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Home My WebLink About07-4250ROBERT D. KODAK, ESQUIRE KODAK & IMBLUM, P.C. 407 N FRONT STREET, PO BOX 11848 HARRISBURG, PA 17108-1848 (717) 238-7152 Attorney for Plaintiff FIRST NATIONAL BANK OF OMAHA IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 07- '~fo?5a Civi ( TerM ALICE S. VAN SCYOC Defendant :CIVIL ACTION -LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 AVISO USTED HA SIDO DEMANDADOlA EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparencencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier sums de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE~ LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 FIRST NATIONAL BANK OF OMAHA Plaintiff v ALICE S. VAN SCYOC Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- v.7 sv CGc~ 1 ~.~-- CIVIL ACTION -LAW COMPLAINT The Plaintiff, FIRST NATIONAL BANK OF OMAHA, by its attorneys, KODAK ~ IMBLUM, P.C., brings this action of Assumpsit against the Defendant to recover the sum of SIX THOUSAND ONE HUNDRED TWELVE DOLLARS AND FIFTY-SEVEN CENTS ($6,112.57) ,along with interest thereon at the rate of 31.86% from May 24, 2007, upon a cause of action of which the following is a statement: 1. The Plaintiff, FIRST NATIONAL BANK OF OMAHA, is a National Banking Association organized and existing under the laws of the state of Nebraska, having mailing address of Post Office Box 2951, Omaha, Nebraska, 68103-2951. 2. The Defendant, ALICE S. VAN SCYOC, is an adult individual residing at 139 Elm Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant did apply for a Visa Account with Plaintiff, which Visa Account was opened on or about September 24, 2002. Upon receipt and use of said card Defendants did agree to abide by Plaintiffs terms and conditions for the card as set forth on Plaintiffs Cardmember Agreement, attached hereto, marked Exhibit "A" F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\FIRST NAT OMAHA\OMAHA 33406.wpd: 2 and made a part hereof. 4. Defendant did, at various times, in various places, and for various amounts, avail herself of using the card for credit, thereby creating a balance due and owing in the amount of Five Thousand Ninety-Three Dollars and Eighty-One Cents ($5,093.81), asset forth on Plaintiff s Invoice Statement attached hereto, marked as Exhibit "B" and made a part hereof. 5. The prices charged for said goods, wares, merchandise, services, and/or labor which Defendant charged on said card were just and reasonable, were the legal and market prices therefor and were the prices which the Defendant promised and agreed to pay. 6. Due to the default of Defendant, and pursuant to the terms and conditions of the CardmemberAgreementexecuted by Defendants hereto attached, marked Exhibit "A" and made a part hereof, attorney's fees in the total amount of One Thousand Eighteen Dollars and Seventy-Six Cents ($1,018.76) have been added to said account. 7. Plaintiff frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant refused and neglected and still refuses and neglects to pay said amount of any part thereof. F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\FIRSTNRT OMAHA\OMAHA 33406.wpd: 3 WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of SIX THOUSAND ONE HUNDRED TWELVE DOLLARS AND FIFTY-SEVEN CENTS ($6,112.57) ,along with interest thereon at the rate of 31.86% as set forth herein. Respectfully submitted, KODAK 8~ IMBJ.l,JM, P.C. ,, / .~ Robert D. Kodak, Esquire 407 North Front Street Post Office Box #11848 Harrisburg, PA 17108-1848 (717) 238-7159 Attorney ID No. 18041 Attorney for Plaintiff F:\USER\ROBIN\CCP&DJ CMPS\CCP COMPLAINTS\FIRST NAT OMAHA\OMAHA 33406.wpd: -i/ ~" ~ ~ ~ ~• ~• ~ ~~~ s~ ~~~. ~~ . ~~ ~~~ g ~~~~ ~ ~<~ .~~ G ;~ ~~ ~ ~ ~ ~ ~.. ~~ ~~ ~ . ~ ~ ~~8:~~~ ~~~~ a .~ a ~~ $ s a ~ ~ ~ ~ ~ S. '9 ~ ~ ~~ ~~ ~. ~ ~ o y ~9 ~ ~ ~ }~ ~~~s~ ~~ ~~~ ~~ ~ P .. ~ ~ J ~ "J V T 'C ~ A ]~ {{~~ V~ T M ~ O t, k ~2 D ~T3 sFil ~a. ~, 69~~ ~ P ~~ ~ ~~°~ 3 ~~~ ~' ~a~ a~ $ m` y a ~ 'o ~ ~E ~~~~ V~ a a~~ ~': v ~~ ~ ~ ~r~$3 .~ ~ S ~ & ~~ ~~~~ ~~ ~ ~~s ~ ~ ~~ ~~'~ .~ ... a~ g ~f~ ~ ~• ~~3 .~ ~~~~ ~. ~. ~~~$~ 3~. ~ ~ .~ •~• ~~ ~••~ b ~~~• ~• ~ ~~ ~~~~ o~~~9~ ~~~~~~ ~~~ ~.. ~ ~~ ~~~_ ~ ~ s ~~.~ .~,~ ~~ ~~ s~~~~~ ~~ ~~ y ~~~ a$ ~,~ ~ ~ ~ ~ ~;~ ~ ~~ ~~~~ ~ ~ S ~ ~•~ ~~~ ~~~ ~~~•x z ~~ .. ~~~ ~~~~~~$ s$9~ ~ :~~~.~:~ ~~~~:~ ~~~$~~ ~ ~ ~' ~~~ g ~~. .~~~_ ~` ~ F y~g~.9~ ~.~~ ~~~~ ~~~ ~~ • ~ ~~~~~ ~ ~~ ~• .~~~ g ~ ~ ' ~ ~ ~~ ~ ~~~ ~~_ ~~~~~~ ~5 .. ~ ~~ ~ ~ ~~s~~ ~:~~g~ g'~E.BlS ,~~E~ ~~$~ s ~~~: ~~ ~~ ~~~ • ~~~ . ~ ; ~~ ~~ ~$ ~~ ~~ ~s • ~~ ~ ~~~ ~~ ~~.~~ ~~~ ~ ~ ~.~ ~~. ~~ ~. ~~ ~~ ~~ ~~ ~$ ., ~~~~~ zp8'gL:~ v,~y g, K a .a a 'o ; ~v~~ a _ ~ k a l~ ~~g R ~~qpj{ '~7 p.% A ~ ~ 5 ~ ~ ~ 6 ~ ~~A gF C ~a.~~ $.~y~ -.'off 8 ~^ ~,~ii ls~ jfy ~1 6, ~vvY ~ ~. ~i R4'. ~^ ~~ iL 8 ~ ,~ .~ ~• ~ Mr 8 ~ ~ ~e ~~ ~ ~ ~ ~ ~' . ~• 6 6~ ~ ~ ,g ~ o s ~v"~Q~ ~^~ 3~~fig'g; $ ~_ ~_.~ oy fi' o SP ~ 6^.~ ~:~6 ~~Q ~°~ a ~• ~ ~ ~ ~'"~$ ~`~, R. ~~+ ~ 6 = ~ ~ ~.~ ~o fig' ~" H ~ ; b tD ~ o .~ n 6. ~ ~ ~~ ~.~ ~ $ ~ ,~ ~~ ~~~ ~ ~ s g$- ~ ~ ~~ ~~ ~> ~ ~ ~ ~ ~ r. ~~ ~~ .fig ~ ~ ~ ~ ~ a~~ s ~2 5 8 ~'B'~~~~ ~~~ ~~ ~~~ ~~'A ~~~~ ~~~~~ ~~~ .~~~ .~# ~~~~~ FBCLIg1g ..~.n rvai nanKCaM (a division of First National Bunk of Omaha) and are referred to olleCtivery ~ u9 out this documen as the "Agreement". Frst National Bank Ornoha Oes313 ALICE VANSCYOC 139 ELM ST CARLISLE PA 17013-1921 ~1/ISA Fksl Natbnal Bank Omaha P.O. Box 2557 Omaha, NE 68103-2557 4418940160712571 0000000062800 D000000509381 PLEASE DETACN NERE AND RETURN TOP PORTION WITH YOUR PAYMENT Planaum Edldoa ®visa Account Number. 4418 9401 6071 2571 Payment Due Account Summary Credit Line Statement Closing Date 04-24-07 Previous Balance E 4,881.20 Total Credit LimN S 5,000.00 Days In BlNing Cyde 32 Payments and CredNs - E 0.00 Cash Limit 1 E 2,500.00 Payment Due Date 05-14-07 New Transactions * E 74.00 Available Credit E 0.00 Amount Past Due E 367.00 reel eaea Available Cash E 0.00 Minimum Payment Due $ 628.00 FINANCE CHARGES +E 138.81 New Balance E 5,093.81 Important Information Regarding YourACCOUnt Your account is past due. If your account is not already dosed, your ability to use this account has been suspended. Please submN a payment by return mall. Need Help? OM~negaeas www.flreNa[fonal.com Customer Servbe _ _ _ Balance Transfer Hodine 7DD Telsrommurapdom Davkw for tlro Dsaf TRANSACTIONS Purchase Post CredNa ((CR) Date Date Reference Number Merchant Name J Transadbn Descriptbn and Oebka 4-13 A-24 7dNP947f 1A0001140B2000 LATE CHARrE FEE 53900 L2~ - ~-1-11 7~RAg4711 ~9001140S1d00 -- , O~RLIMtT FEE - - - 3J5~Ob Charge Summary Daly l bg ~ Annu PE~TAGE Average Dally Balance Parbdb Rate a Parton Role Purchases N $ 4,260.58 0.0873% 31.850% 31.86% Cash Advance N $ 701.93 0.0873% 31.850% 31.85% Billed Periodic Rate FINANCE CHARGES 1138.81 Issued by Fkat Natbnal Bank of Omaha Account Number: 4418 9401 6071 2571 Page 001 of 001 Payment Due Date: May 14, 2007 New Balance: 55,093.81 Minimum Payment Due: E628.00 Males drsoks psyaab ro First National Bank anaha Meant P_nclwsa Change of Address? Please check box and compote reverse skle. r~eit~. y/ W ~ ~v /` v~ See reverse for addkbnal bformatbn. ( J~ Thank You For Your Business ~I ~s~2~~°~ ~ ~ ~i ' 'JUN-21-2007 16:52 KNUPP KOpAK &, IMBLUM 717 238 7158 P.07 VERIFICATION I, Teresa McCart Supervisor , (name) (tttle) of FIRST NATIONAL BANK OF OMAHA, verify tha# the statements made in the aforegoing documert are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unsworn falsification to authorities. FIRST NATIONAL BANK OF OMAHA By: Title: Dated: ,~(~lil~ ~~ o2Od 33406 N ~_ u s O ~... ((( J~~ ~ ~ r n v 1 j j ~y~ '~ Jw' ~ ~ T W ' . ~~~ .. ~ t . ~~ C. , "1 ---- `/ SHERIFF'S RETURN - REGULAR CASE NO: 2007-04250 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONAL BANK OF OMAHA VS VAN SCYOC ALICE S KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE VAN SCYOC ALICE S DEFENDANT the at 1548:00 HOURS, on the 24th day of July 2007 at 139 ELM STREET CARLISLE, PA 17013 ALICE VAN SCYOC was served upon by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Postage .41 Surcharge 10.00 .00 $~)~~n9 ~ 33.21 Sworn and Subscibed to before me this day of , So Answers: ~~ .~ R. Thomas Kline 07/25/2007 KODAK & IMBLUM By: pu iff A.D. FIRST NATIONAL BANK OF OMAHA IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 2007-4250 CIVIL TERM ALICE S. VAN SCYOC Defendant ': CIVIL ACTION -LAW TO: PROTHONOTARY COURT OF CpMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT 1ZJDGMENT Enter judgment in favor of Plaintiff and against Defendant(s) ALICE S. VAN SCYOC, named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiff's damages as follows: Amount claimed in Plaintiff s Complaint $6,11257 Interest from May 24, 2007 at the rate of 31.86X per annum ri2,Z 4~ Total $6,640.01 It is hereby certified that a written notice of intention to file this Fraecipe was mailed to flue Defendants} and his attorney of record, after the default occurred and at least ten (10) days prior io the date of the filing of this Praecipe. See Exhibits A & B attached. KODAK &r .C. By _. Robert D. Kodak, Attorney for Plaintiff DATED: S, L,~~ ~ ,~- ~ ~ Judgment entered and damages assessed as above. /5~ ~ ~ oC 0'N..~„ Prothonotary ~ j LAW OFFICES OF KODAK &IMBLUM, P.C. Robert D. Kodak CAMERON MANSION Gary J. Imblum 447 NORTH. FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 kki.law®verizonnet August 16, 2007 ALICE S VAN SCYOC Cf0 RUTHER & ASSOCIATES LLC P O BOX 729 COLUMBIA MD 21045 RE: First National Bank of Omaha VS: Alice S. Van Scyoc No. 2007-4250 Civil Term , Court. of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No. 33406 Dear Ms. Van Scyoc: ~~~~n F 717.238.7158 In accordance with Pennsylvania Rules of Civil Procedure 237.1(a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint: Very truly yours, KODAK &c IMBLUM, P.C. Robert D. Kodak THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDK/kqb enclosure cc: KIRK BRUMBAUGH ESQUIRE BRUMBAUGH & 4885 S 118 STRE OMAHA NE 6813 #07-08918-0 . . ~'!i. E CQPY FIRST NATIONAL BANK OF OMAHA IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 2007250 CIVIL TERM ALICE S. VAN SCYOC Defendant :CIVIL ACTION -LAW IMPORTANT NOTICE TO: ALICE S. VAN SCYOC, Defendant(s) DATE OF NOTICE: AUGUST 16, 2007 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITIN WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIlVIS SET FORTH AGAIlVS~ YOU. UNLESS YOU ACT WTTHIN TEN (~10 DAYS FROM THE DATE OF THIS NOTICE, ,A JUDGMENT MAY BE ENTERED AGAIlV$T YOU W TTHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRIl~TG 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 LEGALSERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 i~ FIRST NATIONAL BANK OF OMAHA ' IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v ALICE S. VAN SCYOC Defendant CIVIL ACTION -LAW TO: SLICE S. VAN~'~OC ,Defendant(s) You are hereby notified that on ` ~ ~ , ~~7 t~ following Qudgment} has been entered against you in the above-captioned case. Tud t entered in the amount of X6.640.01. DATE• S z~a~- 'S, ~~~ NO. 2007-4250 CIVIL TERM Prothonotary ~Q __._ I hereby certify that the name and address of the proper person(s) to receive this notice is: ALICE S vAN SCYOC C/O RUTHER & ASSOCIATES LLC POBOX729 COLUMBIA MD 21045 . ` ~R : ~/i C ' , ~, ' ~. ~'1~1 . ~ . . 1 ~ , ~ ~~yy ~ r„~ .C, Q' -- "C7 .? ~=1 ' ~T1 G _ . . ~- • r PRAECIPE FOR WRIT OF EXECUTION - (MONE~C JUDGMENTS) P.R.C.P..3101 to 3149 FIRST NATIONAL BANK OF OMAHA Plaintiff writ No. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Term 20 No. 2007250 CIVIL Term .2007 vs Amount due $ 6,640.01 ALICE S. VAN SCYOC Interest FROM DATE OF TUDG - 09/05/07 Atty's Comm. $ 332.00 139 ELM STREET Costs to be determined $ CARLISLE, PA 17013 Defendant(s) TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania (2) against ALICE S. VAN SCYOC e en an s ; - (3) and against MEMBERS 1ST FEDERAL CREDIT UNION arras ee s ; (4) and index this writ (a) against ALICE S. VAN SCYOC eenansan (b) against MEMBERS 1ST FEDERAL CREDIT UNION ~ arras ee s , as a lis pendens against the real property of theldefendant(s) in the name of the Gainishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) ATTHE ABOVE ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT-LIMITED TO CASH ON HAND, EQUIPMENT, FURNITURE, JEWELRY, ELECTRONICS, VEHICLES, SUPPLIES, ETC.-AND GARNISH MEMBERS ls= FBDERAL CREDIT UNION, 5000 LOUISE DRIVE, MECBANICSBURG, PA 17055, ACCOUN'P',NO. 2181212107, OR ANY OTHER ACCOUN'PS UNDER DEFENDANT'S NAME (S) . /~ (5) Exemption has (not) been waived. Dated 9 20 07 1(obert u. xoaaK, ~squu'e PO Box 11848 Harrisburg, PA 17108 (717)238-7159 Attorney For Plaintiff(s) •(a)~ipT£ aTn~ aag •pa.z~sap st suapuad eZS s sa bu~xapui pus pagas~~e sT aac~etuxsB aq~ ;o awsu aq~ u•r ~C~.zadoxd taax ;i .CSuo pa~atdmoa aq ptnoc~a (q) (3) gdsx$vxad • lq) bOTE a'[ng aag •.tzsaouou~oxd aq~ .Cq ,~C~unoa ~su~ ui asxnoo ;o es pax~nbaz eF buixapui .{~unoa xaq~ous oa sansei ~~xe+ aq~ uagM •(s)~OS£ ajng ~iq paz~xaq~ne ss pax~sap sF 'aausxnssi ;o .{~unoo aq~ ut suot~naaxa aq~ ;o butxapu-c ;~ ~CSuo paaaSdwoo aq pSnogs (s)(i,) udsxbsxsd ~(~Txe+ au~ ui papnS~ut aq o~ st aaKatuxs6 pamsu a uz ~Suo pa~aSduioo aq pTnous anogs} (£) udsx&gxsa, •pansst gazuM ut d~tmoo au~ ;o ;;txaz{s aua o~ ~CTuo pa~aaxip aq Asw ~uawbpn~ paxxa;susxa s uo panssY atxM a (o)£OT£ aSn~ xapup •pa~saiput aq pSnogs .C~unoa auk '(q)£OT£.Ptn2t ~q pazixoK~na ss .Caunoa xaq~our ;o ;;txags aq~ o~ pa~oaitp st ~txh auk uaga+ (T) gdszbsxsd xapuII 3,LON ~ of ~ N N xy E"~ H O O ~i 5 ~ U ~ o ~ ~ ~ o z z H ~ ~ z w ~* ~. ~8 ~~ 0 i i ~,, ~ _ H w ~... w 0 ~ ~ O w ^ Q w ~~ W ~ a •£ - .. •~ - ~ ~ J ~S ~ ~, ~ ~ ~' 3 ~a r > Q a ~~ ~~. ~-~ ~~ ~ > ; ~ =~ ~_ D ~" . _ ... ~, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4250 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIItST NATIONAL BANK OF OMAHA, Plaintiff (s) From ALICE S. VAN SCYOC, 139 ELM STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO CASH ON HAND, EQUIPMENT, FURNITURE, JEWELRY, ELECTRONICS, VEHICLES, SUPPLIES, ETC. . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FEDERAL CREDIT UNION, 5000 Louise Drive, Mechanicsburg, PA 17055 ACCOUNT NO. 2181212107 OR ANY OTHER ACCOUNTS UNDER DEFENDANT'S NAME(S) 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 $6,640.01 Interest from Date of Judgment - 9/05/07 Atty's Comm $332.00 Atty Paid $152.71 Plaintiff Paid Date: 9/25/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs ~. 's R. Long, Prothonota By: i Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 FIRST NATIONAL BANK OF OMAHA ~ IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 2007-4250 ALICE S. VAN SCYOC Defendant(s) CIVIL ACTION -LAW v MEMBERS 1~ FEDERAL CREDIT UNION Garnishee A,~Sw~ INTERROGATORIES IN ATTACHMENT TO GARNISHEE TO: GARNISHMENT ADMINISTRATOR/LEGAL DEPT MEMBERS 1~ FEDERAL CREDIT UNION, GARNISHEE 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 YOU ARE REQUIRED TO FILE ANSWERS TO THE FOLLOWING INTERROGATORIES WITHIN TWENTY (20) DAYS AFTER SERVICE UPON YOU. FAILURE TO DO SO MAY RESULT IN JUDGMENT AGAINST YOU: 1. At the time you were served, or at any subsequent time, did you owe the defendant(s) above-listed, account no. 2181212107, or any other accounts under defendant(s) name(s), any money or were you liable to the defendant (s) 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? (If yes, please describe.) ANSWER: N~ ~~ cJ~~J~(~~ ~ 'C~- (7(_ 1~SS) 33406 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 (1) or more other persons and/ or entities, any property of any nature owned solely or in part by the defendant(s)?( If yes, please describe.) ANSWER: N~ 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(s) held or claimed any interest? (If yes, please describe.) ANSWER: ~ V 33406 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? ANSWER: ~ ~'f ~ 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 therefor? ANSWER: 33406 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 the defendant's direction or otherwise discharge any claim of the defendant(s) against you? (If yes, please describe.) ANSWER: ~~ 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. ANSWER: N~ 33406 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. ~ 8123? If so, identify each account. ANSWER: ~~ KODAK BLUM, P.C. Robert D. Kodak, Esquire ~ Attorney for Plaintiff 407 North Front Street Post Office Box 11848 Harrisburg, PA 17108-1848 (717) 238-7159 Supreme Court ID No. 18041 33406 VERIFICATION I, CJ- ~~ ~S ~ C ~~~~ , of MEMBERS 1ST FEDERAL CREDIT UNION, Garnishee herein, verify that the statements made in these Interrogatories in Attachment are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. BY: ADDRESS: 0 Louise Drive . Box 40 MEMBERS 1'° echanicsburg, PA 17055.0040 FFDEq,V,CRFDii UNION Dated: (O~ ~~~ st 500 P.0 M 33406 ~ ~... C c ' ~ ~. 1 Z'j~,° ~-- C? _ ~-{ - _- ~ ~ _, ..._ rz i -?? ~;- t ~, ._,. ~~ •• i (`~.) J C":> •C SHERIFF'S RETURN - GARNISHEE CASE N0: 2007-04250 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND FIRST NATIONAL BANK OF OMAHA VS VAN SCYOC ALICE S And now WILLIAM CLINE ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:09 Hours, on the 27th day of September, 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , VAN SCYOC ALICE S in the hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to MARY BEASTON (ACCOUNT REP 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 true and made So answers: . 0 0 ,, , .00 .00 Thomas Kline .00 Sheriff of Cumberland County . o000 / ~-,- is/>%~ 12/06/2007 S day of By Deputy eriff A.D FIRST NATIONAL BANK OF OMAHA Plaintiff v ALICE S VAN SCYOC Defendant(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-4250 CIVIL ACTION -LAW v MEMBERS 1ST FEDERAL CREDIT UNION Garnishee TO THE PROTHONOTARY: PRAECIPE Please dissolve the Garnishment against MEMBERS 1ST FEDERAL CREDIT UNION issued in the above-captioned matter. TO: Cumberland County Prothonotary Dated: October 22, 2007 Robert D. Kodak, Esquire Attorney for Plaintiff Attorney I.D. No. 18041 ~--~ ;,~~ ~ ~ ~ C~~ ;~ ~ r ~ ~~~ r-- p_ i ~ ~,Y F F I ~.: y R ,t ' Qp ~~ , .. , \ l4"~ ~ ~ ' ' ~~ -- ~~ ~+.: ~ :.. y. r +"r .. j ;~ w. ^^.... .M::s . M_ z. Thomas Kline, Sheriff, who being duly sworn according to law, states 's writ is returned STAYED. `~eriff s Costs: Advance Costs: 150.00 Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL Sheriff s Costs: 150.00 18.00 000.00 2.89 10.00 .50 2.00 Refunded to Atty on 02/19/08 12.61 40.00 40.00 ~- ,=-_ . 4 _,~ ~_ ~: ~: . -_ 15.00 9.00 $ 150.00 / ;~lz~lo~'~So Answers; R. Th mas Kline, eriff ~~~~~ By Claudia A. Brewbaker ~~'N ~ ~~S'y7 ~. ~ .? D.~ 3 7 S 0 s WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4250 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST NATIONAL BANK OF OMAHA, Plaintiff (s) From ALICE S. VAN SCYOC, 139 ELM STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO CASH ON HAND, EQUIPMENT, FURNITURE, JEWELRY, ELECTRONICS, VEHICLES, SUPPLIES, ETC. . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FEDERAL CREDIT L'NION, 5000 Louise Drive, Mechanicsburg, PA 17055 ACCOUNT NO. 2181212107 OR ANY OTHER ACCOUNTS UNDER DEFENDANT'S NAME(S) 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 $6,640.01 Interest from Date of Judgment - 9/05/07 Atty's Comm $332.00 Atty Paid $152.71 Plaintiff Paid L.L. $.50 Due Prothy $2.00 Other Costs Date: 9/25/07 (Seal) REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 urtis R. Long, Prothonot By: Deputy Supreme Court ID No. 18041