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HomeMy WebLinkAbout01-04137a VALERIE ROSENBLUTH PARK, Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street P.O. BOx 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND FIRST SELECT, INC. Plaintiff VS. WILLIAM H ZIMMERMAN Defendant ESQUIRE COUNTY COURT OF COMMON PLEAS NO. DI -°4I37 NOTICE ~~~~C`T~ 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 an 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 other claims 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 (800) 990-9108 THIS 25 AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF ACT#:4168100013495526 CUMBERLAND COUNTY COURT OF COMMON PLEAS FIRST SELECT, INC. 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 PLAINTIFF VS WILLIAM H ZZMMERMAN 841 ERFORD RD CAMP HILL, QA 17011-1128 DEFENDANT NO. d / - Y/,.~7 l~ ~-u~-- 1. The Plaintiff, First Select, Inc. is a Delaware corporation organized and existing under the laws of the State of Delaware with its principal place of business at 4460 Rosewood Drive, Pleasanton, CA 94588. Plaintiff is the owner of this account, which is the subject matter of this action. 2. The Defendant, WILLIAM H ZIMMERMAN is an individual who resides at 841 ERFORD RD CAMP HILL, PA 17011-1128, . 3. The Defendant is indebted to Plaintiff on the credit account by virtue of charges or cash advances incurred by the Defendant or authorized by the Defendant on a credit card or line of credit, bearing accPUnt number 4168100013495526. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USER FOR THAT PURPOSE. ~ + 4. The terms of said account are stated in the documentation attached hereto as Exhibit "A". 5. The Defendant has failed to pay the amount owed in accordance with the Account Agreement and has failed to pay the outstanding debt a5 agreed. 6. The Defendant is indebted to the Plaintiff in the amount of $5,241.09 as of OS/2fi/2001, plus pre-judgment contractual interest at the rate of 18.00% per annum, less payments made. 7. In accordance with the documentation attached as Exhibit "A," Plaintiff is entitled to reasonable attorney's fees, and Plaintiff will incur attorney's fees in the amount of $891.00. WHEREFORE, Plaintiff demands that .judgment be rendered in favor of the Plaintiff, FIRST SELECT, INC. and against the Defendant in the amount of $5,241.09, plus pre-judgment interest at the contractual rate of 18.00% per annum from 05/26/2001 until the date of the judgment herein, plus reasonable attorney's fees in the amount of $891.00, less payments made, plus costs and any other such relief as this Court deems reasonable and just. cornum sz 8. Plaintiff hereby incorporates paragraphs 1 through 7 above as though set forth in full. 9. The Defendant received a monetary benefit, which was in fact appreciated by the Defendant. 10. The Defendant accepted the benefits. 11. By virtue of the circumstances surrounding the request for funds made, the Defendant knowingly requested the funds at issue and/or knowingly and voluntarily accepted the benefits bestowed. 12. It would be inequitable for this Court to allow the Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USSD FOR THAT PURPOSS. to retain the benefits of the funds or to be unjustly enriched at the expense of the Plaintiff or allow the Defendant to retain the value of the funds at issue without repaying the Plaintiff the value of same. WHEREFORE, Plaintiff demands that Judgment be rendered in favor of the Plaintiff, First Select, Inc. and against the Defendant in the amount of $5,241.09, plus pre-judgment interest at the contractual rate of 18.00°s per annum from 05/26 /2001 until the date of the judgment herein, plus reasonable .attorney's fees in-the amount of $891.00, less payments made, plus costs and any other Such relief as this Court deems reasonable and just. PARK LAW ASSOCIATES, P.C. BY: ROSENBLUTH PARK, ESQUIRE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ORDER FOR SERVICE THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. x VEEtIFICATION I ~ ~Y ~~~~~ _ declare that : I am a Designated Agent of FIRST SELECT, INC., the Plaintiff in this action, and I am duly authorized to make this verification on its behalf. I have read the foregoing complaint and know the contents thereof; that the same is true of my own knowledge, except as to those matters stated on information and belief and, as to those matters, I believe them to be true. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. i declare under penalty of perjury that the foregoing are true and correct. Executed at Alameda County, in the State of California. Date Designated Agent ...ter" a :~ F1RST SELECT ' '~ ~ C O R P O R A T I O N ACCOUNT AGREEMENT E1~f7~D~ i Your SIJ; i TRUST account has barn tramfetred to First Select Corporaion. Your SLti TRUST amoum was cloGsedlat~[he time of this transfer, and will therefore continue to be closed. This Account Agreemrnt contains the terms that govern your First Select account (the "account"). In this Agreement, "you" and "your" mean each person who is liable for payment on the Account "We," "our," "outs," and "us" mean First Select Corpoation or ifs assignees. Because your Aceount has been Vansferred to us, you aze now obligated to repay the Account to us instead of SLN TRUST. !f the Account was opened as a joint account, we may act on the insWCtions of anyjoint accountholder. Payments /Finance Charges. As long as you have a balance outstanding on your Account, fmance charges aze calculated as follows: To figure the finance charges for each billing ryclq we multiply the average daily balance on your Account by a daily periodic rate. The daily periodic rate we apply is your Accoum's Annual Pererntage Rate divided by 365. The Annual Parerntage Rate will be calculated as disclosed in your mast recrn[ SUN TRUST account terns (Ne "Original Terms"). if your Original Terms provided for different Annual Percentage Rates to be applied to different componrnts of your outstanding balance, we will apply the lowest such Annual Pererntage Rate to your rntve outstanding balance. We may accept late or partial paymems, or paymems mazked "paid in full" or marked with other restrictions, withom losing our right to collect all amounts owing under this Agreemrnt Fees. W e will charge your Accoum a fee For each billing cycle within which your Accourt is delinquent (late charge). The amount of the late charge will be as disclosed in your Original Tema or the maximum late chazge permitted by the law of your stau of residrnce, whichever is lower. We will charge your Account a fee for each returned payment check (returned check charge). The amount of the returned check charge will be as disclosed in your Original Turns, or the maxunum returned check charge pemtitted by the law of your state of residrnm, whichever is lowec. To the a#rnt provided in your Original Terms, and to the extrnt permitted by applicable law, in addition to your obligation to pay the outstanding balance on your Account, plus interest and fees as disclosed herein, we may also charge you far any collection costs we incur, including but not lunited to reasonable attorneys' fees and court costs. If your Original Terms provided for an award of attorneys' fees and court costs, such provision as mcorporated herein shall apply reciprocally to tkte prevailing party in any lawsuit arising out of this Agreement Non-Waiver oFCertain Rights. We may delay or waive enforcement of any provision of this Agreement without losing our right to enforce it or any other provision later. Applipble Law; Severability; Assignmentr No matter where you live, this Agreemrn[ and your Account are governed by federal law and by the law of the state designated as the applicable law in your Original Turns. If your Original terms did not contain an applicable law provision, thrn this Agreement and your Amoum are governed by federal law and the law of your state of residence. Tftis :4greement is s fmal expression of the agreemrnt between you and us and may not be coniradiRed by evidence of any alleged oral agreement If any provision of this Agreemem is held to be invalid or unenforceable, you and we will coraider thaz provision mod~ed to conform to applicable law, and the rest of the provisions in the Agreement will still be enforceable. We may transfer or assign our right [o all or some ofyour payments. If state law requires that you receive notice of such an evem to proud the purchaser or assignee, we may give you such notice by filing a Financing statement with the state's Secretary of State. Credit Reporting. If you fail to fulfill the terms of your credit obligation, a negative credit report reflecting on your credit record maybe submitted to a credit reporting agrncy. In order to dispute any information we are reporting about your Account, you must write to us at the following address: First Select Corporation, P.O. Box 9104, Pleasanton, California, 94566. YOUR BILLING RIGHTS -KEEP THIS NOTICE FOR FL7L'RE USE This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act Notify Us in Case of Errors or Questions About Your Bill If you think your bill is wrong, or if you need more information about an rnuy on your bill, write us, on a separate sheet at the following address: First Select Corporation, P.O. Box 9104, Pleasanton, CA 94566. Write to us as soon as possible. W e must hear From you na later than 60 days after we srn[ you the fast bill on which the error or problem appeared Yau can telephone us, but doing so will not preserve your rights. Tn your letter, give its the Following: - • Your name and Account number. • The dollar amount of die suspected eror. • Desmbe the eror and explain, if you can, why you believe there is an error. if you need more information. desRibe [he item you aze not sure about Your Rights and Our Responsibilities After We Receive Your ~Yritten Notice We must acknowledge your letter within 30 days, unless we have corretted the eror by then. Within 90 days, we must either cored the eror or explain why we believe the bill was corece After we rettive your letter, we cannot try to collect or repot you as delinqurnt as m any amount you question, including finance charges. We can apply any unpaid amount against your credit line. You do not have to pay any quesuoned amount while we azi: investigAting, but you are still obligated to pay the parts of the bill that are not in question - - If we find Iha[ we made a mistake on your bill, you will not have to pay any fmance charge related to any questioned amount If we did not make a mistake, you may have to pay fmance charges, and you will have to make up die missed paymems on the questioned amount 1n either case, we will srnd you a statemrnt of the amount you owe and tht date that it is due. If you fail to pay the amount we think you owe, we may report you as delinquent However, if our explanation does not satisfy you and you write to us within 10 days telling us that you still refuse to pay, we must [ell anyone we report you to that you question your bill. And we must tell you the name of anyone we reported you to. We must tell anyone wx report you to that the mantr has hten settled between us when i[ final)}~ is. If we do not follow these roles, we cannot collect the first SSO of the questioned amount even if your bill was coned. Special Rule for Credit Card Purchases if you have a problem with die quality of goods and services that you purchased with your SUS TRUST Tedit card and you have Vied in goad faith to cored tht problem with the merchant you may not have to pay the remaining amount due on tht goods or services. Thtte are two limitations to this right: (u) you must have made the purchase in your homt start or, if not within your home start, within 100 miles of your curent mailing address; and (b) the purchase prict must have been more than 550. `I nose limitations do not apply if either we or SUN TRUST own or upemtt tht mtrchant or rf wt or SUN TRUST mailed you the advertisemtn[ For the property or services. mY4'..'" ~" "WSau'~ed~tM~d-'r~Ftwrva.wvm: a~~.. z .~ ._~asu,~w~nSfib~. _ _ ~- YSJfaVr~r~e~,~SNw.~a`e&Gt , ~ 1 \ \ ~ C -, c ~ ~~ (~) { I I ~-- _ ~ LL'"' V ~. ~. ,~ __ -- _~ ~ -- -z ~:~ SHERIFF'S RETURN - REGULAR CASE N0: 2001-04137 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST SELECT INC VS ZIMMERMAN WILLIAM H BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, say9, the within COMPLAINT & NOTICE was served upon ZIMMERMAN WILLIAM H the DEFENDANT at 1735:00 HOURS, on the 9th day of July 2001 at S41 ERFORD ROAD CAMP HILL, PA 17011-1128 by handing to WILLIAM ZIMMERMAN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.75 Affidavit .00 Surcharge 10.00 .00 37.75 Sworn and Subscribed to before me thi//s~~ .23,,x( day of Pr t onotary So Answers: ~ Q R. Thomas Kline 07/10/2001 PARK LAW ASSOCIATES ~ By . / ~/ ~/ e~-- Deputy heriff ~,~; VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE AND CORRECT ADDRESS IS: C. PLAINTIFF: 4460 ROSEWOOD DRIVE PLEASANTON, CA 94588 DEF: 841 ERFORD RD CAMP HILL, PA 17011-1128 CUMBERLAND COUNTY COURT OF_COMMON PLEAS FIRST SELECT, INC. Plaintiff VS WILLIAM H ZIMMERMAN Defendant NO. 01-4137 PRAECIPE FOR JUDGMENT BY AGREEMENT TO THE PROTHONOTARY: Please enter Judgment in favor of the Plaintiff and against the Defendant named in the attached Praecipe for Entry of Judgment by Agreement attached hereto and made a part hereof as Exhibit "A". AMOUNT OF CLAIM ATTORNEY FEES PLUS ACCRUED INTEREST AT 18.00% PER ANNUM FROM 05/26/2001. LESS PAYMENTS MADE TOTAL $5,241.09 $891.00 $191.26 ($0.00) $6,323.35 PLUS ADDITIONAL COSTS PARK LAW ASSOCIATES, P.C. VAL IE ROSENBLUTH PARK, ESQUIRE Attorney for the Plaintiff AND NOW, ~~LtS3 Lc~-J- o~ ~ 1 Judgment is entered as above. PROTHONOTARY THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VAI~~RIE'ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P.C. 25 EAST STATE STREET DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS FIR5T SELECT, INC. Plaintiff VS WILLIAM H ZIMMERMAN Defendant PRAECIPE F( BY TO THE PROTHONOTARY: Please enter Judgment by Agreement this day of 2001. It is hereby agreed between the parties that Judgment be entered in this action in favor of Plaintiff, FIRST SELECT, INC., and against Defendant, WILLIAM H ZIMMERMAN for the principal amount of $5,241.09 plus interest at 18.00% per annum from 05/26/2001, until judgment is entered plus attorney fees of $891.00, less payments of $0.00 plus court costs. NO. 01-4137 PARK LAW/ASSOCIATES, P.C. BY: / VALERIE ROSENBLUTH PARK, ESQUIRE Attorney for Plaintiff ~ ~~ LLIAM H ZINIME --_.~ ~u~ a ~ ~0~1 a~ , VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street DoylesCown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF FIRST SELECT, INC. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. WILLIAM H ZIMMERMAN . Defendant NO. 01-4137 N O T 2 C Ps pursuant to Rule 236 of the Supreme Court- of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: { } Judgment { } Money Jw { } Judgment { } Judgment { } Judgment ( } Judgment { } Judgment {X} Judgment by Default 3gment in Replevin in Possession on Award of Arbitration on Verdict on Court Findings by Agreement IF YOU HAVE ANY QUESTIONS CALL: PARK LAW ASSOCIATES, P.C. 348-5200. CONCERNING THIS NOTICE, PLEASE at this telephone number: (215) PROTHONOTARY: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,~ f7 ~ J {~. '~ C ,r ~ O '~ r ~ _ ~ ! ~ `V C ~' <~~ ~ p > ~ ~ ~ L, ,- ~; -l ~ I ~~ .~ '~ -< ~ b ~' ~ GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2122835 C) 4-„ 7 m -T'E = Z;:0 7-0 m F -Jrn ,,r ? cn 7a CZ) o C-j -< Ln First Select, Inc. vs. WILLIAM H ZIMMERMAN TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 01-41.37 ENTRY OF APPEARANCE Kindly enter my appearance on behalf of the plaintiff in the above-captioned matter. GORDON & WEINBERG, P.C. i BY: 7--) FREDERIC,! INBERG, ESQUIRE JOEL M. FL.NK, ESQUIRE Attorney for Plaintiff P012 CERTIFICATION OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Substitution of Attorney and Entry of Appearance Pursuant to Pa.R.C.P. 1.028(c)(1), via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDERIC I. AINbERG, ESQUIRE Dated: dp? GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 4841351-0500 ? ?C'TH 0N0TA L 12OCT I 1 FM 1: 56 ,t #E ERL.AND COUNTY ENNS YL.VANIA First Select, Inc. 3715 Davinci Court Norcross, GA 30092-2670 VS. WILLIAM H ZIMMERMAN 841 ERFORD RD CAMP HILL PA 17011-1128 and Metro Bank 3201 Trindle Rd. Camp Hill, PA 17011 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 01-4137 k506 4-v INTERROGATORIES IN ATTACHMENT TO: Metro Bank - GARNISHEE You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so my result in judgment against you. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? No Accounts 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. 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. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had an interest? 5. At any time before or after you were served did the defendant(s) 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 therefore? 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to his(her, their) direction or otherwise discharge any claim of the defendant(s) against you? 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time, did the defendant(s) 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 of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 8. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant(s) 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. 58123? If so, identify each account. 9. How much is the value of any property in your possession belonging to the defendant(s)? FREDERIC I. WEI ERG, ESQUIRE JOEL M. FLI K ESQUIRE Attorney for Plaintiff DATED: G ?!L(?I V VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. A LA)?S6 SI NA RE) 2122835 C70RDDN & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOE=~ M. FUNK, ESQU=_RE Identification No.: 41200 1.00~~ E. Hector Street, Ste 220 Conshohocken, PA 19428 484,'351-0500 First Select, Inc. vs. [niILLIAM H ZIMMERMAN and Metro Bank Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NC. O1-413;' PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant's k_~a~~.k acco,in~ Faith Metro Bank, as Garnishee in the above ent1t::~e-d. matter. GORDON & WEINBERG, P.C. ~~ ~~-° ~ r ti BY : 1~ FREDERIC I WF~ NBERG, ESQUIRE JOEL M. FLw~iIC, ESQUIRE Attorney for Plaintiff P01_. SHERIFF'S OFFICE OF CUMBERLAND COUNTY my R Andersonr. ,heriff Jody S Smith c r J(i —4 r a, Chief Deputy Richard WStewart _l � �i iylt� i" Solicitor OFFICE p f-r z'4RIFr PEW4� YLI/APIs First Select, Inc. vs. Case Number William H Zimmerman 2001-4137 SHERIFF'S RETURN OF SERVICE 10/02/2012 02:50 PM -William Cline, Deputy Sheriff,who being duly sworn according to law, states that on October 2, 2012 at 1455 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: William H. Zimmerman, in the hands, possession, or control of the within named garnishee, Metro Bank, 3201 Trindle Road, Camp Hill, Cumberland County, Pennsylvania, by handing to Angelique Waters, Customer Service Representative personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on October 3, 2012 to William H. Zimmerman at 841 Erford Road, Camp Hill, PA 17011-1128. 06/03/2013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $97.58 SO ANSWERS, June 03, 2013 R-ONW R ANDERSON, SHERIFF moo. a 91-3 71 .':cu.rty.u:e Sheritt.T--Oseft rc. V