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HomeMy WebLinkAbout07-0853BELCO COMMUNITY CREDIT UNION Plaintiff VS. TAMMY JO EDMUNDSON Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION-LAW NO: O7't - I' olu? ? N O T I C E 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 with the Court 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 claim 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Legal Services, Inc. 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 N 0 T I C I A Le han demandado a usted en la corte. Si usted quiere 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 notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Legal Services, Inc. 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 BELCO COMMUNITY CREDIT UNION Plaintiff TAMMY JO EDMUNDSON Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.. 0 °1- Psi C" Imo.-. CIVIL ACTION - LAW COMPLAINT 1. Plaintiff is Belco Federal Credit Union, hereinafter referred to as "BELCO", a Pennsylvania Corporation with an office at 403 N. 2nd Street, Harrisburg, Dauphin County, Pennsylvania 17108. 2. Tammy Jo Edmundson, a Defendant, is an adult individual with an address at 11C Richard Lane, Apt. 211, Camp Hill, Pennsylvania 17011. 3. Defendant applied for a L8 Signature Loan from Plaintiff pursuant to the Application dated August 30, 2004, which is available but not attached because it contains social security numbers and other personal information. 4. Defendant's delinquent balance on the account is $12,879.90. 5. Because of Defendant's failure to make monthly payments and in accordance with the standard Security Agreement, a copy which is attached hereto, marked Exhibit "A" and made part hereof, Defendant owes an attorney commission of $1931.99 for a total of $14,811.89. 6. Defendant made two payments totaling $609.00, leaving a balance of $14,202.89. 7. Defendant has failed and refused to bring her account current. 8. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. WHEREFORE, Plaintiff requests entry of judgment against Defendant in the amount of $14,202.89 together with costs of suit thereon. Respectfully, Submitted, Date : -2-o o M , VQ(I) Arthur M. Feld, Esquire Attorney I.D. No. 07172 1309 Bridge Street New Cumberland, PA 17070 (717) 770-0292 ..*v. s::.r s=s € . r??an r_r_ear e_ev ? it a lL)n ;:, , ?? cd A? iMe rice.e d ? pltp i? I ? -1 ? Gam i bc' i ^i references r" JT - • •- J c ?naTY r. :I?: L,:!tP: - 6y ti h? ec:Ir n :jr r the crP, it tjc?cn r Col;p• Inca re. flr, d dt'Srf, d _t. _ ti:P, .. ..,.. _ ,il a i, ,. ., agree 4.. Lac of it r yo.' reee ac Jar cc, you giV I", ;r d t union `re taxes e e me propel v wna-. cur- ° keep it Insurec, s I, ?,,? .- „ur i•.,. r , in the p-cper ,tescrib d in the oec,i Ity t r ? ,rl sect i r interest you give in-li,des all accosslon tl c E , Iv v pay uG ons a e th lo; tAihicn re attached to or insta;lru iii the prate v now ?. - se n -ere<' a'sc includ er- .or the aMoun?s 1, In J - ` Fit ut M cup,, ` i , c L re. luotls any inoi?i you re,; , n r t. r ., .. : .. Jilt! UlIde, if - ?i0 are in defanit under the f i S t , .: , a t. COVERS -ThP SBCurlty it QI ST 9 Mttres tnP rIC7 L /a GS X17. g'? Upe f h8'Je no! signed ; , .,DI ;; I : au t 'Gi;f detain, t se-ure,S of ,i e1 have no%' : In the., ful,-e uri- el IFF , : n A r LuANLI IE a Crtt and any of you owe rho c e„ It _ _ jiltr. IL.3lil. to any a, son no fi the -scripti . is irl' ,t -R' . Y: Ef3c r :, c tt EEA E:?. T .. .ter, t, rh s1a lliitJ_( -I U it - (. I':D kly 1 ., : ,.. i illcB Practice Ru u, Ill", ,roariyv,l. secure only Uhe a aid Lot Julie f_ilcu t" ,it , o't 0? c U7 d " tIIL ..0?`,`gI INt n eda y'[ec lent a J tJI '-8 pC5Se5SI0r1 you owe. -- the property. You agree the credit union has the right to take possession PI NIERSHIP OF THE ROPER Y - You `lroml , i I .i you own the prone t , of the property taathout going to court and without giving you advance notice, f { to i l t t I: o l? aCtv flce , ert ou rom you NIII use the 1 , 'U ar: asked GO t c ..V un Ur :DI p'Onllse to de lve"Ina property , r. : . , . p y; y p , au a - - 1 ?t p ,lG ' t at no one else. ,. s any ImpreST '.P I J - m:. anG DI a.; ' lit .'JT t r, „OSC r cut U., on N ii not Vii hid ,; hav? r a. n I t It mu! a ma.]trDIL the 'fedlt union t a, nj; (E ffir ar xi ofl e 'Rich t n i I U tl Free t ent ;)romise n.,1 to °ell or h r urcrty c it to use it as security o : Ida I %eIIII ti e inside t r r O l t;. ?r (r r. p y ?nl. t,t another creditor until the adva it c regard Y.,u promise you will illoth nt: Security r you or make I? atanat et L t,a,m. , L In erest or lien to attach !L , '. I Ivt . , rt • ?t is,r, -n,;r act l ?s ? . the . c edi, -essic l ,I.l the o. .. of -property, it can son it and apl;l;r r iaJC. : Inon?.y receiv it Lc _ :nfs you dwe the credit union. The credit union Rtif CTIN;? THE SECURITY IN? Y It your our state issues a titsa Tor the M! give you notice r` hdlg sa!e or lire date after vriit,h a private a i n III he held. The menses of the credit union for taking possessing of and selling p ?it; you promise to have [he crct l unions security nterest shown ro the title The I ru union may h vi in II P(;' a Ina ",ng to re. c;i Ti i to property will be ut-ted from the monev receive from t[h(! .,.al. . rr?e to rroiec I ril 'I unnt t:c r tn,:rl , t. ,I t,e I t; ss ma Include flit, of sane. ng the on A,,. ; : e.Pn c r` `r l kale and i + J rrt S to 1h uei T'tte d!r sta v, of ded 0Idel r .gfjr;•i FBI P Si Ill l: nr r;L 1 , Ur t G li lit 1-. WII !it aDra trl kd tip? , . you owe. Wi.:ci a v mL? (, . It acreemen t. c.ropelty. ?,. I e. .F R Ir F i l ;ida,W11 ;,1 , dig t , r:,,rail ,o ha , rpa,Inn amount In it IIb if l Ii UI It/ L?11t I Ili ,P v tLll goo t, tt:uat 1c r rt?in dsli tbli *lo e r ; been applied to the gripaid balance ' ''-It In tkitlg maJoI Chan 1 t i I?IooPft tie at yara lilt to ? .at lta VY I - i S agreement YOU ac+°r to IiiV ios . ne :.,edit Uniu, ui ore changing you 3 esT c.I that a nuJr,t at the same etc the advance a it:t that at,_iun? ?- ymere the property is kept- the credit untol 1, i! t rc ? it,pF iv paid. 5j Promptly notify the credit u.,,a, he prope y I riagc ?It: ; u ?aSac. - s a .I. 64.' nt Ilv€ i ;GH S AND CHANGES IN THE AuREENIENT - The (t; NCt use the o, operty ?t. ,lay wliawful purpose ,;tilt t ion can d( .,y enfor:; g ally of its rights under this agreement any number PRLIPEP r' INSURANCE it ,ES AND FEES i .. „?u tl 1:, p„? all pxas v tI r.. t sent ii,r III'' tc ? w e it - rights later. The credit union art' f e., fluke registl +tlon c:r ?, clue Dn the property and to keep he property u Ifrr r iltiS aoreerne a gad ,st your eirs or legal representatives. If the T } insured against lc end ca ge h; mount and coverage of the property i; w,on C:angjeS the tot ? of t h e (, iLiNFR"' Credit Agreement, you agree i nJrancc !nu.. ce ?, cept?hln, to tltt> cn.,i * anion. you tnay ,l.,vide. the property IJ (, nt: n, s n5tcc mcnt will . protect the credit un in n C_ e ..P .. ,.; - thruUgh 3 of l,,.{ clog a(Bafl}? h,:Vr;• tit I. l a;i t011C'y y',I f' "•``tPeTE,.111F.D FFFECTII,'FNESS - i. ,utip3r[ Of TFIS agree tIB;?' IS dFfermined ;;;r. You prolT tic tJ .rake the Insu 1 e policy paya;,h, th. r+ a t i..rt remain in ef[ect. F. oR TE:NNE:SS_EE CREDIT UNI®IVS ONLY OFi [?OI?TI?' DAKOTA. CREDIT UNIONS ONLY - APPLIES USE WHEN AUTOMOBILE IS PIJRCHA? ', -P ;.X &Y A N40TOR VEHICLE rS PU CH41,SLC, HOT!CE: if you do no" t4-r4 hale the i t_!j tlC( i!L _ )hie adtonloully il'IGE. .Li'_ ??` tIIC! E )„ THIS T r f f n% A.lSAC IO v,r + a nld .:e r ,.cll,,?tlo„ aurcnasen `u' ?..., ?. -inics has . 1 pu -T F, t_S L? 10 . I, ' REPOSSESSED AND SOLD , , MI if t by the c „c;I, u t ? nli cover only rn, i t8ie ih the piopc fy :1 l 'vE HE SECURED PAR"i ARE 1 ,?? The insurance will not be liability illsulanc(.. RFCEIVED A THAT SALE YOU MAY HAVE TO PAY THE DIFFERENCE You have read the above statement. and ar kr:o.rvledge that the credit union , . has explained it to you. SIGNATURE. LATE X Tue. PROPERTY DESCRIPTION ON THE REVERSE SIDE iS PART OF THIS AGREEMENT SIGNATURF DATE . . x N0 r 1U: SIGN YHly AGREEMENT ON THE REVERSE SIDE. CHECK APPLICABLE l DO iOT WRITE BELOW -- FOR CREDIT UNION USE ONLY APPROVED Q? $ w Livil rS. -.!-. DATE S,CRATURE - LINE OF CREDIT 07 -R DEBT G.SIO ?LOAN OFFICEF f TIT."iGE n PROVED- i_ YES ' "JO _iUNTCI .. Ef3 'JJILL 6E ivtHi.;t=, iF ACCEPTED, ADVANCE APPROVED ...:CREDIT COMMITTEE ON OTHER O.;_-SIDE tNFORMAPON CON IDERED: I iF `'ES, ATTACH ADDITIONAL SHEET AND DESCRIBE REFERRED TO/REASON(S) FOR. REFERRAL: - 'DESCRIBECOUNTER OFFER: - SPECIFIC REASON(S) FOR REJECTION: - ^.IGNATURES: - ,- - -- DATE X n CA" ?iEDlt COMMi7 EF .. - a VERIFICATION Helen Lorwey states subject to the penalties of 18 Pa C.S.Section 4904 relating to unsworn falsification to authorities, that he/she is the Loss Prevention Specialist for the Plaintiff in this matter, that he/she is authorized to make this affidavit on its behalf and that the facts set forth in the foregoing pleading is true and correct to the best of his/her knowledge, information and belief. 7J- a ,n , Y ?,p > C- c-n ,4W , Z BELCO COMMUNITY CREDIT UNION COURT OF COMMONS PLEAS OF CUMBERLAND COUNTY, PA Plaintiff NO.: 2007-853 TAMMY JO EDMUNDSON CIVIL ACTION - LAW Defendant PRAECIPE TO REINSTATE Would you please reinstate the Complaint against the Defendant in the above captioned matter. To Prothonotary Date: March 19, 2007 a-MA-iiv Arthur eld 1309 Bridge Street New Cumberland, PA 17070 ID# 07172 (AJ Is Q V 0 C _0 r-,c=_ C" N ra 3 tv -cf p C1 ?-t f BELCO COMMUNITY CREDIT UNION Plaintiff VS. TAMMY JO EDMUNDSON Defendant COURT OF COMMON PLEA CUMBERLAND COUNTY, P NO. 2007-853 CIVIL ACTION - LAW OF Would you please enter judgment in favor of Plaintiff and against Defendant, Tammy Jo Edmundson, 11 C Richland Lane, Apt. 11, Camp Hill, PA 17011 for failure to plead to the Complaint with ''n twenty days of service thereof. I hereby certify that the Default Notice required by Rules of Court was sent to the Defendants as,shown on the copy attached hereto. Assess damages as follows: $14,202.89, together with interest thereon from date of 'judgment together with costs of suit thereon. thur M. Feld, Esq. May 22, 2007 S SIT' .mac ?,° D C7 BELCO COMMUNITY CREDIT UNION Plaintiff VS TAMMY JO EDMUNDSON Defendant/s To TAMMY JO EDMUNDSON : IN THE COURT OF COMMON : CUMBERLAND COUNTY, PA No. d'r - Psi You are hereby notified that on MAY J6 , 2007, th judgment has been entered against you in the above capti( JUDGMENT IN THE AMOUNT OF $14,202.89 PLUS INTEREST FROM DATE OF JUDGMENT PLUS C OF SUIT THEREON DATE : MAY .30 , 2007 Lf Prothonotary I hereby certify that the name and address of the proper receive this notice under Pa. R. Civ. P. 236 is/are: ?LEAS following ed case. rson/s to TAMMY JO EDMUNDSON 11 C RICHLAND LANE, APT. 211 CAMP HILL, PA 17011 BELCO COMMUNITY CREDIT UNION Plaintiff TAMMY JO EDMUNDSON Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO.: 2007-853 CIVIL ACTION - LAW IMPORTANT NOTICE To: TAMMY JO EDMUNDSON DATE OF NOTICE: May 9, 2007 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER 4 WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORT AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THI NOTICE, A JUDGMENT MAY BE ENTERED AGAIN T YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT IRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE' MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT M Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO EE. Legal Services, Inc. 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 Arthur M. Feld, Esquire 1109 Bridge Street Njw Cumberland, PA 17070 ( 17) 770-0292 I.D. No. #07172 N I W C' 7-J W ?i t't C" v s CIO Q -V t SHERIFF'S RETURN - REGULAR CASE NO: 2007-00853 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BELCO COMMUNITY CREDIT UNION VS EDMUNDSON TAMMY JO ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VnMTTTTn QnTT 'rAMMV .7n the DEFENDANT , at 1918:00 HOURS, on the 23rd day of March 2007 at 11C RICHARD LANE APT 211 CAMP HILL, PA 17011 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 56.70 Not Found 5.00 Surcharge 10.00 Postage .39 31? 9/d 17 90.09 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 03/27/2007 ARTHUR FELD By eputy Sheri f A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION BELCO COMMUNITY CREDIT UNION VS. TAMMY JO EDMUNDSON 11 C RICHLAND LANE, APT. 211 CAMP HILL, PA 17011 Defendant ( ) Confessed Judgment (X) Other DISTRICT JUSTICE File No. 2007-853 Amount Due $13,952.00 Interest FROM 05 23 07 Atty's Comm Costs Total MEMBERS FIRST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17015 Garnishee 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. 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) LEVY ON DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY 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) and mall other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against DATE: Signature: V Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 Attorney for Plaintiff (717) 77 0-02 92 ID No. #07172 r ?'- 0?0 cY? v LU .D p O 4 6 9 4j c U _ +46 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-853 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BELCO COMMUNITY CREDIT UNION, Plaintiff (s) From TAMMY JO EDMUNDSON,11 C RICHLAND LANE, APT. 211, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY. (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, 1166 WALNUT BOTTOM RD, CARLISLE PA 17015 PROPERTY OF THE DEFENDANT IN THE POSSESSION, CUSTODY OR CONTROL OF THE SAID GARNISHEE 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 $13,952.00 L.L. $.50 Interest from 5/23/07 Atty's Comm % Atty Paid $196.59 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 9/11/07 (Seal) REQUESTING PARTY: Name ARTHUR M. FELD, ESQUIRE Address: 1309 BRIDGE STREET NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 717-770-0292 f, 2, R/Clvi?k Long, Prothonotary By: Ll"', P, . tZ., AA%L? Deputy Supreme Court ID No. 07172 0 -1 BELCO COMMUNITY CREDIT UNION IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. TAMMY JO EDMUNDSON No.2007-853 Defendant MEMBERS FIRST FEDERAL CREDIT CIVIL ACTION - LAW UNION Garnishee porcz E& -s 4-0 INTERROGATORIES TO GARNISHEE TO: MEMBERS FIRST FEDERAL CREDIT UNION, 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 CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did he claim that you owed the defendant any money or were liable to him for any reason? If so, specify how much. I 00 qCS-J\CL-F *-D L)-5 4?? i ? ?? . (OV 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, specify how much. 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? v 0 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? I`O 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 therefor? 00 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? v 7. If you are a bank of other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. K V) t 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. I v 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 a supplemental answer under oath ontaining the same. VTA , ( &? Arthur M. Feld Attorney for Plaintiff 1309 Bridge Street New Cumberland, PA 17070 (717) 770-0292 Dated: 20__a_7 ID #07172 For signature by Garnishee: IS?u- , 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. r i Dated: - 2?, 20 Q? c 3 ?1 ro = BELCO COMMUNITY CREDIT UNION Plaintiff VS. TAMMY JO EDMUNDSON Defendant/s MEMBERS FIRST FEDERAL CREDIT UNION Garnishee } IN THE COURT OF COMMON PLEAS } CUMBERLAND COUNTY } } } }#2007-853 } } } } } } Would you please dissolve the attachment against Members First Federal Credit Union Garnishee, in the above captioned matter. To Prothonotary October 5, 2007 l Y Attorney for Plaintiff ?, 1 c'? SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-00853 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BELCO COMMUNITY CREDIT UNION VS EDMUNDSON TAMMY JO And now VALERIE WEARY ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0009:36 Hours, on the 17th day of September, 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , r T AeTT TT n/lTT TT TRAIfV Tn hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM RD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BETH WAGNER (ASST. MANAGER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscribed to before me this So answers: in the true and made .00 .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County 0000 100/»-0-5/2007 day of By Deputy Sheriff 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: Advance Costs: 150.00 Sheriff's Costs 131.28 Docketing 18.00 18.72 Poundage 2.58 Advertising Law Library .50 Prothonotary 2.00 Refunded on 07/29/08 Mileage 19.20 Misc. Surcharge 40.00 Levy 40.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 131.28 ? $-? 3 -Q$ So Answers, ?Vq R. Thomas Kline, Sheriff B • Y Y a ti?J 4 2. so?r? ° e - ?V57 ?- ?l3o s3 c W WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-853 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BELCO COMMUNITY CREDIT UNION, Plaintiff (s) From TAMMY JO EDMUNDSON, 11 C RICHLAND LANE, APT. 211, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY. (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, 1166 WALNUT BOTTOM RD, CARLISLE PA 17015 PROPERTY OF THE DEFENDANT IN THE POSSESSION, CUSTODY OR CONTROL OF THE SAID GARNISHEE 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 $13,952.00 Interest from 5/23/07 Atty's Comm % Atty Paid $196.59 Plaintiff Paid Date: 9/11/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs C is R. Long, Prothonotary By:tl?d.. At e r, Deputy REQUESTING PARTY: Name ARTHUR M. FELD, ESQUIRE Address: 1309 BRIDGE STREET NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 717-770-0292 Supreme Court ID No. 07172 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-853 Civil CIVIL ACTION - LAW TO THE SHERIFF OF YORK COUNTY: To satisfy the debt, interest and costs due BELCO COMMUNITY CREDIT UNION Plaintiff (s) From TAMMY JO EDMUNDSON, 11 C RICHLAND LANE, APT. 211, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON DEFENDANTS HOUSEHOLD GOODS AND PERSONAL PROPERTY (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$11,894.31 Interest Atty's Comm % Atty Paid $357.37 Plaintiff Paid Date: AUGUST 18, 2011 (Seal) REQUESTINC PARTY: Naiae ARTHUR M. FELD, ESQUIRE Address: 1309 BRIDGE STREET NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 717-770-0292 Supreme Court ID No. 07172 L.L. Due Prothy $2.00 Other Costs David D. Buell, Prothonotary Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION BELCO COMMUNITY CREDIT UNION VS. TAMMY JO EDMUNDSON 11 C RICHLAND LANE, APT. 211 CAMP HILL, PA 17011 Defendant ( ) Confessed Judgment (X) Other DISTRICT JUSTICE c.e L? File No. 2007-853 - -- : Amount Due $11,894.31 -- Interest FROM 05/24/07r M Atty' s Comm f.'7'- ; Costs Total CO C 5' zo ar Cr c -; 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. 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) LEVY ON DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY 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) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). Indicate) DATE : _ v %ay.Ct ?a 1 O0-Ol C? 3' . ) % it u S S. SO K 1 V• 00 a cr ?4. DO 4 4 a?. u„ ?o Signature. Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 Attorney for Plaintiff (717) 770-0292 ID No. #07172 Index this writ against a a ap lam- Ck?r ygbal -e?6'_Vo9 w4j, C? ?0 1s-'::%'bkeCL