKNOWLEDGES AND AGREES THAT SUCH DOCUMENT CONTAINS PROVISIONS UNDER WHICH BOROUGH MAY, AFTER ENTRY OF JUDGEMENT AND WITHOUT NOTICE AND A HEARING, FORECLOSE UPON, ATTACH, LEVY OR OTHERWISE SEIZE PROPERTY OF THE UNDERSIGNED IN FULL OR PARTIAL PAYMENT OF THE JUDGMENT. BEING FULLY AWARE OF THE UNDERSIGNED'S RIGHTS AFTER JUDGEMENT IS ENTERED, THE UNDERSIGNED HEREBY FREELY, KNOWINGLY AND INTELLIGENTLY WAIVES THESE RIGHTS AND EXPRESSLY AGREES AND CONSENTS TO BOROUGH TAKING SUCH ACTIONS AS MAY BE PERMITTED UNDER APPLICABLE LAW WITHOUT PRIOR NOTICE TO THE UNDERSIGNED. THE UNDERSIGNED ACKNOWLEDGES THAT THEY HAVE READ AND UNDERSTAND THE CONTENTS OF THIS DISCLOSURE AND HAVE HAD THE OPPORTUNITY TO CONSULT WITH LEGA-_L COUNSEL OF THEIR CHOICE TO REVIEW THIS AND THE OTHER DOCUMENTS MENTIONED ABOVE PRIOR TO SIGNING ANY OF THEM. si~ing below;, and that thc undcrsigned received a copy hereof at thc time of signing. ~ime~ ' Matthew Pow~ll Date THE BOROUGH OF SHIREMANSTOWN, Plaintiff MATTHEW POWELL AND SANDRA POWELL, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CONFESSION OF JUDGMENT CIVIL ACTION - LAW VERIFICATION I, William Runkle, III, Borough President, for the Borough of Shiremanstown, being authorized to do so on behalf of the Borough of Shiremanstown, hereby verify that the statements made in the foregoing pleading are tree and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. BOROUGH OF SHIREMANSTOWN William Runkle, llI Borough President THE BOROUGH OF SHIREMANSTOWN, Plaintiff Vo MATTHEW POWELL AND SANDRA POWELL, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of the Borough of Shiremanstown, Plaintiff in the above captioned matter. Date: Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY By: Ledebohm,~Esq~f~~'~ 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attomey for Plaintiff THE BOROUGH OF SHIREMANSTOWN, Plaintiff MATTHEW POWELL AND SANDRA POWELL, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE TO THE PROTHONOTARY: I do certify, to the best of my knowledge, that the Defendants, Matthew Powell and Sandra Powell, in the above-captioned action are not presently on active or nonactive military status. Date: Respectfully submitted, SAIDIS, SHU~F, FLOWER & LINDSAY ~arl M. Ledebohm, Esquire Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff THE BOROUGH OF SHIREMANSTOWN, Plaintiff MATTHEW POWELL AND SANDRA POWELL, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW CERTIFICATE OF ADDRESSES I hereby certify that the precise address of Plaintiff, the Borough of Shiremanstown, is One Park Lane, Shiremanstown, Pennsylvania 17011; and that the last known address of the Defendants, Matthew Powell and Sandra Powell, is 729 Old Silver Spring Road, Mechanicsburg, Pennsylvania 17055. Date: Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY ~ Ledebohm, Esquire Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff THE BOROUGH OF SHIREMANSTOWN, Plaintiff MATTHEW POWELL AND SANDRA POWELL, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : . : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW NOTICE TO: Matthew Powell and Sandra Powell Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT BY CONFESSION has been entered against you in the above proceeding and that enclosed herewith is a copy of all the documents filed in support of the said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: KARL M. LEDEBOHM, ESQUIRE TELEPHONE NUMBER: (717) 761-1881 Prothonotary THE BOROUGH OF SHIREMANSTOWN, Plaintiff MATTHEW POWELL AND SANDRA POWELL, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :No. CONFESSION OF JUDGMENT CIVIL ACTION - LAW NOTICE UNDER RULE 2958.3 OF JUDGMENT AND EXECUTION THEREON TO: Matthew Powell and Sandra Powell A judgment in the amount of $4,867.64 has been entered against you and in favor of the plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper allegedly signed by you. The court has issued a Writ of Execution which directs the sheriff to take your money or other property owned by you to pay the judgment. If your money or property has been taken, you have the right to get the money or property back if you did not voluntarily, intelligently and knowingly give up your constitutional right to notice and hearing prior to the entry of judgment or if you have defenses or other valid objections to the judgment. You have a right to a prompt court hearing if you claim that you did not voluntarily, intelligently and knowingly give up your rights to notice and hearing prior to the entry of the judgment. If you wish to exercise this right, you must immediately fill out and sign the petition to strike the judgment which accompanies the Writ of Execution and deliver it to the Sheriff of Cumberland County at Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IT IS IMPORTANT THAT YOU ACT PROMPTLY. IT WILL BE TOO LATE TO REGAIN YOUR PROPERTY IF YOU WAIT UNTIL AFTER THE PROPERTY HAS BEEN SOLD BY THE SHERIFF OR TURNED OVER TO THE PLAINTIFF. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. 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 1-800-990-9108 Date: Respectfully submitted, SAIDIS, SH~F, FLOWER & LINDSAY By /~_~ ,~ ~F~~ 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff THE BOROUGH OF SHIREMANSTOWN, Plaintiff MATTHEW POWELL AND SANDRA POWELL, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW PETITION TO STRIKE JUDGMENT REQUEST FOR PROMPT HEARING I hereby certify that I did not voluntarily, intelligently and knowingly give up my right to notice and hearing prior to the entry of judgment. I petition the court to strike the judgment on this ground and request a prompt hearing on this issue. I verify that the statements made in this Request for Hearing are tree 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. Notice of the hearing should be given to me at Street Address City, State Telephone Number Date: Defendant THE BOROUGH OF SHIREMANSTOWN, Plaintiff Vo MATTHEW POWELL AND SANDRA POWELL, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CONFESSION OF YUDGMENT CIVIL ACTION - LAW PRAECIPE FOR WRIT OF EXECUTION UPON A CONFESSED JUDGMENT To the Prothonotary: Issue a (1) (2) (3) writ of execution upon a judgment entered by confession in the above matter. directed to the sheriff of Cumberland County; against Matthew Powell and Sandra Powell, 729 Old Silver Spring Road, Mechanicsburg, Pennsylvania 17055, Defendants; and against: (a) Hoover Hinson, Apartment l-A, 104 Locust Street, Shiremanstown, Pennsylvania 17011, Garnishee; Kim Copeman and Evan Huicak, Apartment 2-A, 104 Locust Street, Shiremanstown, Pennsylvania 17011, Garnishee; (c) Mr. and Mrs. or Ms. Everhart, Apartment l-B, 104 Locust Street, Shiremanstown, Pennsylvania 17011; Garnishee; (d) Mr. and Mrs. or Ms. Freedman, Apartment 2-B, 104 Locust Street, Shiremanstown, Pennsylvania 17011; Garnishee; and (e) Member 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA 17055; Garnishee. (4) and index this writ (a) against Matthew Powell and Sandra Powell, 729 Old Silver Spring Road, Mechanicsburg, Pennsylvania 17055; Defendants; and (b) against: (i) Hoover Hinson, Apartment l-A, 104 Locust Street, Shiremanstown, Pennsylvania 17011, Garnishee; (ii) Kim Copeman and Evan Huicak, Apartment 2-A, 104 Locust Street, Shiremanstown, Pennsylvania 17011, Garnishee; (iii) Mr. and Mrs. or Ms. Everhart, Apartment I-B, 104 Locust Street, Shiremanstown, Pennsylvania 17011; Garnishee; (iv) Mr. and Mrs. or Ms. Freedman, Apartment 2-B, 104 Locust Street, Shiremanstown, Pennsylvania 17011; Gamishee; and (v) Member 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, PA 17055; Garnishee. and levy upon and attach as required the following: (a) Any and all personal property located at the address of the Defendants at 729 Old Silver Spring Road, Mechanicsburg, Pennsylvania 17055. Co) Any and all personal property of Defendants in the possession of the following Garnishee/Tenants at the following addresses including, without limitation, any and all rents: Hoover Hinson 104 Locust Street Apartment 1-A Shiremanstown, PA 17011 Kim Copeman and Evan Huicak 104 Locust Street Apartment 2-A Shiremanstown, PA 17011 Mr. and Mrs./Ms. Everhart 104 Locust Street Apartment 1-B Shiremanstown, PA 17011 Mr. and Mrs./Ms. Freedman 104 Locust Street Apartment 2-B Shiremanstown, PA 17011 (c) Any and all personal property of Defendants held in the possession of Members 1st Federal Credit Union, Garnishee, at 5000 Louise Drive, Mechanicsburg, Pennsylvania 17055, including without limitation any and all deposit accounts and safety deposit boxes. (5) Amount due: Interest from May 23, 2002 Attorney's fees Costs $4,867.64 at $1.10767 per day (to be added) (to be added) (to be added) Certification I certify that (a) This praecipe is based upon a judgment entered by confession; and (b) Notice will be served with the Writ of Execution Pursuant to Rule 2958.3. SAIDI~,.~FF, FLOWER ~ ~Ay 2109 Market Street Camp Hill, PA 17011 (717) 761-1881 Attomey for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-2665 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BOROUGH OF SHIREMANSTOWN, Plaintiff (s) From MATTHEW POWELL AND SANDRA POWELL, 729 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL PERSONAL PROPERTY LOCATED AT THE ADDRESS OF THE DEFENDANTS AT 729 OLD SILVER SPRING ROAD, MECHANICSBURG, PA 17055. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of ANY AND ALL PERSONAL OF DEFENDANTS IN THE POSSESSION OF THE FOLLOWING GARNISHEE/TENANTS AT THE FOLLOWING GARNISHEE/TENANTS AT THE FOLLOWING ADDRESSES INCLUDING, WITHOUT LIMITATION, ANY AND ALL RENTS: HOOVER HINSON, 104 LOCUST STREET, APARTMENT I-A, SHIREMANSTOWN, PA 17011 KIM COPEMAN AND EVAN HUICAK, 104 LOCUST STREET, APARTMENT 2-A, SHIREMANSTOWN, PA 17011 MR. AND MRS/MS. EVERHART, 104 LOCUST STREET, APARTMENT l-B, SHIREMANSTOWN, PA 17011 MR. AND MRS/MS. FREEDMAN, 104 LOCUST STREET, APARTMENT 2-B, SHIREMANSTOWN, PA 17011 ANY AND ALL PERSONAL PROPERTY OF DEFENDANTS HELD IN THE POSSESSION OF MEMBERS 1ST FEDERAL CREDIT UNION, GARNISHEE, AT 5000 LOUISE DRIVE., MECHANICSBURG, PA 17055, INCLUDING WITHOUT ANY AND ALL DEPOSIT ACCOUNTS AND SAFETY DEPOSIT BOXES. 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 $4,867.64 L.L. $.50 Interest FROM 5/23]02 AT $1.10767 PER DAY (TO BE ADDED) Atty's Comm % Atty Paid $32.50 Plaintiff Paid Date: MAY 31, 2002 Due Prothy $.50 Other Costs CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name KARL M. LEDEBOHM, ESQUIRE Address: SAIDIS, SHUFF, FLOWER & LINDSAY 2109 MARKET STREET CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-761-1881 Supreme Court ID No. 59012 THE BOROUGH OF SHIREMANSTOWN, Plaimiff MATTHEW POWELL AND SANDRA POWELL, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2665 CIVIL TERM CONFESSION OF JUDGMENT CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please mark the judgment entered in the above-captioned action satisfied. Date: July 22, 2002 Respectfully submitted, //Karl M. Ledebohm, Esquire / Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff THE BOROUGH OF SHIREMANSTOWN, Plaintiff Vo MATTHEW POWELL AND SANDRA POWELL, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2665 CIVIL TERM : CONFESSION OF JUDGMENT : CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please dissolve the attachment of Defendants, Matthew Powell's and Sandra Powell's property in the possession of Brett Freedman, Mrs. Charles Everhart, Evan Huicak, Kim Copeman and Hoover Hinson as garnishees in the above captioned matter. Date: Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY By: ~ ~7~ ~0r~4 ~ ~hm~ Escl-uire~-~-~ ~u;reme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff R..Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing $ 18.00 Poundage 97.35 Advertising Law Library .50 Prothonotary .50 Mileage 15.87 Misc. Surcharge 110.00 Levy 120.00 Post Pone Sale Garnishee 72.00 434.22 Advance Costs: 434.22 Sheriffs Costs: 434.22 000.00 Refunded to Arty on 7/24/02 Sworn and Subscribed to before me This -2J~u- day 2002 A.D. 'Prothonotary So Ams ers' , R. Thomas Kline, Sheriff SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYV~kNIA COUNTY OF CUMBERLAND SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now GERALD WORTHINGTON Cumberland County of Pennsylvania, to law, at 0014:33 Hours, on the 24th day of June , as herein commanded all goods, chattels, rights, debts, moneys of the within named DEFENDANT POWELL SANDRA hands, possession, or control of the within named Garnishee MEMBERS 1ST FED CREDIT UNION 5000 LOUISE DRIVE ,Sheriff or Deputy Sheriff of who being duly sworn according 2002, attached credits, and , in the MECI43~NICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to DELICE MURPHY (FP~AUD INVESTIGATOR) 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: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 So answers: R. Thomas-Kline~~ Sheriff of Cumberland C~ty oo/oo/oooo Sworn and subscribed to before me this /~ day of ~z~ ~2~2 2~ A.D. J PFo~honotary ' /-" Deputy ~riff SHERIFF'S RETURN CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND - GARNISHEE SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now GEtLALD WORTHINGTON Cumberland County of Pennsylvania, to law, at 0014:33 Hours, on the 24th day of June , as herein commanded all goods, chattels, rights, debts, moneys of the within named DEFENDANT POWELL MATTHEW hands, possession, or control of the within named Garnishee MEMBERS 1ST FED CREDIT UNION 5000 LOUISE DRIVE ,Sheriff or Deputy Sheriff of who being duly sworn according 2002, attached credits, and , in the MECHA-NICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to DELICE MURPHY (FRAUD INVESTIGATOR) 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: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 So answe s: R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo Sworn and subscribed to before me this /3 - day of 2~o~ A.D. Prothdnotary ' Deputy ~/4eriff SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now DAWN L. KELL ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0018:40 Hours, on the 24th day of June , 2002, attached as herein commanded all goods, chattels, rights, moneys of the within named DEFENDANT , POWELL MATTHEW debts, credits, and , in the hands, possession, or control of the within named Garnishee HOOVER HINSON 104 SOUTH LOCUST STREET VE APT 1-A SHIRENLANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to KIM HINSON (WIFE) 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 .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this /~ day of ~.~3~ ~o2~ A.D. / Prothonotary ~: So answers: Sheriff of Cumberland County 00/00/0000 Deputy Sheriff SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now DAWN KEL~ ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0018:40 Hours, on the 24th day of June , 2002, attached as herein commanded all goods, chattels, rights, moneys of the within named DEFENDANT , POWELL SANDRA debts, credits, and , in the hands, possession, or control of the within named Garnishee HOOVER HINSON 104 SOUTH LOCUST STREET VE APT 1-A SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to HOOVER HINSON 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 .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this /~ day of 0,~ ~o j~ A.D. ~ pz~ot~on~t ~ry / R. Thomas Kline Sheriff of Cumberland County 00/00/0000 Deputy Sheriff SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now DAWN KELL Cumberland County of Pennsylvania, to law, at 0018:40 Hours, on the 24th day of June , as herein commanded all goods, chattels, rights, debts, moneys of the within named DEFENDANT , POWELL MATTHEW hands, possession, or control of the within named Garnishee KIM COPEMAN 104 SOUTH LOCUST STREET VE ,Sheriff or Deputy Sheriff of who being duly sworn according 2002, attached credits, and , in the APT 2-A SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to KIM COPEMAN personally three copies of interogatories together with 3 t rue and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this /~J~ day of ~ Pz6fhonotary R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo Deputy Sheriff SHERIFF'S RETURN - CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GARNISHEE SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now DAWN KELL Cumberland County of Pennsylvania, to law, at 0018:40 Hours, on the 24th day of June as herein commanded all goods, chattels, moneys of the within named DEFENDANT , POWELL SANDRA rights, debts, ,Sheriff or Deputy Sheriff of who being duly sworn according 2002, attached credits, and , in the hands, possession, or control of the within named Garnishee KIM COPEMAN 104 SOUTH LOCUST ST APT 2-A SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to KIM COPEMAN 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 .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this /~ day of ~ ~3~ A.D. ~ Pr~onotary ' R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo By Deputy Sheriff SHERIFF'S RETURN - CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GARNISHEE SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now DAWN KELL ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0018:40 Hours, on the 24th day of June 2002, attached as herein commanded all goods, chattels, rights, moneys of the within named DEFENDANT , POWELL MATTHEW debts, credits, and in the hands, possession, or control of the within named Garnishee EVAN HUICAK 104 SOUTH LOCUST ST APT 2-A SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to KIM COPEMAN (ADULT ROOMATE) 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 .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this ~ day of ~ ~t~2~ A.D. Proffh6notary ~ ! So answers: R. Thomas Kline Sheriff of Cumberland County 00/00/0000 Deputy Sheriff SHERIFF'S RETURN - CASE NO: 2002-02665 P COMMON-WEALTH OF PEN-NSLYVANIA COUNTY OF CUMBERLAND GARNISHEE SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now DAWN L. KELL ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0018:40 Hours, on the 24th day of June , 2002, attached as herein commanded all goods, chattels, rights, moneys of the within named DEFENDANT , POWELL SANDRA debts, credits, and , in the hands, possession, or control of the within named Garnishee EVAN HUICAK 104 SOUTH LOCUST ST APT 2-A SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to KIM COPEMAN (ADULT ROOMATE) , 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 .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 00700/0000 Sworn and subscribed to before me this /~ day of ~ ~_~ ~ 2 J A.D. ; Prot~h6notary By R. Thomas Kline Sheriff of Cumberland County Deputy Sheriff SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLJ~ND SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now R. Thomas Kline , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, at 0000:00 Hours, on the 24th day of June 2002, attached as herein commanded all goods, chattels, rights, moneys of the within named DEFENDANT , POWELL MATTHEW debts, credits, and , in the hands, possession, or control of the within named Garnishee CHARLES W. EVERHART 104 SOUTH LOCUST STREET APT 1-B SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to NOT SERVED, GARNISHEE NAMED IS DECEASED personally__ true and attested copies of the within WRIT OF EXECUTION and made the contents thereof known to His Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 So answers: R. Thomas Kline Sheriff of Cumberland County oo/oo/ ooo Sworn and subscribed to before me this 73* -~ day of ~ ~c~0 ;L A. D. Prat a%nX~ot ary , ~ SHERIFF'S RETURN - C~SE NO: 2002-02665 p COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GARNISHEE SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now R. Thomas Kline Cumberland County, Pennsylvania, to law, at 0000:00 Hours, on the 24th day of June , as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , POWELL SANDP~A , in the hands, possession, or control of the within named Garnishee CHARLES W. EVERHART 104 SOUTH LOCUST STREET , Sheriff or Deputy Sheriff of who being duly sworn according 2002, attached APT 1-B SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to NOT SERVED- GARNISHEE NAMED IS DECEASED personally__ true and attested copies of the within WRIT OF EXECUTION and made the contents thereof known to His Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 So answers: R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo Sworn and subscribed to before me this /~f~ day of0,~~ ~2~ A.D. Pro~h6hotary ' SHERIFF'S RETURN - GARNISHEE CA.SE NO: 2002-02665 P COMMONWEALTH OF PENNSLYV~zNIA COUNTY OF CUMBERLAND SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now DAWN L. KELL Cumberland County of Pennsylvania, to law, at 0018:40 Hours, on the 24th day of June , as herein commanded all goods, chattels, rights, debts, moneys of the within named DEFENDANT , POWELL MATTHEW hands, possession, or control of the within named Garnishee MRS CHARLES EVERHART 104 SOUTH LOCUST ST ,Sheriff or Deputy Sheriff of who being duly sworn according 2002, attached credits, and in the APT 1-B SHIREMA/qSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to MRS. CHARLES EVERHART , 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 .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this /A~ day of ~ A.D. Pr6thonotary ' 7 ' R. Thomas Kline Sheriff of Cumberland County 00/00/0000 Deputy Sheriff SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYVA_NIA COUNTY OF CUMBERLAND SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now DAWN L. KELL ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0018:40 Hours, on the 24th day of June , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , POWELL SANDP~A in the hands, possession, or control of the within named Garnishee MRS. CHARLES EVERHART 104 SOUTH LOCUST STREET APT 1-B SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to MRS. CHARLES EVERHART personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION true and made the contents there of known to Her . Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this /~f_ day of O~,,~3- ~ o~ A.D. pz~ot~honotary v _ So answe s: ' ·. R. Thomas Kline '~ Sheriff of Cumberland County oo/oo/oooo Deputy Sheriff SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now DAWN L. KELL Cumberland County of Pennsylvania, to law, at 0016:48 Hours, on the 24th day of June as herein commanded all goods, chattels, moneys of the within named DEFENDANT POWELL MATTHEW hands, possession, BRETT FREEDMAN 104 rights, debts, ,Sheriff or Deputy Sheriff of who being duly sworn according 2002, attached credits, and or control of the within named Garnishee SOUTH LOCUST ST , in the APT 2-B SHIRENLANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to BRETT FREEDMAN personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this /~--- day of 0J~.u~3~ ~b3o .2~ A.D. Pr~tt~onotary R. Thomas Kline Sheriff of Cumberland County 00/00/0000 Deputy Sheriff SHERIFF'S CA~E NO: 2002-02665 P COMMONWEALTH OF PENNSLYVAiqIA COUNTY OF CUMBERLAND RETURN - GARNISHEE SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now DAWN L. KELL Cumberland County of Pennsylvania, to law, at 0016:48 Hours, on the 26th day of June , as herein commanded all goods, chattels, rights, debts, moneys of the within named DEFENDANT , POWELL SANDRA hands, possession, or control of the within named Garnishee BRETT FREEDMAN 104 SOUTH LOCUST ST ,Sheriff or Deputy Sheriff of who being duly sworn according 2002, attached credits, and , in the APT 2-B SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to BRETT FREEDMAN personally three copies of interogatories together with 3 t rue and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this /~t~ day of ~ ~/~o 2~ A.D. P/rc~hon0tary ~ ' ' R. Thomas Kline Sheriff of Cumberland County 00/00/0000 By Deputy Sheriff SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02665 P COMMONWE~LLTH OF PENNSLYVANIA COUNTY OF CUMBERLAND SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now R. Thomas Kline , Sheriff or Deputy Sheriff of Cunzberland County, Pennsylvania, who being duly sworn according to law, at 0016:48 Hours, on the 24th day of June , 2002, attached as herein commanded all goods, chattels, rights, moneys of the within named DEFENDANT , POWELL MATTHEW debts, credits, and , in the hands, possession, or control of the within named Garnishee MRS. BRETT FREEDMAN 104 SOUTH LOCUST ST APT 2-B SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to NOT SERVED- NAMED GARNISHEE DOES NOT EXIST personally __ true and attested copies of the within WRIT OF EXECUTION and made the contents thereof known to Her . Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo Sworn and subscribed to before me this /~ day of 0~,.~ Pro[hbnotary ~ * ' SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-02665 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND SHIREMANSTOWN BOROUGH OF THE VS POWEL MATTHEW ET AL And now R. Thomas Kline Cumberland County, Pennsylvania, to law, at 0016:48 Hours, on the 24th day of June as herein commanded all goods, chattels, rights, debts, moneys of the within named DEFENDANT , POWELL SANDRA hands, possession, or control of the within named Garnishee MRS. BRETT FREEDMAN 104 SOUTH LOCUST ST , Sheriff or Deputy Sheriff of who being duly sworn according 2002, attached credits, and , in the APT 2-B SHIREMANSTOWN, PA 17011 Cumberland County, Pennsylvania, by handing to NOT SERVED-NAMED GARNISHEE DOES NOT EXIST , personally__ true and attested copies of the within WRIT OF EXECUTION and made the contents thereof known to Her . Sheriff's Costs: So answers: Docketing .00 Service .00 Affidavit .00 Surcharge .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 00/00/0000 Sworn and subscribed to before me this I~~ day of ~v~3~ ~ ~L- A.D. ~ Pro~6not ar~ *~