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HomeMy WebLinkAbout03-6502IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff, VS, CIVIL DIVISION ARBITRATION DIVISION COMPLAINT IN CIVIL ACTION RAYMOND D. SCOTT, JR., Defendant. Filed on behalf of Unifund CCR Partners, Plaintiff Counsel for Unifund CCR Partners: Jonathan S. McAnney, Esquire Pa. I.D. #50041 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 LIT:306605-1 014636-105796 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff, VS. RAYMOND D. SCOTT, JR., Defendant. No. 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 ara 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 ara 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 railer requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAVVYER 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONE~ LA OFICINA FIJADA AQUI ABA JO. ESTA OFICINA PUEDE PROVEERE~ CON INFORMACION DE COMO CONSEGUIR UN ABOGADO, SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERI~ INFORMACl0N ACERA AGENClAS. QUE PUEDAN OFRECER SERVIClOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 NOTICE TO DEFEND IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff, VS. RAYMOND D. SCOq-r, JR., Defendant. ) ) ) ) ) No. ) ) ) ) ) ) COMPLAINT IN CIVIL ACTION AND NOW, comes the Plaintiff, UNIFUND CCR PARTNERS, by its counsel, Tucker Arensberg, P.C. and files this Complaint stating as follows: 1. The Plaintiff is Unifund CCR Partners, a Delaware partnership, with offices located at 10625 Techwoods Circle, Cincinnati, Ohio 45242. 2. The Defendant, Raymond D. Scott, Jr. is an individual and resident of 5 Hidden Noll Road, Carlisle, PA 17013. 3. On or about November 25, 1998, the Defendant applied for and was approved to receive a Providian National Bank Credit Card (hereinafter "Account"). Such Account was issued at Account Number 4465680200583327. and owing. The Defendant utilized such Account and incurred a balance due 5. As of Apdl 1, 2002, the Defendant owed $4,193.98 in principal, and $401.49 in interest. The total amount owed is $4,595.47. See the AfFidavit of Indebtedness attached hereto as Exhibit "A" and incorporated by reference as if fully set forth at length herein. 6. Despite wdtten and oral demands for payment, the Defendant has failed and refused to pay the amount due and owing, 7. Reasonable attorneys' fees in the amount of 20% of the principal balance are due and owing. Defendant: The following amounts are currently due and owing from the Principal and Interest Reasonable Attomey's Fees (20%) TOTAL: $4,595.47 $ 919.09 $5,514.56 9. The Account has been assigned by Providian National Bank to the Plaintiff including all dghts to collect the amount due from the Defendant. -2- WHEREFORE, the Plaintiff, Unifund CCR Partners demands that judgment be entered in its behalf and against the Defendant, Raymond D. Scott, Jr., in the sum of $5,514.56 plus costs and interest. TUCKERARENSBERG, P.C. By nney, Esquirepa' 1.1~.~50041 Counsel for Unifund CCR Partners: TUCKER ARENSBERG, P.C. 1500 One PPG Place Pittsburgh, PA 15222 Attorneys for Plaintiff -3- VERIFICATION The undersigned verifies that the statements made in the foregoing Complaint are true and correct to the best of her knowledge, information and belief and understands the statements therein made are made subject to the penalties of 18 Pa.C.S, ~4904 relating to unsworn falsification to authorities. AFFIDAVIT OF INDEBTEDNESS State of Ohio ) County Of Hamilton ) ss. Jessica Bergholz, being sworn, deposes and says that she is Media Supervisor of Unifund CCR Partners herein called assignor, which is doing business at 11802 Conrey Road, Cincinnati, Ohio 45249 and that she is authorized to make the statements and representations herein.. The defendant is not in any branch of the military. There is due and payable from RAYMOND D SCOTT JR, Account Number 4465680200563327, the amount of $4595.47 (principal balance in the amount of $4193.98 plus interest up through 04/0112002 in the amount of $401.49). By the terms of the agreement between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of 6.00 percent per annum. This account was originated with Providian National Bank. Unifund CCR Partners purchased this account from Providian National Bank. Said account has been assigned, trasferred and set over unto, Tucker Arensberg with full power and authority to do and perform all acts necessary for the collection, settlement, adjustment, compromise or satisfaction of said claim. DATED 01 April 2002 ~UNIF~ND CCR PARTNERS By: Jessica Bereholz Media Supervisor Title 11802 Conrev Road Cincinnati. OH 45249 Address Client# 215 Subscribed and sworn to before me this 1 day of April ,2002 Notary Public JESSICA STEVENS Notaw Public In snd for the State of Ohio My Commission Expires April 7, 2.002 My commision expires SHERIFF'S RETURN - REGULAR CASE NO: 2003-06502 P COMMONWEALTH OF PENNSYLV~NIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS SCOTT RAYMOND D JR HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according says, the within COMPLAINT & NOTICE was served upon SCOTT RAYMOND D JR the DEFENDANT at 1650:00 HOURS, on the 26th day of December , __ at 1917 SPRING ROAD CARLISLE, PA 17013 by handing to RAYMOND D SCOTT a true and attested copy of COMPLAINT & NOTICE to law, 2003 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this /2 ~ day of P~oqhonot ary So Answers: R. Thomas Kline 12/29/2003 TUCKER ARENSBERG Deputy Sh~iff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff, VS. RAYMOND D. SCO']-I', JR., Defendant. CIVIL DIVISION ARBITRATION DIVISION No. 03-6502 Civil Term TEN DAY NOTICE Filed on behalf of Unifund CCR Partnem, Plaintiff Counsel for Unifund CCR Partners: Jonathan S. McAnney, Esquire Pa. I.D. #50041 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 LIT:311176-1 014636-105796 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff, VS. RAYMOND D. Sco'I-F, JR., Defendant. CIVIL DIVISION ARBITRATION DIVISION No. 03-6502 Civil Term TO: Raymond D. Scott, Jr. 1917 Spring Road Carlisle, PA 17013 DATE OF NOTICE: January 20, 2004 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 (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 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990-9108 Jonat , Esquire Pa. I.D. ~5q041 Counsel{fo~ Plaintiff TUCKEI~RENSBERG, P.C. 1500 One PPG Place Pittsburgh, PA 15222 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Ten Day Notice was served on the following by first class mail, postage pre-paid on January 20, 2004: Raymond D. Scott, Jr. 1917 Spring Road Carlisle, PA 17013 Jonath ey, Esquire Pa. I.D. #5~)~)41 TUCKER ,~ENSBERG, P.C. 1500 One PPG Place Pittsburgh, PA 15222 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff, VS. RAYMOND D. SCO']-I', JR., Defendant. CIVIL DIVISION ARBITRATION DIVISION No. 03-6502 Civil Term PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT LIT:312823-1 014636-105796 Filed on behalf of Unifund CCR Partners, Plaintiff Counsel for Unifund CCR Partners: Jonathan S. McAnney, Esquire Pa. I.D. #50041 TUCKER ARENSBERG, P.C. Firm ¢Y287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, ) ) Plaintiff, ) ) VS. ) ) RAYMOND D. SCO']-I', JR., ) ) Defendant. ) No. 03-6502 Civil Term PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT To Prothonotary: Please enter Judgment by Default in the above-captioned case for the Plaintiff and against Defendant, in the amount of $5,514.56 plus costs and interest, for failure to answer or otherwise respond to the Complaint. I hereby certify that the attached written Notice of Intention to take a Default Judgment was mailed to the Defendant ten days prior to the filing of the Praecipe for Entry of Default Judgment. Date: February 2, 2004 By: ~nne Jonathan y, Esquire Pa. I.D. #50041 Counsel for Unifund CCR Partners: TUCKER ARENSBERG, P.C. Firm fl287 1500 One PPG Place Pittsburgh, PA 15222 412-566-1212 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff, VS. RAYMOND D. SCOTT, JR., Defendant. CIVIL DIVISION ARBITRATION DIVISION No. 03-6502 Civil Term TEN DAY NOTICE Filed on behalf of Unifund CCR Partners, Plaintiff Counsel for Unifund CCR Partners: Jonathan S. McAnney, Esquire Pa. I.D. #50041 TUCKER ARENSBERG, P.C. Firm #287 1.500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 LIT:311178-1 014636-105796 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS, ) ) Plaintiff, ) ) ) RAYMOND D. SCO'I]', JR., ) ) Defendant. ) CIVIL DIVISION ARBITRATION DIVISION No. 03-6502 Civil Term TO: Raymond D. Scott, Jr. 1917 Spring Road Carlisle, PA 17013 DATE OF NOTICE: Januar~ 20, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI']-r'EN APPEARANCE PERSONALLY OR BY AN A'CI'ORNEY 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 PAPER TO YOUR LAWYER AT ONCE, F' 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (800) 990o9108 Jonat , Esquire Pa. I.D. ~5q04'1 Counsel(for Plaintiff TUCKEP,~,RENSBERG, P.C. 1500 One PPG Place Pittsburgn. PA 15222 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Ten Day Notice was served on the following by first class mail, postage pre-paid on January 20, 2004: Raymond D. Scott, Jr. 1917 Spring Road Carlisle, PA 17013 Jonath ey, Esquire Pa. I.D. #5p~41 TUCKER ,~ENSBERG, P.C. 1500 One PPG Place Pittsburgh, PA 15222 -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CCR PARTNERS, Plaintiff vs. CIVIL-LAW 5 i ?aaen RAYMOND D. SCOTT JR., DOCKET NO. 2003-06502 CIVIL `- Defendant oaf t 'IS. l M&T BANK, k S} . Garnishee ? W. 1?5 ,?oc3 •" PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of Cumberland County, Pennsylvania (2) against Raymond D. Scott Jr., defendant; and (3) Against M&T Bank, Garnishee; (4) and index this Writ in the judgment index and (a) against Raymond D. Scott Jr., defendant(s), and (b) against M&T Bank, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: N/A (5) Amount Due: Interest from 02/04/2004 Credits Other Costs to be added: Clerks Fee: Sheriff: Total: Aa 31.4's e af, ItLI Litt $ 5,514.56 $ 2,893.56 $ 0.00 $ 95.95 $ 29.00 $ 150.00 $ 8,683WS .p7 of 2012 Dat day Angela L. Mattis, PA ID #309229 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax: (570) 387-6474 O L?' my:.. # a8a'aM C? C_? T?S' Lf WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-6502 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS Plaintiff (s) From RAYMOND D. SCOTT, JR, 5 HIDDEN NOLL ROAD, CARLISLE, PA 17013 (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: M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 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 $5,514.56 Interest FROM 2/4/2004 - $2,893.56 Atty's Comm % Atty Paid $127.45 Plaintiff Paid L.L. $.50 Due Prothy $2.25 Other Costs $95.95 Date: 11/7/12 (Seal) REQUESTING PARTY: Name : ANGELA L. MATTIS, ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorney for: PLAINTIFF Telephone: 570-387-1873 Supreme Court ID No. 309229 David D. Buell, Prothonotary oo? Deputy s ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~- COMMONWEALTH OF PENNSYLVANIA ` ---- . „ ___. t .,~_ , -s ~~ _". UNIFUND CCR PARTNERS, _ Plaintiff rf . _ °-- f. +~ -°~ vs. CNIL-LAW : > ; ;-~_ . ~~a - RAYMOND D. SCOTT JR., :DOCKET NO. 2003-06502 CIVIL ~.; e, Defendant - . --- vs. M&T BANK, Garnishee ~Su~ ~° INTERROGATORIES TO GARNISHEE TO: M&T Bank Frnt, 1 West High Street Carlisle, PA 17013 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. If you need additional information such as a social security number, contact the attorney listed at the end of this document. 1. At the time you were served or at any subsequent time did you owe the defendant 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? L~I'~ M & T BAN~c MAS NO OPEN ACCOUNT; ~(~R ABC-VE NAMEI`' 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? ?~~'1~ 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? ~~ 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? ~~1~ 5. At any time before or after you were served did the defendant transferor deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration thereof? V~ 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? ~~ 7. If you are a bank or other 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 exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. ~, ~ ~ y 8. If you are a bank or other institution, at the time you were served or at 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. § 8123? If so, identify each account. J~-~~~ 9. If your answer to any of the above is in the affirmative, state the amount on deposit or owed or describe the property in detail and provide any other particulars of the transaction as maybe relevant to this attachment. ~%1'~ COMPLETED BY: Signature CATHY S FISHER Name (print) M&T BA~1K `=~ ~~r~v y ~ ~m~ Title Interrogatories submitted to garnishee by: Angela L. Mattis, PA ID #309229 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: 570-3 87-1873 Fax: 570-387-6474 SHERIFF'S OFFICE OF CUMBERLAND COUNTY > ~ ~ ~ Ronny R Anderson `v3 m -- ^~ :C "{ ~ ~~ Sheriff ~~`~ti,, of ~~t,,,bir~f~f~ r i ~~ -~ -~~ Jody S Smith 0 4 tn~ ~ -- ~~; Chief Deputy r -~ ~ ~~, Richard W Stewart ~~ ~ ~-Yi Solicitor "~~ `~'~` ~ ~,,, _. ..~- • ~- :; Unifund CCR Partners vs. Raymond D Scott, Jr Case Number 2003-6502 SHERIFF'S RETURN OF SERVICE 11/13/2012 11:10 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on November 13, 2012 at 1100 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Raymond D. Scott Jr., in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania, by handing to Donna Egolf, Teller, 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 November 15, 20 to Raymond D. Scott Jr., at 5 Hidden Noll Road, Carlisle, PA 17013. WILLIAM CLINE, DEPUTY SO ANSWERS, November 15, 2012 RON R ANDERSON, SHERIFF ;.~ c~ U~:4s.~~tE S~,rntr: r~i:~o~;on, in- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA IJ1VIFtJND CCR PARTNERS, : ~` . ~..~. Plaintiff - "'' vs. RAYMOND D. SCOTT JR., Defendant vs. M&T BANK, Garnishee r., ,_. CIVIL-LAW , r::.~ .. y l.J -- DOCKET NO. 2003-06502 CIVIL. _, _~' -' . -- ~~- r, ~' `- ~, c-;~ PRAECIPE TO DISCONTINUE ATTACHMENT To the Prothonotary: Kindly Discontinue the Attachment of the Defendant's bank account with M&T Bank. SUBMITTED BY: Angela L. Mattis, PAID #309229 Attorney for Plaintiff ~ 36 West Main St. Bloomsburg, PA 1781 S Tel. (570)387-1873 Fax (570)387-6474 a C ~~ ~ ~~ ~ 3 lo~v~ 2+~ ~ $ r . t p M~TBank November 15, 2012 Angela L. Mattis, Esq. 36 West Main Street Bloomsburg, PA 17815 Legal Document Processing Phone # 716-635-7711 Fax # 716-635-7725 ~~~~~ U` Re: Garnishment Summons on Garnishee received by Manufacturers and Traders Trust Company Unifund CCR Partners vs. Raymond D Scott Jr. Case: 03-6502 CIVIL Pursuant to the above Garnishment Summons, Manufacturers and Traders Trust Company has searched its records and has identified the following open accounts with balances due its customer(s). cct No. Balance Acct No. Balance none If the Writ of Garnishment and Interrogatories also sought to restrain access to safe deposit boxes, then any safe deposit boxes identified at any of our branches are listed below. ranch Number Safe Deposit Box Number one With respect to all safe deposit boxes, an order directing the drilling of the box must first be obtained and Manufacturers and Traders Trust Company must be reimbursed for the cost of drilling and replacing the lock on the box. Pa.R.C.P. No. 3110, 42 Pa.C.S.A. Sincerely, Cathy S. Fisher Legal Document Analyst (716)635-7711 Enclosure: Responses to Interrogatories Manufacturers and Traders Trust Company P.O. Box #844, Buffalo, New York 14240 r 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY r~~ ~`.,'~'~~1~i ~ T ~r'r~ Tzrri vfr~ii ~1~-r~ir~~l~ UNIFUND CCR PARTNERS, Plaintiff vs. RAYMOND D. SCOTT JR., Defendant vs. M&T BANK, Garnishee CNIL-LAW DOCKET N0.2003-06502 CIVIL INTERROGATORIES TO GARNISHEE TO: M&T Bank Frnt, 1 West High Street Carlisle, PA 17013 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. If you need additional information such as a social security number, contact the attorney listed at the end of this document. 1. At the time you were served or at any subsequent time did you owe the defendant 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? 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? :x,4;1 3. At the time you were served or at any subsequent time did you hold legal defendant held or claimed any interest? '~~., ~~. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? :.~,1-~ 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration thereof? L 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? 7. If you are a bank or other 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 exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. ~-- t,~, 8. If you are a bank or other institution, at the time you were served or at any on deposit, not including any otherwise- exempt funds, -did-not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. ~/ 9. If your answer to any of the above is in the affirmative, state the amount on deposit or owed or describe the property in detail and provide any other particulars of the transaction as maybe relevant to this attachment. ;~ `k`~ COMPLETED BY: ~-~ Signature CATHY' S FiSHEFt Name (print) iUi&T BAi'~~C -d~~~t i~~~V ~ .~ 2D12 Title Interrogatories submitted to garnishee by: ~~~ Angela L. Mattis, PA ID #309229 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: 5 70-3 8 7-18 73 Fax: 570-387-6474 SHERIFF'S OFFICE OF*CUMBERLAND COUNTY y R Anderson F!L.ED-OF 1:7 riff 1*HE PROTHONOTAiR)r Jody S Smith Chief Deputy I 3SEP 19 AV, If: I- I Richard W Stewart T P CUMBERLP40 COUn'ry Solicitor 1O CRF PENNSYLVAmA Unifund CCR Partners Case Number vs. Raymond D Scott,Jr 2003-6502 I SHERIFF'S RETURN OF SERVICE 11/13/2012 11:10 AM-William Cline, Deputy Sheriff,who being duly sworn according to law, states that on November 13, 2012 at 1100 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Raymond D. Scott Jr., in the hands, possession, or control of the within named garnishee, M&T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania, by handing to Donna Egolf,Teller, 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 November 15, 2012 to Raymond D. Scott Jr., at 5 Hidden Noll Road, Carlisle, PA 17013. 09118/2013 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: $88.40 SO ANSWERS, September 18, 2013 RbNW R ANDERSON, SHERIFF J. 'oe Caunty&Re Shedff,Tefcosoft Inc, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ` Sheriff s �t�, �t Jody S Smith Viol, HE PRO Tf 101,4 ;l TA Chief Deputy Richard W Stewart SE, 19 AM 1,1: 1 ,�,,,$.��.�� Solicitor Ofi�FGEOF THE SHERIFF CUMBERLAND C o W i r Y PEMSYLVAMA Unifund CCR Partners vs. Case Number Raymond D Scott, Jr 2003-6502 SHERIFF'S RETURN OF SERVICE 02/21/2013 10:33 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 21, 2013 at 1026 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Raymond D. Scott Jr., in the hands, possession, or control of the within named garnishee, F & M Trust, 214 A Westminster Drive, Carlisle, Cumberland County, Pennsylvania, by handing to Terry Glass, Security 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 February 22, 2013 to Raymond D. Scott Jr., at 1917 Spring Road,Apartment 5, Carlisle, PA 17013. 09/18/2013 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: $86.95 SO ANSWERS, September 18, 2013 RbNO R ANDERSON, SHERIFF r.�o3d {C}Cou-tySui;e Sheriff,Teleosoff,Inc.