HomeMy WebLinkAbout07-7000Leonard A. Sanguedolce, Esquire
Attorney for Plaintiff, CACH, LLC.
Identification No. 204325
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
Phone: (570) 823-0101
Fax: (570) 825-7799
CACH, LLC,
Plaintiff
vs.
JEFFREY HIMES,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
NO. D 7 ' 70 0 D > ?:e?i?1
NOTICE
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 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
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
800-990-9108
Respectfully submitt d,
Leonard A. Sangue ce, Esquire
Leonard A. Sanguedolce, Esquire
Attorney for Plaintiff, CACH, LLC.
Identification No. 204325
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
Phone: (570) 823-0101
Fax: (570) 825-7799
CACH, LLC, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
vs. CIVIL ACTION - LAW
JEFFREY HIMES,
Defendant NO. D 7- -7 b C a ?f -???.?.?
COMPLAINT
AND NOW, comes the Plaintiff, CACH, LLC, by and through its Attorney, Leonard A.
Sanguedolce, Esquire and files this, its complaint against the Defendant, JEFFREY HIMES, and
avers as follows:
1. That, the Plaintiff, CACH, LLC, is a Delaware corporation with its principal place
of business located at 370 17th Street, Suite 5000, Denver, Colorado, 80202.
2. That, the Defendant, Jeffrey Himes is an adult and competent individual who
resides at 9 Courtney Drive, Shippensburg, Cumberland County, Pennsylvania 17257.
3. That on or about June 1, 2006, the Defendant, Jeffrey Himes was indebted to
Bank of America, N.A. on credit card account number 4319 0410 1761 1882 in the amount of
$4,333.34. A copy of the June 2004 statement is attached hereto, made a part hereof and
labeled Exhibit "A".
4. That, on or about October 6, 2006, Bank of America, N.A. assigned the above
referenced debt, for good and valuable consideration, to CACH, LLC. A copy of Certificate of
Purchase is attached hereto, made a part hereof and labeled Exhibit "B".
5. That, pursuant to the cardholder agreement entered into between the Defendant
and Bank of America, N.A., the Plaintiff is entitled to pre-litigation interest of $3.59 per day from
the date of charge-off which is calculated as follows: 30.24% annual percentage rate X
$4,333.34 . 365 days or $3.59 x 600 days which equals an additional $2,154.09,
reimbursement of costs and reasonable attorney fees in the amount of $300.00.
6. That, despite repeated demands by the Plaintiff, Defendant has failed to pay the
sum of $6,787.43 which remains due and owing on the above referenced account.
7. That, the claims raised in the Complaint are subject to an agreement to submit
these claims to arbitration.
WHEREFORE, Plaintiff, CACH, LLC, prays this Honorable Court for Judgment in
favor of Plaintiff and against Defendant, JEFFREY HIMES, for $6,787.43 together with costs
and interest.
Respectfully submitted,
Aolwl J /Z
Leonard A. San u Ice, Esquire
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
(570) 823-0101
Attorney for Plaintiff,
CACH, LLC
VERIFICATION
I Dawn Rannells
hereby depose and state that:
The language of the foregoing document is that of counsel and not
necessarily my own; however, I have read the foregoing document and
the factual information contained therein is true and correct to the best of
my personal knowledge.
I am the Authorized Representative and a duly authorized representative
of the plaintiff;
The factual allegations set forth in the foregoing pleading are true and
correct to the best of my knowledge, information and belief, and they are
that JEFFREY D HIMES owes the balance of $4,333.34 to CACH, LLC on
previously submitted invoices, which balance is due and unpaid as if the
date of the execution of this Verification.
I am aware that if any of the foregoing is willfully false, I am subject to
punishment.
I understand that false statements made herein are subject to the penalties
relating to unsworn falsification to authorities.
By:
Dated: MAR 0 2 2041
Authorized Representative
JEFFREY D HIMES
I 'Account Number: 4319 04101761 1882
Your Bank of America VisaS Account
New Balance $1,704.78 Past Due Amount 5396.9E
Total Credit Line $0.00 Available Credit $0.00
Cash Limit $0.00 Available Cash $0.00
Oved1mit Amount $0.00 Billing Date 08/08104
Minimum Payment Due $1,704.78 Payment Due Date 07/01/04
24-Hour Customer Service 1.800.732.9194 Pay onllnel vim
For Lost or Stolen Cards 1.800.848.6090 wwwbankofalnerka o nl
Transactions View recent transactions and pay your bill onine at www.bankolamerim.com
Posy. TRANS. REP.
DATE DATE NO. DESCRIPTION AMOUNT
CR-CREDIT
May 31 May 31 LATE PAYMENT FEE 530.00
Jun 08 Jun 00 PURCHASE FIN CHO CREDIT CR 524.42
Jun 06 Jun 00 LATE FEE CREDIT CR $319.2S
Jun oe Jun 06 PURCHASE FIN CHO CREDIT CR $22.87
Jun 08 Jun 08 MISCELLANEOUS FEE CREDIT W-$1000
Jun oe Jun 06 PURCHASE FIN CHG CREDIT CR $1.46
Jun 08 Jun 08 PURCHASE FIN CHO CREDIT CR 5232.10
Jun 08 Jun 08 PERIODIC FINANCE CHARGE $49.44
Account Summary
Previous Balance $2,228.24
Purchases + $0.00
Cash Advances + $000
Other Debits + $39.00
creme $am-go
FINANCE CHARGE' + $49.44
payments $0.00
New Balance = $1,704.78
Past Due Amount OWN
Finance Charge'Summary
Wff"Wding Dairy (0) / Monthly @4 Avempe Daily Minimum (M) /
APR Periodic Rabe Belarme (ADS) F*Wo (P) Charge
Purchases 25.990% 0.07121 %v D $498.58 $11.01 P
Cash 25.990% 0.07121 %v D $0.00 $0.00 P
Balance Transfer 25.990% 0.07121 %y D $1,740.74 $38.43 P
ANNUAL PERCENTAGE RATE 25.990% v--Variable
Bankof America -W
a EXHIBIT
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0011220 0170478 0170478 4319041017611882
BANK OF AMERICA
Po Box 5270
CAROL STREAM IL 60197-5270
111111111111111111141111111111111111111111111111111111111111,1
PlinmWet Cau n
Account Number 4319 04101761 1882
Payment Due Date 07/01104
Tdal Minimum Payment Due $1,704.78
JEFFREY D HIMES
9 COURTNEY DR
SHIPPENSBURG, PA 17257-8216
Amount Enclosed
11a1II1e111lei1111111loll Iloilo 11i11111111111111111hill 111111 Make check or nwwy anter payable to Bank of Amariea.
Thla lie an aNctronk 1VPfodoneW of YOWSWORM t and klcludea awoual fiW,, 1 *w 0,1fy,
CERTIFICATE OF PURCHASE
I, D Q Wn Rap po ft_, hereby depose and state that:
1. I am an Authorized Agent of CACH, LLC, a Colorado Limited
Liability Company.
2. As such, I am authorized to give this Certificate, and possess sufficient
personal knowledge to do so regarding:
Customer Name:
Original Creditor:
Account Number:
JEFFREY D HIMES
Bank Of America,N.A
4319041017611882
3. On or about October 6, 2006 this account was issued by the original
creditor. CACH, LLC is the current owner of the account and
purchased the account for good and valuable consideration.
BAR 0 2 7007
Date:
By
Sworn and subscribed to before me this day of
2007.
Notary Public
My Commission Expires:
® EXHIBIT
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-------------
PRUDENCE TINBERG
NOTARY PUBLIC
STATE OF COLORADO
[0000000 ---------------- I
My Commission Expires 05/03/2010
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-07000 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CACH LLC
VS
HIMES JEFFREY
TIMOTHY REITZ
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
HIMES JEFFREY
the
DEFENDANT at 1700:00 HOURS, on the 11th day of December , 2007
at 9 COURTNEY DRIVE
SHIPPENSBURG, PA 17257 by handing to
JEFFREY HIMES
a true and attested copy of COMPLAINT & NOTICE
together with
Sheriff or Deputy Sheriff of
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
40.32
.00
10.00
.00
68.32
So Answers:
/,'-// -7/0 -7 G),,,
Sworn and Subscibed to
before me this day
of
R. Thomas Kline
12/12/2007
JOHN P RODGERS
?..._
By. _
Dep: y Sheriff
A. D.
Leonard A. Sanguedolce, Esquire
Attorney for Plaintiff, CACH, LLC
Identification No. 204325
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
Phone: (570) 823-0101
Fax: (570) 825-7799
CACH, LLC, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
CIVIL ACTION - - LAW
VS.
JEFFREY HIMES,
Defendant No. 07-7000-civil
PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
TO: Prothonotary, Cumberland County
Enter judgment by default, in favor of the Plaintiff, CACH, LLC, and against the
Defendant, JEFFREY HIMES for his failure to plead to the Complaint in this action within the
required time. The Complaint contained a Notice to defend within twenty (20) days of the date
of service thereof. The Defendant was served with the Complaint on December 11, 2007.
Attached hereto as Exhibit "A" is a copy of the Plaintiffs written Notice of intent to file
Praecipe for Entry of Judgment by Default, which I can certify was mailed by first class mail to
the Defendant at his last known addresses on January 8, 2008, which is at least ten (10) days
prior to the filing of this Praecipe.
Please assess damages in the amount of six thousand seven hundred eighty seven and
43/100 ($6,787.43) Dollars, being the amount demanded in the Complaint, together with costs
and interest.
Leonard A. Sanguedolce, Esquire
Attorney for Plaintiff, CACH, LLC
Identification No. 204325
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
Phone: (570) 823-0101
Fax: (570) 825-7799
CACH, LLC, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
CIVIL ACTION - - LAW
VS.
JEFFREY H1MES,
Defendant No. 07-7000-civil
CERTIFICATE OF SERVICE
I, Leonard A. Sanguedolce, Esquire, certify that on the above stamped date & time, I
caused to be served a time-stamped copy of each of the following documents: Praecipe for
Entry of Judgment by Default, Entry of Judgment and Notice of Entry of Judgment along with a
Certificate of Service, upon the below listed Defendant, by United States, first class mail,
postage prepaid, addressed as follows:
Jeffrey Himes
9 Courtney Drive
Shippensburg, PA 17257
Respectf Ily submi d,
Leonard A. S gu o ce, Esquire
Attorney for Plaintiff,
CACH, LLC
Leonard A. Sanguedolce, Esquire
Attorney for Plaintiff, CACH, LLC
Identification No. 204325
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
Phone: (570) 823-0101
Fax: (570) 825-7799
CACH, LLC, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
VS.
JEFFREY HIMES,
Defendant
CIVIL ACTION - - LAW
No. 07-7000-civil
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF LUZERNE
SS
I, Leonard A. Sanguedolce, attorney for Plaintiff, CACH, LLC, being duly sworn, depose and say
that:
To the best of my knowledge, information and belief the Defendant, JEFFREY HIMES is
not in the Military Service of the United States nor any State or Territory thereof, or its allies as
defined in the Soldiers and Sailors Civil Relief Act of 1940 and amendments thereto.
Dated: -\ " Q- - '?)0()E
Sworn to and subscribed before me
this day of 2008.
?J c7 ? . ? t UCN-\
NOTARY PUBLIC
OMjMaLTH !RtM!V*jft
V
NOTARIAL SERI
LM L VMILSOIN, Noiery Pubic
?V?Mo?B»Ine, Usa»e Cater
28, 2011
Leonard A. S gu o ce, Esquire
'dA
-oe
Leonard A. Sanguedolee, Esquire
Attorney for Plaintif , CACH, LLC
Identification No. 204325
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
Phone:.(570) 8234101
Fax: (570) 825-7799
CACH, LLC, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
vs. CIVIL ACTION - LAW
JEFFREY HIMES,
Defendant NO. 07-7000-civil
IMPORTANT NOTICE
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 (10) 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
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
800-990-9108
Respectfully submitted,
Dated: zz"
Leonard A. an edolce, Esquire
EXHIBIT
A
Leonard A. Sanguedolce, Esquire
Attorney for Plaintiff, CACH, LLC
Identification No. 204325
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
Phone: (570) 823-0101
Fax: (570) 825-7799
CACH, LLC, IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
vs. CIVIL ACTION - LAW
JEFFREY HIMES,
Defendant NO. 07-7000-civil
CERTIFICATE OF SERVICE
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1, Leonard A. Sanguedolce, Esquire, certify that on the AL day of JANUARY. 2008, 1
made service of the Original Important Notice of intention to enter default judgment upon the
below listed Defendant, by United States, first class mail, postage prepaid, addressed as
follows:
Jeffrey Himes
9 Courtney Drive
Shippensburg, PA 17257
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Respectfully submitted,
Leonard A. g dol , Esquire
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
(570) 823-0101
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Leonard A. Sanguedolce, Esquire
Attorney for Plaintiff, CACH, LLC
Identification No. 204325
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
Phone: (570) 823-0101
Fax: (570) 825-7799
CACH, LLC,
Plaintiff
VS.
JEFFREY HIMES,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - - LAW
No. 07-7000-civil
NOTICE OF ENTRY OF JUDGMENT
TO: Jeffrey Himes
9 Courtney Drive
Shippensburg, PA 17257
AS PRESCRIBED BY LAW, YOU ARE NOTIFIED THAT A JUDGMENT HAS BEEN
FILED IN THIS OFFICE AGAINST YOU BY PLAINTIFF, CACH, LLC, IN THE AMOUNT OF
$6,787.43 TOGETHER WITH COSTS AND INTEREST FROM THE TIME OF THE PRESENT,
AND CONTINUING TO ACCRUE UNTIL THE TIME OF PAYMENT.
Prothonotary, CUMBERLAND COUNTY
BY
a
Leonard A. Sanguedolce, Esquire
Attorney for Plaintiff, CACH, LLC
Identification No. 204325
Law Offices:
Harrison Ross Byck, Esq., P.C.
15 Public Square, Suite 202
Wilkes-Barre, PA 18701
Phone: (570) 823-0101
Fax: (570) 825-7799
CACH, LLC,
Plaintiff
VS.
JEFFREY HIMES,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - - LAW
No. 07-7000-civil
ENTRY OF JUDGMENT
Pursuant to Praecipe filed for Entry of Default Judgment, Judgment is hereby entered in
favor of the Plaintiff, CACH, LLC and against the Defendant, JEFFREY HIMES, in the amount of
six thousand seven hundred eighty seven and 43/100 ($6,787.43) Dollars, together with costs
and interest from the time of the present and continuing to accrue until the time of payment.
PROTHONOTARY, CUMBERLAND COUNTY
BY
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149
CACH, LLC. COURT OF COMMON PLEAS
4340 S. Monaco street, 2nd Floor CUMBERLAND COUNTY, PENNSYLVANIA
Denver, Colorado 80237
------------------
Plaintiff(s),
vs. : Docket No.: 07-7000-CIVIL
JEFFREY D HIMES ° F
9 COURTNEY DRIVEy
o -,
SHIPPENSBURG, PA 17257 Defendant(s).°
-f c" ;
TO THE PROTHONOTARY: ISSUE and INDEX WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania,
(2) against JEFFREY D HIMES Defendant(s);
(3) and against
Garnishee(s);
as a lis pendens against the real property of the defendant(s) in the name of the
Garnishee(s) as follows: (Specifically describe property to be levied upon by Sheriff)
(4) Amount Due $ 6,787.43
Interest from
TOTAL
Dated a "/F
0&x %ay.aa Pd a
(off. 3a CIS
J41 6Z> Lc e,
a ?so Lt .?
ii an.
Plus costs.
4iS Ilanth, E q.
Attorney for Plaintiff(s)
rOLAA
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7000 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CACH, LLC Plaintiff (s)
From JEFFREY D. RIMES, 9 COURTNEY DRIVE, SHIPPENSBURG, PA 17257
(1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL
PERSONAL PROPERTY OF THE 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:
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$6,787.43
Interest
Atty's Comm %
Atty Paid $187.32
Plaintiff Paid
Date: OCTOBER 24, 2011
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
David D. Buell, Prothonotary
Y:
Deputy
REQUESTING PARTY:
Name ALLAN C. SMITH, ESQUIRE
Address: HARRISON ROSS BYCK ESQUIRE P.C.
BRISTOL OFFICE CENTER
1276 VETERANS HIGHWAY, SUITE E-1
BRISTOL, PA 19007
Attorney for: PLAINTIFF
Telephone: 215-428-0666
Supreme Court ID No. 61511
LAW FIRM OF ALLAN C. SMITH, P.C.
BUCKS COUNTY OFFICE CENTER
1276 VETERANS HIGHWAY, SUITE E-1
BRISTOL, PA 19007
1-888-275-639y It k/,,, __
Attorney for Plaintiff
CACH, LLC. ) COURT OF COMMON PLEAS
4340 SOUTH MONACO STREET 2ND FLOOR ) CUMBERLAND COUNTY
DENVER, CO 80237 )
Plaintiff, 3 -?
1 =M •? f ?F
VS. ) No.: 07-7000-CIVIL rri
;
JEFFREY D HIMES ) -X
r --4c>
9 COURTNEY DRIVE ) c7
SHIPPENSBURG, PA 17257 ) r
rv
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance of behalf of CACH, LLC., the plaintiff in this action.
./Ilan .
C. SmiVEs?aq
I.D No. 204756
Law Firm of Allan C. Smith, P.C
1276 Veterans Hwy- Suite E-1
Bristol, PA 19007
WITHDRAWAL OF APPEARANCE
TO THE PROTHONOTARY:
Kindly withdrawal my appearance of behalf of CACH, LLC., the plaintiff in this action.
Ross Bc !Es
ID Nd:A 1511
Law Office ofkfarrison Ross Byck, Esq. P.C
1276 Veterans Hwy- Suite E-1
Bristol, PA 19007
Date: November 16, 2011
f R Anderson
Tiff
,ody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Law Firm of Allan C. Smith
vs.
Jeffrey D Himes
-1 r
PM 2: 1'3 33
r ..c ?;F:I ?-? '?iV1:t I€J?1.l L. `ri ??21 t?F
Case Number
2007-7000
SHERIFF'S RETURN OF SERVICE
12/06/2011 11:02 AM - Michelle Gutshall, Deputy, being duly sworn according to law, states that on December 06,
2011 at 11:02 AM hours, served the requested Writ of Execution and Claim for Exemption Form by
"personally" handing a true and attested copy to a person representing themselves to be the Defendant, tc
wit: Jeffrey D Himes at 9 Courtney Drive, Southampton, Shippensburg, PA 17257, informed Defendant of
contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to
attorney and letter mailed to defendant on December 7, 2011.
06/05/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $83.03 SO ANSWERS,
June 05, 2012 RON R ANDERSON, SHERIFF
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