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HomeMy WebLinkAbout08-3228IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERATED RETAIL HOLDINGS, INC. nn DB/A KAUFMANN'S No. C18Saa 8 t?iVil tp. F/K/A THE MAY DEPARTMENT STORES COMPANY Plaintiff vs. RUTH A HENRY Defendant(s) CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), Ruth A Henry , pursuant to the attached Exemplified Judgment Record. (X) Amount due $2,035.50 TOTAL $2,035.50, plus interest and 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 occured and at least ten days prior to the date of the film is praecipe and a copy of the notice is attached. Date: t Amy F. Doyle #87062 / Phi David R. Galloway #87 yn . Chippie #878 Sarah E. Ehasz #86469 / o ert o as, Jr. 59 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff NOW, 161 , 20-Q&-, JUD MENT IS E TERED AS ABOVE. Pro onotary? ivi ivision By: Deputy W&A FILE NO. 134718032 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERATED RETAIL HOLDINGS, INC. DB/A KAUFMANN'S F/K/A THE MAY DEPARTMENT STORES COMPANY Plaintiff vs. RUTH A HENRY Defendant(s) No. 0-6 - 3Z. Z b Ci Yi 1 -T'erM CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF EXEMPLIFIED JUDGMENT To the Prothonotary: Please enter the attached Exemplified record as a civil judgment. Respectfully Submitted, D ate: Amy . Doyle #87062 / Philip C. Warholic #86341 / David R. Galloway #873 M. Chippie 7n852 / Sarah E. Ehasz #86469 / Peaas;-Jr-. *MT259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 134718032 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERATED RETAIL HOLDINGS, INC. D/B/A KAUFMANN'S F/K/A THE MAY DEPARTMENT STORES COMPANY Plaintiff VS RUTH A HENRY Defendant(s) No. G$ - 3Z Z Q) CIVIL ACTION - LAW 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, Ruth A Henry, above-named, is over 21 years of age; is last known to reside at Po Box 81593 Pittsburgh, County of Allegheny, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. Date: Amy F. oyle #87062 / Philip C. 34.1 David R. Galloway #873 onilyn M. Chippie #8785 Sarah E. Ehasz #86469 / o e o as, r. Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff SWORN and SUBSCRIBED to before me this 2day of 20 y? W & A File No. 134718032 Notary Public COMMONWEALTH OF PENNSYLVANIA Notaria! ;;Pal Aklny R. Wise, Notary Public Nand den Tavp., :umb3dand County my Expiras Nov. 30, 2010 tv'e nber, Fernsy!vania AsjoCiation of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERATED RETAIL HOLDINGS, INC. DB/A KAUFMANN'S NO. OPj - 3 GCB C,1 Y1? 7e'rm F/K/A THE MAY DEPARTMENT STORES COMPANY Plaintiff CIVIL ACTION - LAW vs. RUTH A HENRY Defendant(s) 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. Amy F?vle #87062 / Philip C. Warhol David R. Galloway #87326 Chi Sarah E. Ehasz #86469 / . o as, Jr. #201259 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff SWORN and SUB9 RIBED to before me this ? d p of , 20? O o (Lu Nota blic c,-O?JMCI IW? EAST; CF F'ENNSYLVANIA i _ Notarial Seal Amy R. Wise, Nota^1 Public Harroden Twp.: Cumberland County ii ???y (,,yorr,ssion Expiros Nov. 30, 2010 L ..__ ` F\SSOCiatlon of Notaries W&A File No. 134718032 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERATED RETAIL HOLDINGS, INC. D/B/A KAUFMANN'S F/K/A THE MAY DEPARTMENT STORES COMPANY No. 0-6- 3ZZ? Plaintiff VS CIVIL ACTION - LAW RUTH A HENRY Defendant(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise address of Plaintiff is: Federated Retail Holdings, Inc. 111 Boulder Industrial Drive Bridgeton MO 63044 and certify that the last known address of the within Defendant(s) is: Ruth A Henry Po Box 81593 Pittsburgh PA -?Vl 15217 Date: 0 Amy F. Doyle #87062 / Ph' David R. Galloway #8 Chi ie # 52 / Sarah E. Ehasz #86469 / o ert . Po as, Jr. #201259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 134718032 r ' i IN THE COURT OF COMMON PLEAS OF io ALLEGHENY COUNTY, PENNSYLVANIA COVER SHEET Prothonotary Plaintiff(s) Case Number: CP lo/ _ ?3 ,?1 FEDERATED RETAIL HOLDINGS, INC IV lJ(p -7 4?v D/B/A KAUFMANN'S F/K/A THE MAY ?J DEPARTMENT STORES COMPANY Type of pleading: JUDGMENT Code and Classification: I vs Defendant(s) i RUTH A HENRY 309 GLEN DOUGLAS DR APT D GLENSHAW PA 15116 C,.- o„ v i r M ?. c; Filed on behalf of FEDERATED RETAIL HOLDINGS, INC D/B/A KAUFMANN'S F/K/A THE MAY DEPARTMENT STORES COMPANY (Name of the filing party) 0 Counsel of Record 0 Individual, If Pro Se Name, Address and Telephone Number: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 3RD FLOOR CAMP HILL, PA 17011 (717) 303-6700 Attorney's Stated ID: Attorney's Firm ID: 0 ( I, V7 -t7-f- COMMONWEALTH OF PENNSYLVANIA COUNTY OF: ALLEGBENY Map. Dist. No.: 05-2-03 MW Name: Hon. ROBERT P. DSVOEICK Aftem: 1007 MT ROYAL BLVD PITTBBORGH, PA Telephone: (412) 487-7630 15223 FEDERATED RETAIL HOLDIMS 4660 TRIMLE RD FL3 C/O VOLPOFF is ABRAMSO]N CAKF HILL, PA 17011 THIS IS TO NOTIFY YOU THAT: Judgment: FOR PLAINTIFF o`3' -6 ZZa Ci vi J -T?r m NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rP=ZRATED RETAIL HOLDIINGB 4660 TRI]NDLE RD FL3 C/0 VOLPOFF L ABRAMSON LFAMP HILL, PA 17011 J VS. DEFENDANT: NAME and ADDRESS rm- mY, ROTE A -1 309 GLEN DOUGLU DR APT/STE D GLERSHAN, PA 15116 L J Docket No.: CV-0000327-06 Date Filed: 6/26/06 (Date of Judgment) 7/25/06 Judgment was entered for: (Name) FEDER>TED RETAIL 80L, DINGS © Judgment was entered against: (Name) HENRY, ROTE A in the amount of A. 2,035.5(F Defendants are jointly and severally liable. Damages will be assessed on Date & Time This case dismissed without prejudice. F1 Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 F] Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 1,960.00 Judgment Costs $ 75- Interest on Judgment $ 0 Attorney Fees $ .0 Total $ 2,035.50 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY]CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIFT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 7125 106 - 10 Date I certify that this is a true anroorrect copy of the reco of the 10/5 /&O Date "Ov My commission expires first Monday of January, 2012 B ?9?? iD?F?q?o?oy ?o??sq?o ?sr ??- ti? si0 ?s 9, ll?G Magisterial Districts ?? ot? containing the judgment. ti `? _ , Magisterial District Judge SEAL AOPG 315-06 DATE PRXNTE) t 10105106 2: 12: 00 PM Allegheny County Civil Division Docket Report Home GD-06-027530 Federated Retail Holdings vs Henry Run Date: 03/19/2008 Court Type: General Docket Run Time: 09:25:27 AM Case Type: District Justice Transcript Related Cases: Judge: No Judge Jury Requested: No Current Status: Notice of Judgment Mailed Amount In Dispute: $ 2035.50 Parties -- Litigants - ID LName FName MI Type Address Phone @1390273 Federated Retail IF - 4660 Trindle Road c/o Wolpoff & Holdings ?? Plaintiff IlAbranson Camp Hill PA 17011 -@669060 Henry Ruth E] Defendant No Default Address Available=E- -- Attorney -- ID LName FName MI Type Address Phone 87062 Doyle Amy Plaintiffs Attorney No Default Address Available ?? IE -- Non Litigants -- No Listing Docket Entries I Filing Date Docket Type Docket Text Filing Party 11/16/2006 DJ Transcript of Judgment Federated Retail Holdings 11/16/2006 Notice of Judgment Mailed Federated Retail Holdings Judgment Against ID Type *enRu:th7 Amount Satisfied Docket Filing Date ------------- @669060 Defendant 2035.50-? DJ Tran script of Judgment j 11/16/2006 Judgment For ID Type Name -l Amount Docket @1390273 Plaintiff Federated Retail Holdings 2035.50 DJ Transcript of J Filing Date 11/16/2006 FORM 26 PRO. COPY OF DOCKET ENTRIES COMMONWEALTH OF PENNSYLVANIA SS. ALLEGHENY COUNTY Among the Records and Proceedings of the Court of Common Pleas in and for the County of Allegheny, and State of Pennsylvania, the following is a true and correct copy of the Docket Entries at No. GD - 0 6 - 0 2 7 5 3 0 DOCKET ENTRY Federated Retail Holdings, Inc., D/B/A Kaufmann's, F/K/A The May Department Stores Company VS. Ruth A Henry See Attached Sheets I, Michael E. Lamb Prothonotary of the Court of Common Pleas in and for said County, Certify that the foregoing is a full and correct copy of the Docket Entries wherein : Federated Retail Holdings, Inc. , D. B/A Kaufmann's F/K/A The May Department Stores Company Plaintiff and Defendant; as the remains of record before the said Court, at No. GD - 0 6- 0 2 7 5 3 0 IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of the said Court, the 19 th. day of March 2008 PROTHONOTARY D 0 FA b 0 F-h r-r, n d rp r ? r g a CR In z Ca H d fi =" rn m ? o °(D W C n c rnO? G) > ? OZ Z?m 9 ?3 m x X 3 00 S 0 0 ° Z b m Ol Z0O o m c (D En F -? r rn 'Tl ? 2 ?40 ??W C C7 W >()O ° rt 74 f-- N.) zOX rn 5: rr-- a W zo C) (D z cn rn o OA rn 10 -n (/) 10 z 0 d 0 V Ui W 0 IN THE COURT 07 CC,%-,,%tON PLEAS OF ALLEGHEk4Y COUNTY. PEN^;S'r'L VAy!A IN RE: Dept. of Court Records - D;Ffi;"CTOR 01= C Civil C)iv Sion 0 U R T IiEC01)JS Qurr ir:i . s.ri t !ve tlccket No. i._ of 2008 c:^ ORDER OF COUjC AND NOW, this 7th day of January, 2008, this Court reco nize ? S that;. a) cn.December 6, 2004, the Allegheny County Council duly passed Ordinance No. 38-04-OR- (b) D Chief Executive signed Ordinance No 04-OR authorized the placement of a ballot question on the May 17, 2005, municipal primary ballot, which, if passed by the electorate of Allegheny County, would amend and modify the Allegheny County Home Rule Charter by, inter aiia abolishing the elected Row Offices of Prothonotary, Clerk of Courts and Register of Wills and replacing them with a single appointed office of Director of Court Records, which would be vested with all the power and authority that all applicable law, including without limitation, 16 P.S. § 4301, etseq., 20 Pa,C.S.A. § 901, et seq., 42 Pa. C.S.A. § 2731, et seq., and 42 Pa. C. S.A. § 2751, et se 4". had vested in the elected Rcw Offices of Prothonotary, Clerk of Courts and Register of Wills, (d) the ballot quest:en ;,,uthorized by Ordinance No. 38-0,4-OR WaS ar•i??(?'?'C'd "' t'y f Aiieg ;.any Cou,n+\? in the May 17, 2005, 'J Vi mu^icipal primary ei r Cl.'IL?n :l'ld !I ie A ;'?^ •?ny ? Ccurty f-iL,me Rule " t C. , ? ?r ?.vus amended in :?000rU:?"?'? l','`h Q• i. l?r,a.nce No. ?3 ?? -0^ ac' r--?' the - ,* . an c' ??mer,dn-,,r; on ecember 15, 2004, tho Allegheny County 38-04-OR into law; (c) Ordinance No. 38- t? i? Aie?? wr'y' cc `,? I`'? E'._ ,i.?r c f f 'C (,i _ P:- C 2 ! ?e e!" _.i. J_'J C. C y FL!R i L1-:, l ? abolished e'eclec' Rc?: Cif" ns of Prothon ? c'r,. , C er,c c Ccur?s and R clsLe r cf Ve"lls to the ne,,v!y created appointed office of Director cf Court Records, it is hereby ORDERED, ADJUDGED and DECREED that: (a) effective January 7, 2008, all power and authority previously vested in the elected Row Offices of Prothonotary, Clerk of Courts and Register of Wills under all applicable law, including without limitation, 16 P.S. § 4301, etseq., 20 Pa.C.S,A. § 901, etseq., 42 Pa.C.S.A. § 2731, et seq., and 42 Pa.C.S.A. § 2751, et seq., is now vested in the appointed office of Director of Court Records, pursuant to the Allegheny County Home Rule Charter, as amended; and (b) all documents, orders, instruments, and other papers issued by the Director of the Allegheny County Department of Court Records on or after January 7, 2008, that are printed on forms of the abolished elected offices of Prothonotary, Clerk of Courts and/or Register of Wills, or that bear the signature and/or seal of the individuals who held the offices of Prothonotary, Clerk of Courts and/or Register of Wills immediately prior to the abolition of those offices, shall have the same legal effect as if such documents, orders. instruments and other papers were printed on for ills of tie Depainitnt of Court Records an J`or bear ti-Ie sign_?tu e and'ar seal of the Director of Court Records, until such time as they DI .tor of Court Records provides tl,i3- Ccu?t with ice ? ?0.. .h t "'ll f.?r;-T,c • ?, '. sign .,ai,_:res and seals othhe at;'e?ished erected offices of Frcthenotary, C!er of Coin's nu Register of Wills c? ?c nte4 office Cr 14 7r CQ'?Nlt;? y ?nS.tiQne' ?e y and `?a C? r Said written no, ce +c t`,e CcL,r' be fi;eu r: the cf Cirec;or of Court Records. Office cf Court Records. BY THc CCUnT: JOISERH`'M, JAMI ,P PRESIDENT JUDGE CERTIFIED FROM THE RECORD 90, Qn Proth notary Deputy. ^'l tC Y C :.J O ..,p^ 71 0o r., .1 1:5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERATED RETAIL HOLDINGS, INC. DB/A KAUFMANN'S F/K/A THE MAY DEPARTMENT STORES COMPANY Plaintiff vs. RUTH A HENRY Defendant(s) No. 056- 3ZZ-g Ci V1 ??1'(1? 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 $2,035.50, plus interest, on Mb., 1 20?. I (x) A copy of all documents filed with the Prothono in support the within judgment is/are attached. By: If you have any questions regarding this Notice, please co act the filin party. Date: Amy F. Doyle PW2 / Philip C David R. Galloway #873 onilyn M. :I', i pie #87852 Sarah E. Ehasz #86469 / goo e Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: Ruth A Henry Po Box 81593 Pittsburgh PA 15217 W&A File No. 134718032 122 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 TO 3149 FEDERATED RETAIL HOLDINGS, INC. D/B/A KAUFMANN'S F/K/A THE MAY DEPARTMENT STORES COMPANY Plaintiff VS. RUTH A HENRY Defandant (s ) : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 08-3228 PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $ 2,035.50. (1) Directed to the Sheriff of CUMBERLAND (2) against, RUTH A HENRY PO BOX 81593 Pittsburgh PA 15217 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 RUTH A HENRY Defandant(s) and (B) against, MEMBERS FIRST FCU County, Pennsylvania; Garnishee(s); ,Garnishee(s), as a lis pendens against the real property of the Defandant(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: $ 2,035.50 Interest From: 11/16/2006 To Be Determined At an interest rate of 6% per year Total: $ 2,035.50 Plus costs & interest (total includes post judgment credits). David R" Gallowfy #$17326JI%hilip C. Warholic #863 Sarah E. Ehasz #86469/Ro ert N. Polas, J'r. #'la'1 Amy 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/PABANK FILE # 134718032 4 a z M -N trip SU (}1 ?. -r rr ao cn ohs. w, g' 139 '.-i O WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3228 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FEDERATED RETAIL HOLDINGS, INC., INC., d/b/a KAUFMANN'S, f/k/a THE MAY DEPARTMENT STORES COMPANY, Plaintiff (s) From RUTH A. HENRY, PO Box 81593, Pittsburgh, PA 15217 (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 Road, 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 $16,240.74 L.L. $.50 Interest from 11/16/06 at an interest rate of 6% per year - To be Determined Atty's Comm % Due Prothy $2.00 Atty Paid $116.25 Other Costs Plaintiff Paid Date: 12/16/08 rtis R. L o ono ry (Seal) By: Deputy REQUESTING PARTY: Name PHILIP C. WARHOLIC, 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. 86341 1L3 11 IN THE COURT OF COMMON PLEAS CUMBERLAND FEDERATED RETAIL'HOLDINGS, INC. D/B/A KAUFMANN'S F/K/A THE MAY DEPARTMENT STORES COMPANY Plaintiff VS RUTH A HENRY Defendant (s) TO: MEMBERS FIRST FCU 1000 BRYN MAWR RD CARLISLE PA 17013-1588 COUNTY, PENNSYLVANIA No. 08-3228 CIVIL ACTION - LAW ?nsw,IK? -i?- - - INTERROGATORIES TO GARNISHEE '`,,,-uF'VCL ?t 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. 1L4 INTERROGATORIES TO GARNISHEE DEFENDANT(S) - RUTH A HENRY 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 name and address. no o(co u iA 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. nG Roce '6t 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. no /A CCC U Tnt 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. no acceL, ?-? t 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? i LU Q (c L) C)IJ/1 t 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. ()() a (Y,-() U ,I t 1GJ 1 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. (-? C a CC 0 c_? (/) t- 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). 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). 0 0 ((6) (J V? t 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. David R. Galloly #87326<hilip C. Warholic #- Sarah E. Ehasz #86469/Robert N. Polas, Jr. ! Amy 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 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that lrl 1? he/she is ? ? ?V1 C *1 ' -t041 of (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. (SIGNATU ) (Name) AIM= lstfedetal Credit Union r0 Cai SHERIFF'S RETURN - GARNISHEE CASE NO: 2008-03228 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND FEDERATED RETAIL HOLDINGS INC VS HENRY RUTH A And now JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0019:SS Hours, on the 18th day of December , 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , HENRY RUTH A hands, possession, or control of the within named Garnishee MEMBERS 1ST FCU 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to MARISOL BARBER (ASST. MGR) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION , in the true and made the contents there of known to Her . Sheriff's Costs: Sow t? Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County Sworn and Subscribed to before me this 0 -,/ 1.???ufv8 00 12/19/2008 day of By ep y Sheriff A.D / L/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERATED RETAIL HOLDINGS, INC. DB/A KAUFMAN'S, F/K/A THE MAY DEPARMENT STORES COMPANY Plaintiff NO. 08-3228 CIVIL TERM vs. RUTH A HENRY Defendant CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, MEMBERS FIRST FCU, discontinued, upon payment of your costs only. Respectfully Submitted, Dated: ( 16 vV ? Am F. 2 ilit) C. Warholic #86341 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 MB File No. 134718032 Q o O r? O lope c R-1 c c.. C- .sa ? rn R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. S4 l frs Costs: Advance Costs: 150.00 '', Sheriff's Costs: 86.58 Doug 18.00 63.42 Poundage 1.70 Law Library .50 Refunded on 06/23/09 Prothonotary 2.00 Mileage 4.50 Surcharge 30.00 Levy 20.00 Postage .88 Garnishee 9.00 So Answers, $ 86.58 ? c.???/o?;,.° R. oma§ Kline, Sheriff// ,, By Sharon R. Lantz b ? :b V L I ON 8001 f-Ilt .. Gal •` y , T ? J- ?- yv CT In 7 b 3 0-.t- .7; 7jS/