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HomeMy WebLinkAbout08-3581z J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 ASSET ACCEPTANCE, LLC, Assignee of Home Depot/Citibank and Assignee of GE Capital- Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L.KUHN 151 Oak Flat Road Newville, PA 17241 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS PRAECIPE Kindly docket the attached Judgment in the amount of $4,319.76 in favor of Plaintiff, Asset Acceptance, LLC, Assignee of Home Depot/ Citibank and Assignee of GE Capital- Walmart, and against the Defendant, Mervin L. Kuhn, for execution purposes only. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA mini iNTv nF• Map. DW. W: 09-3-02 LIM Name: Hm. V=VX= CO$=CZ PO Sm iss 27 K BIG SPBISQ JLV= xzwvxI.L=, PJ1 Tabph w: (717) 776-3187 17241 JLrlO?! "It PL nVTXNT s ST a. IMTSM 24 BAY PLZ J scorn tlatTsci f PC GLXII NILLS, PA 19342 THIS IS TO NOTIFY YOU THAT: Judgment: DIQAAVLT `UDC PLT! y0 700 V6 , ya 7006 y(, NOTICE OF JUDGM NTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 5JORT IL LLC, 24 =sage: PLaaa .T SCOTT IMTRW XNQ LOLM KXLLS, PJL 19342 J VS. DEFENDANT: NAME and ADDRESS I=, JUMVI! L 1 131 OAK PLAT ROJO M MYILLZ, PA 17241 L J Docket No.: CP-0000166-07 Date Filed: 11/13/07 V (Date of Judgment) 12/19/07 © Judgment was entered for. (Name) ASSET LLCI © Judgment was entered against: (Name) XOM, 11aL'SY]? L in the amount of It 4.319.7} F1 Defendants are jointly and severally liable. ? Damages will be assessed"on Date & Time This case dismissed without prejudice. 17 Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease Amount of Judgment $ 4.17 6.91 Judgment Costs $?i3 Interest on Judgment $? .? Attorney Fees Total $ 4,319.76 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 RLWG A NOTICE OF APPEAL WITH THE PROTH N CTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CHYIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT 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 of IBeUED BY THE MAGISTERIAL DISTRICT JUDGE . UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUrX; WNT 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. Date 7J,", IF rial District I certify that this is a true and rrect copy of thil rd of the proceedings Containing the judgment. Date ` Magisterial District Judge My commission expires first Monday of January, 2012 STEAL AOPC 315-07 DM PRXN 12/20/07 4:29:00 PS Ili Ric a ? 1 r t? ?- -?ra na `? C- J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff ASSET ACCEPTANCE, LLC, Assignee of Home Depot/Citibank and Assignee of GE Capital- Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L.KUHN 151 Oak Flat Road Newville, PA 17241 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval 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 as amended; that Defendant, Mervin L. Kuhn, is over eighteen (18) years of age, and resides at 151 Oak Flat Road, Newville, Pennsylvania 17241. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF 97u-?-/ 2008. NOTAR COMm64 EALTH OF PENNSYLVAN NOTARIAL SEAL LAURA ANN MALONEY Notary Public Concord Twp., Delaware County My Commission Expires April 29, 2010 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff ASSET ACCEPTANCE, LLC, Assignee of Home Depot/Citibank and Assignee of GE Capital- Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L.KUHN 151 Oak Flat Road Newville, PA 17241 AFFIDAVIT CUMBERLAND COUNTY COURT OF COMMON PLEAS I, J. Scott Watson, Esquire, hereby certifies that the debt in the above matter is valid, enforceable and unsatisfied to date. SWORN TO AND SUBSCRIBED -9c v;t_ BEFORE ME THISO DAY OF 2008. OTARY/ :OMMONWEALTH OF PENNSYLVAh NOTARIAL SEAL LAURA ANN MALONEY Notary Public my Concord Twp., Delaware County y Commission EYnires April 29, 2010 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff w J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff ASSET ACCEPTANCE, LLC, Assignee of Home Depot/Citibank and Assignee of GE Capital- Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L.KUHN 151 Oak Flat Road Newville, PA 17241 AFFIDAVIT CUMBERLAND COUNTY COURT OF COMMON PLEAS I, J. Scott Watson, Esquire hereby certifies that the name and the last known address of Plaintiff and Defendant are as stated below: Plaintiff: Asset Acceptance, LLC Assignee of Home Depot/ Citibank And Assignee of GE Capital- Lowe's P.O. Box 2041 Warren, MI 48090 Defendant: Mervin L.Kuhn 151 Oak Flat Road Newville, PA 17241 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF 2008. NOTARY-` COMb1oNWEALTH of PEN14SyLVAN1 NOTARIAL SEAL Public LAURA ANN MALONEY Notary Concord Twp., Dee Count t0 ?ssion Expires April M= J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff ASSET ACCEPTANCE, LLC, Assignee of Home Depot/Citibank and Assignee of GE Capital- Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L.KUHN 151 Oak Flat Road Newville, PA 17241 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NO APPEAL I, J. Scott Watson, Esquire, hereby certifies that the District Court judgement in the above matter was not appealed into a higher court to date. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED /j BEFORE ME THIS e7V OF ')V?U/ 2008. NOTARY COMMONWEALTH OF PENNSYLVAN NOTARIAL SEAL LAURA ANN MALONEY Notary Public Concord Twp., Delaware County My Commission Expires April 29, 2010 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Mervin L. Kuhn 151 Oak Flat Road Newville, PA 17241 ASSET ACCEPTANCE, LLC, CUMBERLAND COUNTY Assignee of Home Depot/Citibank and COURT OF COMMON PLEAS Assignee of GE Capital- Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L.KUHN 151 Oak Flat Road Newville, PA 17241 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. PR THONO JUDGMENT BY DEFAULT X MONEY JUDGMENT JUDGMENT IN REPLEVIN JUDGMENT FOR POSSESSION If you have any questions concerning this Judgment, please call J. Scott Watson, Esquire at 610-358-9600. CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Asset Acceptance, LLC Assignee of Home Depot/Citibm* and Assignee of GE Capital-LoWe'S . P.O. Box 2041, Warren, MI 48090 Vs. MMUN L. KUHN, SSN XXX-XX-8339 151 Oak Flat Road Newsville, PA 17241 and Members First F.C.U., Garnishee 1166 Walnut Bottom Road, Carlisle, ( ) Confessed Judgment (X ) Other File No. 08-3581 Amount Due 4,319.76 Interest 151.19 Atty's Comm Costs PA 17013 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) Checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee belonging to. the Defendant at Members First F.C.U., 1166 Walnut Bottom Road, Carlisle, PA 17013 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Checking accounts savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee belonging to and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date Signature: Print Name: Address: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA J. Scott Watson, Esquire Attorney for: Telephone: Supreme Court ID No.: 24 Regency Plaza Glen Mills; PA 19342 Plaintiff 610-358-9600 41060 (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. P# i W t O 0 1 cis R? v - 0 C T?om' E . 1 D D C: N C= GO C) -rr s to (3 q --s rn c? M 0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ASSET ACCEPTANCE, LLC CUMBERLAND COUNTY Assignee of Home Depot/Citibank and COURT OF COMMON PLEAS Assignee of GE Capital-Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L. KUHN 151 Oak Flat Road Newsville, PA 17241 S.S.N. XXX-XX-8339 and MEMBERS FIRST F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 NO. 08-3581 WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. If you wish to exercise your rights, you must act promptly. Exempt Propertv. The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of $300.00. There are other exemptions which may be applicable to you. Attached is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have any exemption, you should do the following promptly: (1) Fill out the attached exemption claim form and demand for a prompt hearing; (2) Deliver the form or mail it to the Sheriffs Office at the address noted. You should come to court ready to explain your exemption. If you do not choose to come to court and prove your exemption, you may lose some of your property. Property Belonging to Another Person. If there is a property at your residence (or in your bank account) that belongs to another person or that you own with another person, you should notify that person so that he/she can file a Property Claim or other legal papers with the Sheriff s Office to prevent his/her property from being taken or sold at Sheriff s Sale to satisfy your debt. See enclosed forms. 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 ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 COUNTY BAR LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 COUNTY BAR f MONEY JUDGMENT ASSET ACCEPTANCE, LLC Assignee of Home Depot/Citibank and Assignee of GE Capital-Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L. KUHN 151 Oak Flat Road Newsville, PA 17241 S.S.N. XXX-XX-8339 and MEMBERS FIRST F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 08-3581 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption; 2. Bibles, school books, sewing machines, uniforms and equipment; 3. Certain 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. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ASSET ACCEPTANCE, LLC CUMBERLAND COUNTY Assignee of Home Depot/Citibank and COURT OF COMMON PLEAS Assignee of GE Capital-Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L. KUHN 151 Oak Flat Road Newsville, PA 17241 S.S.N. XXX-XX-8339 and MEMBERS FIRST F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 NO. 08-3581 CLAIM FOR EXEMPTION TO THE SHERIFF: I, the above-named defendant, claim exemption of property from levy or attachment: (1) From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be [ ] (1) set aside in kind (specify property to be set aside in kind; [ ] (11) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption (specify property and basis of exemption: (2) From my property which is in the possession of a third party, I claim the following exemptions: (a) my $300.00 statutory exemption: [ ] in cash; [ ] in kind (specify property): ; (b) Social Security benefits on deposit in the amount of: $ ; (c) other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relative to unworn falsification to authorities. Date: Defendant: THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY, CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA 17013-3387. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ASSET ACCEPTANCE, LLC CUMBERLAND COUNTY Assignee of Home Depot/Citibank and COURT OF COMMON PLEAS Assignee of GE Capital-Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L. KUHN 151 Oak Flat Road Newsville, PA 17241 S.S.N. XXX-XX-8339 and MEMBERS FIRST F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 NO. 08-3581 NOTICE TO CO-OWNER OF ATTACHMENT OF PROPERTY The bank account or other property that you own with the defendant, Mervin L. Kuhn, has been attached by plaintiff, Asset Acceptance, LLC, to satisfy a judgment obtained by the plaintiff against the defendant. Your money or property may soon be taken even though you owe nothing to the plaintiff. If some of the funds in the account or some of the property held by the garnishee, Members First F.C.U., belongs to you, you should contact the bank or garnishee to see if it is defending your funds or property against garnishment. If the bank or garnishee is not defending against garnishment of your property, you can prevent garnishment by filing a Petition with the Sheriff. To protect your funds or property,.you should complete the attached Petition to Intervene,. Stay and Set Aside Writ of Execution as to Non-Judgment Debtor Property and file it in the Office of the Sheriff of Cumberland County, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pa 17013-3387, within fifteen (15) days after the date of this Notice. For additional information, you may call the Sheriffs Office at (717) 240-6390. 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 COUNTY BAR COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ASSET ACCEPTANCE, LLC Assignee of Home Depot/Citibank and Assignee of GE Capital-Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L. KUHN 151 Oak Flat Road Newsville, PA 17241 S.S.N. XXX-XX-8339 and MEMBERS FIRST F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 08-3581 PETITION TO INTERVENE, STAY AND SET ASIDE WRIT OF EXECUTION AS TO NON-JUDGMENT DEBTOR PROPERTY This Petition respectfully represents: 1. I, , the Petitioner, am a party in interest and hereby move to intervene in this garnishment proceeding pursuant to Pa. R. Civ. P. Nos. 3121 and 2326 et seq. 2. The plaintiff has attached personal property belonging to me currently in possession of the garnishee. 3. This attached property consists of: [ ] money held in a bank account held in common or jointly with the defendant; [ ] other (specify) 4. The Writ of Execution must be stayed and set aside as to my property because the plaintiff does not have the legal right to attach and/or garnish property other than that belonging to the judgment debtor in this matter. 5. I verify that the foregoing statements of fact are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4944 relating to unsworn falsifications to authorities. Date: Petitioner COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ASSET ACCEPTANCE, LLC Assignee of Home Depot/Citibank and Assignee of GE Capital-Lowe's P.O. Box 2041 Warren, MI 48090 V. MERVIN L. KUHN 151 Oak Flat Road Newsville, PA 17241 S.S.N. XXX-XX-8339 and MEMBERS FIRST F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 08-3581 APPLICATION TO PROCEED IN FORMA PAUPERIS (PROPERTY CLAIM/PETITION TO INTERVENE, STAY AND SET ASIDE WRIT OF EXECUTION) TO THE SHERIFF: 1. My personal property is subject to levy or attachment due to a judgment against another person. 2. Because of my financial condition, I am unable to pay the fees and costs of filing my Property Claim form/Petition to Intervene, Stay and Set Aside Writ of Execution, and to defend my property interests. 3. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of this litigation. I understand that I have a continuing obligation to inform the Court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 4. I verify that the information disclosed on this Application and the attached Financial Statement are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsifications to authorities. Date: Applicant (a) Name _ Address (b) (c) (d) (e) FINANCIAL STATEMENT Social Security Number Employment If you are presently employed, state: Employer Address Salary or wages per month Type of Work If you are presently unemployed, state: Date of last employment Salary or wages per month Type of work Other Income within the Past Twelve Months Business or profession Other self-employment Interest Pension and Annuities Social Security Benefits Disability Payments Unemployment Compensation Worker's Compensation Public Assistance Other Contributions to Household Support (Wife)(Husband)Name If your(wife)(husband) is employed, state: Employer Salary or wages per month Type of work Contributions from Children Contributions from Parents Property Owned Cash (f) (g) Checking Account Certificates of Deposit Real Estate (including home) Savings Account Motor Vehicle Make Cost Year Amount Owed Stocks, Bonds Other Debts and Obligations: Mortgages Rent Loans Other Persons Dependent Upon You for Support (Wife)(Husband)Name Children, if any: Name Age Name Age Other Persons: Name Age Name Age Dividends Support Payments Other WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3581 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSET ACCEPTANCE, LLC Assignee of HOME DEPOT/CITIBANK and Assignee of GE CAPITAL - LOWE'S, Plaintiff (s) From MERVIN L. KUHN, 151 Oak Flat Road, Newsville, PA 17241 (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,1166 Walnut Bottom Rad, Carlisle, PA 17013 Checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee belonging to the Defendant. and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,319.76 L.L. $.50 Interest -- $151.19 Atty's Comm % Atty Paid $54.25 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 9/10/08 (Seal) is R. Lon ary By: Deputy REQUESTING PARTY: Name J. SCOTT WATSON, ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-358-9600 Supreme Court ID No. 41060 SHERIFF'S RETURN - GARNISHEE CASE NO: 2008-03581 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND ASSET ACCEPTANCE LLC VS KUHN MERVIN L And now MARK CONKLIN ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:15 Hours, on the 16th day of September, 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT KUHN MERVIN L in the hands, possession, or control of the within named Garnishee MEMBERS FIRST FCU 1166 WALNUT BOTTOM RD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BRIAN PETERS (BRANCH MANAGER0 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 His . Sheriff's Costs: So answers: Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .0000 911g10Y 09/17/2008 ow -7 Sworn and Subscribed to before me this day of By puty Sheriff A.D qe -w *11 Ur"Icccol& J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 ASSET ACCEPTANCE, LLC, Assignee of Home Depot/Citibank and Assignee of GE Capital- Lowe's V. MERVIN L.KUHN TO THE PROTHONOTARY: Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 08-3581 Kindly mark the attachment against the Garnishee, Members First F.C.U., discontinued upon payment of your costs only. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff kl ? Q ? ? ? p O r v -o n r a w ,t } 27 r-r.' a...' d Thomas Kline, Sheriff, who being duly sworn according to law, states this rit is returned ABANDONED, no action taken in six months. riffs Costs: Advance Costs: 150.00 86.19 UWcketing 18.00 63.81 Poundage 1.69 Advertising Refunded on 11/05/08 Law Library .50 Prothonotary 2.00 Milage 5.00 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 So Answers 86.19 /2.la ti/o 8 9-- ?i?r?Ci?i.?! ,,.1? c R. T o s Kline, Sheriff w By G> - 7 C42.44Y3L .2% Y03 sr- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3581 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSET ACCEPTANCE, LLC Assignee of HOME DEPOT/CITIBANK and Assignee of GE CAPITAL - LOWE'S, Plaintiff (s) From MERVIN L. KUHN, 151 Oak Flat Road, Newsville, PA 17241 (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, 1166 Walnut Bottom Rad, Carlisle, PA 17013 Checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee belonging to the Defendant. 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 $4,319.76 Interest -- $151.19 Atty's Comm % Atty Paid $54.25 Plaintiff Paid Date: 9/10/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs rtis R. Long, Pro By: Deputy REQUESTING PARTY: Name J. SCOTT WATSON, ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-358-9600 Supreme Court ID No. 41060 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Asset Acceptance, LLC Assignee of Home Depot/Citibank and Assignee of GE Capital-low's P.O. Box 2041, Warren, MI 48090 VS. Mervin L. Kuhn, SSN XXX-XX-8339 151 Oak Flat Road, Newsville, PA 17241 and Members First F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 TO THE PROTHONOTARY OF THE SAID COURT: ( ) Confessed Judgment : ( X ) Other - Bank Attachment File No. 08-3581 Amount Due $4,319.76 Interest to 4/19/09 - $345.58 Atty's Comm Costs The undersigned hereby certifies that the below doe's "not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it.does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland for debt, interest and costs, upon the following described property of the defendant(s) County, All checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee belonging to the Defendant at Members First F.C.U., 1166 Walnut Bottom Road Carlisle, PA 17013 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) all checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee, belonging and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date Signature: Print Name: Address: J. Scott Watson, Esquire 24 Regency Plaza Glen Mills. PA 19342 Attorney for: Plaintiff Telephone: 618:358-9600 Supreme Court ID No.: 41060 (over) (S ,.: T1 i `Y ??. 2609 t°i r 2 Notes: If real property, supply six Q ",of despriptiop. fcluding improvements and an original and copy of affidavit of ownership (PaR.C.P.talr°? j If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. a4. So PD ATty s(j.lq 0,8F al. AS $I aq. SO 110. 4#4 - Pb AlTy #a .m bue 0.0 0*.* LA--)f,,+ of E?, Jar WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3581 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSET ACCEPTANCE, LLC, Assignee of HOME DEPOT/CITIBANK and Assignee of GE CAPITAL-LOWE'S, Plaintiff (s) From MERVIN L. KUHN,151 Oak Flat Road, Newville, PA 17241 (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 F.C.U., 1166 Walnut Bottom Road, Carlisle, PA 17013 All checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee belonging to the Defendant at Members First F.C.U., 1166 Walnut Bottom Road, 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 $4,319.76 Interest to 4/19/09 -- $345.58 Atty's Comm % Atty Paid $170.44 Plaintiff Paid Date: 5/22/09 L.L. Due Prothy $2.00 Other Costs CZtis R. Lon of (Seal) By: Deputy REQUESTING PARTY: Name J. SCOTT WATSON, ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-358-9600 Supreme Court ID No. 41060 Sheriffs Office of Cumberland County R Thomas Kline 0*01T of Eu"tht.1 Edward L Schorpp Sheri' r Solicitor Ronny R Anderson Jody S Smith Chief Deputy oIIF CE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/28/2009 09:20 AM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on May 28, 2009 at 0920 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Mervin L. Kuhn , in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Christopher Birch, Customer Service Representative personally three true and attested copies of the writ of execution and three copies of writ of execution notice and made the contents there of known to him/her. No interrogatories were served as none were received from plaintiffs attorney. A copy of the writ of execution and writ of execution notice were mailed to the defendant on 05-29-09 2008-3581 Asset Acceptance LLC vs Mervin L. Kuhn So rhomas r , 1/1 R. Kline, Sheriff By eputy Sheriff r4 ? £.- - a rv J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 VO-70 O 070&f Attorney for Plaintiff ASSET ACCEPTANCE, LLC, Assignee of Home Depot/Citibank and Assignee of GE Capital- Lowe's CUMBERLAND COUNTY COURT OF COMMON PLEAS V. MERVIN L. KUHN NUMBER 08-3581 ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, Member's First F.C.U., discontinued upon payment of your costs only. 7,11- --11 5'-7- -? J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff F1lr=?C TAP' of vi P-,.- All Z0o9 JUN -9 AM 8' 04 PD???LJSyLVA IA $8. co PC) 1%1" U'K 49416 l SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor Asset Acceptance LLC, Assignee of Home Depot/Citibank and Assignee of Number vs. I Case 2008-3581 Mervin L Kuhn SHERIFF'S RETURN OF SERVICE 05/28/2009 09:20 AM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on May 28, 2009 at 0920 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Mervin L. Kuhn , in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Christopher Birch, Customer Service Representative personally three true and attested copies of the writ of execution and three copies of writ of execution notice and made the contents there of known to him/her. No interrogatories were served as none were received from plaintiffs attorney. A copy of the writ of execution and writ of execution notice were mailed to the defendant on 05-29-09 04/08/2010 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: $86.07 SO ANSWERS, April 08, 2010 RON R ANDERSON, SHERIFF } f , By 4nar R. L antz RZO oyo2.8? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3581 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSET ACCEPTANCE, LLC, Assignee of HOME DEPOT/CITIBANK and Assignee of GE CAPITAL-LOWE'S, Plaintiff (s) From MERVIN L. KUHN, 151 Oak Flat Road, Newville, PA 17241 (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 F.C.U., 1166 Walnut Bottom Road, Carlisle, PA 17013 All checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee belonging to the Defendant at Members First F.C.U., 1166 Walnut Bottom Road, 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 $4,319.76 Interest to 4/19/09 -- $345.58 Atty's Comm % Atty Paid $170.44 Plaintiff Paid Date: 5/22/09 (Seal) L.L. Due Prothy $2.00 Other Costs 1 7, k5?k . C rtis R. Lon of ry By: Deputy REQUESTING PARTY: Name J. SCOTT WATSON, ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-358-9600 Supreme Court ID No. 41060