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