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HomeMy WebLinkAbout08-3643 4 GORDON & WEINBERG, F.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 2049829 THIS IS AN ARBITRATION MATTER. DAMAGES HEARING REQUIRED. ASSESSMENT OF Atlantic Credit & Finance Inc. Assignee from Washington Mutual 3353 Orange Avenue Roanoke, VA 24012 VS. BRANDON J MITCHELL 3133 CHESTNUT ST CAMP HILL PA 17011-4529 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : b8- 3(043 0'iv I l- erwt 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 4 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 $2,053.19. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,053.19 but the defendant(s)has failed and refused and still refuses to pay the same or any part P. thereof. 7. Defendant's last payment on account was made on 3/26/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,053.19 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EI ERG, ESQUIRE JOEL M. FL K SQUIRE Attorney fo Plaintiff P01A.DB r OL 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 0 0' MAY9?11-? Name U ATLANTIC CREDIT & FINANCE, INC. p`? V. BRANDON J MITCHELL 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. Plaintiffs principal business consists of purchasing charged off receivables. 2. The Defendant defaulted on WASHINGTON MUTUAL BANK Account No. 4185862662448515. Said Account was charged off on 10/31/2007 and subsequently sold to Atlantic Credit & Finance, Inc with a balance of $2053.19. 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 Plaintiffs records, the last payment date was3/26/2007 in the amount of $ 50.00. After application of all payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and owing on this indebtedness of $2,053.19. 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: Amana Dunbar Authorized Representative %%G ,OF`R'p, •,?,,r tire.;. 4? Subscribed and sworn before me, April 11, 2008. r , o • MSG °! 7 } - v _ r? No blic: Cameron Gray ; o THIS COMMUNICATION IS FROM A DEBT COLLECTOR Gordon & Weinberg, P.C.: CGAFF- 3324086 - 0001661 OiAd tic CREDIT & FINA ACE AFC ATEO PO Box 13386 • Roanoke, VA 24033 Account Statement Original Creditor Account Number: 4185862662448515 BRANDON J MITCHELL 3133 CHESTNUT 11-4529 Original Creditor: WASHINGTON MUTUAL BANK CAMP HILL, PA 17001 Original Creditor Last Pay Date: 3/26/2007 Original Creditor Last Payment Amount: $ 50.00 Original Creditor Charge Off Date: 10/31/2007 ACF ID Number: 3324086 SSN: XXX-XX-2941 CONFIDENTIAL PROPERTY OF ATLANTIC CREDIT & FINANCE, INC. 0 r?3 C= CA C-- -,DAM SHERIFF'S RETURN - REGULAR CASE NO: 2008-03643 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS MITCHELL BRANDON J 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 MITCHELL BRANDON J DEFENDANT the at 0923:00 HOURS, on the 28th day of June , 2008 at 3133 CHESTNUT STREET CAMP HILL, PA 17011-4529 by handing to BRANDON MITCHELL 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 42.00 Affidavit .00 Surcharge 10.00 / 0 7? 0.00 ?./":SIos 9-V 0 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 06/30/2008 GORDON & WEINBERG By: eputy Sherif 0 f A. D. 2049829 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. BRANDON J MITCHELL DOCKET NO. : 08-3643 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: $2,053.19 $2,053.19 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, BRANDON J MITCHELL, 3133 CHESTNUT ST, CAMP HILL PA 17011-4529. 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 Ae' day of 2008 Judgment is entered in favor of the plaintiff and ag nst defendant by default for want of an answer and damages assessed at the sum of $2,053.19 as per the above certification. r thonotary GORDON & WEINBE(R'GG, P.C. BY: / FREDERIC I. EINB RG, ESQUIRE JOEL M. FLI UIRE Attorney for Plaintiff 4 2049829 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. BRANDON J MITCHELL TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-3643 CIVIL TERM NOTICE OF INTENTION TO TARE DEFAULT BRANDON J MITCHELL 3133 CHESTNUT ST CAMP HILL PA 17011-4529 DATE OF NOTICE/FECHA DEL AVISO: July 22, 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: a), FFREDE'k I. WEINBERG, ESQUIRE JO M. FLINK, ESQUIRE P10D-2 q e: N cz:) "n la 1 FT- E' 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 2049829 Atlantic Credit & Finance Inc. Assignee from Washington Mutual VS. BRANDON J MITCHELL COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO TERM NOTICE : 08-3643 CIVIL 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. /X/ Judgment by Default $2,05319 Money Judgment $ Judgment on Award of Arbitrators$ LL 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 is/ dcL? !C . R THONOTARY SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ?a?;r?t'? ct ?:?cmbrrf?h? nFFU: ? ? 1- ` Nl RIFF ,r qy 2009 CiwC -L, F- [' C 9 Edward L Schorpp Solicitor Atlantic Credit & Finance, Inc., Assignee from Washington Mutual Case Number vs. 2008-3643 Brandon J Mitchell SHERIFF'S RETURN OF SERVICE 12/02/2009 09:55 AM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2009 at 0956 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Brandon J. Mitchell , in the hands, possession, or control of the within named garnishee, Citizens Bank, 665 N East Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to John Cappawana, Branch 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 him. The writ of execution and notice to defendant was mailed on December 4, 2009 to Brandon J. Mitchell at 3133 Chestnut Street, Camp Hill, PA 17011. So Answers, R. ehirmoa Kli Fay De ty Sher (c) CountySuite Sheriff. Teleosoft, Irc. 14 or 5-K- S eriff GORDON & WEINBERG, P.C. Fay: FREDERIC I. WEINBERG, ESQUIRE Identification ado.: 41360 JOEL M. FLINK, ESQUIRE Identification Cdo.: 41200 -:001 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. BRANDON J MITCHELL 3133 CHESTNUT ST CAMP H1LL PA 17011--4529 and Citizens Bank 665 North East Street Carlisle PA 17073 GARN:; SHEE 2049829 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-3643 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION 0 THE PROTHONOTARY : Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (_) against BRANDON J MITCHELL defendant(s)and (2) against Citizens Bank garnishee(s) (3) AMOUNT DUE $2,053.19 1NTEREST from Au.gus'.: 28, 2008 $151.89 COSTS * see,,, (4) Less: Payments on Account ( $.00) TOTAL $2,700.A(p FREDERIC I. WE NB RG, ESQUIRE JOEL M. FLINK, SQUIRE Attorney for Plaintiff -ry Rl FD-Cli i 'RUE 2009 NO'S 19 PM I ' 3 5 CU}"i'.,_ 1tJWrY ?a y.,s-n '11C n 70.00 CBF '78. 50 q p 14.00 rr 0 Per fgN`ove? 61 ,50 0& uK? ? req. - a-TY 5'0 j,L e. K,-V Q say 7 2? .Z 3383 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3643 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ATLANTIC CREDIT & FINANCE, INC, Assignee from WASHINGTON MUTUAL, Plaintiff (s) From BRANDON J. MITCHELL, 3133 Chestnut Street, Camp Hill, PA 17011-4529 (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: CITIZENS BANK, 665 North East Street, Carlisle, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2,053.19 Interest from 8/28/08 Atty's Comm % Atty Paid $189.50 Plaintiff Paid Date: 11/19/09 L.L. $.50 Due Prothy $2.00 Other Costs (Seal) REQUESTING PARTY: Name FREDERIC E. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, PC 1001 E. HECTOR STREET, SUITE 2290 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Deputy Supreme Court ID No. 41360 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION NEW CUMBERLAND BORO, Plaintiff VS. MARK/SUANNE MCCONNAUGHEY, Defendant ? Confessed judgment ? Other File No. 2008 - 04592 Amount Due $468.48 Interest 6% from June 19, 2008 Attorney's Comm Costs 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 1996 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue a Writ of Execution in the above-matter to the Sheriff of Cumberland County, for debt, interests and costs, upon the following described property of Defendant (s): Any and all electronic equipment, motor vehicle(s), personal property, cash and other contents of the Defendant located at 207 11th Street, New Cumberland, Pennsylvania, 17070. Date: November 12- , 2009 Andrew C. Sheely, Esquire PA ID 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717-697-7050 717-697-7065 (fax) f. '` I t ^? ?„F £''th 4F ? 7'144 14- NG ?!w, ?3333? S GC S't' 6L PI Co s ?-, 6 6 ?p cL e WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-4592 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NEW CUMBERLAND BOROUGH Plaintiff (s) From MARK MCCONNAUGHEY AND SUANNE MCCONNAUGHEY (1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL ELECTRONIC EQUIPMENT, MOTOR VEHICLE(S), PERSONAL PROPERTY, CASH AND OTHER CONTENTS OF THE DEFENDANT LOCATED AT 207 11TH STREET, NEW CUMBERLAND, PENNSYLVANIA, 17070.. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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$468.48 Interest 6% FROM JUNE 19, 2008 Atty's Comm % Atty Paid Plaintiff Paid $165.85 Date: November 12, 2009 (Seal) L.L. Due Prothy $2.00 Other Costs S C is R. Long, Prothonotary By: Deputy REQUESTING PARTY: Name ANDREW C. SHEELY, ESQUIRE Address: 127 S. MARKET STREET, P.O. BOX 95, MECHANICSBURG, PA 17055 Attorney for: PLAINTIFF Telephone: 717-697-7050 Supreme Court ID No. 62469 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION ATLANTIC CREDIT & FINANCE INC Assignee from WASHINGTON MUTUAL Plaintiff(s), VS. BRANDON J. MITCHELL Defendant(s), VS. Citizens Bank of Pennsylvania, Garnishee. DOCKET NO.: 08-3643 CIVIL TERM Answers to Interrogatories Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA I.D. No. 62378 Stradley, Ronon, Stevens & Young Great Valley Corporate Center 30 Valley Stream Parkway Malvern, PA 19355-1481 (484) 323-1351 (610) 640-1965 fax ndeenis@stradley.com www.stradley.com Kyy G a -ri ?.'.. r .?? 1 ??} r T M } "rFn xJ?= 'rn C,..y l.fJ ? i r-n - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION ATLANTIC CREDIT & FINANCE INC. Assignee from WASHINGTON MUTUAL Plaintiff(s), VS. BRANDON J. MITCHELL Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. DOCKET NO.: 08-3643 ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of PA, states that with the information provided it maintains no deposit accounts in the name of the Defendant, BRANDON J. MITCHELL. Therefore, no funds are being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Christina Graham who being duly sworn according to the law deposes and says that she is an Operations Clerk, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. ?)w Christina Graham .r1VIVl V V V L-",4 9nce Notarial Seal V • D. Moungoy, Notary pubj- City ycO(Pi. - 'gh, Allegheny County I my corn"'. Ex Y _._ t? es May 15, p Sworn and subscribed before me this day of ???"'1 , 2010. Certificate of Service I, Christina Graham, hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this day of 2010. FREDERICK I. WEINBERG 1001 E. HECTOR STREET SUITE 220 CONSHOHOCKEN, PA 19428 stina Graham 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. BRANDON J MITCHELL and Citizens Bank Garnishee 2049829 _i.. -n 71 IT, -? -Ir -? -. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-3643 CIVIL TERM PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant's bank account with Citizens Bank, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. Z/?? BY: FREDERIC I. W IN RG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff Poll $g,oo Po A'm/ GG-' lot S L3 RT'? d37 8a,7 ~.~ Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 201 Q Ji! - ~ I~:`~~ ~ ~ ~ ~~~,,;;r Ott ~ uuibr~*~~~~~ QF FiGE ,..,~ Tr~E ~rGRIFF Atlantic Credit & Finance, Inc., Assignee from Washington Mutual I Case Number vs. Brandon J Mitchell 2008-3643 CiU1Y'r ' 'Ji`a t ~ SHERIFF'S RETURN OF SERVICE 12/02/2009 09:55 AM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2009 at 0956 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Brandon J. Mitchell , in the hands, possession, or control of the within named garnishee, Citizens Bank, 665 N East Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to John Cappawana, Branch 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 him. The writ of execution and notice to defendant was mailed on December 4, 2009 to Brandon J. Mitchell at 3133 Chestnut Street, Camp Hill, PA 17011. 07/07/2010 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: $87.94 July 07, 2010 SO ANSWERS, a RON R ANDERSON, SHERIFF ,~ B _ ___ Sharon R. Lantz _.~~ ~ ~ ,ems a~s'~~ ~ (c) CountySuite Shei~ff. Teleosoft, Inc_