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Home My WebLink About03-5425IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLATINUM FINANCIAL SERVICES, CORPORATION, A MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC. ASSIGNEE BANKFIRST CORPORATION INC. c/o WOLFSON & ASSOCIATES, P.C. 267 EAST MARKET STREET YORK, PA 17403 vs. BARBARA SHEAFFLR 132 S BEDFORD STREET CARLISLE, PA 17013 File No. C%3 5 Civil Action - Law PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK: Issue summons in Law in the above case. XX Writ of Summons shall be issued and forwa Date: lcA 03 Supreme Court ID Number 87062 SUMMONS IN CIVIL ACTION l _ LC?i C??'1Lr?1 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. Date: (?Ir4 I y( )-06 3 Prothonotary/Clerk, Civil Divi O?, 0 7 /QL/?J Deputy Amy F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, PA 17403 (717) 846-1252 1 61 w?I S? 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 VS. BARBARA SHEAFFER, Defendant No. 03 :SqZ ?LUIC?? CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK 1, 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 age; is last know to reside at 132 S. Bedford Street Carlisle, Pa 17013, Cumberland County, Pennsylvania; 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. AP, Amy F. 1 (fson, E Fe Attorney for the mtiff Attorney ID#8 62 Wolfson 8i Associates, P.C. 267 East Market Street York, PA 17403 SWORN and SUBSCRIBED to before me this day of 20 Notary Public n - z, ?> c < . ?. , ;- -,; ?_? .n 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 Vs. BARBARA SHEAFFER, Defendant No. 6.3-.S q 1S Cfi. 4,? wL CIVIL ACTION - LAW CERTIFICATE 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 8z 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 WOLFSON $ ASSO 267 East Market Str! York, PA 17403 (717) 846-1252 ID No. 87062 Attorney for Plaintiff P.C. C7 (::.- ,_. -? ?_? , ,. .. ?- '?? __. ? _?t SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee PLATINUM FINANCIAL SERVICES CORP., A MARYLAND CORPORATION COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. BARBARA M.SHEAFFER and NO. 03-5425 WACHOVIA BANK, N.A., (;ARNTSHFF. TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Wachovia Bank, N.A., Garnishee, in the above-captioned matter. JONRSIRLIN Atto e for Garnishee ?? o -., ?? in ' ? ? '? i n N ; -n?„ -'?? C ? f'-. ?? .; i ?-`-' r,,a .? 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 JUDGMENT NO. 03-5425 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 IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania; (2) against, BARBARA M SHEAFFER 132 S BEDFORD ST CARLISLE PA 17013-3402 (3) and against, WACHOVIA BANK , Defendant(s); 604 E HIGH ST CARLISLE PA 17013-2661 Garnishee(s); (4) and index this writ (a) against, BARBARA M SHEAFFER Defendant(s) and (b) against, WACHOVIA BANK Garnishee(s), as a lis pendens against the real property of the Defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property) *** GARNISH ONLY *** You are directed to attach the property of the Defendant(s) not levied upon in the possession of WACHOVIA BANK 604 E HIGH ST CARLISLE PA 17013-2661 Garnishee(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 $ 1406.33 Interest from 10/14/2003 To Be Determined At an interest rate of 62 per year Total $ 1406.33 Plus costs & interest Dated: //V? Amy F. oyle /87062 / Danie F. Wolfson #20617 Bruce H. Cherki #18837 / Philip C. Warholic #86341 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Donald P. Shiffer #89451 / Andrew C. Spears #87737 WOLPOFF & ABRAMSON, L.L.P. j Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 / (717) 303-6700 ATT1/PAWRIT W&A FILE NO. 101600127 V{ s Rte, A , ?J vii :69 `' `? o c C uj- ?s r`.1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-5425 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 Plaintiff (s) From BARBARA M. SHEAFFER, 132 S. BEDFORD ST., CARLISLE, PA 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 WACHOVIA BANK, 604 E HIGH ST., CARLISLE, PA 17013-2661 -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. GARNISHEE(S) as follows: 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 $1406.33 L.L. $.50 Interest FROM 10/14/03 AT AN INTEREST RATE OF 6 % PER YEAR Atty's Comm % Atty Paid $82.50 Plaintiff Paid Date: SEPTEMBER 7, 2005 Due Prothy $1.00 Other Costs rothonota (Seal) By: Deputy REQUESTING PARTY: Name PHILIP C. WARHOLIC, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD 3"n FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 86341 SHERIFF'S RETURN - GARNISHEE CASE NO: 2003-05425 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PLATINUM FINANCIAL SERVICES VS SHEAFFER BARBARA And now SHANNON SHERTZER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:39 Hours, on the 16th day of September, 2005, 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 WACHOVIA BANK 604 E. HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to JILL MANLEY (FINANCIAL 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 Her . Sheriff's Costs: So an1s'?? Docketing .00 ? Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 00 09/19/2005 Sworn and subscribed to before me this day of S? ?r4441Lr T- A. D. Pr ono y By Deputy Sh iff SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee PLATINUM FINANCIAL SERVICES CORP., COURT OF COMMON PLEAS A MARYLAND CORPORATION COUNTY OF CUMBERLAND VS. BARBARA M. SHEAFFER : NO. 03-5425 and WACHOVIA BANK, N.A., GARNTSHFF TO: PLATINUM FINANCIAL SERVICES CORP., A MARYLAND CORPORATION, Plaintiff 1. No. 2. Yes. At the time of service of the Writ, Defendant maintained the following accounts and balances: Account titled in the name of Marvin R. Valentine, Barbara M. Sheaffer with a balance of $817.99, and an account titled Marvin M. Valentine, Barbara M. Sheaffer with a balance of $1,269.41. The total sum of $2,087.40 has been restricted pursuant to this Writ. Garnishee is unable to determine from its records whether Marvin R. Valentine, Barbara M. Sheaffer, and the account titled Marvin R. Valentine, Barbara M. Sheaffer are entireties accounts or a joint accounts. Garnishee incorporates herein by reference its New Matter as set forth below. 3: 6. No. 7. See answer to No. 2 above and No. 9 below. YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS OF SERVICE THEREOF OR A DEFAULT JUDGMENT MAYBE ENTERED AGAINST YOU. 8. Garnishee incorporates by reference its Answers to Interrogatories one through seven above as though fully set forth herein. 9. As set forth above, the account titled Marvin R. Valentine, Barbara M. Sheaffer, and the account titled Marvin R. Valentine, Barbara M. Sheaffer are titled to either tenants by the entireties or to joint tenants. Garnishee is unable to determine from its records as to the appropriate designation of the accounts. If the parties to the instrument are husband and wife, then such assets are entireties assets and are not subject to execution pursuant to a judgment against either party, but only pursuant to a judgment against both parties. If the assets are titled to joint tenants, the assets cannot be executed upon without competent proof by Plaintiff that the attached assets belong to the judgment debtor and without an appropriate Order of Court directing the Garnishee to permit execution against such assets by Plaintiff in whole or in part. Garnishee will stay further action pending a hearing and determination by the appropriate Court. JON C. SIRLIN Attorney for Garnishee Cy WACHOVIA VERIFICATION Legal Order Processing 104 Independence Mall East 11th Floor - PA4418 Philadelphia, PA 19106 Kathleen Gormley, being duly sworn according to law, deposes and says that she is the Writ of Execution Administrator of Wachovia National Bank, Garnishee herein, and verifies that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to sworn falsification to authorities. Kathleen Gorml Manager bated: 1?? ?? ?' CT Ul ?_ _ U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Platinum Financial Services Plaintiff NO. 03-5425 VS. Barbara M. Sheaffer Defendant CIVIL ACTION - LAW PRAECIPE TO DISMISS WRIT OF EXECUTION To the Prothonotary: Please dismiss the Writ of Execution which has been filed in the above-referenced matter. Dated: I / / I"t, ? Respectfully Submitted, Aze ? Amy F. Doyle ##062 Daniel F. Wolfs #20617 Philip C. Warho tc #86341 Andrew C. Spears #87737 David 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. 101600127 ?... (_- f U SinLTV OAALLACTX & LESSER, P_C By: Jon C. Sirlin, Esquire, I.D. No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee PLATINUM FINANCIAL SERVICES CORP., A MARYLAND CORPORATION COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. BARBARA M.SHEAFFER and NO. 03-5425 WACHOVIA BANK, N.A., GARNISHEE ATTORNEY I.D.#17498 Garnishee, Wachovia Bank, N.A., hereby bills the following costs to the fund attached and will be satisfied therefrom, as authorized by 42 Pa.C.S.A. Section 2503: Garnishee's fee pursuant to 42 Pa. C,S.A Section 2503: $200 00 Notary Charges: % 0 00 Entry of Appearance: % 000 Answers to Interrogatories: % n_nn Order to Discontinue or Satisfy: % 000 Other: $ 0 00 TO S20000 JON C. IN Attom for Garnishee Costs are hereby taxed in the amount of $ ts\ [jT d ofd` , 2005. PRO ON Y BY: r_o +.J "--? ? ; _ _ i7 C..'". .. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-5425 Ciyi1 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PLATINUM FINANCIAL SERVICES CORP., A MARYLAND CORPORATION Plaintiff (s) From BARBARA M. SHEAFFER, 132 S. BEDFORD ST., CARLISLE, PA 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 WACHOVIA BANK, 604 E HIGH ST., CARLISLE, PA 17013-2661 - 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. 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) 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 $1406.33 L.L. $.50 Interest FROM 10/14/03 AT AN INTEREST RATE OF 6 % PER YEAR Any's Comm % Atty Paid $82.50 Plaintiff Paid Date: SEPTEMBER 7, 2005 Due Prothy $1.00 Other Costs Pro/thonotar (Seal) By Deputy REQUESTING PARTY: Name PHILIP C. WARHOLIC, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD Sao FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 86341 Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Advance Costs: 150.00 Sheriffs Costs: 111.37 Docketing 18.00 $ 38.63 Poundage 28.13 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 11 /22/05,., Mileage 4.00 Surcharge 30.00 Levy 20.00 Certified Mail Post Pone Sale Garnishee 9.00 cr' Postage .74 TOTAL $ 111.37 Sworn and Subscribed to before me So Answers- day of This _ R. Thomas Kline, Sheriff v 2005 A.D. Prothonof I ?? r (100, Di / 2? Ak X By Claudia A. Brewbaker c. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-5425 PLATINUM FINANCIAL ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF BANKFIRST CORPORATION, INC. 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff Vs. BARBARA M SHEAFFER 132 S BEDFORD ST CARLISLE PA 17013-3402 Defendant(s) PRAECIPE TO SETTLE AND SATISFY PLEASE MARK THE JUDGMENT IN THE ABOVE-ENTITLED CAUSE AS PAID AND SATISFIED. Respectfully submitted, By: Amy F. D yle #87062 / aniel Wolfson #20617 Philip C. Warhol'c #86341 / David R. Galloway #87326 Tonilyn M. Chip e #87852 / Robert N. Polas, Jr. #201259 Sarah E. Ehasz #86469 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (800) 830-2793 Fax: (866) 281-9028 cc: PAPR2/PA176A W&A FILE NO. 101600127 " -1%. CERTIFICATE OF SERVICE I, Brandi Stabley, an authorized agent of WOLPOFF & ABRAMSON, LLP, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Camp Hill, PA, first class mail, postage prepaid, addressed as follows: r 13?. S . ?df o-rd ?. ?liste., '?, 11 U ? ? WOLPOFF & ABRAMSON, LLP By bAW& \aQ N 0 Brandi Stabley- Quality Control 4660 Trindle Rd., 3`d Fl. Camp Hill, PA 17011 (717) 303-6700 Dated: ?? ' 01 O C? _.t ?.., ?,?, " ? ? _ _? ?. ? '?. .. i ._?? ; ? r? ?-- :? G..a •• --a a