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HomeMy WebLinkAbout08-35462049792 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 Washington Mutual 3353 Orange Avenue Roanoke, VA 24012 VS. MONIQUE WATSON 341 MAPLE LN CARLISLE PA 17015-7822 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: b$- 3S4(v CNV<< Te-m 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, if available, 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 $2,593.89. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,593.89 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 3/12/2007. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,593.89 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERI I. EINBERG, ESQUIRE JOEL M. L , ESQUIRE Attorney for Plaintiff P01A.DB VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements Name ATLANTIC CREDIT & FINANCE, INC. V. MONIQUE WATSON AFFIDAVIT OF DEBT AND VERIFIED BILL OF PARTICULARS The undersigned being first duly sworn according to law, deposes and says that she is familiar with the policies and practices, as well as the books and records of the Plaintiff with respect to the matters 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 WASHINGTON MUTUAL BANK Account No. 4185860343465403. Said Account was charged off on 10/31/2007 and subsequently sold to Atlantic Credit & Finance, Inc with a balance of $2593.89. 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 Plaintiff's records, the last payment date was3/12/2007 in the amount of $ 200.00. After application of all payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and owing on this indebtedness of $2,593.89. 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: ,/ Amanda Dunbar Authorized Representative Subscribed and sworn before me, April 11, 2008 . Not ic: Cameron Gray THIS COMMUNICATION IS FROM A DEBT COLLECTOR 47-1: _J C =F„ Gordon & Weinberg, P.C.: CGAFF- 3324090 - 0001661 tic A 'la CREDIT & FINANCE It RP 4TED Account Statement PO Box 13386 • Roanoke, VA 24033 5 rc L M., Original Creditor Account Number: 4185860343465403 MONIQUE WATSON 341 MAPLE LN CARLISLE, PA 17015-7822 Original Creditor: WASHINGTON MUTUAL BANK Original Creditor Last Pay Date: 3/12/2007 Original Creditor Last Payment Amount: $ 200.00 Original Creditor Charge Off Date: 10/31/2007 ACF ID Number: 3324090 SSN: XXX-XX-9753 CONFIDENTIAL PROPERTY OF ATLANTIC CREDIT & FINANCE, INC. R 3 ? °O o C c'_ rv w O SHERIFF'S RETURN - REGULAR CASE NO: 2008-03546 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS WATSON MONIQUE SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WATSON MONIQUE the DEFENDANT , at 1210:00 HOURS, on the 14th day of June , 2008 at 341 MAPLE LN CARLISLE, PA 17015-7822 by handing to ROY ETTINGER, HUSBAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 G J?41D? V .00 33.00 Sworn and Subscibed to before me this day So Answers: f R. Thomas Kline 06/16/2008 GORDON & WEINBERG By. (L" ?, ? eputy She ff of A. D. 4. t 2049792 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 Washington Mutual VS. MONIQUE WATSON COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-3546 CIVIL TERM 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 Total: $2,593.89 $2,593.89 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 Washington Mutual and that the last known address of defendant, MONIQUE WATSON, 341 MAPLE LN, CARLISLE PA 17015-7822. 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 4+k_ day of AUQ M4 , 2008 Judgment is entered in favor of the plaintiff(s) ai against defendant(s) by default for want of an answer and damages assessed at the sum of , $2,593.89 as per the above certification. S aKB r thonotary GORDON & WEINBER , P.C. BY: FREDERIC\ I .?WEINBERG, ESQUIRE JOEL M. NK, ESQUIRE Attorney for Plaintiff f 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 2049792 Atlantic Credit & Finance Inc. COURT OF COMMON PLEAS Assignee from Washington Mutual CUMBERLAND COUNTY MONIQUE WATSON TO/PARA Vs. DOCKET NO. : 08-3546 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT MONIQUE WATSON 341 MAPLE LN CARLISLE PA 17015-7822 DATE OF NOTICE/FECHA DEL AVISO: July 7, 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: ?- FREDE WEINBERG, ESQUIRE JOEL/' FLINK, ESQUIRE P10D-2 Cz? ? ? ? t1. ? ter.. NJ `i 4 f 2049792 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 Washington Mutual VS. MONIQUE WATSON COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. TERM : 08-3546 CIVIL 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. /XL Judgment by Default $2,593.89 Money Judgment $ Judgment on Award of Arbitrators$ 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 Id aulti P OTHONOTARY A0&6 ' �r F iLEl;1­0FFICf,,' 2169494 OF 1����E 'PRO T NONOTP`a,R"y GORDON & WEINBERG, P.C. 2013 SEP'23 PPS 2:_00 BY: FREDERIC I . WEINBERG, ESQUIRE CUMBERLAND COUNTY Identification No. : 41360 PENNSYLVANIA JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ATLANTIC CREDIT AND FINANCE COURT OF COMMON PLEAS INC CUMBERLAND COUNTY VS . DOCKET NO. : 2008-3546 MONIQUE WATSON ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the plaintiff in the above-captioned matter. GORDON & WEINBERG, P. C. BY: _ FREDERIC I . W INBERG, ESQUIRE JOEL M. FLI , ESQUIRE Attorney for Plaintiff P012 CERTIFICATION OF SERVICE I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Substitution of Attorney and Entry of Appearance Pursuant to Pa. R.C. P. 1028 (c) (1) , via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDERIC ILWONBERG, ESQUIRE Dated: �,�� I` 2169494 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 E 'P RSI HUNUTAt' « 'r 'M Y --1 PH 3: I GJ CUMBERLAND COUNTY PENNS YLVANIA - ATLANTIC CREDIT AND FINANCE INC - 2727 Franklin Road =SW Roanoke, VA 24014 vs. - --MONIQUE WATSON X341 MAPLE LN DCARLISLE PA 17015-7822 and - Members 1st FCU ---401 East King St Shippensburg, PA 17257 GARNISHEE TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2008-3546 PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) (2) against MONIQUE WATSON against Members 1st FCU defendant(s)and garnishee(s) (3) Amount Due Interest from June 12, 2008 Costs Prothonotary fee Sheriff fee (4) Less: Payments on Account TOTAL << << \\A. optt SD .fid ok 6). S� diS J FREDERIC I. WE LL JOEL M. FLINK ebb Attorney for tqsti-rtp F4A___gosp?-) $2,593.00 $92.53 $.00 BE r , ESQUIRE SQ RE aintiff Uoit ot i/ceJ THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net ATLANTIC CREDIT AND FINANCE INC. Vs. MONIQUE WATSON WRIT OF EXECUTION (Pa R.C.P. 3252) NO 08-3546 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against MONIQUE WATSON, 341 MAPLE LANE, CARLISLE, PA 17015 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of MEMBERS 1sT FCU, 401 EAST KING STREET, SHIPPENSBURG, PA 17257 GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $2,593.00 Interest FROM JUNE 12, 2008 - $92.53 Attorney's Comm. % Attorney Paid $154.50 Date: 5/1/14 (Seal) Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary REQUESTING PARTY: Name : JOEL M. FLINK, ESQUIRE Address: GORDON & WEINBERG, P.C. 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41200 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 '— E D ` /�~�SHERUFF'S OFFICE OF CUMBERLAND COUNTY RonnyRAnderaon Sheriff %,)..tP '�u��0T-,.`� '' ~''~ . D . • Jody SSmith �p'- *^ Chief Deputy Richard VVStewart CUMBERLAND _v Solicitor OpriU,oprwsoHE"/Fp PENNSYLVANIA /LyAN/A Atlantic Credit&Finance Inc. Case Number vs. 2OU8'354G Monique Watson SHERIFF'S RETURN OF SERVICE O505/2O14 11:05 AM -William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1St Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Denise Harman, Manager, 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 May 6, 2014 to Mo ique Watson, 341 Maple Lane, Carlisle, PA 17015-7822. ~/� IAM CLINE, DEPUTY SO ANSWERS, May 06, 2014 RONNY R ANDERSON, SHERIFF (c)CounlySuito Sheriff,Te!iosoft,inc. r -G OON & 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 AND FINANCE INC COURT OF COMMON PLEAS 2727 Franklin Road CUMBERLAND COUNTY C CI SW Roanoke, VA 24014 C:. P "i 3 : rn -;: .r- , MONIQUE WATSON �Y 1''3 -:::-''''---- 341 MAPLE LN -.3 -o c�T CARLISLE PA 17015-7822 vs. DOCKET NO. : 2008-3546 and -" Members 1st FCU i ''` 401 East King St Shippensburg, PA 17257 ��� �,o�� GARNISHEE �/�,/ lcUL U' � INTERROGATORIES IN ATTACHMENT TO: Members 1st FCU - 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 in judgment against you. 1. At the time you were servedor 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? 0.0 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. (�p.,:o,,tiPs& 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(s) had an interest? 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 if so what was the consideration therefore? Qp 6. At any time after you were 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? 7. If you are a bank or other financial institution, at the time you were servedor 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 of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 00 8. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant(s) 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. 9. How much is the value of any property in your possession belonging to the P cc*- Anip.a53 DATED: 11125114 defendant(s)? FREDERIC I WE''NBtRG, ESQUIRE JOEL M. F rNK, ESQUIRE Attorney .r Plaintiff G(7RDON & 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 AND FINANCE INC 2727 Franklin Road SW Roanoke, VA 24014 vs. MONIQUE WATSON 341 MAPLE LN CARLISLE PA 17015-7822 and Members 1st FCU 401 East King St Shippensburg, PA 17257 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2008-3546 iMilgaerr -/Nz. INTERROGATORIES IN ATTACHMENT TO: Members 1st FCU - 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 in judgment against you. 1. At 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? 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. ulef..,,a,„-vicsPNc-,'N-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. '1)p 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? Olp. 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 if so what was the consideration therefore? M •6. At any time after you were 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? 1, 7. 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 of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 00 8. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant(s) 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. OC) 102 How much is the value of any property in your possession belonging to the defendant(s)? �- (s.a5 --1G6 -bc\1c-r‘ 545.E FREDERIC I WE' NBtRG, ESQUIRE JOEL M. FNK, ESQUIRE Attorney .r Plaintiff DATED: 1117_5114 GO DON & WEINBERG, P.C. t'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 AND FINANCE INC 2727 Franklin Road SW Roanoke, VA 24014 vs. MONIQUE WATSON 341 MAPLE LN CARLISLE PA 17015-7822 20/ CUMBERLCOUNTY COURT OF COMMON FPLEA ' 4NI4 LT t r�;; is t3T110/1rC~1:=,i; CUMBERLAND COUNTY DOCKET NO. : 2008-3546 and Members 1st FCU 401 East King St Shippensburg, PA 17257 GARNISHEErs INTERROGATORIES IN ATTACHMENT TO: Members 1st FCU - 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 in judgment against you. 1. At 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? t4 b 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.eN�cA 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. 0 0 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? 0 \ 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 if so what was the consideration therefore? 00 6. At any time after you were 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? 7. 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 of funds in each account, 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(s) 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.. 9. How much is the value of any property in your possession belonging to the defendant(s)? FREDERIC JOEL M. F Attorney DATED: iJ25j l WE'NBERG, ESQUIRE NK, ESQUIRE r Plaintiff 2169494 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 FILED—OFFICE OF Tea -;E P RO THONO TJ i `t Za!1j JUN 27 PM 3: 45 CUMBERLAND COUNTY PENNSYLVANIA ATLANTIC CREDIT AND FINANCE INC vs. MONIQUE WATSON and Members 1st FCU Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2008-3546 PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment against Members 1st FCU, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. BY: P011 FREDERIC I. INBERG, ESQUIRE JOEL M. FL K, ESQUIRE Attorney for Plaintiff auk ickecov°1 )2* 3076n0) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY si 'R0THD#j'::i"i', 2015 JAN -5 Ft's CUMBERLAND COUNT' OFFICE OFME$WEnt PENNSYLVANIA Atlantic Credit & Finance Inc. vs. Monique Watson Case Number 2008-3546 SHERIFF'S RETURN OF SERVICE 05/05/2014 11:05 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Denise Harman, Manager, 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 May 6, 2014 to Monique Watson, 341 Maple Lane, Carlisle, PA 17015-7822. 12/30/2014 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: $89.26 SO ANSWERS, December 30, 2014 RONi' R ANDERSON, SHERIFF o?- Pd eo. 9..asv 04315".? -?-5 tc) CountySuite Sheriff, Teleosoft, Inc. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net ATLANTIC CREDIT AND FINANCE INC. Vs. MONIQUE WATSON WRIT OF EXECUTION (Pa R.C.P. 3252) NO 08-3546 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against MONIQUE WATSON, 341 MAPLE LANE, CARLISLE, PA 17015 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of MEMBERS 1sT FCU, 401 EAST KING STREET, SHIPP.ENSBURG, PA 17257 GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are -directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $2,593.00 Interest FROM JUNE 12, 2008 - $92.53 Attorney's Comm. % Attorney Paid $154.50 Date: 5/1/14 (Seal) REQUESTING PARTY: Name : JOEL M. FLINK, ESQUIRE Address: GORDON & WEINBERG, P.C. 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No, 41200 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs LLJL David D. Buell, Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law TRUE COPY FROM RECORD In Testimony whereof: I here unto set my hand and the seal of said CouJ4.at Carlisle, Pa. This day of , 20 rothono ary 2