HomeMy WebLinkAbout03-5423
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYlVANIA
CIVIL DIVISION
PLATINUM FINANCIAL SERVICES,
CORPORATION, A MiI.RYLAND
CORPORATION ASSIGNEE OF
FORWARD PROPERTIES, INC
ASSIGNEE BANKFIRST CORPORATION,
INC
c/o WOLFSON & ASSOCIATES, P.C
267 EAST MARKET STREET
YORK, PA 17403
vs.
FileNo. ^'4 -~ (}';tL~~
BARBARA SHEAFFER
132 S BEDFORD STREET
CARLlS LE, P A 17013
Civil Action - Law
PRAECIPE FOR SUMMONS
TO THE PROTHONOTARYICLERK:
Issue summons in Law in the above case.
XX Writ of Summons shall be issued and forwarded to Defe
Date: tl )cJ!1/03
Amy F. Wolfson, Esq r
WOLFSON & ASSO ATES, P.C
267 East Market Street
York, PA 17403
(717) 846-1252
Supreme Court ID Number 87062
* :;: * * *
SUMMONS IN CIVIL ACTION
TO: BARBARA SHEAFFER 132 S BEDFORD STREET CARLISLE, PA 17013
(Defendant Name and Address)
YOU ARE NOTIFIED THAT THE ABOVE.NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION
AGAINST YOU. \ /J
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES,
CORPORA nON, A MARYLAND
CORPORATION ASSIGNEE OF
FORWARD PROPERTIES, INC
ASSIGNEE OF BANKFIRST
CORPORA TION, INC.,
Plaintiff
No. D.3 ~3 CiOlC-lfll.nJ
vs.
CIVIL ACTION - LAW
BARBARA SHEAFFER,
Defendant
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF YORK
I, Amy F. Wolfson, Esquire, being duly sworn according to law, depose and say that
I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of
my knowledge, information and belief Defendant, Barbara Sheaffer, above named, is over
21 years of agej is last know to reside at 132 S. Bedford Street Carlisle, Pa 17013,
Cumberland County, Pennsylvaniaj is not in the military service of the United States or its
Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of
Congress of 1940 and its Amendments.
SWORN and SUBSCRIBED
to b~e me this .t.9Il..Aay
of u:,r;etJ~r-, 20 tJ3 .
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.../YUMNota IC
Notarial Seal
MeIiSSll Dee sweeney. NoIBryPu\:iIC
Clty Of York. York ColrtY_
MyCofTl11lsslOl1 Expires ~ 12.
. .-........... OfNolarieS
Member. f'ennSYIvan'" ~_.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES,
CORPORATION, A MARYLAND
CORPORATION ASSIGNEE OF
FORWARD PROPERTIES, INC
ASSIGNEE OF BANKFIRST CORPORATION,
INC.,
Plaintiff
No, 03 -SlIJJ C?z~~C-T~
vs,
CIVIL ACTION" LAW
BARBARA SHEAFFER,
Defendant
CERTIFlCA TE OF RESIDENCE
PA. R. C. P. 236
I, hereby certify that the precise residence of Plaintiff is:
PLATINUM FINANCIAL SERVICES CORPORATION, A MARYlAND
CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC.
ASSIGNEE OF BANKFIRST CORPORATION, INC.
c/o WOlFSON & ASSOCIATES, P.c.
267 EAST MARKET STREET
YORK, PA 17403
and certify that the last known address of the within Defendant is:
BARBARA SHEAFFER
132 S BEDFORD STREET
CARlISLE, PA 17013
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PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
, P.R.C.P. 3101 to 3149
. .
PLATINUM FINANCIAL SERVICES
CORP., A MARYLAND CORPORATION
ASSIGNEE OF FORWARD
PROPERTIES, INC., ASSIGNEE'"
OF BANKFIRST CORPORATION, INC.
P.O. BOX 10247
ROCKVILLE, MD 20849-0247
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
I
JUDGMENT NO. 03-5423
BARBARA M SHEAFFER
132 S BEDFORD ST
CARLISLE PA 17013-3402
:
PRAECIPE FOR WRIT OF EXECUTION
(MONEY JUDGMENT)
Defendant (s)
To the Prothonotary: PLEASE ISSUE WRIT OF EXECUTION
(1) Directed to the Sheriff of CUMBERLAND
(2) against, BARBARA M SHEAFFER
132 S BEDFORD ST
CARLISLE PA 17013-3402
IN THE ABOVE MATTER.
COUNTY, Pennsylvania;
, Defendant (s) ;
(3) and against, MEMBERS FIRST FCU
1000 BRYN MAWR RD
CARLISLE PA 17013-1588
(4) and index this writ
(a) against, BARBARA M SHEAFFER
, Garnishee (s);
(b) against, MEMBERS FIRST FCU
as a lis pendens against the real property of the
Garnishee(s) as follows:
(Specifically describe property) *** GARNISH ONLY
, Defendant(s) and
, Garnishee (s),
Defendant(s) in the name
of the
***
You are directed to attach the property of the Defendant(s) not levied upon in the
possession of MEMBERS FIRST FCU
1000 BRYN MAWR RD
CARLISLE PA 17013-1588
Garni shee (s)
All accounts including but not limited to all savings, checking and other accounts,
certificates of deposit, notes receivables, collateral, pledges, documents of
title, securities, coupons and safe deposit boxes.
Amount due
Interest from 10/14/2003
At an interest rate of 6% per year
Dated: ~
$ 1778.28
To Be Determined
28 Plus costs & interest
Amy F. Doy e #870 /
Philip C. Warh lie #86341 /
David R. Gallo ay #87326 /
Ronald M. Abramson #94266 /
Bruce H. Cherkis #18837
WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
4660 Trindle Road. 3rd Floor. Camo Hill. PA 17011 I
Daniel Wolfson
Andrew C. Spears
Tonilyn M. Chippie
Ronald S. Canter
1120617
1187737
1187852
1194000
(717) :\03-6700
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-5423 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PLATINUM FINANCIAL SERVICES CORP., A
MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF
BANKFIRST CORPORATION, INC., Plaintiff (s)
From BARBARA M. SHEAFFER, 132 S BEDFORD ST" CARLISLE, PA 17013-3402
(I) You are diJ:ected to levy upon the property of the defendant (s)and to sell
(2) You aJ:e also directed to attach the property of the defendant(s) not levied upon in the possession
of MEMBERS FIRST FCU, 1000 BRYN MAWR RD" CARLISLE, P A 17013-1588 - ALL
ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER
ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL,
PLEDGES, DOCUMENTS OF TITLE, SECURITITES, COUPONS AND SAFE DEPOSIT BOXES,
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attaclunent has been issued; (b) the gamishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any propeJ:ty of the defendant
(s) OJ: otherwise disposing theJ:eof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attaclunent is found in the possession
of anyone other than a named garnishee, you aJ:e directed to notify him/heJ: that helshe has been added as a
garnishee and is enjoined as above stated.
Amonnt Due $1778.28
LL $,50
InteJ:est FROM 10/14/03 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm
Atty Paid $82.50
Plaintiff Paid
%
Due Prothy $1.00
OtheJ: Costs
Date: DECEMBER 28, 2005
(Seal)
By:
Deputy
REQUESTING PARTY:
Name PHILIP C. WARHOLIC, ESQUIRE
Address: WOLPOFF & ABRAMSON, L.L.P,
4660 TRINDLE ROAD
3RO FLOOR
CAMP HILL, P A 17011
Attorney fOJ:: PLAINTIFF
Telephone: 717-303-6700
Supreme Court ID No. 86341
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-05423 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PLATINUM FINANCIAL SERVICES
VS
SHEAFFER BARBARA
And now CPL. TIMOTHY REITZ
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0012:38 Hours, on the 6th day of January
2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
SHEAFFER BARBARA ' in the
hands, possession, or control of the within named Garnishee
MEMBERS FIRST FCU 1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
BRIAN M, PETERS (BRANCH MANAGER)
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 His ,
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers:
,00
,00
,00
,00
,00
,00
R. Thomas Kline
Sheriff of Cumberland County
01/09/2006
Sworn and subscribed to before me
this In IS day of C)....,.u-;
-<wi,. A,D. 2J4!~
prot~~~7
By
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248
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
. .
PLATINUM FINANCIAL SERVICES
CORP., A MARYLAND CORPORATION
NO. 03-5423
Plaintiff
vs.
CIVIL ACTION-LAW
BARBARA M SHEAFFER
132 S BEDFORD ST
CARLISLE PA 17013-3402
:
.
.
..
Defendant(s)
/) JU. S l.0 ens --lo
INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION
TO:
PURSUANT TO RULE 3114 OF THE.RULES OF CIVIL PROCEDURE, THE FOLLOWING
INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY
REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND
FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE
CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE
REFERENCED DEBTOR(S).
IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE
A. 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.
B. The term "Defendarit(s)" means the individual(s) or entity against
whom the Writ of Execution was issued.
C. "You" means the main office and all branch offices,
representatives, employees, and agents of your organization.
D. By service of the Writ of Execution upon you, all property of the
Defendant(s) subject to attachment which is in your possession, custody or
control is attached, including all property of the Defendant(s) which comes
into your possession thereafter.
E. These Interrogatories are considered to be continuing and
therefore should be modified or supplemented as you receive further or
additional information.
F.
is to be
as such,
es t imate
Where exact information cannot be furnished, estimated information
supplied. When an estimate is to be used, it should be identified
and an explanation should be given as to the basis on which the
is made, and the reason the exact information cannot be furnished.
G. Where knowledge or information in possession of a party is
requested, such request includes knowledge of the party's agents,
representatives, and attorneys.
ORALEX/PAWR IT
S51t 196 48 1944
W&A FILE NO. 101598726
246
PLAINTIFF'S INTERROGATORIES TO GARNISHEE
, DEFENDANT(S) -, BARBARA M SHEAFFER
. .
132 S BEDFORD ST
CARLISLE PA 17013-3402
". sslI 196 48 1944
1. DEPOSITORY ACCOUNTS: At the time you wer~ served or at any subsequent
time, state whether or not the Defendant(s) maihtains any checking, savings,
lines of credit, certificate of deposit's or other depository accounts with
your institution. If so, state the identification numbers of those accounts,
and the amount or amounts the Defendant(s) has in each account. If the
Defendant(s) maintains any of these jointly with any other person, or'
persons, give their name ,and address. yes
Acd.::#: :i3Cf8^OI ~ Cv\)L~ill~ F/, 149.ltf
SOUln~:J -119.11
Prltnaty- bC/Ybartl ftj. ShPtlfftr ,)tJf!)f -SDndrt1 J,~fvafff;
1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have
listed above direct deposit accounts? If yes, please state the
identification numbers of those accounts. yes.
a 39m;
2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent
time, state whether or not the Defendant(s) maintains any safe deposit box or
boxes. If so, include the identification number or other designation of the
box or boxes. Include a full description of the contents and also the amount
of cash among those contents. If the Defendant(s) maintains any of these
jointly with any other person or persons, give their full name and address.
NO.
3. PERSONAL PROPERTY: At the time you were served or at any subsequent
time, state whether or not Defendant(s) owns any personal property that was
in your possession and/or control. If so, include a full description of all
personal property giving full value and present location. State also whether
or not there are any encumbrances or liens holders, the present balance of
the encumbrance. State where and when the encumbrances or liens was
recorded. If the Defendant(s) owns any personal property jointly with any
person or persons, give names and address.
ND,
4. OTHER ASSETS: At the time you were served or
did you know of the existence of any other asset(s)
are not disclosed in the preceding Interrogatories.
all details concerning those asset(s).
I~D.
at any subsequent time,
of the Defendant(s) which
If so, please set forth
('\'tI A' 1:'') I'D At.I'DTT
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247
, .
5. PROPERTY: At the time you were served or at any subsequent time, was
there in your possession, custody, or control or in the joining possession,
custody, or control of yourself and one or more other persons any property
of any nature owned solely or in part by any Defendant (s)? If so, please
describe for each Defendant(s) each item of property including its value.
Nu
6. REAL PROPERTY: At the time you were served or at any subsequent time,
did you hold legal, or equitable title to any property of any nature owned
solely or in part by the Defendant(s) or in which and Defendant(s) held or
claimed any interest? If so, describe for each Defendant(s) each item of
property including its value and the interest held by the Defendant(s).
I\J D,
7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any
subsequent time, did you hold as a fiduciary any property in which any
Defendant(s) had an interest? If so, please describe for each Defendant(s)
the nature of the property including its value and the interest
of Defendant(s).
NO,
8. TRANSFER OF PROPERTY: At any time before or after you were served, did
any Defendant(s) transfer or deliver any property to you or to any person or
place pursuant to your direction or consent. If so, for each Defendant(s)
describe the property transferred or delivered including the dates of
delivery or transfer and state the consideration paid.
I~D
9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or
processing fees charged by you against the Defendant(s) or account(s) of the
Defendant(s) for the completion of this Answer. If yes, outline the exact
amount of any fees due and owing to the garnishee or the attorney for the
garnishee for ti\!{)~paration of the Answer. ~
Amy F. Doyle #87062 /
Philip C. Warho ic #86341 /
David R. Galloway #87326 /
Ronald M. Abramson #94266 /
Bruce H. Cherkis #18837
WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011
(717) 303-6700
1120617
1187737
1187852
1194000
Daniel olfson
Andrew C. Spears
Tonilyn M. Chippie
Ronald S. Canter
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES
Plaintiff
NO. 03.5423
vs.
CIVIL ACTION - LAW
BARBARA M SHEAFFER
Defendant
vs.
Members First FCU
Garnishee
Garnishee:
Members First FCU
1000 Bryn Mawr Road
Carlisle, Pa 17013-1588
PRAECIPE FOR JUDGMENT UPON ADMISSION
To the Prothonotary:
Please enter judgment in favor of the Plaintiff and against the Garnishee, Members First
Feu, in the amount of $614.59, as admitted in the answer to Interrogatories to be in the
possession of Garnishee. The amount of the judgment together with interest and costs of the
Plaintiff against the Defendant is $1 ,77B.2B,
1/;:;;:(0
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Dated:
Amy F. Doyle # 062
Daniel F. Wolf n #20617
Philip C. Warholic #86341
Andrew C. Spears #87737
Da~id R. Galloway #87326 ,.-/
Tonilyn M. Chippie #87852
Ronald M. Abramson #94266
Ronald S. Canter #94000
Bruce H. Cherkis #18837
WOLPOFF & ABRAMSON, LLP
Attorneys in the Practice of Debt Collection
4660 Trindle Rd., 3,d Floor
Camp Hill, PA 17011
(717) 303.6700
W&A File No. 101598726
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES
CORP., A MARYLAND CORPORATION
ASSIGNEE OF FORWARD
PROPERTIES, INC., ASSIGNEE
OF BANKFIRST CORPORATION, INC.
P.O. BOX 10247
ROCKVILLE, MD 20849-0247
Plaintiff
No. 03-5423
vs.
BARBARA M SHEAFFER
132 S BEDFORD ST
CARLISLE PA 17013-3402
Defendant (s)
PRAECIPE TO SETTLE AND SATISFY
PLEASE MARK THE ABOVE-CAPTIONED ACTION AS SETTLED, SATISFIED AND DISCONTINUED.
Respectfully submitted,
By:
(k
Amy F. Doyle #87062 /
Philip C. Warholic #86341 /
David R. Galloway #87326 /
Ronald M. Abramson #94266 /
Bruce H. Cherkis #18837
WOLPoFF & ABRAMSON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011
(717) 303-6700
Daniel F. Wolfson
Andrew C. Spears
Tonilyn M. Chippie
Ronald S. Canter
1120617
1187737
1187852
1194000
cc:
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IN THE COURT OF COMMON PLEAS OF
CUMERLAND COUNTY, PENNSYLVANIA
PLATINUM FINANCIAL SERVICES
Plaintiff
NO. 03-5423
vs.
CIVIL ACTION - LAW
BARBARA M. SHEAFFER
Defendant
...
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
To the Pmthonotary:
Kindly mark the attachment against the Garnishee, Members First Fcu. discontinued. upon
payment of your costs only.
Respectfully Submitted,
Dated:
f f;.e~
/
A~#87062
Daniel F, Wolfson #20617
Philip C, Warholic #86341
Andrew C. Spears #87737
David R. Galloway #87326---
Tonilyn M. Chippie #87852
Sarah E. Ehasz #86469
Robert N. Polas, Jr, #201259
Ronald M, Abramson #94266
Ronald S. Canter #94000
Bruce H. Cherkis #18837
WOLPOFF & ABRAMSON. LLP
Attomeys in the Practice of Debt Collection
4660 Trindle Rd" 3'd Floor
Camp Hill. PA 17011
(717) 303-6700
W&A File No, 101598726
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriffs Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
TOTAL
18.00
1.66
.50
1.00
4.40
30.00
20.00
Advance Costs: 150.00
Sheriffs Costs 84.56
65.44
Refunded to Atty on 10/04/06
9.00 ...J / /1
84.56 ./ J'fIJII)(, --,-.
So Answers;
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R. Thomas Kline, Sheriff - c.e-
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-5423 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PLATINUM FINANCIAL SERVICES CORP., A
MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF
BANKFIRST CORPORATION, INC., Plaintiff (s)
From BARBARA M. SHEAFFER, 132 S BEDFORD ST., CARLISLE, P A 17013-3402
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of MEMBERS FIRST FCU, 1000 BRYN MAWR RD., CARLISLE, P A 17013-1588 - ALL
ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER
ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL,
PLEDGES, DOCUMENTS OF TITLE, SECURITlTES, COUPONS AND SAFE DEPOSIT BOXES.
GARNISHEE(S) as follows:
and to notify the gamishee(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) Ifproperty 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 himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $1778.28
1.1. $.50
Interest FROM 10/14/03 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm %
Atty Paid $82.50
Plaintiff Paid
Date: DECEMBER 28, 2005
Due Prothy $1.00
Other Costs
(Seal)
By:
Deputy
REQUESTING PARTY:
Name PIDLIP C. W ARHOLIC, ESQUIRE
Address: WOLPOFF & ABRAMSON, L.L.P.
4660 TRINDLE ROAD
3RD FLOOR
CAMP HILL, P A 17011
Attorney for: PLAINTIFF
Telephone: 717-303-6700
Supreme Court ID No. 86341