HomeMy WebLinkAbout01-04492- COMMONWEALTH OF PENNSYLVANIA
' ~rnllnlTVnF~ CIIkIDSRLAND
09-1-02
DJ Name: Hon.
ROBERT V. MANLOVE
Adtlress: 1901:'STATE STREET
CAMP'HZLL, PA
Telephone: 17171 761- 0583 17011- 0000
NQTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASE
NAME antl ADDRESS
rCITIBANR(SOIITH DAKOTA), N.A. ~
PO BOX 356
WEST CHESTER, PA 19381-0356
L J
VS.
DEFENDANT: NAME and ADDRESS
rSHOWER$, CONNIE ao-~ ~ 3
314 SRFORD RD
CAMP HILL, PA 17011
o OLIN, NEIL & HALTRECHT L J
PO BOX 356 DocketNo.: CV-0000390-00
.p;
WEST CHESTER, PA 193 81-0356 Date Filed: 10/30/00
THIS IS TO NO~'IFY YOU THAT:
Judgmeht: - - a xH :m ~~M.,. .,~.,.. _ .._-
Judgment was entered for: (Name) srm'rnAax (cnrtmu nAx(~~, N A
Judgment was entered against: (Name) SHOWERS, CONNTE
in the amount of $ 6, 595.75 on: (Date of Judgment) 1 9/1 9/00
Defendants are jointly and severally liable. (Date & Time)
Damages-will be assessed on:- - -- --
This'dase dismissed without' prejudice. " '
Amount of Judgmeht Subject to
Attachment/Act 5 of 1996 $
Levy is stayed for days or ^ generally stayed.
Objection to levy has been filed and hearing will be held:
AmountofiJudgment.,.~,, ; ,$ .6.498.78
Judgment Costs $ 97.00
Interest on Judgment $ . 00
AttoPrey Fee§ $ . 00
Total $ 6,595.78
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
Date: Place:
Time:
^
ANY PARTY HAS THE RIGHT TO APPEAL WITH N 30 DAYS AFT HE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOT / K OF TH C T OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A "CORY OF'THIS rt RANSCRIPT FORwI WITH YOUR„NOTICE OF APPEAL...
-1 --OODate .:... " "
l a a ; .District Justice
I certify that this is a true an o ord of the proceedings containirig the judgment.
(0~-1 a -UU Date ;District Justice
My commission expires first Monday of January, 2006 SEAL
AOPC 315-99
00-813
f COMt~tONWEALTH OF PENNSYLVANIA
GOiJJVTY OF: CUMBERLAND
Mag Dist. No.: 09-1-02
' o, Nang, Hen_ Robert Manlove
Address 1901 State Street
Camp Hill, PA 17011
Telephone: 717-761-0583
PLAINTIFF: -
CIVIL COMPLAINT
NAME and ADDRESS
Citibank (South Dakota), N.A.
c/o Olin, Neil & Haltrecht 610-696-3030
P.O. Box 356, West Chester, PA 19381-0356
vs.
DEFENDANT:
NAME and ADDRESS
Connie Showers
314 Erford Road
Camp Hill, PA 17011
occe o.:~. cZU-UZ~
Date Filed: ~ DI3 ~/O a
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AMGUNT DATE PAID -----~ '•~, '~
FLING COSTS $ / (_
SERVING COSTS $ _/_/
TOTAL $ ~ 7. CSb /d l 3J l~
TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $ $6,498.78 together with
costs upon the following claim (Civil fines must include citation of the statute or ordinance
violated}:
For past due balances for goods and merchandise purchased and/or
cash advances made by the defendant on a credit card issued by the $5,415.65 Principal
plaintiff in the name of Mary E. Duras, plus reasonable attorneys fees Credit
per terms and conditions of account and court costs. The defendant Interest
agreed to repay the balance pursuant to an Acknowledgement of
$1,083.13 Atty. Fees
Responsibility.
$6,498.78 Balance
I, Burton Neil, Esquire; Att. for Plaintiff ,verify that the facts set forth in this complaint are true and correct to the
best of my knowledge, information, and belief. This statement is made subject to„tlie penalties of Section 4904 of the
Crimes Code (18 PA. S.C.A. § 4904) related to unsworn falsification to aerthoritiest'
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(Signature of Plaintiff or AutAarized Agent)
Plaintiffs
Attorney:
Burton Neil, Esquire
Address: 26 S. Church St., P.O. Box 356
Telephone: 610-696-3030 1A/pct C; attar, PA 19481-n45F
IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE
TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU Dq
JUDGMENT WILL BE ENTERED AGAINST YOU BY DEFAULT.
If you have a claim against the plaintiff which is within the district justice jurisdiction and which you intend
to assert at the hearing, you must file it on a complaintform at this office at least five (5) days before
the date set for the hearing. If you have a claim against the plaintiff which is not within district justice
jurisdiction, you may request information from this office as to the procedures you may follow. If you are
disabled and require assistance, please contact the Magisterial District office at the address above.
~.
OLIN, NEIL & HALTRECHT
By: Burton Neil, Esquire
Identification No. 11348
26 South Church Street
West Chester, PA 19382
610-696-3030
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA) N.A.
701 East 60'" Street North
Sioux Falls, SD 57117
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CONNIE SHOWERS
314 Erford Road
Camp Hill, PA 17011-1115
Defendant
NO.
CIVIL ACTION -LAW
Certification of Address and
Affidavit of Non-Militarv
Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities, I verify that:
1. The above are the precise last-known addresses of the judgment creditor and debtor.
2. The said defendant is not in the Military Service of the United States or its Allies or
otherwise within the coverage of the Soldiers' and Sailors' Relief Act of 1940, as amended, is over 18
years of age and has a civilian occupation.
& ALTRECHT
Burton Neil, Esquire
Attorney for Plaintiff
In making this communication, we advise that our fum is a debt collector.
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PRAECIPE FOR WRIT OF EXECUTION (MONEY NDGMENT)
Pa.R.C.P. § 3103 to 3149
CITIBANK (SOUTH DAKOTA) N.A.
Plaintiff
VS.
CONNIE SHOWERS
Defendant
FISRT UNION NATIONAL BANK
Garnishee
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.O1-4492
CIVIL ACTION -LAW
To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER
L Directed to the Sheriff of Cumberland County, Pennsylvania
2. against- Connie Showers _ _, Defendant(s)
3. and against First Union National Bank ,Garnishee(s)
4, and index this writ
(a) against Defendant(s)
(b) against 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: 804 E. High Street, Carlisle, PA 17013
5. Amount Due $6,595.78 ~~
Interest from 12/12/00 $ 311.33
Total $6,917.12*
*Plus writ costs
Dated: September 25, 2001
Attorney for Plaintiff
NOTE: Under pazagrapfi 1 when the writ is directed to sheriff of aunther county as authorized by Rule 3103(6), the county should be
indicated. Linder Rule 3103(c) a writ issued on a transferred judgment maybe directed only to the sheriff of the count in which issued.
Pazagraph 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(6). Pazagraph 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 Olin Neil & Haltrecht is attempting to collect a debt.
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2001-04492 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
IBANK
VS
SHOWERS CONNIE
And now KENNETH GOSSERT
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:20 Hours, on the 5th day of October 2001, attached
a5 herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
SHOWERS CONNIE in the
hands, possession, or control of the within named Garnishee
RST UNION NATIONAL BANK 804 E. HIGH ST
CARLISLE „ PA 17013
Cumberland County, Pennsylvania, by handing to
WANDA SHAFFER (FINANCIAL SPECIALIST) ,
personally three copies of interogatories together with 3 true
and attested copies of the within JUDGMENT - DJ and made
the contents there of known to Her
Sheriff's Costs:
Docketing .00
Service .00
Affidavit ,00
Surcharge .00
.00
.00
So answ//y' ~-
s % .aC
R. Thomas Kline
Sheriff of Cumberland County
00/00/0000
Sworn and subscribed to before me
B
this '~'~ y
~ day of ®e.C,..t„_,
,~7on / A . D .
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P t onotary ~ '
OLIN, NEIL & HALTRECHT
By: Burton Neil, Esquire
Identification No. 11348
26 South Church Street
West Chester, PA 19382
610-696-3030
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA) N.A.
VS.
Plaintiff
CONNIE SHOWERS
Defendant
and
First Union National Bank
Garnishee
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-4492
CIVIL ACTION -LAW
Praecipe to Dissolve Attachment
To the Prothonotary:
Dissolve the attachment against First Union National Bank, garnishee.
OLIN, HALTRECHT
BI;;.
Burton Neil, Esquire
Attorney for Plaintiff
In making this communication, we advise that we are a debt collector.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 01-4492 CIVIL ~ TE1S4
COUNTY OF CUMBERLAND) CIVIL ACTION -LAW
TO THE SHERIFF OF CLm~Y~er~ and COUNTY:
To satisfy the debt, interest and costs due Citibank (South Dakota) N•A.
PLAINTIFF(S)
from Connie Showers, 314 Erford Rd, Camp Hill, PA 17011
DEFENDANT(S)
(1) You are directed io levy upon the property of the defendant(s) and to sell ~ I,E</Y- GARNISHMENT ONLY
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
First Union National Bank, 804 E. High St., Carlisle, PA 17013 -Serve Interrogatories
GARNISHEE(S) as follows:
and to not'rfy the,garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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) Ifpropertyofthedefendant(s)notlevieduponansubjecttoattachmentisfoundinthepoSsessionofanyoneother
than a named garnishee, you are directedlo notify himlherthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due 56.595.78 L.L. $.50
Interest fran 12/12/00 - $311.33 Due Prothy $1.00
Atty's Comm % Other Costs 8.50 due garnishee
Atty Paid $31.75
Plaintiff Paid
Date: October 2, 2001 Curtis R. Long
Prothonotary, Civil Division
Deputy
REQUESTING PARTY:
Name Burton Neil, Esq.
Address: Olin, Neil & Haltrecht
~6~~-St., Pte-nom-35~
West Chester, PA 19381-0356
Attorney for: Plaintiff
Telephone: 610-696-3030
Supreme Court ID No. 11348
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: 7 3.18
Docketing 18.00 ~$2~
Poundage 1.43.
Advertising
Law Library ~. 50
Prothonotary 1.00
Mileage 3.2 5
Misc.
Surchazge 20.00
Levy 20.00
Post Pone Sale
Garnishee 9.00
.18
Sworn and Subscribed to before me
this ~_ day of n,
2002 A.D. _ ~ T/
pro onotary
Refunded toAttyon 7/15/02
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So Answers;
N
R. Thomas Kline, Sheriff ' J
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