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Home My WebLink About96-02144 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Sears, Roebuck and Company, Plaintiff NO. 96-2144 vs. Katherine L. Barnhill, Defendant CIVIL ACTION-LAW INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION TO: PSECU 1 Credit Union Place Harrisburg, PA 17110 PURSUANT TO RULE 3114 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE! A. 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. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was issued. C. "You" means the mai" office and all branch offices, representatives, employees, and agents of Southwest National Bank. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, and an explanation should be given as to the basi~ on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT .KATHERINE L. BARNHILL SSIt 227-70.9813 1. DEPOSITORY ACCOUNT~ At the time you were served or at any subsequent time, state whether or not the De endant(s) maintains any checking, savings, lines 01 credit, certllicate 01 deposit's or other depository accounts with your institution. II so, state the idenliflcatlon numbers 01 those accounts, and the amount or amounts the Defendant(s) has In each account. lIthe Delendant(s) maintains any 01 these jointly with any other person, or persons, give their name and address. See rcvcrse s ide for answcr I. lA. DIRECT DEPOSIT ~CCOUNf.S: Are any 01 the accounts you have listed above direct deposit accounts II yes, p ease state the Identlllcatlon numbers 01 those accounts. Yes. Account 0227709813 Katherine Bamhi 11 2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequenttime, state whether or not the Delendant(s) maintains any sale deposit box or boxes. II so, Include the Identilicatlon number or other designation 01 the box or boxes. Include a lull description 01 the contents and also the amount 01 cash among those contents. lIthe Delendant(s) maintains any of these jointly with any other person or persons give their lull name and address. No Sd fc depc: n~ L t: be )xe~j. 3. PERSONAL PROPERTY: At the time you were sarved or at any subsequenttime, state whether or not Delendant(s) owns any personal property that was In your possession and/or control. II so, include a lull description 01 all personal property giving lull value and present location. State also whether or not there are any encumberances or liens holders, the present balance 01 the encumberance. State where and when the encumberances or liens was recorded. II the Delendant(s) owns any personal property jointly with any person or persons, give names and address. None. ........ ' L 4. OT~EA ~SSETS: At the lime you were served or at any subsequent lime, did you know of t e ex stence of any other asset(s) of the Defendant(s) which are not disclosed In the preceding Interrogatories. If so, please set forth all details concerning those asset. None. 6. PROPE~TY: At the time you were served or at any subsequent time, was there In your possess on, custody, or control or in the Joining possession, custody, or control of yourself and one or mora other persons any property of any nature owned solely or in part by any Defendant(s)? If so, please describe for each Defendant each item of property including Its value. None. 6. ~EAL PROPERTY: At the time you were served or at any subsequent time, did you hold egal, or equitable title to any property of any nature owned solely or In part by the Delencfant(sl or In which and Defendant(s) held or claimed any interest? If so, describe lor each Delendant each item of property Including its value and the interest held by the Delendant(s). No. ._..,,/A II- . ) I , ( ,'f 'I, ;'.j l~ ~I: I;: ,t/ t' D,'.(}PH!~~ Cl)lU4 r ( '1t(I;IFF'~ OFFICE r ,', Uh.!~ (;(/'I~. r , Cf ut.' ,,,"u., ~ II,', ~ ~ ,', [11 iI. ,.., I. ,\ I.': (J I ',.. '"''] 11., c, ~'f I: II ; : NE'CEIVLD " ..... \ll '- 11-; lJ': r,; ,-::" . (" & ,';-:-- ./1 ~ , .... "l,' 'I:; :,' ., --!-J' /. ,'- ' f 'j', C:l .:jj Ii'" f"l ) ;( J' ..>: IT: 1 ;-., : II!.ll , C. !: If.L , ,', ;,,: ~j " m <..i (1\ 0 ,0' .~. rJ ,j , ,,' " f IN THE COURT OF COHMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERIlAN AQUISITION, LP ASSIGNEE OF SEARS, ROEBUCK AND CO. 1.5 SOUTH MAIN STREET GREENVILLE S.C. 29601 Plaint i ff I No. ll~_ ?14d I I I I I v.. KATHERINE L BARNHILL 107 MY DR CARLISLE PA 17013-8810 D.hndant (.) PRAECIPE TO SETTLE AND SATISFY PLEASE HARK THE ABOVE-CAPTIONED ACTION AS SETTLED, SATISFIED AND DISCONTINUED. Re.pectfully .ub.ittad. By: A8y #87062 Daniel F. Wol on 1120617 Bruca H. Cherki. #18837 Philip C. W.rholic #86341 Ronald K. Abra..on #94266 Ronald S. C.ntar #94000 Donald P. Shiffer, III 11894.51 WOLPOF' 60 ABRAIISON, L. L. P. Attorney. in the Pr.ctice of Debt Collection 267 Ea.t Market St., York, PA 17403 (717) 846-12.52 Couneel for Plaintiff .I~ ee: PAPR4/PAI76A W60A FILE NO. 119641077 f I 1 , ! t ~ i , .-..1\ , FORM IIA WAIVER EXPLANATION OF RIGHTS IN CONNECTION WITH SIGNING OF INSTRUMENT CONTAINING CONFESSION OF JUDGMENT, AS REQUIRED BY OPINION OF SUPREME COURT OF HIE UNITED STATES. The undersigned clearly and spedfically understand that by signing the note above referred to, containing a Confession of Judgment clause: I. We and each of us authorize SEARS._ ROEBUCK AND CO.MFMI.L__.____to enter a judgment against the undersigned, or either of us, at. its discretion and in its favor without Mtice and without declaration of default for non-payment, which entry will give the holder a lien as security for payment upon the real property (including the home) owned by the undersigned at the time of entry, and a lien on personal property owned by the under- signed at the time it is given to the Sheriff for execution. 2. We and each of us waive all right to notice and to have an opportunity to be heard prior to the entry of the judgment on the Court records, understanding that the only method to challenge this judgment would be by proceedings in Court to open or strike it, which proceedings would result in ~ub5tantial attorneys fees whkh the undersigned would have to pay. (Without such clause containing a Confession of Judgment the holder would have to file suite against the undersigned which would give the undersigned an opportunity for a hearing wili',h the undersigned doe.s not have by reason of the Confession.) The undersigned acknowledge receipt of a copy of this affidavit and certify that after reading and fully understanding iI, the undersigned have signed this affidavit intentionally, understandingly and voluntarily waiving all the above rights, being willing to sign such note despite the consequences set forth above. )(~61 t! J) J ;U/ _~ .6~IL< . ~ f KA ERINE L. BARNHII.L . (SEAL) .____._______(SEAl.) ro' .' t: ~ 1 )" - 'I, i'" ';1, , , -, " t'" .. -.1 , , :, c, l...;~.l ) ,") ." "l ) " , , ,I II , c.::J ,', I ~ , \., I , 244 . PAOTH .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SEARS, ROEBUCK AND COMPANY vs. KATHERINE L. BARNHILL NO. 127 TOWER CIRCLE CARLISLE, PI'. 17013-9628 NOTICE OF ORDER, OE'CFlEF. OR JUDGMENT TO: ( ) Plaintiff ( >>Defendant ( ) Garnishee ( ) Additional Defendant You are hereby notified that the following Order, Decree, or Judgment has been entered against you on ( ) Decree Nisi In Equity. ( ) Final Decree in Equity. (X ) Judgement of ( X) Confession ( ) Default ( ) Non.Pros (X ) Judgement Is in the amount of $ ) Verdict ) Non-Suit ( ) Arbitration Award 2387.62 , PLUS COSTS. ) District Justice Transcript of Judgment In CIVIL ACTION in the amount 01 $ .__" PLUS COSTS. ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by th.e Pennsylvania Department or Transportation. PROTHONOTARY by If you have any qL'estlons concerning the above. olease contact: Name of (Attorney/Filing Party) _ Address WOLFSON .\ KAHAN, P.C. 267 fast Market Street York, PA 17403 Telephone Number l1J.7..J..__.~1_i?_::.!~' 2... ~' ~ ~ ...j' II, ~ " r \j f '--\' ~ r \...1 C>.') 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