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Home My WebLink About07-3092IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GA FINANCIAL TRUST 2002-A Plaintiff VS. STACY M HIGGINS Defendant No. 0'7 - X 7k lCOMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire Pa. I.D. No. 42524 Weltman, Weinberg & Reis, Co, LLC 2718 Koppers Building 436 7th Avenue Pittsburgh, PA 15219 WWR#05487587 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GA FINANCIAL TRUST 2002-A Plaintiff vs. Civil Action No. STACY M HIGGINS Defendant COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND 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 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENICES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-31665 COMPLAINT 1. Plaintiff is a corporation with offices at 6851 JERICHO TURNPIKE #190, SYOSSET, NY 11791. 2. Defendant is an adult individual residing at 510 W CUMBERLAND RD ENOLA,PA 17025 . 3. Defendant entered into a Cardmember Agreement with PROVIDIAN for a credit card bearing the account number 4361452701147124 . A true and correct copy of the Cardmember Agreement is attached hereto, marked as Exhibit "1" and made a part hereof. 4. This account was subsequently assigned to Plaintiff for value. 5. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of MAY 9, 2007, in the amount of $6837.27. 6. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 7. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 18.0% per annum on the unpaid balance. 8. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 9. Plaintiff avers that such attorneys' fees will amount to $1000.00. 10. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges, attorneys' fees or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, STACY M HIGGINS individually, in the amount of $6837.27 with continuing finance charges thereon at the rate of 18.0% per annum from MAY 9, 2007 plus attorneys' fees of $1000.00, and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. /27Ko armbrodt, Esquire N .42524 n, einberg & Reis, Co, LLC pers Building venue h, PA 15219 487587 • "`'` ? P-) . PROV1 D{AN Financial PROYIDIAN MAT)OMAL BANK VISA' AND MASTERCARV ACCOUM AGREEMENT Will Pleas, rtview Oft doahment and keep i with your am k»poprN papms This Accgmt Agrftlnla Contains terms MA govern you Providian llatany.llarhk V . -0414* ISA q Mart Ac or any other eovM1 Par'Acwurn The Aaouet allows your to make Patches s by w* your VISA or Ahstntard asdt card file 'Card) wheraa It is honored and to gd stir 96anc buse an t( ? and hou Automated Teller hbdRnes: Coum ions duxks may also be provided to you IS an Addlf cal wax to use the Accwrt to yet { AC you bhing sbtemst The ea each Person it willow we have opened a OEM cad Accoun!'Wk-orr..ours,_ ahd've mean Provi iau Nation Barg, or its ssslitu , as lskd 1 Aount any be osrd only lot persomt be*. household, and dwitable Purposes, and not for any business or comnercm purpose. Any use d qis Account Shah constitute acceptance of On bras of pis Agreemea You and we agree as f m=- Poinno s. You will receive a r Wd* statement dwwhng Your oubbnupng hall= PayAmi on gds Accused is required In U.& dollars (checks must be pgAhr at a U.S, eke a pan bank rro cndt is drawn on) for ol least pre doo as shown on yaw stdemant by the payment due date in as inane will payment kstrhrciorhs on yore mashy statement The bait d you monthly statement kndudts No? lorour when we post b your Account Coaveniahce cheChs and older clacks we may issrkc b Yin ray be rsN to motet paymo t ou your Accootnl Of 10 mete, P h 00 ay dint account you ? art r osr alMales The parymhetnt due wit be 3% a to new bahtce :bons onytwr stalarrpi part pit. amount d any past due pWmerbt, we male brJude pie a11awn by which 1111 row b,tarne miceo ds your aedN pus fbvrave; pre parymere due wit not De toss than ti5 fps your new balance is less Pon $15, In Which, case to prim" in will be pan smoue a the new balane N yt111r Aocou11e h past dn, r above the sent pike, wr racy r,quie a Mattis eihhbrn&m Paymenttadwo will ropy you kdore "All soar N your payirherhl Is more 111311 pro pay11ent des.res wh7 be baled as a skgk Payment ant none d N wit tea appk0 b lulus payrneMt due. We a"" accept bb or palfal paymoft or paw marked pofd h RW or marked wRh other ticpms, w81noW Iosk,p ow?igle to coned cep arrnowhh awklg under 11is Agreement Fiuane Chain. ftoact charges begib b,ccrw as a debit when R is included in one ayour daily how= and contlane to acwc well OW balance is reduced by a pro mat or credit; Your Account has h" daily habnces; the bSkULUMM Oft o tdsh at pardwes; you waft wRh your Card aril heir o0nr than cub advance basac11og lose; charged to yore Account. including lees ter op& a savf aunt Nle I?StAlkmLt t 1rih d a/ onto advances and cash alwncc trarsarfort Iges Any prryrbni m-ni tso aeekt pit m vernalift utant on bare charges and law 11no an will adbuy be applied Brut to 11o Balance whit pro bwer ANNUAL PERCENIM RATE (APR) we ghat latent te n#% ad on is the enDoWm We reserve the ? to v* pgnmft diNem* whbod JaMer nokk The Pwdlaw and tasfr Advance Bagnces are redkcsd by pWmeft se d the date Naheuk . end b CU of ud the posted. Puchosas an khdhided In your Purchase Babncs at of the dal, made Fees are included he yew Purchase Balance as d 1111 tranacke dye, pad ad-n are khd ekcbo rata r bartided k your Cash Admw Bymce as bpmx asb advances pout other bnncM bsipAk- and linut b Automated Teter Madden as d ph, dab mWa; hinds seven drys slier s kasmi st crib adhonc?e decks made pair" b pat arekWvNW asasbier's docks. which we 11W aM b regrew se v days after a er dale , a as 11 d of the we print is the d"t dale; t all deie other xs isc Including ? conovergoice clacks. u a the data PreseMCd to ss Crib advance tnrmalmr 1 are kKk*d ter Ibe Coale Cash Advance Bata o ces f each day and as plain posted an the test day of y Purcom ar Caslr Advance Balance as of ens date Posted. Firmwo Charges art added layout Puid" and the b111% cydt Then is no period within which credit admded may be repaid wahaA khnu ft a inane dur9e: b figure On dally Arnmet CWW for purchom and Ids fthr hfronce. charge for ash advance; we start wipe you previous day's Purchase Balance and Cash Anises Bsbua. add a$ debit and subbad all aedih fo go estrous day to an apppcabk Babas (as explained Is 1b, paragraph abovel and NNW* the nd amount by the appjinW -iapl psrbdie rob (sw hiowtoa Paragraphs). The inara charge for pure arses is to added to and included b that day`s Purchase Babra:4 and Bra fWa nce Charge for cash advances is than added io acrd included he gnat days Cash Advance Odom I* Yeas a credit balance for any dry as zero. W0 determine go total linance charges on your Babnm to the M* ft 11r13nce Charge IN Porcloses for each by Wk pan bibg cycle and to hUnce charge for chic advances for each day within the billing cyck he cacycle lculating by D bOs r finance dsop^ go adjustment will be made for any Vasadim or pWand Met would bout affected pan li am charge alm"m In a Prior billing cyds had R been posted In that cydL The applicable date pettodic role for such a transaction will be the retain eNeet ter to curse biilg cycle rather than the Fab in eNed on the date of the traosac"W The bum 'P?Ime Rate- as and to this Agreem a nears the prime rats pubishod ter T)n Wolf Sleet .lburna! an the first business day of the previous calendar north decrease In In APR will take tiled to The first day of your biting cycle and may resui in a sight Increase or decrease in the amount of Your midnwm prymnnt or The ANNUAL PERCENTAGE RATE for purchases vva vary and may be adjusted each billing cycle up to 10.99% above Prime Rake. Using tics formtdk the APR for purchases In the APB 21100 bWkg cycle Is 19.99%. corresponding to a daily periodic rate d 0.054aX, and your APR for purchases will not go below 19.99%. The ANNUAL PERCENTAGE RATE for pub adrims: will very and may be adjusted each baling cycle rap to 1299% above Prime Ralc Using this f mrm)k the APR for pub advances In do *112000 billing cycle Is 21.99%. carrespondwhg to a dally perbdk Fab 61-0.0602X. and you APR for cub advances war W go below 21.99%. To ddemdne the -maps daay haoct Vwm on your statement for phuc13se; add each "do purchase Balance (indadrq daily finance charge) in the NNW cycle ad divide by Ile I nO aW divide o Ibe raumpera sboins on yoar statement ter cub advanc s, add easy day's Cur Advance flabom (ihceft d.* finance oOP a ?Y Perk rate b. abOi byby dm w Nra bglkrp cycda Ya an nadtgy each of tense amino daily balances by khe number of days Is Ow bftg cycle and by pane adranoe Iarmdlo11 tee crcd11 fire Ihcr Bpress Wad Iwo sndrlotah topdher b Aeterrrie the total arnount of inane charges aft you balences For be billing eyes. N a cask proeaskw tee is dnarged (see ran secaoaj, gnus amounts are also FINANCE CIIARGEk Fees. A nnraberslip lee d ST 95 wit tot carped to yomr Aaore each msrel? Hyou request and we issue an additional Card on your Account fa an a 4whed user s in d S20 Our exit ou 0 N you squat aWAabewt ibis tee ei16e dwped b You Account veo11 the additional Card It issued and evhvy t2 months. 11nreatlr for as long as each addif ad M?esskM magi mot ter avaiabk ygo max ebarpepair eachane eke a s1! 95 whbb is a FMANCF CHARGE, MA be verged to Your Accused In some arse; mhpeeu talpaid; each stop paymere order or reroe13f d $uch an order, each you ask us hereplace: each regimen p,ymwnt each dhedh Yoe web all you Accoure that we nk" arhxeds yourcredlipans even N Yar Acmud is disci NYou request bM"copies shlements lhd Pen ft ? deck ache ? wo +rRtukr wadi y naiad S210r ewb slrcb cM. A ash advma ke d 3X(mkrirrwui5), D yon woe 3 two rr?or $m arteL we tnhaDr Burge a or so . ? inaateY. ? may ? which @ a F1NAlICECIUIRGE, maxbe chargedIr eachasthadvaihde tralwr8om male our yoer AedonmL For sane credit a Inane ahea11mte Carped s lok which h o FNNINCE CIMM the amounted which nil be dhdosed b Yon before you accept the inn Increase ollet gym re:qu a lbA wt make wheNW er not brads art mp" Inyour persond we way age you Aaasht a he of to 951or each request This its is a F11IANCE DRAM aW I will V* tfrdtd11g adoooit to male the payrsept Dolook You will be ter ditk N any bdonuation you povided us props to be ktwmpieb or wino; gym der ad campy with any pal of this Agreement Won Your daepl bechbupky; er Inschow N You do not ant pay s dekls when dug N a hsdsupley pddon It Med by or all" you; or It we believe is good hips that you may not pay or perform your tukipafiore uhdtr lit Apraernsd N you acs b deiult urn: mad wlMoe. brpW 11 or ndkk carce! yew credit luMbitte, declare your Account balms irmoedfaMij nee ahd yyablR aW use any relnedyr wit neat l11vm lit part evanf d yowl06ad1, pan ouhbrharg babrle pre jrpyr Axoue wit orontuhon b aware Welvd at to APR(s) &doted In tin Floats Charge: socked peg Agnemenf, oven N wo nave fikdssi b coined pars amoontyer ewe. OWN Lees. Your Cr,at 11110 akin ash aMnc* tin are ANIMM obm yce open yourAmount and on you stahanent ad mach. Yogi ash adva ce lit it hwivil to apqlot d your WM Nan YN my boom r demost your croft No aft your co* advance an hued an Woreadion we obtained has yyooun or yaw credit records. You wdahl, caO for NOW Is NMI* pan dWMM bdinen Yoer amlit be need your Accused balance ( A dfap ttarex0ons erode or arNnorhed but lot yd posbd). Your avS" aoM for a' MIALJte11io611 is ou belrwep your cub adwnce be arw your Cash Advance III or the dMor once DeMeep your A it dyw am us may rdusa to ? LTA Yor waVAk seen wink we ea dkm *A paw dicer wit daE For arfake k av>ibbk any be bss. You win rod inym Yaf vial lpl and ova your ash acv kaM any' e that would arse you to ehccesd your a Wb* creditor yourawBahle credit der cash advances. Youraedi be may bo educe-11 b Pe}. YOU promise if Pali us wbea aN ail ainotgft borrowed wh a you or sormone also eta your Acco rat (even N The amount charged eacueds you parndssia& as ether bansadidi t and chariot to your Accowk and d collodion coats we hww kxkWing, but not 11MAW to. reasonable a11anoy s lass end court costs. (H you win on sulk w"s *We pay your Wso abin atbnoy's has and Brut cash.) Cbongm Alts wt provide you any note required by law, we may change any part of his Agreement ant add or rem n any terms, condifons, or requirements. N a con" Is made Is put Finance Cherries section 91 this Apuses st ft new prance doMe calculation w111 V* b you entire Accused Oabrha nom the alledive dark of The change. Changes wit apply b bdmm 11nt ' and will appy whelber r od you .m& b rase to Accowa Faelp belo"P /Correaey comsha. NYw'Va Your Card for bonsactfons ht a cwTaq other 00 U.S. ddb% do kasmackne wit be conmw to U.& (101111M generally 11311111 WW I (q DaMMO-mandatedpkale or pfd wholesye aarltt rate Is dkd today bdmo7ne barksocip in procisse! Increased by 3%, Ito credit is subsequad?r One two baksad luk I wA donreim ourta d In ?dgAars 'flu oum?7 wrgersis t Fe used on go Mwarsion dab meat differ from the rah in cocci on tho dale you used your Cant, You agree to accept to The Can ; Csrrellades. You may canal your credit privileges at any tktn by ouolyi>9 us Is wM* and destro ft In Cad(s). Upon Ile Card on sh days aryntie at pro end at the modb Cm an It roe MMM do right mat to fernw go Card. We may pried pie Cad and you aW pdvibpes.X time aRer 30 canc?e11td or not renewed, II13rICe cl13rpet and otter lees wit dwniknrs b too assea3ed, paynr?s wa?daklkahe b bs notice to you, or without notice coi i Demil led by too.Nyow p? pre is 6109: N you brmbrak your credit privkM or N we cancel or do not renew to Cud. you may no bpger wets chars on d Ac apa?? par a tlis Agreemented r,mab kt may have issued to you tvhhr Acdove, and you should desl?dy any tlu11ued decks we SM (Cordinued oo mast) ' 06019 ' t!tatoaad bb"A W Douaarttenls Yov Wit provide us at bast 10 days notice 11you darks your name, Proms or mainp address, teleome.na ribers, enAwmenl, or kacorrat Upon orregwst, you will p pick us adelioraN inanciad ?nelofraBon Wt reserve Mt rigid b obGkl kdornatienu bona others iorbudng aeni11 agerudes, and b provideYour address and kdafratla am )W Aooanl b ors - We M - -vowsourbusbassa - - gym do aol bAl11yodr etApatiors order Bus Apretalpt; a rubs aedl report ft may rclkd on your credit may be sutrrmiBed b at6! repprlkq apndes. Ca desew Stinks; Uowbortret Use, Lem or MR of abaft or the Card. Each Card must be sipped on Fec*L You are raporasrbls for salegnardkq on Card; your ltefsewuai MIMVC Nta Nw*w (PIN). w" prodder oases b Aulonaled Ida Mad cats, and any dhecks is:bed leyou from Melt at hr keephg your PM separate bona your cart Y yeti discover or suspnd that pre Card, PIN; or aver wm d d wits art kat or stoke, or pat Urea may k a seranBu used kaesacilbe on vow Aca it You will POO* so* as by pith I-Mr1Mt15. So we can MMMd1d* ad a Ur1 losses' and bbft you w4 phow to even Yrospk yes nM area w* us to wrifto Yaw Aabiigr for maul MW nee kfae yon nosy as k IknRed to 550. A you report of we suspect onvuthotbed use of yaw Account we nay suspend your credit P&&ges soil we resin pat $M a Lowe you a aew Card N probleru to our a me y ors ails reaytae rronNwed or r asdad d is bsl Of stokq you Wit promp0y destroy cep checks that may be it your pouession Ti kirrgove astorrxr service and sarorilX you spree me yotM Notched Aeladvas. We• will rot be liable 11 any peace or Adwaled Jelin Mad*w refuses to honor the Card or accept your docks, or taps to rdom pa end to yore. Usk Nava no raP M Ohs and savias :::=ow* pea Card or cdef eacepd as required by law. (See SpKW Rule below.) Certals benellis that we anAa6le urNu Me Account art provided by IAlyd-paAy voodoo Vh orSNk lest the gsally, avap r, or resups of any d the services you choose to use. SNP PSYMN 011111s: Nyou wish to stop pay. as admxk you spy send us a stop payment order by writing to a d our address for Customer, Swoke listed ss your statew"L You an aala a step peyment order orally by a&* an wm6er listed am ym shkmert. When yon make a stop primed order YON must provide your Account number and spK* kdonmNom about tht dw& lire and amowit on day on the ank go rome of the"to whom r was prfAk the rams d the perm who sipped it ad lie drea Fuld You we be UW b con km as oral stop paynted Order in wilt We nay dsnrsxd vmer oral order N we do ad recdve a M""a w onk"1:, bo v-1e as® ow ? er N we bm no reccbed an adequate desalJdt m Of tin NM so pat payskd an be stopped, The order will not be die' N the check wps paid oppormilly to art an Ike order We may, without is-ft. disregard a written stop payment Order sk months aft recelph winless A Is renewed he wFiti ng. by us belortwt had a rtesoaabte Sbadxd OF Care. Because this Account Mvdres a Credit card and map lrmolre drdk tranaadlow pas ore processed through separate rotiond systems before to bvax*res we Cm ,'I' bm sat beans 1101 every dneda and Card slip will be not iv ms4 bxux*m loyour Aarouns win be propmed ardhakatiy wiftd our er wkup tray Our precasatag sysemn tri aN err atbrdba y eerbh liners, %W* ws+d aondno We WIN e? , I - d bxsacom wit" you repod that yaw Card any d?Ws?y o leas loaf dolor Wo da set blind WOMWI b averilm all itemm and we will not be neyige d N we do not do so. Tide role eshbi a the stadard of ordinary aye Nat we k Voed folk w11 toareitt iA I Your Aeoouat Because d nor smiled «rkvR and became neNw your cancelled ducks poll Cord t ancatt oa slips will be reewited 19)w wft the - --W *j abtemmetY you should ba ardui b eta d daeda Nyow cheek repistrr or olllaurfsee keep a retort d Mon Trov Spaeth also earn Your credit and ash advance xed pedgur sips. ? aum w data rode me.?:r 9]__-_ ayy ll.r record? i to Dome us lr d MW LRNI'0@d 130sacd= or oiL work d CUM r4oft We may delay or waive mkrcemed d asp provision d ttds Agrecmed wkhad losing our elpht to enlorce if or any other provision bbc You waive no dgM to phs41111IM4 demand mss; or nines Of Admo ; any appicable statute of knitatiora; and any right van may have to require us to proceed against anyone before we lie snit aerobes yes- Applloalele Law; Serer Mitt Assignow aL no enaaawiwo you bit W- -s AgreerneM and your Accost ore governed by led" haw and by New ibmpsbh lam Tick Agreemao Is a bar eaprom" d the agreeremd Istww you and us ayad spy not be conbadidcd by evidence of any alleged Oral agreement H any provkloo of lids Agreciews k held le be Word at ? you and we tvi eorridet Nat pratston nodftied y mnrlorm y appiabls taw, and the rest d the govisbns b ps Agreeaued oil siN lx adanegble. At arty Moe aAarrs deyrarhe h good hint Nat any proposed or laded legisbBort repadalay action, or 1 dedsia bas «adered or saYretder any makrfaf prorislona d Nis Ag?eerwd krraiA a ssr noaee N Peprakhd arced Neprd aAd?yonr?aedlterp?ilyicages. We may uasWa a assign night to ai err souse olrnpayrnersts. N oak inn, ? ? ? M yos4 rrdee d strdr ere west to probd the pv?dasa or assignee, we nay give Yos sndu ndke by Idng a finxdag statemed with the states Secretary d State. fames thatyor wedeirs . BMless. Ot1aa aotias N yon spar a efledhre vdnen deposied h sex mar addressed ro yon at the seeress shown io ow records, assess a tacker notice pefiod is syecNed. y Mss Agrewrnerit orby tau, wMch period shalt scant upon smTrp NoBce b sea shag De mated b our address nor Customer Service on vow stalemem (Or other addresses we matr spens7y) and shd a decMrt woes we radve it YOUR rNLM MGMS-- KEEP tM NOTICE FOR FUFORE USE. Tills notice c&-Pt *n important information about your rights and our responsibilities ender Br r* Credit 80* Ad. NOW OF 6 Cast Of EMM Wed h rQresnoasAioat raw BIN. N Yoe Odd[yow bill is wrong, or N you need more Wi ca ation about awry transaction on vow brill, Write us, on a separate dwK at our address or probbrs appeathe red. Yos ?? Shy co ? ba ? to as as soon as possbh: We must bear from yoe no liter than 6l1 days after we sent Yoe the ones bill on v AM lint d possible. preserve the svspoded errne - A desoiiplfon dl and v y?lr? obe Nthe foiowkw Your nom ad Accow mmiber-11M dollar cep- l d belim You need more bformum, destrhe Nov Aeon yon are ant son about an volanallorL tdng 3o wood d ova yon ft lo Irwr )% ft cad Oar ReVanbliif cs After We Nwdrs Yaw WMw Aotks. Vh mites admowledge your lemn within 30 days unless we have coneded the prow by Mae, Willi ft 90 bY; we anal siBrr cenad the error or 00afo why we Aelkrs the hi was correct After we receive your kom we armd. try to coked arty amowt Ydv q1 es8, a rspod yw as uteflrquwrt silk ea eornBnae ro tai yon for the smoort you quesNog era kWW Nuance dnxges, and we an ap* arty unpaid xrxmd against your credit ire. Yoe do not hart b pay any uprslbasd amorrd rrhis wt are iw aliga ft but you we still obipkd to pay the parts d yew bill Nat ore not to gmdwL N we AM Nat. we made a rokhki on your bid yoo will snt pan to pay xy diaruce large rebind b ay upaesBalN aruousd N car uffdnl mobs a mistaMR you aaY flirt y flmemcs dprpe; aad)oueryir Caere b spite aP the rnisset peympalt ors the t arrrouat M eNrw ate, wt rri slid you a sbtaaent d tlat anuowd yon nave nut the day 0Nt ti k dine. R yon Fd to payMa auraotaut ws Muds yore ow4 we may report yaw a ddrequerd Howevq N ono exphraNos does roof sattsy Yoe all yaw carne N us wRhM 10 days kfinp srMot yes stR rebore N pap, weswlq bit aayare ise repot)yroouun b 11alyot gsestlpe Your tai. And, we naves k1 yon Bre aar d arrytrae rut reported yes b. Yye rmiai td anyone car repot yoo N Ott Mt saver has Oar settled betsntel use wtaes k Araip.is. M ws donT lolorr Neese ssdes. we wail collect tlue first t50 d Nt pnaBorrd amount eves N vow tai was dorrect t'onrtd Mw? P will ? lrrdl:ses. N you Aare a problem unpin slue gldly d the propcdy a services Mat you prrrJnse• will ow aed7t and arui You lave tried in good Farb to . ice lm ?» ? ?!? nd.Aaw b pap the rpspkdnsp anooorrl dw to tls gepaq a spvioex Tiros are taro imfl>Korvs on Nds right (a) iron name lave salt the _ your iaoant stab wBAAr loo macs d Your carved main, address; xd (b( tlne pwdass cake ?mat haw intern more tlnrt > 7Aest Noes do as appbr 11 ws coon ell operate ft aedanl, or Iwo mthd you the adwoupo wd tar the pftpedy Or services. 1 PROBRRht-The folbwk T"M and Cendiwr, a n will ins RedempNos Ada disclosed b beam" a chen ('IAorhree7, appy y the Rewards Prognae (`n?'lk Ala i dMor revoke UoR tM P?oDrapt is res4iaad ro krdiridunls wfiu saisgtn a Providias YISA rr MaskFCard ata wd account cftcunri loom starA ft YW resem IM right lsanbewslalp or not dow redemption of Room s, as ddned blow to any kMiddal for xry reason whatsonve, EU ft d hNlL Dwbq tilt kd 12 Rtongst yowAccovi d is opnt you wi com 2 pdits CPotrtsl (atoll t1 of Rd P rdwM7bxta ft at Use end of tacit amomNy bit" cyst: )eo w n we 1 PNd b no it d NB Pndtas- RM P111thi ' lmeara pmidtases of pools Or i i ova salt % YON at my Notarized user of the AccooK lmbn ofd Moves x etltlm ad O -1 1bm1 it vebrs dlak; ad aoass dwc*L Points do ad aopoa la bftmd dwm or less d aq bit :rein n Wt nm*rA Nei f xaast ° all dawpes Ciarspes Nadi N the abort ist art Y our sob deatlfon Pint xxrwl wait begkt your EmoAmrnt pall k In R pout Mm m11MIM s VINEW w tam aaxded. TM tnroterma pay mains ft dale ws approve you as a Program mein I Pokds ray oety be arsed1yyow MxONlt b opm amd b mot poet dot w tbora info ONO 1113: bpbnl Your Aawumt b tatnaul ad is toddies b aver lleR yon will begin beats points apakt. Thee b no bur on the Kniberd Points Paco be anrd Pokdt N Mt ka bay Y+I^ camot be ptmdiand or adwuped for asp; and wool tines any rireassstarva be r for a* or used as a paywat for your A==* or oUrr ti101tw set of hinds Prognoi Pokdt is ""ad IMOnYdp as ft rmae d yea Account bilins t Memos. Prints earned ill x" will he posted it your billing Meowd dab all ors ad ardabk7Or rvdlMPSM until A Ipso Iwo buskmes days amer ymar piing statemmt dab D1O"" N POW- ?okrb WM !*M ive YM aAw bekg awarded Potts redeemed eel expired will be based on a N exn Pod-spent basis: A1+dw m of Pehq.'hkds entry be redfsmed to prdods or series (-Reeds-), whkA see sd"In a Mchura mauled to you bona time to Nine. Points m* ofdlr k redeemed A yotarAcco to b?Rerd oo usr o?rr 0 Nv M Rernsds an subJed y araul IMI nsprv Nit ttgM y slodNy orcxlcd arty Reward dam time Mao Pubis tAhare ow b kit your Polls` Points required tar the Reward will be subtracted )ram your Petit Wbn cL You will contact ft parties listed in But Brock" for instructions Irlm " 1111111 UDWV ad F=L Vov will be ? did k resporaibls lot tarry bderA shoe. or bat taxes due arlsi g our of the accroai of Polah or redemption of Bee Rewards. Yov will also be responsible for redt now d any Reword, ibOitpNS M Nta PIBNIata. Tice and on' Me1ON are o0 d our Orb dlsaetioA We reserre In nlpht le ape or damps arty Program fable or Welk prospedfrtlp a abu wAhaA ?l, Point toattl or ?etbrrpUom Or11ek6 amt b caned ortrmpm* suspeM Bu Prapnm at xy punt wkAout itoAa la tAm evad your rxmmA prialypes b tllo aaxrai d Palrrls ell d Rewards: we MUM Be right to cxsce7 xry acaued Pdrds as well as anal Yeu Aaamlf all t1 7trAi s sad N ova eafted lire Pso11rxA wt wq aorm>11jr?leas130 days w.111 Police b you ton address provided IDOL NOWA K 11yes viohy ay brhR say tamatd PopC d` cep ice defatdl coder o AaroorN or Auxowd its cbse4 we Nay anal vi hogam wAhart ovidkg yon 30 days wrAtpt sorties amt yov will say tarlcd your poeUslpalbn mf meii? Nmr tart Progam b role where prddbrad by lede al, sink or Coal ba A serrtces.fOr redernpNoil d tite Rerrxds llnfh Mt and MV are independent comradors all are not atifided with sec Aellim we, no? 1>od113 y hxn? snutkr DnoDerly tint may ?atdl bona paAkipalimi M Nn PrVgrara, euor We rte redempllom Of Rewuds and use of Rewards N xrp tepair, tetuand, or satistadlom d detective, a unsatisfandory to Yoe. yov we bale solely to the rnerdad or mamshclurer of Br Reward and not to es for your dekn We ore ruoFresppsiMe fOr any bet, SID R. destroyed, on expired Rewards. KM 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 -Sara Rubin (NAME) Agent of C Flnfl,,iG??r u?l 1001-Alaintiff herein, that (TITLE) (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) WWR# 19. ? C.aS A7 LAD f 6 SHERIFF'S RETURN - REGULAR CASE NO: 2007-03092 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GA VINANCIAL TRUST 2002-A VS HIGGINS STACY M MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HIGGINS STACY M the DEFENDANT , at 1216:00 HOURS, on the 25th day of May 2007 at 510 W CUMBERLAND ROAD ENOLA, PA 17025 by handing to 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 14.40 Affidavit .00 Surcharge 10.00 .00 &)6N107? 42.40 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 05/29/2007 WELTMAN WEINBERG REIS By : Deputy Sheriff A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GA FINANCIAL TRUST 2002-A Plaintiff vs. STACY M HIGGINS Defendant No. 07-3092-CIVIL PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#05487587 Judgment Amount $ 7837.27 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GA FINANCIAL TRUST 2002-A Plaintiff vs. STACY M HIGGINS Defendant TO THE PROTHONOTARY: Civil Action No. 07-3092-CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, STACY M HIGGINS above named, in the default of an Answer, in the amount of $7837.27 computed as follows: Amount claimed in Complaint $6837.27 Interest from MAY 9, 2007 TO AUGUST 24, 2007 at the contract interest rate of 18.0% per annum $1000.00 TOTAL $7837.27 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: -j? ' - " William T. Molcza quire PA I. D. #47437 WELTMAN, WEINBERG &REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05487587 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7m Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 510 W CUMBERLAND RD ENOLA,PA 17025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GA FINANCIAL TRUST 2002-A Plaintiff STACY M HIGGINS Defendant(s) IMPORTANT NOTICE TO: STACY M HIGGINS 510 W CUMBERLAND RD ENOLA,PA 17025 i Date of Notice: ! WWR##: 05487587 Case # (?q -3 -I 2- -C, I V`I L 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 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY: ?aZ44L*- a4 PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GA FINANCIAL TRUST 2002-A Plaintiff vs. STACY M HIGGINS Defendant Case no: 07-3092-CIVIL NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, STACY M HIGGINS is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, STACY M HIGGINS is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence this 0?2_ day of PENNS' ' ia! Sec This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. ?? P B l y (l Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 AUG-24-2007 09:57:54 < Last Name First/Middle Begin Date Active Duty Status . Service/Agency HIGGINS Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. 4131 )4. it Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seg] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faA/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 8/24/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: FNHMBDGHZJ https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 8/24/2007 r 3 i 4 ? ,J r '1l ? h - ~i'7 w r"o ~ j IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GA FINANCIAL TRUST 2002-A Plaintiff vs. Civil Action No. 07-3092-CIVIL STACY M HIGGINS Defendant NOTICE OF JUQGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Ju gment was entered against you on 11510 (xx) Assumpsit Judgment in the amount of $7837.27plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By. 1.51 11"d' 12 Ua PR ONOTARY (OR DEP ) STACY M HIGGINS 510 W CUMBERLAND RD ENOLA,PA 17025 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219 1-888-434-0085 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GA FINANCIAL TRUST Plaintiff VS. STACY M HIGGINS Defendant SUSQUEHANNA VALLEY FCU, Garnishee Civil Action No. 07-3092-CIVIL PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... all persona-1 proper of de?encf"f- 1. directed to the Sheriff of CUMBERLAND County: 2. against STACY M HIGGINS,-Defendant 510 w . Comberland Bal d ?+? ? z6L, PA 170aX 3. against SUSQUEHANNA VALLEY FCU, Garnishee 3as 0- gnola ", F-Kola. PA 1-7-Dar 4. Judgment Amount 7837.27. Interest Costs SUBTOTAL: $ 9.02 $ 7846.29 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: - William T. Molcz , Esquire PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5487587 64* .+? 00 J ,?, as /p OV Vy 9-1 r n O -6A- . a?u 9s Z 4 ¢ 01 s0 p. d 100 C Q r r, CD _ > y 4 . C?Lr 4 CAL, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-3092 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: . To satisfy the debt, interest and costs due GA FINANCIAL TRUST, Plaintiff (s) From STACY M. HIGGINS, 510 W. Cumberland Rd., Enola, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property of defendant. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: SUSQUEHANNA VALLEY FCU, 325 N. Enola Rd., Enola PA 17025 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 $7,837.27 L.L. $.50 Interest $9.02 Atty's Comm % Due Prothy $2.00 Atty Paid $161.90 Other Costs Plaintiff Paid Date: 9/19/07 /4J.L41A- P-1"" s R. Long, Prothonota (Seal) By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412434-7955 Supreme Court ID No. 47437 GA FINANCIAL TRUST, IN THE COURT OF COMMON PLEAS PLAINTIFF OF CUMBERLAND COUNTY PENNSYLVANIA VS. : STACY M. HIGGINS, CIVIL ACTION - LAW DEFENDANT AND SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, GARNISHEE NO. 07 - 3092 CIVIL ANSWER TO INTERROGATORIES IN ATTACHMENT TO: GA Financial Trust c/o William T. Molczan, Esquire Weltman, Weinberg & Reis Co. L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 1 a. No. 1 b. No. 2. Yes. Accounts (savings and checking) titled in the name of Stacy M. Parnell and Frederick Allen Hipple. Upon information supplied by the Plaintiff the said Stacy M. Parnell appears to be Stacy M. Higgins. The Savings Account had a balance at time of service of the Writ of Execution of $5.00. The Checking Account had a balance at time of service of the Writ of Execution of $27.30. Pursuant to the terms and conditions of the deposit agreement and policies between the credit union and the depositor/s the credit union claims a priority lien in and a right of set off against the accounts consisting of a $175.00 legal processing charge, leaving $0.00 balance for execution purposes. In addition, pursuant to 42 Pa. C.S.A. §2503, Garnishee's attorney's fees are authorized in an amount to be determined and deducted from the attached funds. No. 4. No. V Yes. For the reasons set forth in Answer to Interrogatory #7 depositors have not been precluded from accessing electronically deposited payroll checks. 6. No. 7. Yes. Funds are electronically deposited on a bi-weekly basis by Coca Cola Enterprises into the financial accounts. These sums are exempt from attachment in accordance with Pa. R.C.P. 3111.1 and 42 Pa. C.S.A. §8123 ($300.00 general monetary exemption). Personal earnings are exempt from attachment under 42 Pa. C.S.A. §8127 and Pa. R.C.P. 3123.1. See Answer to Interrogatory 47. Respectfully submitted, BY: S Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Garnishee CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served by postage prepaid, first class United States Mail on all interested parties or counsel of record at the addresses set forth below. William T. Molczan, Esquire Weltman, Weinberg & Reis Co. L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 Stacy M. Higgins (LISPS Certified Mail Return Receipt Requested) Apartment T8 12 B Richland Lane Camp Hill, PA 17011-1115 Date: October 16, 2007 t' 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 Matthew T whit, ---__ (Name) yEru ,garnishee herein. Collections Supervisor of Susquehanna V;4_ne ('T'itle) (Coin]),-Illy) that :,e slic is duly authorized to make this verification, and that the facts set forth in fic: 1-61-egoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNACUIU;) C7 r.? ? p i. ., C.7) _ ? ? .._. u , ?.e+? 'may SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-03092 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GA VINANCIAL TRUST 2002-A VS HIGGINS STACY M And now GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0003:00 Hours, on the 1st day of October , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , HIGGINS STACY M , in the hands, possession, or control of the within named Garnishee SUSQUEHANNA VALLEY FCU 3850 HARTZDALE DRIVE CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to CATHY MCLAUGHLIN (ASST OPERATIONS) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: So a S, Docketing .00 -? Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 10/23/2007 Sworn and Subscribed to before me this day of BY. Deputy S iff A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GA FINANCIAL TRUST 2002-A Plaintiff No. 07-3092-CIVIL VS. PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE SUSQUEHANNA VALLEY FCU ONLY STACY M HIGGINS Defendant SUSQUEHANNA VALLEY FCU Garnishee FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esq. PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5487587 4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GA FINANCIAL TRUST 2002-A Plaintiff VS. STACY M HIGGINS Defendant SUSQUEHANNA VALLEY FCU Garnishee Civil Action No. 07-3092-CIVIL PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE, SUSQUEHANNA VALLEY FCU, ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, SUSQUEHANNA VALLEY FCU, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: '- Ma ew D. Urban, Esq. PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Sworn to and subscribed Before me the A- Day of L , 2008 N TARY P LIC WWR#5487587 COMMONWEAa Tt CP PENNSYLVANIA Noa,lal Seal EWendy GaulNotary Public urgh, Ai;agheny County on Ear7ires July 15, 2010 ember, Pennsylvwniw Assiciation of Notaries 61..} O 00 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: 300.00 Sheriff's Costs 126.38 Docketing 18.00 173.62 Poundage 2.48 y='? Advertising Law Library .50 Prothonotary 2.00 Refunded on 07/29/08 Mileage 14.40 Misc. Surcharge 40.00 Levy 40.00 Post Pone Sale Certified Mail Postage Garnishee TOTAL 9.00 126.38 g -13 -US So Answers `T- 'Are ,40 R. Thomas Kline, Sheriff By LI .LI V ' t" z 0-go Pct cK? 1.5113 gal 12/ 3vsa 0 v w 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-3092 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GA FINANCIAL TRUST, Plaintiff (s) From STACY M. HIGGINS, 510 W. Cumberland Rd., Enola, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property of defendant . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: SUSQUEHANNA VALLEY FCU, 325 N. Enola Rd., Enola PA 17025 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 $7,837.27 Interest $9.02 Atty's Comm % Atty Paid $161.90 Plaintiff Paid Date: 9/19/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs ilia d,#Q is R. Long, Prothonotart By: De u REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437