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'
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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
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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
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2049 APR 14 AM 9, 48
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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{