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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 C7 •? u) %%A J J Q Bankof America'' Customer Corner we've redesigned your monthly Milling statement. We hope you will find the new statement dear, concise and easy to read. Al of your important aooount information including New Balance, Payment Due Date and Minimum Payment Due are conveniently Wood together at the top of the first page of your statement. Please use the remit coupon located at the bottom of the first page when maiing your payment. You may also enrol in free Online Banking and stop mail dWNwy of your paper statement. Enroll today at `vwuw.bankofamwica.comJ onlinebanking'. Then access your account and click the Customer Service tab and follow the stain under `Stop mail delivery of your paper credit card fill 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 `% ? 1 ------------- PRUDENCE TINBERG NOTARY PUBLIC STATE OF COLORADO [0000000 ---------------- I My Commission Expires 05/03/2010 r q ? ? r .t t r7 Po f G'?t 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 0 m V 0 0 . 1k 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 R ? ? fA me O -4 ?o D Z t+ r C- M 3o m o ? m vmi m M M o -n ? a Mm o C o o z M i 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 Cn N 0 ? CD c N S r D m?(n D(D? Q -4 0 CD (D Qt+i"A. ? y 10L8 L 3003dlZ NI15? " 800Z 80 NVF b886Z8d`0000 050' G00 $ 0 0 n. c? w a 6 fl 73 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 4'.56 1-/- C,k,il 9(4dciN 1Z.?-?(oG 3 ?Lf W, -? ap 5;" Aq "?P./ 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 ?2 . DD p?,t Cc . .sow - a7?,??/7 Shenff. Teieoaf4. inc