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Home My WebLink About08-2148IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff vs. CHARLES L RIGGS JOAN RIGGS Defendant(s) NO. 1R- o'L148 bV t ler" CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF EXEMPLIFIED JUDGMENT To the Prothonotary: Please enter the attached Exemplified record as a civil judgment. Dated: 312111-0 A WA File No. 119366211-N Respectfully Submitted, 64L ( . 4/ Am Daniel F. Wolfson #20617 clip C. Warhol, #86341 Tonilyn M. Chippie #87852 avi a oway #8 6 Robert N. Polas, Jr. #201259 Sarah E. Ehasz #86469 Wolpoff & Abramson, LLP 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. vs. CHARLES L RIGGS JOAN RIGGS CIVIL ACTION - LAW Defendant(s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), CHARLES L RIGGS and JOAN RIGGS, pursuant to the attached Exemplified Judgment Record. ( X ) Amount due $4,370.69 TOTAL = $4,370.69, plus interest & court costs. ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. Date: t Amy F. Doyle #0062 17 Daniel F. Wolfson #20617 arh is #86341 Tonilyn M. Chippie #87852 avid R. Galloway #87326 Robert N. Polas, Jr. #201259 Sarah E. Ehasz #86469 Wolpoff & Abramson, LLP 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff NOW, Apc , 20-D&, JUDGMENT ;ISE REDAS 6BVE . onotary/ , ivis ion By: Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff vs. CHARLES L RIGGS JOAN RIGGS Defendant(s) NO. CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: PALISADES COLLECTION LLC 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632- And certify that the last known address of the within Defendant(s) is: CHARLES L RIGGS JOAN RIGGS 1960 OLD MILL RD 107 E COLUMBIA RD, APT 1 MARYSVILLE, PA 17053 ENOLA, PA 17025 Date: Q ' Amy F. D Daniel F. Wolfson #20617 1 ip C. Warholic #86 41 Tonilyn M. Chippie #87852 David R. Galloway #87 6 Robert N. Polas, Jr. #201259 Sarah E. Ehasz #86469 Wolpoff & Abramson, LLP 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. vs. CIVIL ACTION - LAW CHARLES L RIGGS JOAN RIGGS Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, CHARLES L RIGGS, above named, is over 21 years of age; is last know to reside at 1960 OLD MILL RD, MARYSVILLE, PA 17053, PERRY County, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. Date: 3 d 0 eyF . D D aniel F. Wolfson #20617 p C. Warholic :#8634 Tonilyn M. Chippie #87852 oway 326 Robert N. Polas, Jr. #201259 Sarah E. Ehasz #86469 Wolpoff & Abramson, LLP 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff SWORN and SUBSCRIBED to before me this ? day of M"C , 20-at Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Amy R. Wise, Notary Public Hampden Twp., Cumt?eriand County My Commission Expires Nov. 30, 2010 Member, 4'ennsy'vania :-ssa iation of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. vs. CHARLES L RIGGS JOAN RIGGS Defendant(s) CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, JOAN RIGGS, above named, is over 21 years of age; is last know to reside at 107 E COLUMBIA RD, APT 1, ENOLA, PA 17025, CUMBERLAND County, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. Date: L o G; C?v l' Amy F. Do le # Daniel F. Wolfson #20617 hi < C. Warhol' 634 Tonilyn M. Chippie #87852 David R. Galloway #87326 Robert N. Polas, Jr. #201259 Sarah E. Ehasz #86469 Wolpoff & Abramson, LLP 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff SWORN and SUBSCRIBED to before me this ?`-'? day of ?, 2(?, /-**% Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Amy R. Wise, Notary Public, Hampden Twp., Cumberland 1cunty My Commission Expires Nav : k ?()10 Member, Pennsylvania r',ssociraior. of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff vs. CHARLES L RIGGS JOAN RIGGS Defendant(s) NO. CIVIL ACTION - LAW AFFIDAVIT OF FOREIGN JUDGMENTS Commonwealth of Pennsylvania County of Cumberland :ss. AND NOW, TO WIT, this day of , 20 , comes the undersigned who being duly sworn according to law, deposes and says that they are the Attorney for the Plaintiff in the above-captioned action; that the judgment is valid, enforceable and unsatisfied. aEN _ 2 / Daniel F. Wolfson #20617 ?Polas, ?,„_ #86341 David R. Galloway #87326 o. Jr. #201259 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 Wolpoff & Abramson, LLP/Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 (717) 303-6700 SWORN and S BS IBED to bef r me this d of llnl_OY? ' 20 G n Notk* Public CCMMpNWEALTH OF PENNSYLVANIA Notarial Seat Amy R. Wise, Notary Public Hampden Twp., Cumberland County My Commission Expires Nov. 30, 2010 hie of Notares mher, Penrsylv.n z;,?cia4io? IN THE COURT OF COMMON PLEAS OF PERRY COUNTY, PENNSYLVANIA OFFICE OF PROTHONOTARY PALISADES COLLECTION LLC CIVIL #JP-2005-00139 V CHARLES L. RIGGS, ET AL CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, Brenda J. Albright, Prothonotary Of The Court Of Common Pleas Of Perry County, Pennsylvania, Do Hereby Certify That The Following Is A True, Correct And Full Copy Of The Docket Entries In The Above Captioned Case. I FURTHER CERTIFY THAT JUDGMENT WAS ENTERED IN FAVOR OF Plaintiff, PALISADES COLLECTION LLC AND AGAINST Defendants CHARLES L. RIGGS & JOAN RIGGS 1960 OLD MILL ROAD, MARYSVILLE PA 17053 ON THE 31 IT DAY OF JANUARY 2005 IN THE ABOVE CAPTIONED CASE IN THE AMOUNT OF J1270.69 plus costs, plus interest. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND A OFFICIAL SEAL OF THE SAID COURT ON THE 1sT DAY OF MAY, A.D. 2007 ' PROTH NOT RY BY DEPUTY ?? Date: 5/1/2007 41st Judicial District of PA, Perry County Branch User: RUTH S Time: 09:15 AM Complete Case History Page 1 of 2 Case: CV-JP-2005-00139 PALISADES COLLECTION LLC vs. CHARLES L RIGGS, etal. Filed: 1/31/2005 Subtype: JP Trans Physical File: Y Appealed: N Comment: Judge History Date Judge Reason for Removal 1/31/2005 REHKAMP, C. JOSEPH Current Payments Receipt Date Type Amount PHILIP WARHOLIC ESQ 27384 4/30/2007 Civil Filing 20.90 SPEARS, ESQ 21431 10/4/2005 Civil Filing 20.90 WOLPOFF & ABRAMSON 18360 1/31/2005 Civil Filing 14.00 Total 55.80 Plaintiff Name: PALISADES COLLECTION LLC SSN: Address: 267 E. MARKET STREET DOB: YORK PA 17403 Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys WARHOLIC, PHILIP C (Primary attorney) Send Notices Defendant Name: RIGGS, CHARLES L Address: 1960 OLD MILL ROAD MARYSVILLE PA 17053 Phone: Home: Work: Employer: Litigant Type: Comment: SSN: DOB: Sex: Send notices: Y Defendant Name: RIGGS, JOAN Address: 1960 OLD MILL ROAD MARYSVILLE PA 17053 Phone: Home: Work: Employer: Litigant Type: Comment: Register of Actions 1/31/2005 Judgment entered in the amount of $4,370.69+C+I Exit 236 notice to defendant. SSN: DOB: Sex: Send notices: Y CERTIRIE? TRUE COPY PROTHONOTARY REHKAMP, C. JOSEPH ywo BURT GmFW M Yf n,. ,40hhl Cofl9 Yi'U43q Date: 5/1/2007 Time: 09:15 AM Page 2 of 2 41st Judicial District of PA, Perry County Branch Complete Case History Case: CV-JP-2005-00139 PALISADES COLLECTION LLC vs. CHARLES L RIGGS, etal. Register of Actions 1/31/2005 Filing: JP TRANS Old Fee Paid by: WOLPOFF & ABRAMSON Receipt number: 0018360 Dated: 01/31/2005 Amount: $14.00 (Check) 10/3/2005 Praecipe to Request Exemplified Judgment filed. Exit is to atty, file. 10/4/2005 Filing: Exemplified Record Paid by: SPEARS, ESQ Receipt number: 0021431 Dated: 10/4/2005 Amount: $20.90 (Check) 4/30/2007 Filing: Exemplified Record Paid by: PHILIP WARHOLIC ESQ Receipt number: 0027384 Dated: 4/30/2007 Amount: $20.90 (Check) Request for Exemplified Record filed. Exit exemplified record to atty Phillip C. Warholic, file. Judgment Order date In Favor Of Disposition 01/31/2005 Plaintiff 00/00/0000 Comment: 4, 370.69+C+I Plaintiff: PALISADES COLLECTION LLC Defendant: RIGGS, CHARLES L RIGGS, JOAN REHKAMP, C. JOSEPH UNASSIGNED, REHKAMP, C. JOSEPH REHKAMP, C. JOSEPH REHKAMP, C. JOSEPH Judgment JP Trans User: RUTH S CERTIFIED TRUE COPY DEPUTY PROTHONOTARY ?....._ .r=- :77: Date: 4/30/2007 41st Judicial District of PA, Perrv County Branch NO. 27384 Tire: 12:49 PM Receipt =age 1 of 1 Received of: PHILIP V,,r '-RriOLIC ESQ $ 20.90 Twenty and 90/100 Dc-.-i._rs Case: CV-JP-2005-00139 Plaintiff: PALISADES CGLLECTION LLC vs. Amount Exemplified Record Total: Check: 00503964 Payment Method: Check Amount Tendered: Change Returned: Clerk: BRENDA 20.90 0.00 Brenda J. By: _ Deputy 20.90 20.90 fight, Prothonotary & Clerk o :. tll ? j? CD N U W MAY 2 2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. vs. CHARLES L RIGGS JOAN RIGGS Defendant(s) CIVIL ACTION - LAW NOTICE OF JUDGMENT (x) Notice is hereby given that a JUDGMENT in the above-captioned matter has been entered against you in the amount of $4,370.69, plus interest, on Aw,1 3 (x) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. Pr onotary C' is' n By: If you have any questions regarding this Notice, please contact the filing party. Date: vla i ? *av . Do Dani el F. Wolfson #20617 Tonilyn M. Chippie #87852 R. Galloway 87326 Robert N. Polas, Jr. #201259 Sarah E. Ehasz #86469 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: CHARLES L RIGGS 1960 OLD MILL RD MARYSVILLE, PA 17053 JOAN RIGGS 107 E COLUMBIA RD, APT 1 ENOLA, PA 17025 W&A File No. 119366211-N PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 TO 3149 PALISADES COLLECTION,L.L.C. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VB. JOAN RIGGS Defandant(s) JUDGMENT NO. 08-2148 PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $4,370.69 . (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against, JOAN RIGGS 107 E COLUMBIA RD APT 1 ENOLA PA 17025 Defandant (s) ; (3) and against MEMBERS FIRST FCU located at 1000 BRYN MAWR RD CARLISLE PA 17013-1588 (4) And index this writ (A) against JOAN RIGGS Defandant (s ) and (B) against, MEMBERS FIRST FCU Garnishee(s); ,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)***GARNISH ONLY*** You are directed to attach the property of the Defendant(s) not levied upon in the possession of MEMBERS FIRST FCU , Garnishee(s) All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount Due: $4,370.69 Interest From: 01/31/2005 To Be Determined At an interest rate of 6% per year Total: $4,370.69 Plus costs & interest (total includes post judgment credits). David R. Gallo*ay #87" 6/Philip C. Warholic #86341 S rah E. Ehasz #86469/Robert N. Polas, Jr. #201259 F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, P. C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (717) 303-6700 Fax: (717) 737-9051 PABGAR/PABANR FILE # 119366211 'fM >? cµ- ca • O O N Q 0 0 O 4 9R> O -0 co W 0. b ]y r' r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-2148 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC, Plaintiff (s) From JOAN RIGGS, 107 E. Columbia Rd, Apt 1, Enola, PA 17025 (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: MEMBERS FIRST FCU,1000 Bryn Mawr Rd, Carlisle, PA 17013-1588 All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. 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 $4,370.69 L.L. $.50 Interest from 1/31/05 at an interest rate of 6% per year - to be determined Atty's Comm % Arty Paid $56.00 Plaintiff Paid Date: 1/28/09 (Seal) Due Prothy $2.00 Other Costs urtis R. , otho tart' By: Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: MANN BRACKEN LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87062 SHERIFF'S RETURN - GARNISHEE CASE NO: 2008-02148 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS RIGGS JOAN And now SHAWN HARRISON ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0017:01 Hours, on the 3rd day of February-, 2009, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT RIGGS JOAN in the hands, possession, or control of the within named Garnishee MEMBERS FIRST FCU 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to MARISOL BARBER (ASST. BRANCH MANAGER) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscribed to before me this So answers- .00 .00 ? I ? ?? ? .00 R. Thomas Kline .00 Sheriff of Cumberland County .uu 02/04/2009 day of By A.D Deputy Sherif N ? "? ?' ?? ,?. -, r? ... qs,_ J ? .?,?. ?' ? +? y ? .? ? ? ? ?.r ?? tiw! -. IN THE COURT OF COMMON PLEAS CUMBERLAND PALISADES COLLECTION,L.L.C. Plaintiff VS 01-of-L" L JOAN RIGGS COUNTY, PENNSYLVANIA No. 08-2148 CIVIL ACTION - LAW RECEIVED Defendant (s) FEB o 4 7nn9 INTERROGATORIES TO GARNISHEE TO: MEMBERS FIRST FCU 1000 BRYN MAWR RD CARLISLE PA 17013-1588 PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE A. 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. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ Execution was issued. C. "You" means the main office and all branch offices, representatives, employees and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. PABINT/PABANK FILE # 119366211 INTERROGATORIES TO GARNISHEE DEFENDANT(S) - JOAN RIGGS 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each account. If the Defendant(s) maintains an of these jointly with any other person, or persons, give their me and address. am& 1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. a 2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) 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. n 1 3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds on deposit, not including any otherwise exempt funds, did not exceed the amount of general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. 4. TRANSFER OF PROPERTY: 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(s) against you? PO 5. SAFE DEPOSIT BOX: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. no PABIN2/PABANK FILE # 119366211 .. M 6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not the Defendant(s) own any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumbrances or liens holders, the present balance of the encumbrance. State where and when encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. P 0 7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). /6 8. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). no 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charged by you against the Defendant (s) or account (s) of the Defendant (s) for the completion of this Answer? If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. "J? V v r David R. Gallo ay #87 26/Philip C. arholic #86341 y Zah E. Ehasz #86469/Robert N. Polas, Jr. #201259 F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, P. C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (717) 303-6700 Fax: (717) 737-9051 PABIN3/PABANK FILE 11 119366211 A fV1@ MEMBERS 1St FEDERAL CREDIT UNION February 4, 2009 Account Number: XXX585 Name: Charles L Riggs Address: 5022 Trent Road Harrisburg, PA 17109 Savings: $1,251.66 2( 5.00) Processing Fee $1,226.66 Checking: $571.91 Total in account: $1,798.57 Payroll: Tyco Electronics $300.00 Statutory Exemption was not taken out. Tania S Young Deposit Operation An t 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • wwwmemberslst.org a VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/she is GL of me (Name) 6efosJ (kzhi/)s J l? mbers 1st Federal Credit Won (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. c (SIGNATURE G7 a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION, LLC Plaintiff NO. 08-2148 VS. JOAN RIGGS CHARLES L RIGGS CIVIL ACTION - LAW Defendant(s) VS. MEMBERS FIRST FCU Garnishee . Garnishee: MEMBERS FIRST FCU __:r.,?. ...?. 5000 LOUISE DR MECHANICSBURG, PA 17055 PRAECIPE FOR JUDGMENT UPON ADMISSION To the Prothonotary: Please enter judgment in favor of the Plaintiff and against the Garnishee, MEMBERS FIRST FCU, in the amount of $1,498.57, as admitted in the answer to Interrogatories to be in the possession of Garnishee. Dated: z /4r5? Respectfully Submitted, n MB File No. 119366211 e-t18?b Philip olic #86:t L:YrEhhas / David R. oway #873 z 9 o rt . oas, MANN BRACKEN LLP The Suocessor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, PC Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 / (717) 303-6700 cc: KEN LEWIS, ESQ. 1101 N FRONT ST HARRISBURG, PA 17102 e _ ?6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,. PENNSYLVANIA PALISADES COLLECTION, LLC Plaintiff NO. 08-2148 VS. CIVIL ACTION - LAW JOAN RIGGS CHARLES L RIGGS Defendant(s) vs. MEMBERS FIRST FCU Garnishee CERTIFICATE OF SERVICE The undersigned does hereby certify that a true and correct copy of Judgment Upon Admission, was served upon the individual(s) listed below by Regular Mail, Postage Pre-Paid on this Q14-day of A oc%' 20Qq.. JOAN R RIGGS 1234 WALNUT ST HARRISBURG, PA 17103 KEN LEWIS, ESQ. 1101 N FRONT ST HARRISBURG, PA 17102 MEMBERS FIRST FCU 5000 LOUISE DR MECHANICSBURG, PA 17055 Amy F..Du a #87062 Philip C. arholic #86341. David R. Galloway #87326 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 MANN BRACKEN LLP The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, PC Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 (717) 303-6700 .w JJS ?ei i 14k, DO iq S'? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. 08-2148 vs. CIVIL ACTION - LAW CHARLES L RIGGS JOAN RIGGS Defendant(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, MEMBERS FIRST FEDERAL CU, discontinued, upon payment of your costs only. Respectfully Submitted, Dated: Warholic 7062 avi . Galloway #87326 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 MANN BRACKEN LLP The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, PC Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 (866) 253-0128 MB File No. 119366211 OF TH 20 9,; 33 rt 1: 22 $8.oo QD Arn ct,*o?aq u*'Us(olz R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. 4 Sheriff s Costs: Advance Costs: 150.00 Sheriffs Costs: 86.58 Docketing 18.00 63.42 Poundage 1.70 Law Library .50 Refunded on 09/25/09 Prothonotary 2.00 Mileage 4.50 Surcharge 30.00 Levy 20.00 Postage .88 Garnishee 9.00 $ 86.58 So Answers, ? ??? 4?o q ?, °?? R. Thomas Kline, Sheriff By Sharon R. Lantz r` ` o -Tl (`iry f .Z'10 e .5D L I- c °Q C-k -7 _7 .2 -3, (r) .23)175 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-2148 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC, Plaintiff (s) From JOAN RIGGS, 107 E. Columbia Rd, Apt 1, Enola, PA 17025 (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: MEMBERS FIRST FCU, 1000 Bryn Mawr Rd, Carlisle, PA 17013-1588 All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. 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 $4,370.69 L.L. $.50 Interest from 1/31/05 at an interest rate of 6% per year - to be determined Atty's Comm % Atty Paid $56.00 Plaintiff Paid Date: 1/28/09 (Seal) Due Prothy $2.00 Other Costs gis. Lon, t no By: Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: MANN BRACKEN LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87062