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HomeMy WebLinkAbout07-7514A6 2042494 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Atlantic Credit & Finance Inc. Assignee from Household Bank 3353 Orange Avenue Roanoke, VA 24012 VS. BARBARA L BAKER 332 N COLLEGE ST # 2 CARLISLE PA 17013-1843 COURT OF COMMON PLEAS CUMBERLAND COUNTY -- l ?? n, DOCKET NO. O? 1... l U fit, T ep-kn 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 JUDGEMENT 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 .. COMPLAINT IN CIVIL-ACTION 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 2. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 3. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 4. The defendant (s) received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. A true and correct copy of the Statement of Account is attached hereto as Exhibit "A". 5. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due in the amount of $2,824.82. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,824.82 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 7. Defendant's last payment on account was made on May 19, 2006. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,824.82 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I WEI ERG, ESQUIRE JOEL M. FLI ESQUIRE Attorney for Plaintiff P01A.DB VERIFICATION FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff (s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I. W G, ESQUIRE EXHIBIT "A" ATLANTIC CREDIT & FINANCE, INC. V. BARBARA L BAKER ao 4a U4y AFFIDAVIT OF DEBT AND VERIFIED BILL OF PARTICULARS aai' with The undersigned being first duly sworn according of the Plaintiff with respect to the matters the policies and practices, as well as the books and records stated herein, and based on information and belief states as follows: 1. Plaintiff s principal business consists of purchasing charged off receivables. 2. The Defendant defaulted on HOUSEHOLD BANK Account No. 5499440913358946. Said. Account was charged off on November 30, 2006 and subsequently sold to Atlantic Credit & Finance, Inc with a balance of $2,824.82. 3. Plaintiff purchased or was otherwise assigned this charged off account along with other debts. As a result of the foregoing sale and assignment, the Plaintiff succeeded to all right, title and interest in the charged off account, and it now owns the account. 4. Plaintiff conducted a due diligence investigation to determine, among other things, the accuracy of the account information provided to ascertain whether the statute of limitations was a bar to demand or institution of suit. Further, Plaintiff and/or its predecessor entered into a contract where the predecessor made representations and warranties that 1) it had clear right, title and interest in the account; 2) the account was free and clear of all liens and encumbrances; and 3) it had the power, authority, and full right, to sell and convey its interest in the account. 5. According to Plaintiffs records, the last payment date was May 19, 2006. After application of all payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and owing on this indebtedness of $2,824.82. 6. The internal Account Statement of Plaintiff is attached hereto as Exhibit A and displays the account information that was provided to Plaintiff at the time of purchase and assignment. . The foregoing is true and correct to the best of my knowledge and belief. By: 02?0 (/-? Heather Clary Assistant Director of Forwarding Subscribed' and sworn before me September 26, 2007. N pv reUAy 0 - E? C = Jami .1 o Public MyFXpMMisso1011 My ommission Expires: 2/28/201 r oy Ali RfS THIS COMMUNICATION IS FROM A DEBT COLLECTOl?'Fgl "NOF GORDON & WEINBERG-RC: JAFF- 2913991 Report Date • " .:' . Atlantic Credit & Finance, Inc. 09/13/2007 15:00:13 At? Account Statement CREM .F 1 C=WIORATEQ Our Account ID: 2913991 Account Number: 5499440913358946 Status: LGJ Received: 12/20/2006 Charge Off Date: 11/30/2006 Purchase Balance: $ 2,824.82 Amount Paid: $ 0.00 Remaining Balance: $ 2,824.82 Original Creditor Last Pay Date: 05/19/2006 Name: BAKER, BARBARA L Other Name: Streetl: 332 N COLLEGE ST # 2 Street2: City, State Zip: CARLISLE, PA 17013-1843 SSN-Last 4 Digits: 0369 HomePhone: 7172414124 WorkPhone:7172432011 Date Type Matched Check No Invoiced Amount Comment No Payments Received Payment 'type ' PU' , 'PA', 'PC' - Payment page No : ? payment Type 'PUR','PAR','PCR' - Returned Payment NSF Confidential Property of Atlantic Credit a Finance Inc. a Do' e• pn c? C-) MIS S:14 rn V03 SHERIFF'S RETURN - REGULAR CASE NO: 2007-07514 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS BAKER BARBARA L KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BARBARA L BAKER the DEFENDANT , at 1444:00 HOURS, on the 26th day of December , 2007 at 332 N COLLEGE ST #2 CARLISLE, PA 17013-1843 by handing to BARBARA L BAKER 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 Service Affidavit Surcharge 18.00 4.80 .00 10.00 .00 32.80 Sworn and Subscibed to before me this of So Answers: R. Thomas Kline 12%28/2007 GORDON & WEIN13ERG By / day Deputy' S eri,ff 4x A.D. S. 2042494 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Atlantic Credit & Finance Inc. Assignee from Household Bank VS. BARBARA L BAKER COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-7514 PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT OF DAMAGES VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $2,824.82 Costs (Complaint & Service) $111.30 Total: $2,936.12 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: Atlantic Credit & Finance Inc.Assignee from Household Bank and that the last known address of defendant, BARBARA L BAKER, 332 N COLLEGE ST # 2, CARLISLE PA 17013-1843. 2. The annexed notice(s) of intention to file this ? .. praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this day of , 2008 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages Msessed at the sum of , $2,936.12 as per the above certiAica?i??. Prothono ary J GORDON & WEINBERG, P.C. BY: FREDERIC I. EINB G, ESQUIRE JOEL M. FLI QUIRE Attorney for Plaintiff GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Atlantic Credit & Finance Inc. Assignee from Household Bank vs. BARBARA L BAKER TO/PARA 2042494 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-7514 NOTICE OF INTENTION TO TAKE DEFAULT BARBARA L BAKER 332 N COLLEGE ST # 2 CARLISLE PA 17013-1843 DATE OF NOTICE/FECHA DEL AVISO: January 28, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 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 GORDON & WEINBERG, P.C. BY: EC I. WEINBERG, ESQUIRE . FLINK, ESQUIRE P10D-2 --f- ? °) - W r-y W .,p -o ?Y 4 w. 2042494 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Atlantic Credit & Finance Inc. Assignee from Household Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. BARBARA L BAKER DOCKET NO. : 07-7514 NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. f1 Judgment by Default $2,936.12 f? Money Judgment $ ?L Judgment on Award of Arbitrators$ ?L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 I ?iU2' PROTHONO Y C2/12 7/L Id . .A i 2042494 GORDON & WEINBERG, P,C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. PLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Atlantic Credit & Finance Inc. Assignee from Household Bank 3353 Orange Avenue Roanoke, VA 24012 VS. BARBARA. L BAKER 332 N COLLEGE ST # 2 CARLISLE PA 17013-1843 and Orrstown Bank 427 Village Drive Carlisle, PA 17015 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-7514 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against BARBARA L BAKER (2) against Orrstown Bank defendant(s)and garnishee(s) (3) AMOUNT DUE $2,936.12 INTEREST from February 27, 2008 $196.26 COSTS Prothonotary fee Sheriff fee TOTAL FREDERIC WEINBERG, ESQUIRE JOEL M.17 LINK, ESQUIRE Attornew; for Plaintiff 0 4 FILED-Y* r=#C," 2049 APR 14 AM 9, 48 :. ly ?l 4 U4. So P Q A7T%/ 3a. Be) C4F 78.So !.4. oo a. So $1 isa.30 • Po ATrY $a.oo bw a •50 LL co'llAsi el* aa-u $ 4 & Z&uad WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-7514 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ATLANTIC CREDIT & FINANCE INC., Assignee from HOUSEHOLD BANK, Plaintiff (s) From BARBARA L. BAKER, 332 N. College St, #2, Carlisle, PA 17013-1843 (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 GARNISHEE(S) as follows: ORRSTOWN BANK, 427 Village Drive, Carlisle, PA 17015 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 $2,936.12 Interest from 2/27/08 -- $196.26 Atty's Comm % Atty Paid $152.30 Plaintiff Paid Date: 4114/09 L.L. $.50 Due Prothy $2.00 Other Costs Cu is R. Lon o to (Seal) By: Deputy REQUESTING PARTY: Name JOEL M. FLINI,, ESQUIRE Address: GORDON & WEINBERG, PC 1001 E HECTOR STREET, STE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41200 Sheriffs Office of Cumberland County R Thomas Kline at cumb,r Edward L Schorpp Sheriff ° Solicitor Ronny R Anderson Jody 5 Smith Chief Deputy OFR oF rHE S,iER FF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/23/2009 09:12 AM - Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on 04-23-09 at 0912 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Barbara L. Baker, in the hands, possession, or control of the within named garnishee, Orrstown Bank, 1 Giant Lane, Carlisle, Cumberland County Pennsylvania 17013, by handing to Judith Cornman, Branch Officer personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on 04-27-09 to Barbara L. Baker, 332 N College Street, Apt. 2, Carlisle, PA 17013. 2007-7514 Atlantic Credit & Finance vs Barbara L. Baker So Answers, 01-1 R. Thomas Kline, Sheriff By_ K"7 De t Sheriff c- "a C-D . f `. -7 0412712009 15:11 ORRSTOWN BANK . (FAX) GORDON & WEINBERG, P.C. ,BY: FREDERIC I_ WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1.001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Atlantic Credit & Finance Inc Assignee from Household Bank 3353 Orange Avenue Roanoke, VA 24012 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. BARBARA L BAKER 332 N COLLEGE ST 4 2 CARLISLE PA 17013-1843 and Orrstown Bank 427 Village Drive Carlisle, PA 17015 GARNISHEE DOCKET NO. : 07-7514 GARNISHEE TO: Orrstown Bank - GARNISHEE You are required to file answers to the following Interrogatories within twenty '.(20) days after service upon you. Failure to do so my result -.n judgment against you. P.007/011 1. P_t the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to the defendant 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? No. 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 or more other persons any property of any nature owned solely or in part by the defendant. Yes. 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 held or claimed any interest. No. 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? Yes. OV2712009 13:11 ORRSTOWN BANK (FAQ{) P.0081011 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 what was the consideration thereof? Yes. Account epotfiynt?im?o??e served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to his(her, their) direction or otherwise discharge any claim of the defendant (s) against you? No. 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. 8. If you are a bank or other financial institution, at the time you were served or 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. §6123? If so, identify each account. Yes. Statement savings Account # 70600600. 9. Now much is the value of any property in your possession belonging to the defendant(s)? 1,870.60. FREDERIC / W BERG, ESQUIRE JOEL M. F INK, ESQUIRE Attorney or Plaintiff DATED: Respectfully submit ed, of EN, B C & ER David A. Baric, Esquire I.D. 44853 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Garnishee, Orrstown Bank VERIFICATION I verify that the statements made in the foregoing Garnishee Orrstown Bank's Answers To Interrogatories In Attachment are true and correct to the best of my knowledge, information and belief. This verification is signed by David A. Baric, Esquire, Attorney for Plaintiff and is based upon the statements provided by Plaintiff, as well as documents reviewed by the undersigned as attorney for Plaintiff. I undersigned that false statements herein are made subject to penalties of 18 Pa.C.S. §4904, relating to unsworn falsifications o authorities. David A. Baric, Esquire Dated: April 29, 2009 _• CERTIFICATE OF SERVICE I hereby certify that on April 29, 2009, I, David A. Baric, Esquire of O'Brien, Baric & Scherer, did serve a copy of Garnishee, Orrstown Bank's Answers To Interrogatories In Attachment, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Frederic I. Weinberg, Esquire Gordon & Weinberg 1001 East Hector Street, Suite 220 Conshohocken, Pennsylvania 19428 r? David A. Baric, Esquire Il )I,_ 1r i 1:?1, 2009 APR 33 Ail :• 3 iZ: l r ? . 2042494 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/3510500 Atlantic Credit & Finance Inc. COURT OF COMMON PLEAS Assignee from Household Bank CUMBERLAND COUNTY VS. BARBARA L BAKER and Orrstown Bank Garnishee DOCKET NO. : 07-7514 PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant's bank si account with Orrstown Bank, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. BY: L?? FREDER . WEINBERG, ESQUIRE JOEL V. FLINK, ESQUIRE Attorney for Plaintiff Poll FILED-Cf'- i 01: Tvir- 2009 MAY 18 PH 3., 11 Sy Sheriffs Office of Cumberland County R Thomas Kline 6O r of 0111" 44o1 Edward L Schorpp Sheriff Solicitor 4,1_51 Ronny R Anderson ? o` Jody S Smith Chief Deputy OFFic6 OF rK S+ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/23/2009 09:12 AM - Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on 04-23-09 at 0912 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Barbara L. Baker, in the hands, possession, or control of the within named garnishee, Orrstown Bank, 1 Giant Lane, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Judith Cornman, Branch Officer personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on 04-27-09 to Barbara L. Baker, 332 N College Street, Apt. 2, Carlisle, PA 17013. 05/22/2009 R. Thomas Kline Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per notification of Chapter 7 bankruptcy filing. May 22, 2009 0-7-75/'? ? 6/61/of 91, SO ANSWERS, R THOMAS KLINE, SHERIFF By Sharon R. Lantz J.0 ?c o? R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned STAYED, due to defendant filing Chapter 7 bankruptcy. Sheriff's Costs: Docketing Poundage Law Library Prothonotary Mileage Surcharge Levy Postage Garnishee 18.00 1.49 .50 2.00 4.50 20.00 20.00 .44 9.00 75.93 Advance Costs: 150.00 Sheriff's Costs: 75.93 74.07 Refunded on 05/22/09 So Answers, R. homas Kline, She Sharon R. Lantz t C-3 .o `Ti C.0 a'1 d n1i (? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-7514 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ATLANTIC CREDIT & FINANCE INC., Assignee from HOUSEHOLD BANK, Plaintiff (s) From BARBARA L. BAKER, 332 N. College St, #2, Carlisle, PA 17013-1843 (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 GARNISHEE(S) as follows: ORRSTOWN BANK, 427 Village Drive, Carlisle, PA 17015 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 $2,936.12 Interest from 2/27/08 -- $196.26 Atty's Comm % Atty Paid $152.30 Plaintiff Paid Date: 4/14/09 (Seal) REQUESTING PARTY: Name JOEL M. FLINK, ESQUIRE Address: GORDON & WEINBERG, PC 1001 E HECTOR STREET, STE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF L.L. $.50 Due Prothy $2.00 Other Costs Curtis Long, Pr o ry By: Deputy Telephone: 484-351-0500 Supreme Court ID No. 41200 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2042494 Atlantic Credit & Finance Inc. VS. Assignee from Household Bank COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 07-7514 BARBARA L BAKER SUGGESTION OF BANKRUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this June 4, 2009, it is suggested of record that Defendant, BARBARA L BAKER, filed a petition in bankruptcy under Chapter 7 of the Bankruptcy Code on or about May 11, 2009, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 09-03598. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: j7X- FREDEVC I.' EINBERG, ESQUIRE JOEL . FLINK, ESQUIRE Attorney for Plaintiff ALED--(: r r-CE OF THE PPOTV' PTARY 2009 JUN -6 PM ?,: 18 CUW,t'. t1 Y i S{