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Home My WebLink About07-1821I Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff V. DONNA J SYLVAIN 302 South Penn Street Shippensburg PA 17257-8717 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0AJ _ IP?I Defendant : CIVIL ACTION - LAW Complaint - Notice 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 (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 claim 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-11407 Burton Neil & Associates, P.C. By: Burton Neil, Esquire, I.D. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North, Sioux Falls, SD Plaintiff V. DONNA J SYLVAIN 302 South Penn Street Shippensburg PA 17257-8717 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 _ IP21 CIVIL ACTION - LAW Complaint Plaintiff is CITIBANK (SOUTH DAKOTA) N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Donna J Sylvain, who resides at 302 South Penn Street, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff is a national banking association, engaged in various types of banking business including consumer lending through the issuance of credit cards. 4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account number 5424180168558192 hereinafter referred to as the credit card account. 5. Plaintiff kept accurate running records of all debits and credits to the account. 6. Plaintiff mailed to defendant monthly statements for the account including the billing statement attached hereto as Exhibit A. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 7. Before plaintiff mailed Exhibit A, defendant had for many months made payments on Defendant account of the billing statement or retained the statement without payment. 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $10,271.03 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. Wherefore, plaintiff demands judgment against defendant for the sum of $10,271.03, and the costs of this action. The law firm of Burton Neil & Associates, P.C. is a debt collector. 12/15/06 $10271.03 $10271.03 SITE:KC-CL TM:C0-5000 02/14/07 CITI CARDS PO BOX 183065 DONNA J SYLVAIN COLUMBUS, OH 302 S PENN ST 43218-3065 SHIPPENSBURG PA 17257-8717000 ? ?1 Citi® Platinum Select Card Account Number 5424 1801 6855 8192 Customer Service: 1-800-950-5114 BOX 6500 SIOUX FALLS SD Total Credit Line Available Credit Line $11400 $0 Statement/ Amount Over Closing 1/22/2006 e $0redit .00e 57117 1 Cash Advance Limit Available Cash Limit $600 $0 Past Due Minimum Due 1524.22 $399.66 C tle New Balance $10271.03 Minimum Amount Due $10271.03 ACID:ROB0554 22:11:57: Sale Date Post Date Reference Number Activity Since Last Statement Amount Standard Purch 39.00 11/22 LATE FEE - OCT PAYMENT PAST DUE 66 0000 0000000000 11122 PURCHASES*FINANCE CHARGE*PERIODIC RATE 84 0000 00000000008.66 Your late fee was based on your account balance as of the payment due date (11/16/06), which was $9,973.37. Help is available! Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. EXHIBIT Previous (+) Purchases (-) Payments +) FINANCE (=) New Account Summary Balance & Advances & Credits CHARGE Balance PURCHASES $9,973.37 $39.00 0.00 00 00 0 0 1 $258.66 0.00 $10,271.03 TOTALCES $9,9730. .37 . . 0.00 $39.00 $258.66 $10,271.03 Days This Billing Period: 29 Balance Subject to Periodic Nominal ANNUAL Rate Summary Finance Charge Rate APR PERCENTAGE RATE PURCHASES Standard Purch $10,097.69 0.08833%(D) 32.240% 32.240% ADVANCES Standard Adv $0.00 0.08833%(D) 32.240% 32.240% Verification I, Shauna Houghton am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA), N.A. retained to perform services including but not primarily limited to collecting delinquent debt. I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. f Signature Shaun Houghton Donna J Sylvain 5424180168558192 nWrlguoH snusri8 ?afryg??H ??u?>n2 (', w CD ..p a { CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. DONNA J SYLVAIN 302 South Penn Street Shippensburg PA 17257-8717 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1821 : CIVIL ACTION - LAW Praecipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $10,271.03 $10,271.03 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER PA.%CIV.P. 236 2. Pro Prothonotary Bu yonil ciates, P.C. Byrit J Suttell, Esquire Attorney for Plaintiff I.D. #204140 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-11407 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. DONNA J SYLVAIN Defendant IN THE COURT OF COMMON PLEAS C-11407 CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1821 : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Donna J Sylvain 302 South Penn Street Shippensburg PA 17257-8717 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 DATE OF NOTICE: April 26, 2007 In making this communication, we advise our office is a debt collector. limillINliIlilliIlilllili III111111111IIIN lullI Burton Neil & Associates, P.C. By: Burton Neil, Esquire Attorney for Plaintiff Identification No. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 I?IIII?I ft .- ti v u ?r i a O' C-) Cv N ca L`.J 0 it I F:: r. r- --G Burton Neil & Associates, P.C. BY: Brit J Suttell, Esquire ID. NO. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. DONNA J SYLVAIN Defendant : NO. 07-1821 : CIVIL ACTION - LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on Prothonotary Deputy If you have any questions concerning the above, please contact: Brit J Suttell, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. SHERIFF'S RETURN - REGULAR CASE NO: 2007-01821 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS SYLVAIN DONNA J RICHARD SMITH day Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SYLVAIN DONNA J the DEFENDANT at 1235:00 HOURS, on the 4th day of April , 2007 at 302 SOUTH PENN STREET SHIPPENSBURG, PA 17257-8717 MELANIDA ROCKWELL, ROOMMATE , Sheriff or Deputy Sheriff of by handing to ADULT IN CHARGE 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 19.20 Affidavit .00 Surcharge 10.00 .00 y?i3?a 7 c" T 4 7. 2 0 Sworn and Subscibed to before me this of So Answers: R. Thomas Kline 04/05/2007 BURTON NEIL ;1epUe S CIATES By: y Sheriff A. D. PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. DONNA J SYLVAIN 302 South Penn Street, Shippensburg PA 17257-8717 Defendant(s) CITIZENS BANK 665 N. East Street, Carlisle, PA 17013 Garnishee(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1821 CIVIL, ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. against DONNA J SYLVAIN , Defendant(s) 3. and against CITIZENS BANK , Garnishee(s) 4. and index this writ (a) against (b) against Defendant(s) Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) NO LEVY. GARNISHMENT ONLY Serve interrogatories on garnishee at: 665 N. East Street, Carlisle, PA 17013 5. Amount Due $10,271.03 Interest from 5/14/07 $346.26 Credit $1,759.00 Total $8,858.29* *Plus writ costs Dated: December 18, 2007 Attorney NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. C-11407 -1' ?6 f 41A n w o g F? J 0 -b D 41 - -.a -?,, ;? oo 00 o Q' tZ o (> v CrIl w ?a r rs WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1821 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK (SOUTH DAKOTA), N.A., Plaintiff (s) From DONNA J. SYLVAIN, 302 South Penn Street, Shippensburg, PA 17257-8717 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: CITIZENS BANK, 665 N. East Street, Carlisle, PA 17013 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 $8,512.03 Interest from 5/14/07 -- $346.26 Atty's Comm % Atty Paid $166.70 Plaintiff Paid Date: 12/26/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs s P, 6p" C i LongProthonotary By: Y??L. Deputy U, V REQUESTING PARTY: Name BURTON NEIL, ESQUIRE Address: 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF Telephone : 610-696-2120 Supreme Court ID No. 11348 SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-01821 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS SYLVAIN DONNA J And now VALARIE WEARY Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:41 Hours, on the 2nd day of January , 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT -7 TT TTT TTT TIfITTTT77T T hands, possession, or control of the within named Garnishee 665 N EAST ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to KAREN A. DIETZ (ASST. BRANCH 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 , in the true and made So answers: .00 .s .? .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 0 0?//aF?6 Y ?j -- 01/03/2008 day of By Deputy Sheriff A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION CITIBANK (SOUTH DAKOTA), N.A., No. 07-1821 Plaintiff(s), ) Answers to Interrogatories vs. ) Code: 200 Execution DONNA J. SYLVAIN, ) Filed on Behalf of Garnishee, Defendant(s), ) Citizens Bank of Pennsylvania vs. s ) Counsel of Record for Citizens Bank of Pennsylvania, ) this Party: Garnishee. ) Nicholas Deenis, Esquire PA I.D. No. 62378 2600 One Commerce Square Philadelphia, PA 19103 - 7098 (215)-564-8142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION CITIBANK (SOUTH DAKOTA), N.A. Plaintiff(s), VS. DONNA J. SYLVAIN Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. No. 07-1821 ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1 to 9) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee Citizens Bank of PA, states that it maintains a checking account in the name of the Defendant; Donna J. Sylvain, with an available balance of $1,121.91, after deduction of garnishee's pfocessing fee of $50.00 and before statutory exemption of $300.00, being held subject to this Writ of Execution. .? y Certificate of Service I, Laura Noel, hereby certify that a true and correct copy of the Answers to Interrogatories-}has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this day of TL )1V 2008. BURTON NEIL & ASSOCIATES 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 DONNA J. SYLVAIN Laura Noel COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Laura Noel who being duly sworn according to the law deposes and says that she is an Operations Clerk, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Laura el Sworn and subscribed before me this day of 2008. ` I MM(--)NWEALrH C-F PENNSYLvH,,,,,, Notarial Seal Bruce D. MounUoy, Notary public City Of PltSbungh, Allegheny County My Commission Expires May 15, 2010 Member, Pennsylvania AssOOlatlon Of Notarise t' A. I A Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. DONNA J SYLVAIN Defendant and CITIZENS BANK Garnishee NO. 07-1821 CIVIL ACTION - LAW Praecipe for Judgment Against Garnishee To the Prothonotary: Kindly enter judgment in favor of plaintiff, CITIBANK (SOUTH DAKOTA), N.A., and against garnishee, CITIZENS BANK, for the amount admitted in its possession in the attached Answers to Interrogatories in the total sum of $821.91. Burton Neyi& Associates, P.C. Neil., Esquire v for Plaintiff AND NOW this `s+ day of Q, favor of plaintiff, CITIBANK (SOUTH DAKOTA), N.A., , judgment is hereby entered in against garnishee, CITIZENS BANK, in accordance with the attached Answers to Interrogatone 'n the total sum $821.91. P thonotary In making this communication, we advise that our firm is a debt collector. i C-(1Y07 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION CMBANK (SOUTH DAKOTA), N.A., ) No. 07-1821 Plaintiff(s), Answers to iiaterrogatonies vs. DONNA Y. SYLVAIN, Y Defendant(s), VS. t Citizens Bank of Pennsylvania, Garnishee. .s Z 'd OD 'ON ) } ) Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Patty: Nicholas Deenis, Esquire PA T.D. No, 62378 2600 One Commerce Square Philadelphia, PA 19103 - 7098 (215)-564-8142 AVD: l l 8006 '66 'lnr 1 IN TIM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION CITIBANK (SOUTH DAKOTA), N.A. Plaintiff(s), VS. DONNA r. SYLVAIN Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. No. 07-1821 ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaindf f(s): ' (NUMBERS 1 to 9) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the follow Answers to Interrogatories: The Garnishee Citizens Bank of PA, states that it maintains a checldng account in the name of the Defendant; Donna J. Sylvain, with an available balmoe of $1,121.91, after deduction of garnishee's processing fee of $50.00 and before statutory exemption of $300.00, being held subject to this Writ of Execution. ti ? 'd OD 'ON 0D: l l 800 U 'inr Certificate of Service I, Laura Noel, hereby certify that a true and correct copy of the Answers to Interrogatoriestas been served upon the following by depositing it in the U. S. Maul, postage a prepaid, this ;?A^Jt day of To 2008. BURTON NEIL & ASSOCIATES 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 DONNA J. SYLVAIN " 6 ;' I/- Laura Noel ti 'd O?ti'ON PD:l l 8001 '61,10P Y COMMONWEALTH OF PENNSYLVANIA } SS; COUNTY OF ALLEGHENY } Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Laura Noel who being duty sworn according to the law deposes and says that she is an Operations Clerk, and that the t statements set forth in foregoing Atswers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Sworn and subscribed before me this day of 2008. Laura el L OA4A4ONwFALTN OF PENNS ' D. Nftriwi Seal Of Y, Notary pubic Mr Altagr,eny caur,Q, Member, pan+d6 May 15, 201o b N a a A&soclasjon of otarlas t 5 'd Orb 'ON AVD: l l 80H U 'inr rw? Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. DONNA J SYLVAIN Defendant and CITIZENS BANK Garnishee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1821 : CIVIL ACTION - LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on q I lot / /C* rBy: Deputy If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 In making this communication, we advise that our firm is a debt collector. 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 85.99 Docketing 18.00 64.01 Poundage 1.69 Advertising Law Library .50 Prothonotary 2.00 Refunded on 07/29/08 Mileage 4.80 Misc. Surcharge 20.00 Levy 30.00 Post Pone Sale Certified Mail. Postage Garnishee 9.00 TOTAL 85.99 $ - 13.09 So Answers, R. Thomas Kline, eriff By. 9Z =Z d LZ 0301001 VJAWNS 3Hiy30 331JJO eK-? `sus 1 c U WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1821 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK (SOUTH DAKOTA), N.A., Plaintiff (s) From DONNA J. SYLVAIN, 302 South Penn Street, Shippensburg, PA 17257-8717 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: CITIZENS BANK, 665 N. East Street, Carlisle, PA 17013 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 $8,512.03 L.L. $.50 Interest from 5/14/07 -- $346.26 Atty's Comm % Atty Paid $166.70 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 12/26/07 (Seal) REQUESTING PARTY: Name BURTON NEIL, ESQUIRE Address: 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF & L4?2 P rtis Long, Prothonotary By: _ Deputy Telephone: 610-696-2120 Supreme Court ID No. 11348 "4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION 07-1821 CITIBANK (SOUTH DAKOTA), N.A., Plaintiff(s), VS. DONNA J. SYLVAIN, Defendant(s), vs. Answers to Interrogatones Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire Citizens Bank of Pennsylvania, Garnishee. PA I.D. No. 62378 2600 One Commerce Square Philadelphia, PA 19103 - 7098 (215)-564-8142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION CITIBANK (SOUTH DAKOTA), N.A. Plaintiff(s), VS. DONNA J. SYLVAIN Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. 07-1821 ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS _1 to _9__) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of PA, states that it maintains a checking account in the name of the Defendant, Donna J. Sylvain, with a balance of $4235.93 after the $300.00 statutory exemption and the $50.00 Garnishee's processing fee, being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Teria Pitts who being duly sworn according to the law deposes and says that she is an operations clerk, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Teria Pitt s Sworn and subscribed before me t is day of ji-?']- 2008. 04t" i1i J&- Notary Public COMMONWEALTH OF PENNSYLVANIA NalIE al Seal Andrea Pare10. Notary Pub i( City Of Pltisburgh, AleglvW County My Cortrnissw Expires Dec. 22.2U08 Member, Pennsylvania Association of Notaries .f Certificate of Service I, Teria Pitts, hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this day of , 2008. BURTON NEIL & ASSOCIATES 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 DONNA J. SYLVAIN Teria Pitts r„l J Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. DONNA J SYLVAIN Defendant and CITIZENS BANK Garnishee : NO. 07-1821 : CIVIL ACTION - LAW Amended Praecipe for Judgment Against Garnishee To the Prothonotary: Kindly amend the judgment in favor of plaintiff, CITIBANK (SOUTH DAKOTA), N.A., and against garnishee, CITIZENS BANK, for the amount admitted in its possession in the attached Amended Answers to Interrogatories in the total sum of $4235.93. Burton ?m By: Associates, P.C. Burton N8i1., Esquire Attorney for Plaintiff AND NOW this I to" day of Ze p'f - , 2008, judgment is hereby entered in favor of plaintiff, CITIBANK (SOUTH DAKOTA), N.A., and against garnishee, CITIZENS BANK, in accordance with the attached Answers to Interrogatories in the total su of $4235.93. rothonota In making this communication, we advise that our firm is a debt collector. .. c-,ryas IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION DONNA J. SYLVAIN Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS _l- to _9___) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of PA, states that it maintains a checking account in the name of the Defendant, Donna J. Sylvain, with a balance of $4235.93 after the $300.00 statutory exemption and the $50.00 Garnishee's processing fee, being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Teria Pitts who being duly sworn according _ to the law deposes and says that she is an operations clerk, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. io ? ) h, _j Teria Pitts COWAONWO& N OF PENNSYLVANIA Ni?atfal Seal Andes Pig v1kN NdWy Pubs:' CKY of Plu &JSA A-- mycow° My OammNeiort E;qM flea ffi, 20Q6 Member, PenroylvaNa Aswok#w of Notaries Sworn and subscribed before i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION CITIBANK (SOUTH DAKOTA), N.A., - - -- - Prain i (s, vs. DONNA J. SYLVAIN, Defendant(s), vs. Citizens Bank of Pennsylvania, Garnishee. 07-1821 } Answers to Interrogatories - -- -- ----------- Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA I.D. No. 62378 2600 One Commerce Square Philadelphia, PA 19103 - 7098 (215)-564-8142 ?' ?{ ? ''?` ? p = O d U'1 d ? ? ?? . ' ,,, .. ? -? ?, ?? Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. DONNA J SYLVAIN Defendant and CITIZENS BANK Garnishee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1821 : CIVIL ACTION - LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on D a Prothonotary By: Deputy If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 In making this communication, we advise that our firm is a debt collector. Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-1821 DONNA J SYLVAIN Defendant and CITIZENS BANK Garnishee : CIVIL ACTION - LAW Praecipe to Satisfy Judgment Against Garnishee To the Prothonotary: Kindly mark the judgment against garnishee CITIZENS BANK, in the above matter, SATISFIED on payment of your costs only. Burton,Xeil &/4Vsociates, P.C. By: Ya em stein, Esquire A mey for Plaintiff The law firm of Burton Neil & Associates is a debt collector: C-11407 r 4 r AL tA