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Home My WebLink About08-3901t 1 ` Our File No.: 165462 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CITIBANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. BOBBY J MCMILLEN 106 REGENCY WOODS NORTH CARLISLE, PA 17013-9065 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0X, 3901 eLj?,-J ? 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 judgment 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. 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 A It APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.# 38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CITIBANK c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0,F - 3 9 01 7?:, BOBBY J MCMILLEN 106 REGENCY WOODS NORTH CARLISLE, PA 17013-9065 Defendant. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CITIBANK c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are BOBBY J MCMILLEN, an adult individual residing at 106 REGENCY WOODS NORTH CARLISLE, PA 17013-9065. 3. Plaintiff, ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CITIBANK, is the Assignee and Successor in Interest of Account #6011766908202120; and said account was issued to Defendant(s) by CITIBANK, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $3,509.40. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,509.40 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASS CIATES, P.C. ff Attorney, fo 1 t A Law Firm Enaag in t C ollecti6 BY: David J. Dated: 6/23/2008 Our File No.: 165462 . ti VERIFICATION David J. Apothaker, EM.. hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsWQln falsification to authorities. David J. ake Attorney for lainti DATE: 6/23/2008 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CITIBANK BOBBY J MCMILLEN 106 REGENCY WOODS NORTH CARLISLE, PA 17013-9065 STATEMENT OF ACCOUNT Debtor's Name: BOBBY J MCMILLEN Account Number: 6011766908202120 Original Creditor: CITIBANK Balance Due: $3,509.40 Our File No.: 165462 EXHIBIT "A" hip? SHERIFF'S RETURN - REGULAR CASE NO: 2008-03901 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS MCMILLEN BOBBY J TIMOTNY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE MCMILLEN BOBBY J the was served upon DEFENDANT at 2056:00 HOURS, on the 8th day of July , 2008 at 106 REGENCY WOODS NORTH CARLISLE, PA 17013-9065 CHAONTEL RHOADES, GIRLFRIEND by handing to ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.00 Affidavit .00 Surcharge 10.00 .00 35.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 07/09/2008 APOTHAKER & ASSOCIATES By: ? Duty S-Yieri. A.D. Our File No.: 165462 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CITIBANK Plaintiff, vs. BOBBY J MCMILLEN Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3901 ) Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, BOBBY J MCMILLEN, in the default of an Answer, in the amount of $3,752.87 computed as follows: Amount claimed in complaint: $3,509.40 Amount Paid: - $(0.00) Interest from June 23, 2008 to 03/20/09 at the legal interest rate of 6.000 per annum $129.97 Attorney fees $0.00 TOTAL $3,639.37 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, BOBBY J MCMILLEN, last know address is 106 REGENCY WOODS NORTH CARLISLE, PA 17013-9065. APOTHAKE AS OCIATES, P.C. Atto eys f Plaintiff A Law Firm naafi in Debt Collection By: Dated: 3/20/2009 i Our File No.: 165462 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CITIBANK VS. Plaintiff, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3901 BOBBY J MCMILLEN Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 106 REGENCY WOODS NORTH CARLISLE, PA 17013-9065. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if the Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David J.\ Attorney Data Center, located at 1600 Wilson ) is/are in any branch of the military. Data Center has sent back our inquiry The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. i • ? 3 v Dqmtment of Dalme Itwfower Dots Ceuta T?ll ilwy St*w Report Pa aaat to the Serviceuumbcra f'iW R* TAO WAR-20-2009 135726 TJpoas seaaarl iqg the iaaCnrmstioat daft baairs ofdae Dept of D4%se Maa>powot Data Cw*w, baurad on th *fta aaskon d"t you prow 4ed, die above is tlrc a arerrt status ofthe ind? w to at br mches ofdie M t wy- Mary lad. Snam*-lam, Director I;aeputment GeDefime - MOPOwer Do" Ce rter° 1600 Wbft mod., Smite 400 Arlagtw VA 22209-2593 The DeEa; w blx4mvra D" Center (DIC)C) is an or n of rise Deporkned ofl nse that misintains the Defime Earcliaauent and 140*y Reporting Systese (D S) database wbeh w the offieW sowre of data on ehoft for amagway medical care and other e: systems. ThtDepi, of UeI:Rroaagly supportr the ddoa+emnens bftae Slavs RddAct C50 USCS App+aa 541 et nqj (SCRA) OoamMy she SoWiia`rr' sad Ssiors` Cry RelefAcl of IMO. DMDC has issued bwdreds ofthaadsamds of 'does not poems nary scion raton indicating that tare in&rAW a e+am* on active responses aed has eapedenced a smA error rue. In dw area the m&ndual rtl necced above, or any Bsstily memba, firoen,4 or represesitdiive asserts in sap mamner that the individ W is on wtiae duty, or is o&erwisae end&d to the proms *(the SCRA, you we seraaa* encowr apd to obtain 6utb er vera&sion oftbe person's um duty styes by comacdog drat persodr Some ma do `defiesel ink ml URL proadad Wow. Tyoas have ewlence the person is on setift-fatty and you Id to obtain dais ad&wA 1 Servsee veti6catiox proviaioms ofdre SCRA may be invoked spine you. If you obtain f r information about dw Pam ( e g. an SM. mgxoved agcy of DOB. a middle ram). You can rubuie your regtst min st this Web site and we wil pro*" a sew certificate for dhat query. Ttrs response rede!cts o urasat awe duty status only. For historical in formation, phase comet the 1!Witrry Seme SCRA posts- of-comet See:. WARL+iIl+TG, This casticape provided baased on as and Social Saac%* number (SSN ) provided by dae requester. Provkhng as erroncow amw or SSW wil assess an wroneoas ceri&aate bo be pros ided 1taFarrll):' • SHERIFF'S RETURN - REGULAR t ASE NO 2008-03901 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS MCMILLEN BOBBY J TIMOTNY REITZ 1 f t 17 JUL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvana, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MCMILLEN BOBBY J the DEFENDANT at 2056:00 HOURS, on the 8th day of Judy , 2008 at 106 REGENCY WOODS NORTH CARLISLE, PA 17013-9055 by handing to CHAtONTEL RHOADES, GIRLFRIEND, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sherif'f's Costs: Docketing 18.00 service 7.00 Affidavit .00 Surcharge 10.00 .00 35.06 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 07/09/2008 APOTHARER & ASSOCIATES By: D ty SfierifX A.D. = 165462 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ATLANTIC CREDIT & FINANCE INC. ASSIGNEE ) COURT OF COMMON PLEAS FROM CITIBANK ) CUMBERLAND COUNTY VS. ) NO. 08-3901 BOBBY J MCMILLEN ) To: BOBBY J MCMILLEN 106 REGENCY WOODS NORTH CARLISLE, PA 17013-9065 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: August 08, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY 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 PAPFA 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 NFORMATION 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR S DAVID J. AP THAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 f ?? D ra 3" w:+ CI'S _ i. s_ !"t ;Fa :?7 M A OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: BOBBY J MCMILLEN 106 REGENCY WOODS NORTH CARLISLE, PA 17013-9065 ATLANTIC CREDIT & FINANCE ) INC. ASSIGNEE FROM CITIBANK ) Plaintiff, ) VS. ) BOBBY J MCMILLEN ) Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3901 Civil Action NOTICE Pursuant to Rule 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. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN 4!?q4 JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION - JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esg, at this telephone number: 215-634-8920 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan I.D. No. 47437 436 Seventh Avenue, 1400 Koppers Bldg Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9412051 2012 FEB -3 AM 11: 36 Attorney for PI??>?(?L ANC COUNTY PEA NRNSYLVANIA ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM CITIBANK Plaintiff vs. CUMBERLAND County Court of Common Pleas No.: 08-3901 BOBBY J MCMILLEN Defendant(s) PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of the Plaintiff in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By 14 in William T. 4PIntiff Attorney fo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT&FINANCE INC. ASSIGNEE FROM CITIBANK Plaintiff o -a a w " vs. Civil Action No. 08-3901 Mm C/) BOBBY J MCMILLEN o lD I?e C,y WS °`-wNn o Defendant(s) n_ `<1< �1 OI 3 D C �' o�. �.A; �� not 3 C-, --) MEMBERS 1STFCU I (- �rA RO 1 �w�tS�C n� o � Garnishee(s) �! PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... I. directed to the Sheriff of CUMBERLAND County: 2. against BOBBY J MCMILLEN , Defendant 3. against MEMBERS 1 ST FCU, , , Garnishee 4. Judgment Amount $ $3,639.37 Less Payments/credits received $ $710.99 -'0 at Interest $ $330.71 Costs $ SUBTOTAL: $ $3,259.09 Costs(to be added by Prothonotary): $ WELTMAN, WEINBERG& REIS CO., L.P.A. By: William T. Molczan,Esquire PA I.D. #47437 WELTMAN, WEINBERG &REIS CO.,L.P.A. VV" 1400 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 . 00 � (412)434-7955 So ash � Ilagoa�s n S Sl W R No. 9412051 ,r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT&FINANCE INC. ASSIGNEE FROM CITIBANK Plaintiff No. 08-3901 vs. PRAECIPE FOR WRIT OF EXECUTION {BANK ATTACHMENT_OA)gq BOBBY J MCMILLEN Defendants) MEMBERS 1 ST FCU Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 WWR No. 9412051 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-3901 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due ATLANTIC CREDIT&FINANCE INC.ASSIGNEE FROM CITIBANK Plaintiff(s) From BOBBY J.MCMILLEN, 106 REGENCY WOODS NORTH,CARLISLE,PA 17013 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: MEMBERS 1sT FCU,1711 SPRING ROAD,CARLISLE,PA 17013 and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the gamishee(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; (2) 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$2,928.38 Plaintiff Paid$ Interest$330.71 Attorney's Comm. % Law Library$.50 Attorney Paid$IS4'.50 Due Prothonotary$2.25 Other Costs$ Date: SEPTEMBER 18,2013 David D.Buell,Prothonotary ('seal) Deputy REQUESTING PARTY: Name : WILLIAM T.MOLCZAN,ESQUIRE Address:WELTMAN,WEINBERG&REIS CO.L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH,PA 15219, Attorney for: PLAINTIFF Telephone:412-424-7955 Supreme Court ID No. 47437 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson } t1‘:t:r'3:. ; .9 Sheriff f _ r Jody S Smith Chief Deputy �� 3 SAP 2 , , Richard W Stewart CUMBERLA D COLI .F� Solicitor ,,Fc10E CG ,.rsar,,F, PENNSYLVANIA Atlantic Credit& Finance Inc. Assignee from Citibank Case Number vs. Bobbie J McMillen 2008-3901 SHERIFF'S RETURN OF SERVICE 09/20/2013 10:05 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, embers 1st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Kathleen Nissley, Sales Assistant, 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 September 23, 2013 to Bobby J. McMillen at 106 Regency Woods North, Carlisle, PA 17013. I-2— ILLIAM CLINE, DEPUTY SO ANSWERS, September 23, 2013 RON R ANDERSON, SHERIFF u:hr,CU e Shc,.f Te OF T . PRO HONG T,F� a y RECEIVE® 1113 SEP 25 A1411: 21 SEP 2 8 2013 CUMBERLA#D COUNTY PENIgs 1� IN THE COURT OF COMMON PLEAS OF >�ALAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT& FINANCE INC. ASSIGNEE FROM CITIBANK Plaintiff VS. Civil Action No. 08-3901 BOBBY J MCMILLEN Defendant(s) dMt,,65 / v INTERROGATORIES IN ATTACHMENT MEMBERS 1 ST FCU Garnishee(s) FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 W W R No. 9412051 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT& FINANCE INC. ASSIGNEE FROM CITIBANK Plaintiff VS. Civil Action No. 08-3901 BOBBY J MCMILLEN Defendant(s) MEMBERS I ST FCU Garnishee(s) TO: MEMBERS I ST FCU, 1711 SPRING RD,CARLISLE, PA 17013 RE: BOBBY-J MCMILLEN, 106 REGENCY WOODS NORTH, CARLISLE, PA 17013 Suggested Reference No.: XXX-XX-9161 XXX-XX- IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty(20)days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. WWR No. 9412051 INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument,or did he claim that you owed him any money or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of deposit)? C, I a. If the answer to Interrogatory I is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. ZIP& .aQ 2. At the time you were served or at any subsequent time was there in your 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. Nt 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 part by the defendant or in which defendant held or claimed any interest? NO 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? W 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? �` 0 Iv 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law?If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. W WR No. 9412051 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant 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. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. S*"d3AA_ 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen,restricted, or otherwise put on hold by this institution. �� M �/ 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not 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? IA- 12. If the response to Interrogatory 11 is in the affirmative,state the amount of non-exempt funds on deposit in the account. WELTMAN, WEINBERG & REIS CO., L.P.A. By: 0,z/'/ William T. Molczan, Esquir PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 W WR No. 9412051 r M' VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is Nei U-tAf-n (Na e) n�a f 111 �?►� of {'� LL , garnishee herein, (Title) -V�� (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SI TU ) W WR No. 9412051 ti k 1 yr-�t- Jl. t i i-L= U 7 HUNS Ar 2013 OCT 21 Phi 3. 35 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT& FINANCE, INC ASSIGNEE FROM CITIBANK Plaintiff No. 08-3901 vs. PRAECIPE FOR JUDGMENT AGAINST GARNISHEE BOBBY J MCMILLEN Defendant MEMBERS 1ST FCU Garnishee FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T Molczan Esquire PA I.D.#47437 Weltman, Weinberg& Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#09412051 Witi- tt I ,5t()(k6 gt-c;prills N0 frce Mat IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT& FINANCE, INC ASSIGNEE FROM CITIBANK Plaintiff vs. Civil Action No. 08-3901 BOBBY J MCMILLEN Defendant MEMBERS 1ST FCU Garnishee PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, MEMBERS 1ST FCU , in the amount of$68.29,which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG&REIS CO., L.P.A. By: L..f r l William T Molczan E uire PA I.D.#47437 Weltman, Weinberg& Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#09412051 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg& Reis Co., L.P.A., 1400 Koppers Building,436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: 1711 SPRING ROAD, CARLISLE, PA 17013 • SEP-23-2013 MON 04: 18 PM MEMBERS 1ST MEMBER SVCS FAX NO 7177956005 P. 01/05 RECEIVED SEP232013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT& FINANCE INC. ASSIGNEE FROM CITIBANK Plaintiff vs. Civil Action No. 08-3901 BOBBY J MCMILLEN Defendant(s) INTERROGATORIES IN ATTACHMENT MEMBERS 1ST FCU Garnishee(s) FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Malczan, Esquire PA I.D.#47437 WELTMAN, WEINBERG& REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 WWR No.9412051 SEP-23-2013 MON 04:18 PM MEMBERS 1ST MEMBER SVCS FAX NO, 7177956005 P. 02/05 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT& FINANCE INC. ASSIGNEE FROM CITIBANK Plaintiff vs. Civil Action No. 08-3901 BOBBY J MCMILLEN Defendant(s) MEMBERS 1ST FCU Garnishees) TO: MEMBERS 1ST FCU, 1711 SPRING RD,CARLISLE, PA 17013 RE: BOBBY.!MCMILLEN, 106 REGENCY WOODS NORTH, CARLISLE,PA 17013 Suggested Reference No.: XXX-XX-9161 XXX-XX- IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty(20)days after service upon you. Failure to do so may result in Judgment against you B. Herein,the word"defendant"means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. W W R No.9412051 SEP-23-2013 M0N 04:18 PM MEMBERS 1ST MEMBER SVCS FAX NO 7177956005 P. 03/05 INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument,or did he claim that you owed him any money or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of deposit)? c I a. tithe answer to Interrogatory I is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him;and the nature and amount of each of such liabilities. 31 &, 2. At the time you were served or at any subsequent time was there in your 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. 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 part by the defendant or in which defendant held or claimed any interest? JO 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? IQO 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant 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 have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account,and the entity electronically depositing those funds on a recurring basis. OD W WR No. 941205) SEP-23-2013 MON 04:18 PM MEMBERS 1ST MEMBER SVCS FAX NO. 7177956005 P. 04/05 8, If you are a bank or other financial institution,at the time you were served or at any subsequent time did the defendant 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. ND 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. ,9,41t-DvuiatiL 2.0 I a 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument,checking or savings account,certificate of deposit,or other funds were frozen,restricted,or otherwise put on hold by this institution. �� L_/ 2-013 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not 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? N1k 1 2. If the response to Interrogatory I I is in the affirmative,state the amount of non-exempt funds on deposit in the account. WELTMAN, WEINBERG& REIS CO.,L.P.A. 4 By: ./�v ? 13 G William T. Molczan, Esquir PA I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR No.9412051 A SEP-23-2013 MON 04:18 PM MEMBERS 1ST MEMBER SVCS FAX NO. 7177956005 P. 05/05 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/she is � � A j '.AI (N. •e) 19C)9F O1r1 of L' - . F , _ , garnishee herein, (Title) Anci irr. (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. r J4 1 t -L (SITU' ) .._ WWII No. 9412051 • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT&FINANCE, INC ASSIGNEE FROM CITIBANK Plaintiff vs. Civil Action No. 08-3901 BOBBY J MCMILLEN Defendant MEMBERS 1ST FCU Garnishee NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff ( ) Defendant (xx)Garnishee You are hereby notified that the following Order or Judgment wa entered against you on lop.i (13 (xx) Assumpsit Judgment in the amount of$68.29 plus costs. ( ) Trespass Judgment in the amount of$ plus costs. ( ) If not satisfied within sixty(60) days,your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration Award Prothonotary } By: PROTHONOTARY(OR DEPUTY) Members 1"Fcu 1711 Spring Road Carlisle, Pa 17013 WELTMAN,WEINBERG & REIS CO.,L.P.A. BY: Ashley L. Sweeney,Esquire Attorney for Plainti I.D.No.313667 '" 14 Ftl 3. 6 436 Seventh Avenue, Suite 1 1400 CUMBERLAND A o Ut4Tv Pittsburgh,PA 15219 PENtisyL " I Phone:412.434.7955 NIA Fax: 412.434.7959 File#9412051 ATLANTIC CREDIT& FINANCE INC ASSIGNEE FROM CITIBANK Cumberland County Court of Common Pleas vs. BOBBY J MCMILLEN NO. 08-3901 and MEMBERS I ST FCU Garnishee(s) PRAECIPE TO SATISFY ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter satisfied as to Garnishee(s),MEMBERS I ST FCU,only. WELTMAN, WEINBERG& REIS CO.,L.P.A. By (,Ks ey6lsw'c�e#ey,Esquire Attorney for l�a,, aintiff log WELTMAN, WEINBERG & REIS, CO., L.P.A. BY: Matthew D. Urban,90963 I.D. No. 90963 436 7th Ave Ste 1400 Pittsburgh PA 15219-1827 (412) 434-7955 FAX: 412-338-7130 File # 09412051 C j Pit SJS Attorney- for 1:)_Iaintiff-(z) ATLANTIC CREDIT AND FINANCE, INC. ASSIGNEE FROM CITIBANK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. BOBBY J MCMILLEN CASE NO. 08-3901 PRAECIPE TO SATISFY TO THE PROTHONTARY: Kindly mark the case and judgment entered against Defendant BOBBY J MCMILLEN as satisfied. WELTMAN, WEINBERG & REIS CO., L.P.A. By Matthew D. Urban Attorney for Plaintiff c5c1 Pa ■I<Y1-)Lito Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY i Hs Pi;OTIIONu j,.,. 411 1.4 APR 14 PM 2: +1[3 Ri r tj CQUNTY PEt'4NSYLVANIA Atlantic Credit & Finance Inc. Assignee from Citibank vs. Bobbie J McMillen Case Number 2008 -3901 SHERIFF'S RETURN OF SERVICE 09/20/2013 10:05 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, embers 1st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Kathleen Nissley, Sales Assistant, 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 September 23, 2013 to Bobby J. McMillen at 106 Regency Woods North, Carlisle, PA 17013. 04/14/2014 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: $88.26 SO ANSWERS, April 14, 2014 (c) CC u^tySui,e Shen!. Teleaseft. Inc. RONNY R ANDERSON, SHERIFF SD t -4d a.-7* gs -pia 0/4 30 i YG 3