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HomeMy WebLinkAbout08-4427 IN TIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONF~ BANK Plaintiff CHRISTINA D Defendant(s) PRAECIPE FOR JUDGMENT ON DISTRICT JUSTICE JUDGMENT/TRANSCRIPT I hereby certify at the true and correct addr ss of Plaintiff is: C/O Patenaude Felix, A.P.C. 213 E. Main Str et Carnegie, PA 1 106 and the last kno address of Defendant is: CHRISTINA D LOR 2432 LOBACH RIVE Mt:(;HANICSB RG PA 17055-5376 The Law Offices of Patenaude & Felix, A.P.C. Gregg L. Morns, PA_129 Prcp Jg on DJ Jg Filed on behalf of: CAPITAL ONE BANK , Plaintiff Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 P&F File No. 762.13003 i IN TI}IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONES BANK Plaintiff v CHRISTINA D LOR Defendant(s) TO:PROTHON TARY Please en er a judgment against the defendant, above named. Amount f Judgment $3,907.87 Judgmen Costs $131.50 Less pay ents received $357.60 NO. TOTAL $3,681.77 With cont nuing interest on the principal amount of ,with interest at the legal rate, plus costs of suit. submitted: Felix, A.P.C. Date: July 08, PA_129 Prcp Jg on DJ Jg mire g .Morris Esquire 21 E. ain eet arnegie, A 15106 (412) 429-7675 P&F File No. 762.13003 i 'COMMONWEALTH OF PENNSYLVANIA COUNTY,OF: ERLAND ` ~ Mag. Dist. No.: 0!9-3-05 MDJ Nama: Hon. MARE MARTIN A`~"`~" 507 N Y RE ST PA ',~~euF,~~:r: 1717) 7 6-4575 17055 ATTORNEY FOR PLAINTIFF GRBGG L. MO IS 213 E MAIN S PATBNANDB S~ BLI% APC CARNBGIE, PA 15106 THIS IS TO NOTIF -~- Judgment: - ® Judgment wa: ® Judgment wa; in the amount Defendants al n u Damages will (] This case disr YOU THAT: BFA~JLT Jl1DGMENT FLTF NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NgME ano gDDRESs CAPITAL ONB BANK ~ C/O G.MORRIS BS 213 BAST MAIN STR88T LCARNBGIB, PA 15106 J VS. DEFEND,4NT: NaM[ and gDDr~ESs rFLOR, CHRISTINA D ~ 2432 LOBACH DRIVB MECHANICSBIIRG, PA 17055 L ~ Docket No.: CV-0000089-08 Date Filed: 3/26/08 . _ ;.gig , ~~ ; (Date of Judgment) 5/23/08 - entered for: (Name) CAPITAL ONE BANE entered against: (Name) FLOR, CHRISTINA D ,f$ 4,039.3 jointly and severally liable. assessed on Date & Tim issed without prejudice. Amount of Judgment $ 3, 907.87 Judgment Costs $ 131.5 Interest on Judgment 1 $ Attorney Fees $ . ~0 Total $ 4, 039.37 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ Amount of Jud ment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judg ent for physical damages arising out of residential leas $ ANY PARTY HAS THE OF APPEAL WITH THE PI MUST INCLUDE A COPY EXCEPT AS OTHERWI JiJDGNffIV"1' HOL[S1=fi ELI COME FROM THE COUR' UNLESS THE JUDGME A REQUEST FOR ENTRY SETTLES, OR OTHERWIf aHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE ITHONOTARYlCLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU = THIS NOTICE OF JUDGMENTlTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. PROVIDED IN THE RULES,OF CIVIL PROCEDURE FQR MAGISTERIAL DISTRICT JUAGES, iF THE TS TO ENTt`R THE JUDGMENT M THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST 1F COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE . " IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE = SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, COMPLIES WITH THE JUDGMENT. i ,- / _ ~' ~:. ~ °~ Dat ~ f - , Ma~gise al District Judge Ice ify th t this is a rue and correct copy of the record of the proceedings cont fining the judgment. . '~ o~ 08 Dat ~ - ~~rial District Jud e g My commission expi s first Monday ofr'y; '~ SEAL AOPC 315-07 ~//7~~^]^/1 ~^ (/\12 i11A T'a D~ Tf7.~471 _ c / ~f 9 Inn ~ w w ~ w w - ~~ / ~/ ` " / (~ ~ ~\ J ~ ~ ~ rv ~ -fin * ~;;; q ~ ~ :%i` ~ ~'p. ~- ~ ~-, -_ ~-~, r-n Q t ~ ~ c ri '~ ~- . r -< 4~` ~o IN TIDE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, I~ PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) NO. v CHRISTINA D Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morns, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412)429-7675 PA_130 Ntc Jg fr DJ Jg ' P&F File No. 762.13003 • CAPITAL BANK Plaintiff 1N TIME COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ~I PENNSYLVANIA v, CHRISTINA D Defendant(s) NO. NOTICE OF ORDER DECREE OR ~T1IDGMENT TO: ( )Plaintiff ~(X )Defendant ( )Garnishee ( )Additional Defendant You are reby notified that the following Order, Decree, or Judgment has been entered against you on ~ p ( ) De ee Nisi in Equity ( )Fin 1 Decree in Equity (X) Jud ment of ( )Confession ( )Default ( )Non-Pros ( )Verdict ( )Court Order ( )Non-suit ( )Arbitration Award ( )Jud ment in the amount of $ ,plus costs. (X) Dis 'ct Justice Transcript of Judgment in the amount of $3,681.77, plus costs. ( ) If n t satisfied within sixty (60) days, your motor vehicle operator's license will be sus ended by the Department of Transportation. If you have questi Name of ~ Prothon tary BY concerning the above, please Contact: ney: GREGG MORRIS, Esquire 213 East Main St Carnegie PA 15106 (412)-429-7675 PA_130 Ntc Jg fr DJ Jg I, P&F File No. 762.13003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff ) NO. 08-4427 V. ) 3 r.? CHRISTINA D FLOR 2432 Lobach Drive Mechanicsburg Pa 17055-5376 Defendant(s) ) < € : s c c.-) -V M&T BANK ) = N 5219 Simpson Ferry Road Mechanicsburg Pa 17055 ) Garnishee PRAECIPE FOR WRIT OF EXECUTION To The Prothonotary: Issue writ of execution in the above matter, ( I ) directed to the Sheriff of Cumberland County; (2) against, CHRISTINA D FLOR Defendant(s); (3) against, M&T BANK, Garnishee; (4) and index this writ (a) against, Defendant(s) CHRISTINA D FLOR, Defendant(s); and (b) against M&T BANK, Garnishee; as a lis pcildens against real property of the Defendant(s) in the name of the garnishee as follows: (5) Amount due $3,681.77 Interest from July 23, 2008 At 6.00 1?lo per annum Court Cost Less: Payment s O Dotal o2R.oo pp A-TTY a9. a5 CBF C;' so ? 58 • ?5 PD AT7"`1 -4.2-.25 hVeCA • So u $693.79 C*5,9 (093 PA_ 134 Prcp Writ of Fxe P-*(9,95138 N&F Nile No, 763.13003 tOF it 4UkAfid IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff NO. 08-4427 V. CHRISTINA D FLOR 2432 Lobach Drive Mechanicsburg Pa 17055-5376 Defendant(s) M&T BANK 5219 Simpson Ferry Road Mechanicsburg Pa 17055 Garnishee PRAECIPE FOR WRIT OF EXECUTION Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esduire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA131 Prch ?tiIit ot I--\c M,I? I?ilc No. 702.13003 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-4427 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK, Plaintiff (s) From CHRISTINA D. FLOR, 2432 Lobach Drive, Mechanicsburg, PA 17055-5376 (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: M&T BANK, 5219 Simpson Ferry Road, Mechanicsburg, PA 17055 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 $3,323.77 L.L. $.50 Interest from 7/23/08 @ 6.00% per annum -- $693.79 Atty's Comm % Due Prothy $2.25 Atty Paid $58.75 Plaintiff Paid Other Costs Date: 5/14/12 (Seal) Deputy REQUESTING PARTY: Name GREGG L. MORRIS, ESQUIRE Address: PATENAUDE & FELIX, APC 213 E. MAIN STREET CARNEGIE, PA 15106 Attorney for: PLAINTIFF Telephone: 412-429-7675 Supreme Court ID No. 69006 L.7. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor of t? II10" f L, r? << ; 1ky 18 FM 1: 11 "L118ERLF, C iii D' PEHNSYLVANIA Capital One Bank vs. Christina D Flor Case Number 2008-4427 SHERIFF'S RETURN OF SERVICE 05/17/2012 02:47 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 17, 2012 at 1445 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Christina D. Flor, in the hands, possession, or control of the within named garnishee, M&T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Yvette Shughart, Teller, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on May 18, 2012 to Christina D. Flor at 2432 Lobach Drive, Mechanicsburg, PA 17055. SO ANSWERS, May 18, 2012 RON R ANDERSON, SHERIFF Noah Cline, Deputy c; C,our Sik `..., IN T1IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CAPI'T'AL ONE BANK Plaintiff V. CHRISTINA D FLOR 2432 Lobach Drive Mechanicsburg Pa 17055-5376 Defendant(s) M&T BANK 5210 Simpson Ferry Road Mechanicsburg Pa 17055 Garnishee OFFICES OF PATENAUDE & FELIX BY: GREGG MORRIS, ESQUIRE 213 East Main St Carnegie PA 15106 858-244-7675 NO. 08-4427 r-TI: ; > ?'r7 > c= ,'C;EJ ! C?Iti01 a ? I` '1 I P 14 3 Is LA! COtt NNI SYLVANIA i rsa You are hereby notified to plead to the enclosed Interrogatories within 20 days from the date of hereof or a default judgment may be entered against you. Gregg Morris, Esquire Attorney for Plaintiff INTERROGATO ES IN ATTACHMENT EXECUTION You are required to answer the following interrogatories about Defendant(s) whose address is 2432 LOBACH DRIVE, MECHANICSBURG PA 17055-5376. You must file with the Court answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in it dcfault judgment being entered against you. A copy of said answers must he served on the undersigned. If your answer to any of the following interrogatories is affirmative, specify the amount, value and/or nature of the subject property. PA I I') Inien,p nttih Fxc P&F File No. 762.13003 I . At the time you were served or at any subsequent time, did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed them any money or were you liable to them for any, reason? If yes, please specify as set forth herein. ? 16; 6,6 oAT04111", ?. At the time you were served, or at any subsequent time, was there in your possession, custody or control, or in joint possession, custody or control of yourself or others, any property of any nature owned solely or in party by the Defendant(s)? If yes, please list and describe the property. 3. At the time you were served, or at any subsequent time, did you hold Ical title to any property or any nature owned solely or in part by the Defendant(s)? If yes please list and describe the property. i 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which the Defendant(s) had an interest? If yes, please list and describe the property. ? . P&F File No. 702.13003 N ? ?. At any time before or after you were served, did the Defendant(s) transfer or deliver any property to you, or to any person, or place pursuant to your directions or consent'? If yes, what was the consideration therefore'? q& P, NO01 TQ 4O?N i4k qN 941, 0. At any time after you were served, did you pay, transfer, or deliver any money or property to the Defendant(s) or to any person or place pursuant to their direction, or otherwise discharge any claim of the Defendant(s) against you. 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited clectroncially on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law'? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 11.? ,Vtctt 1f.\c P&F Idle No. 762.13003 ORA O?At ctC ?r S. If you are a bank or other financial insitution, at the time you were sel-Vc( any subsequent time did the defendant have funds on deposit in an account in which the Cunds on deposit. not including any otherwise exempt funds, did not exceed the amount (4111C Ocncral 111oncLirv exemption under 42 Pa.C.S. § 8123? It' so, indentify each account. ?t r Late: Mav I (), 20 12 Melissa M. Peters M& T Bank In Respectfully submitted: Patenaude & Felix, A.P.C. Gregg L. Morris, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 MAY 1 & 2012 PA131) Intcrog? Attch F:.xc P&F File No. 76-1.13003 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff NO. 08-4427 v. C IRISTINA D FLOR 2432 Lohach Drive Mechanicsburg Pa 17055-5376 Defendant(s) M&T BANK 5219 Simpson Ferry Road Mechanicsburg Pa 17055 Garnishee INTERROGATORIES IN ATTACHMENT EXECUTION Filed on behalf of: CAPITAL ONE BANK Counsel of'Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PEA I39Inlcn>e?.flitch Ixc P&F File No. 762.13003 r . a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff NO. 08-4427 V. CHRISTINA D FLOR Defendants(s) M&T BANK Garnishee n-- ry N_ ; C7 PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 *-9.50 Pb AT7?/ aw -W? / 81 &00 R,7a75880 PA_193 Prcp Disc with Prjdc Garnishee only P&F File No. 762.13003 I I& IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY.. PENNSYLVANIA CAPITAL ONE BANK V. CHRISTINA D FLOR Plaintiff Defendant(s) NO. 08-4427 PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY TO: Prothonotary Please settle and discontinue the matter captioned above without prejudice as to Garnishee only. Thank you. Respectfully submi Patenaude & Fe' N.P.C. Date: May 22, 2012 Sworn to and subscribed before me this Z- ay of M&!J , 204Z; Notary Public Gr/E.ai o r , Esquir 21reet Ca06 (4 75 -ND NOTARIAL SEAL MELINDNotary EMY B R0. ALI EGHENY COUNTY "? 15 mission Expires Jun 2. . PA_193 Prep Disc with Prjdc Garnishee only P&F File No. 762.13003 'k „ r I, GREGG MORRIS, attorney for Plaintiff, CAPITAL ONE BANK, hereby certify that a true and correct of the foregoing document was served this date by US First Class Mail, postage prepaid upon the following: M&T BANK 5219 SIMPSON FERRY ROAD MECHANICSBURG PA 17055 Date: May 22, 2012 PA_193 Prep Disc with Prjdc Garnishee only P&F File No. 762.13003 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff _ Jody S Smith 4# zCc - Chief Deputy x --v �s 7 . v CD Richard W Stewart Solicitorrr)c� � ' (LD Capital One Bank vs. Case Number Christina D Flor 2008-4427 SHERIFF'S RETURN OF SERVICE 04/08/2013 01:30 PM -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, Sovereign Bank, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Julie Myers, Teller, 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 April 9, 2013 to Christina D. Flor at 2432 Lobach Drive, Mechanicsburg, PA 17055-5376. Z- 4WID M CLINE, DEPUTY SO ANSWERS, April 09, 2013 RON R ANDERSON, SHERIFF c) ounh9L1:! Sneritf.'T'eleosoft.inc: OF THE PROTHONOTARCt' 2013 APR 26 PM 1: 49 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) NO. 08-4427 V. ) CHRISTINA D FLOR ) 2432 Lobach Drive Mechanicsburg Pa 17055-5376 ) Defendant(s) ) SOVEREIGN BANK ) 798 E Simpson St Mechanicsburg Pa 17055 ) Garnishee ) INTERROGATORIES IN ATTACHMENT EXECUTION Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude &Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_139 Interogs Attch Exe P&F File No.762.13003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) NO. 08-4427 V. ) CHRISTINA D FLOR ) 2432 Lobach Drive Mechanicsburg Pa 17055-5376 ) Defendant(s) ) SOVEREIGN BANK ) 798 E Simpson St Mechanicsburg Pa 17055 ) Garnishee ) OFFICES OF PATENAUDEA FELIX You are hereby notified to BY: GREGG MORRIS, ESQUIRE ' plead to the enclosed 213 East Main St Interrogatories within 20 Carnegie PA 15106 days from the date of 858-244-7675 hereof or a default judgment may be entered against you. Gregg Morris,Esquire Attorney for Plaintiff INTERROGATORIES M ATTACHMENT EXECUTION You are required to answer the following interrogatories about Defendant(s)whose address is 2432 LOBACH DRIVE MECHANICSBURG PA-1 7055 5376 You must file with the Court answers to the following interrogatories within twenty(20)days after service upon you. Failure to do so may result in a default judgment being entered against you. A copy of said answers must be served on the undersigned. If your answer to any of the following interrogatories is affirmative, specify the amount, value and/or nature of the subject property. PA_139 Interogs Attch Exe P&F File No.762.13003 i 1. At the time you were served or at any subsequent time, did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed them any money or were you liable to them for any reason? If yes,please specify as set forth herein. No 2. At the time you were served, or at any subsequent time, was there in your possession, custody or control, or in joint possession, custody or control of yourself or others, any property of any nature owned solely or in party by the Defendant(s)? If yes,please list and describe the property. Yes — See attached 3. At the time you were served, or at any subsequent time, did you hold legal title to any property or any nature owned solely or in part by the Defendant(s)? If yes please list and describe the property. No 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which the Defendant(s)had an interest? If yes, please list and describe the property. No PA_139 Interogs Attch Exe P&F File No.762.13003 5. At any time before or after you were served, did the Defendant(s)transfer or deliver any property to you, or to any person, or place pursuant to your directions or consent? If yes, what was the consideration therefore? No 6. At any time after you were served, did you pay, transfer, or deliver any money or property to the Defendant(s)or to any person or place pursuant to their direction, or otherwise discharge any claim of the Defendant(s) against you. No 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 electroncially on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. No PA-139 Interogs Attch Exe P&F File No.762.13003 8. If you are a bank or other financial insitution, 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, indentify each account. No Respectfully submitted: Patenaude & Felix, A.P.C. Date: March 16, 2013 Gregg L. Morris, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA-139 Interogs Atteh Exe P&F File No.762.13003 ANSWERS TO INTERROGATORIES Account # 1791053092 Balance: $564.89 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $267.00 Account Holder: Christina D Flor 1449 Arcona Rd Frnt Mechanicsburg, PA 17055-6722 Account# 7672685627 Balance $1,069.15 Account Holder: Christina D Flor 1449 Arcona Rd Frnt Mechanicsburg, PA 17055-6722 VERIFICATION I, Camille Neuwinger, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment 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. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank By: Camille Neuwinger C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Capital One Bank VS. Christina D Flor CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Gregg L. Morris, Esquire Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 Service by certified mail addressed as follows: Christina D Flor 1449 Arcona Rd Frnt Mechanicsburg, PA 17055-6722 n, Camille ger C.O.P. Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 April 18, 2013 a OF d ;` € ,F-o tHDNOI`Afi" ICJ HAY 16 Pm 1: 12 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) NO. 08-4427 V. ) ) CHRISTINA D FLOR ) 2432 Lobach Drive Mechanicsburg Pa 17055-5376 ) Defendant(s) ) SOVEREIGN BANK ) 798 E Simpson St Mechanicsburg Pa 17055 ) Garnishee ) PRAECIPE FOR JUDGMENT UPON ANSWERS TO INTERROGATORIES Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D.#69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412)429-7675 Q M� 416.sb� a.4l C�1�� 1os9�'S PA_]]7B Prcp Jdge Bank Ans P&F File No.762.13003 � .- I,33�e, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) NO. 08-4427 V. ) ) CHRISTINA D FLOR ) 2432 Lobach Drive Mechanicsburg Pa 17055-5376 ) Defendant(s) ) SOVEREIGN BANK ) 798 E Simpson St Mechanicsburg Pa 17055 ) Garnishee ) PLAINTIFF'S PRAECIPE JUDGMENT UPON ANSWERS TO INTERROGATORIES AGAINST SOVEREIGN BANK ONLY TO: PROTHONOTARY Please enter a judgment against the Garnishee, above named, upon Answer's to Interrogatories attached hereto as Exhibit "A". Amount set forth in Garnishee's Answers: $1,336.15 Total: $1,336.15 Respectful/sub *Patenau e Date: May 09, 2013 G i�oxrl�;s ,Esai . Main Street 10 Carnegie, PA 15106 (412) 429-7675 PA_]17B Prep Jdge Bank Ans P&F File No.762.13003 • Sovereign • - Court Ordered Processing - MA1-MB3-02-10 - P.O.Box 841005 - Boston,MA 02284 April 18, 2013 The Court of Common Pleas of Cumberland County, Pennsylvania Prothonotary's Office 1 Courthouse Square Carlise, PA 17013 5 v RE: Capital One Bank r vs. N Christina D Flor No.: 08-4427 S z Dear Sir/Madam: Enclosed are Sovereign Bank's Answers to Interrogatories in Attachment and an original and copy of a Certificate of vitae. Please file the originals-ire your off.10: and return the Time-stamped copy of the Certificate of Service in the enclosed return envelope. By copy of this letter we are serving those parties listed on the Certificate of Service with a set of Answers. We are also serving the Defendant with a copy of the Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order, and Claim p for Exemption. Very try urs, i Z 3 Cami Neu er ' C.O.P. Lead Specialist i Court Order Processing �Q Z 91113 Phone: 617-514-5189 J Fax: 617-533-1188 o P C 9 Enclosures e pc: Gregg L. Morris, Esquire (w/enclosures) Christina D Flor (w/enclosures, certified mail) 1 z 3 L EXHIBIT 1 , `ll�a .1303 o ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) NO. 08-4427 V. ) CHRISTINA D FLOR ) 2432 Lobach Drive Mechanicsburg Pa 17055-5376 ) Defendant(s) ) SOVEREIGN BANK ) 798 E Simpson St Mechanicsburg Pa 17055 ) Garnishee ) ` INTERROGATORIES IN ATTACHMENT EXECUTION Filed on behalf of. CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude &Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_139 Interogs Attch Exe P&F File No.762.13003 r s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) NO. 08-4427 V. ) CHRISTINA D FLOR ) 2432 Lobach Drive Mechanicsburg Pa 17055-5376 ) Defendant(s) ) SOVEREIGN BANK ) 798 E Simpson St Mechanicsburg Pa 17055 ) Garnishee ) OFFICES OF PATENAUDE.& FELIX You are hereby notified to BY: GREGG MORRIS, ESQUIRE plead to the enclosed 213 East Main St Interrogatories within 20 Carnegie PA 15106 days from the date of 858-244-7675 hereof or a default judgment may be entered against you. Gregg Morris, Esquire Attorney for Plaintiff INTERROGATORIES IN ATTACHMENT EXECUTION You are required to answer the following interrogatories about Defendant(s)whose address is 2432 LOBACH DRIVE MECHANICSBURG PA 17055-5376. You must file with the Court answers to the following interrogatories within twenty(20)days after service upon you. Failure to do so may result in a default judgment being entered against you. A copy of said answers must be served on the undersigned. If your answer to any of the following interrogatories is affirmative, specify the amount, value and/or nature of the subject property. PA-139 Interogs Attch Exe P&F File No.762.13003 i a 1. At the time you were served or at any subsequent time, did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed them any money or were you liable to them for any reason? If yes,please specify as set forth herein. No 2. At the time you were served, or at any subsequent time, was there in your possession, custody or control, or in joint possession, custody or control of yourself or others, any property of any nature owned solely or in party by the Defendant(s)? If yes, please list and describe the property. Yes - See attached 3. At the time you were served, or at any subsequent time, did you hold legal title to any property or any nature owned solely or in part by the Defendant(s)? If yes please list and describe the property. No 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which the Defendant(s) had an interest? If yes,please list and describe the property. No PA—139 Interogs Attch Exe P&F File No.762.13003 3 5. At any time before or after you were served, did the Defendant(s) transfer or deliver any property to you, or to any person, or place pursuant to your directions or consent? If yes, what was the consideration therefore? No 6. At any time after you were served, did you pay, transfer, or deliver any money or property to the Defendant(s) or to any person or place pursuant to their direction, or otherwise discharge any claim of the Defendant(s) against you. No 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 electroncially on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. No PA—139 Interogs Attch Exe P&F File No.762.13003 i 8. If you are a bank or other financial insitution, 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, indentify each account. No Respectfully submitted: Patenaude & Felix, A.P.C. Date: March 16, 2013 Gregg L. Morris, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_I39 Interogs Attch Exe P&F File No.762.13003 s ANSWERS TO INTERROGATORIES Account# 1791053092 Balance: $564.89 After allowing for the $300.00 e-;ernp�.on under 42 Pa.C.S. 8123 the balance in this account is $267.00 Account Holder: Christina D Flor 1449 Arcona Rd Frnt Mechanicsburg, PA 17055-6722 Account# 7672685627 Balance $1,069.15 Account Holder: Christina D Flor 1449 Arcona Rd Frnt Mechanicsburg, PA 17055-6722 VERIFICATION I, Camille Neuwinger, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment 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. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank By: Camille Neuwinger .C.O.P. Lead Specialist • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Capital One Bank VS. Christina D Flor CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Gregg L. Morris, Esquire Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 Service by certified mail addressed as follows: Christina D Flor 1449 Arcona Rd Frnt Mechanicsburg, PA 17055-6722 n1 Camille ger C.O.P. Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 April 18, 2013 V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) NO. 08-4427 V. ) CHRISTINA D FLOR ) Defendant(s) ) NOTICE OF ORDER, DECREE OR JUDGMENT Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix,A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_1.30 Ntc Jg fr DJ Jg P&F File No.762.13003 d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) NO. 08-4427 V. ) CHRISTINA D FLOR ) Defendant(s) ) NOTICE OF ORDER, DECREE OR JUDGMENT TO: ( )Plaintiff ( )Defendant (X)Garnishee ( )Additional Defendant You are hereby notified that the following Order, Decree, or Judgment has been entered against you on 4 ')N ( ) Decree Nisi in Equity ( ) Final Decree in Equity (X) Judgment of( ) Confession ( ) Verdict ( ) Court Order ( ) Default ( ) Non-suit ( ) Non-Pros ( ) Arbitration Award (X) Judgment in the amount of$1,336.15, plus costs. ( ) District Justice Transcript of Judgment in the amount of$3,550.27, plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Prothonotar By 2t 1A,to eputy If you have questions concerning the above, please Contact: Name of Attorney: GREGG MORRIS, Esquire 213 East Main St Carnegie PA 15106 (412)-429-7675 PA_1.30 Ntc Jg fr DJ Jg P&F File No.762.13003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA .•q-q CAPITAL ONE BANK ) : s Plaintiff ) NO. 08-4427 r C) CHRISTINA D FLOR ) —C:: 3? Defendants(s) ) SOVEREIGN BANK ) Garnishee ) PRAECIPE TO SATISFY JUDGMENT AS TO GARNISHEE ONLY Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 wwA Cot bb PA-193J Prcp Sat Jgmnt Garnishee P&F File No.762.13003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) NO. 08-4427 V. ) CHRISTINA D FLOR ) Defendants(s) ) SOVEREIGN BANK ) Garnishee ) PRAECIPE TO SATISFY JUDGMENT AS TO GARNISHEE ONLY TO: Prothonotary Please satisfy the judgment entered as to Garnishee, named above, ONLY, upon payment of your costs only. Thank you. Respectful1 u/ itte Patenau elix A Date: May 29 2013 NOTARIAL AL Gr g L. orris, Esquire MELINDA S PERRY V2r ain Street Nota ry Public CARNEGIE BORO..ALLEGHENY COUNTY , PA 15106 My Commission Expires Jun 2,2015 9-7675 Sworn to and subscribed before me this 2-1 day of MA&4 , 20a. Z�h,�'-4 11,4 Notary Public PA-193J Prcp Sat Jgmnt Garnishee P&F File No.762.13003 I, GREGG MORRIS, attorney for Plaintiff, CAPITAL ONE BANK , hereby certify that a true and correct of the foregoing document was served this date by US First Class Mail, postage prepaid upon the following: SOVEREIGN BANK 798 E SIMPSON ST MECHANICSBURG PA 17055 Date: May 29, 2013 Z- Gr (Felix, ire .C. Carnegie, PA 15106 (412) 429-7675 PA_193J Prep Sat Jgmnt Garnishee P&F File No.762.13003 Ir SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,y R Anderson E:I.LEU QF HL,M ariff 11' THE PROTHONU At Jody S Smlth �testi -turitrr{fit#4,4 Chief Deputy C 21113 NOV —6 10' 53 Richard W Stewart Solicitor oFrIcE.A 1-.,F°"ER'Fp CU PENNSYLVANIA T4' Capital One Bank Case Number vs. Christina D Flor 2008-4427 SHERIFF'S RETURN OF SERVICE 04/08/2013 01:30 PM-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, Sovereign Bank, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Julie Myers, Teller, 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 April 9, 2013 to Christina D. Flor at 2432 Lobach Drive, Mechanicsburg, PA 17055-5376. 11/04/2013 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. Plaintiffs attorney did file a Notice of Order, Decree or Judgment on May 16, 2013 in the amount of$ 1,336.15. Plaintiffs attorney also filed a Praecipe to Satisfy Judgment as to Garnishee Only on May 29, 2013. SHERIFF COST: $113.35 SO ANSWERS, g 'X''', c' November 04, 2013 RONNY R ANDERSON, SHERIFF c2 .21 i,<, .6, . as4 X37 U p)1* .)-"(17 @214 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff v. CHRISTINA D FLOR 319 E Main St Mechanicsburg Pa 17055-6516 Defendant(s) SANTANDER BANK, N.A 798 E Simpson St Mechanicsburg Pa 17055 Garnishee ) ) ) NO. 08-4427 ) ) ) ) ) ) ) ) ) PRAECIPE FOR WRIT OF EXECUTION To The Prothonotary: Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against, CHRISTINA D FLOR Defendant(s); (3) against, SANTANDER BANK, N.A, Garnishee; (4) and index this writ (a) against, Defendant(s) CHRISTINA D FLOR, Defendant(s); and (b) against SANTANDER BANK, N.A, Garnishee; as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows: (5) Amount due Interest from July 23, 2008 At 6.00 % per annum Court Cost Less: Payment Total PA_134 P rit of Exe cot --/D0781 -73138 SCio(-1S6 $3,681.77 $1,288.61 P&F File No. 762.13003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff V. CHRISTINA D FLOR 319 E Main St Mechanicsburg Pa 17055-6516 Defendant(s) SANTANDER BANK, N.A 798 E Simpson St Mechanicsburg Pa 17055 Garnishee NO. 08-4427 PRAECIPE FOR WRIT OF EXECUTION Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA 134 Prcp Writ of Exe P&F File No. 762.13003 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net CAPITAL ONE BANK Vs. CHRISTINA D. FLOR WRIT OF EXECUTION (Pa R.C.P. 3252) NO 08-4427 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against CHRISTINA D. FLOR, 319 E. MAIN STREET, MECHANICSBURG, PA 17055 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of SANTANDER BANK, N.A.GARNISHEE(S), as garnishee, 798 E. SIMPSON STREET, MECHANICSBURG, PA 17055 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with 'a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $3,681.77 Plaintiff Paid Interest FROM JULY 23, 2008 AT 6.00% PER ANNUM - $1,288.61 Law Library Attorney's Comm. % Attorney Paid $351.94 Date: 5/27/14 Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : GREGG L. MORRIS, ESQUIRE Address: PATENAUDE & FELIX, A.P.C. 213 E. MAIN STREET CARNEGIE, PA 15106 Attorney for: PLAINTIFF Telephone: 412-429-7675 Supreme Court ID No. 69006 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OPT r THE P�,OTHONO !'',r',. ;lig_ lTnii JUN --6 fiti icy: 514 CUMBERLAND COUNTY PENNSYLVANIA Capital One Bank vs. Christina D Flor Case Number 2008-4427 SHERIFF'S RETURN OF SERVICE 06/02/2014 11:15 AM - Dennis Fry, 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, Santander Bank, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Denise Beecher, Customer Service Representative, 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 June 4, 2014 to Christina D Flor at 319 E Main Street, Mechanicsburg, PA 17055. DEN FRY, DEPU SO ANSWERS, June 04, 2014 RONNY R ANDERSON, SHERIFF ic1 CountySuite Sheriff, Teleosoft. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK ) Plaintiff ) ) NO. 08-4427 ; s-., v. ) �V `' c: c.... "_-'t CHRISTINA D FLOR ) .,, :,� -f r, 319 E Main St MechanicsburgPa 17055-6516 - �. i C/) ry .J r ) —C C.J C` Defendant(s) ) r--:X: SANTANDER BANK, N.A ) c' .w� 798 E Simpson St Mechanicsburg Pa 17055 ) =-+ :" Garnishee ) OFFICES OF PATENAUDE & FELIX You are hereby notified to BY: GREGG MORRIS, ESQUIRE plead to the enclosed 213 East Main St Interrogatories within 20 Carnegie PA 15106 days from the date of 858-244-7675 hereof or a default judgment may be entered against you. Gregg Morris, Esquire SSSAttorney for Plaintiff lu INTERROGATORIES IN ATTACHMENT EXECUTION You are required to answer the following interrogatories about Defendant(s)whose address is 2432 LOBACH DRIVE ,MECHANICSBURG PA 17055-5376. You must file with the Court answers to the following interrogatories within twenty(20)days after service upon you. Failure to do so may result in a default judgment being entered against you. A copy of said answers must be served on the undersigned. If your answer to any of the following interrogatories is affirmative, specify the amount, value and/or nature of the subject property. PA_139 Interogs Attch Exe P&F File No.762.13003 • _ { ..r ..zr ti-. .� n..- -4'- _.fl' ' .fe.., ,.__�.�..- -. _ r -...— .._.mow .. ...+�.1�,�.tea....-... - ..r_..`_...�._..� u_.... e...✓.-+ . C , r 1. At the time you were served Or at any subsequent time, did you owe the • Af1Te iIr •- } t z +lr '1• no ":ti n y i tIE� iCF jn:,1'X•.i Y1 •i i yzt1;. defendarit(s) any money o were'you4 fable to defendant(s),on any`negottabletor other written instrument• , or did defendant(s) claim that,you owed them any money or were you liable to them for any reason?'If yes, please specify as forth herein. NO ft:vr r,,,.. ,s,<• rn,,;: �!i�j3 •,4. r►eSt r•a r rr �.�, , 2: At the time'you were°served,or at any subsequenttime, was there in your possession, custody,or control, or in joint possession, custody or control of yourself or others, any property of any nature owned solely or in party by the Defendant(s)? If yes, please list and describe the property. YES, SEE ATTACHED • —Al the inielyou we Sersed, or at any subsequent•firr'ie1`did"you .hold'legal title to any .3St. 7-a 'F t ♦.. _. c tt+'..r','-� ..-, .,,. .. any property or any nature owned solely or in part by the Defendant(s)? If yes;please list and describe the property:'J ? '� r =`. v?,. '"i t. ;zr s.t • -r _ 'r A NO 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which the Defendant(s)had an interest? If yes, please list and describe the property. NO PA_139lnterogsAttch Exe P&F File No.762.13003 8. If you are a bank or other financial insitution, 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, indentify each account. NO Respectfully submitted: Patenaude & Felix, A.P.C. Date: May 07, 2014 Gregg L. Morris, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_139 Interogs Attch Exe P&F File No.762.13003 ANSWERS TO INTERROGATORIES Account# 1791053092 Balance: $710.93 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $410.93. Account Holder: CHRISTINA D FLOR 1449 ARCONA RD NT MECHANICSBURG, PA 17055-6722 Account# 7672685627 Balance: $0.01 Account Holder: CHRISTINA D FLOR 1449 ARCONA RD NT MECHANICSBURG, PA 17055-6722 VERIFICATION I, John S. Comes, C.O.P. Lead Specialist of Santander, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment 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. Section 4094, relating to unsworn falsification to authorities. Santander ri! By: ,alljr /John S. Comes C.O.P. Lead Specialist A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: CAPITAL ONE BANK vs. CHRISTINA D FLOR CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Gregg L Morris, Esquire Patenaude & Felix, A.P.C. 213 East Main St Carnegie, PA 15106 Service by certified mail addressed as follows: CHRISTINA D FLOR 1449 ARCONA RD NT MECHANICSBURG, PA 170556722 john S. Gom C.O.P. Lead Specialist Santander MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 June 17, 2014 I 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: CAPITAL ONE BANK vs. CHRISTINA D FLOR CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Gregg L Morris, Esquire Patenaude & Felix, A.P.C. 213 East Main St Carnegie, PA 15106 Service by certified mail addressed as follows: CHRISTINA D FLOR 1449 ARCONA RD NT MECHANICSBURG, PA 170556722 Ailf4t, 14 ohn S. Gom- C.O.P. Lead Specialist Santander MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 June 17, 2014 FILED- OFFI'CL OF THE PROTHOHOTAL; • i 2011.1 SEP 2.9 LI (I: •':J3 CUMBERLAND COUNTY FENNSYLV,VflA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff V. CHRISTINA D FLOR 17 High Street Boiling Springs Pa 17007 Defendant(s) SANTANDER BANK, NA 798 E Simpson St Mechanicsburg Pa 17055 Garnishee NO. 08-4427 PRAECIPE FOR JUDGMENT UPON ANSWERS TO INTERROGATORIES Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_117B Prcp Jdge Bank Ans P&F File No. 762.13003 1 a 4-311(boS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff NO. 08-4427 V. CHRISTINA D FLOR 17 High Street Boiling Springs Pa 17007 Defendant(s) SANTANDER BANK, N.A 798 E Simpson St Mechanicsburg Pa 17055 Garnishee PLAINTIFF'S PRAECIPE JUDGMENT UPON ANSWERS TO INTERROGATORIES AGAINST SANTANDER BANK, N.A ONLY TO: PROTHONOTARY Please enter a judgment against the Garnishee, above named, upon Answer's to Interrogatories attached hereto as Exhibit "A". Amount set forth in Garnishee's Answers: $410.94 Total: $410.94 Date: September 12, 2014 Respectfully submitted: Patena 4FeIix, A.P.C. 1r A s, Esquire Street gie, 5,106 (412) 429-7675 PA _117B Prep Jdge Bank Ans P&F File No. 762.13003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff v. CHRISTINA D FLOR 319 E Main St Mechanicsburg Pa 17055-6516 Defendant(s) SANTANDER BANK, N.A 798 E Simpson St Mechanicsburg Pa 17055 Garnishee NO. 08-4427 INTERROGATORIES IN ATTACHMENT EXECUTION Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_139 Interogs Attch Exe P&F File No. 762.13003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff v. CHRISTINA D FLOR 319 E Main St Mechanicsburg Pa 17055-6516 Defendant(s) SANTANDER BANK, N.A 798 E Simpson St Mechanicsburg Pa 17055 Garnishee OFFICES OF PATENAUDE & FELIX BY: GREGG MORRIS, ESQUIRE 213 East Main St Carnegie PA 15106 858-244-7675 NO. 08-4427 You are hereby notified to plead to the enclosed Interrogatories within 20 days from the date of hereof or a default judgment may be entered against you. Gregg Morris, Esquire Attorney for Plaintiff INTERROGATORIES IN ATTACHMENT EXECUTION You are required to answer the following interrogatories about Defendant(s) whose address is 2432 LOBACH DRIVE , MECHANICSBURG PA 17055-5376. You must file with the Court answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default judgment being entered against you. A copy of said answers must be served on the undersigned. If your answer to any of the following interrogatories is affirmative, specify the amount, value and/or nature of the subject property. PA_139 Interogs Attch Exe P&F File No. 762.13003 . 1. At the time you were served or at any subsequent time, did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed them any money or were you liable to them for any reason? If yes, please specify as set forth herein. NO 2. At the time you were served, or at any subsequent time, was there in your possession, custody or control, or in joint possession, custody or control of yourself or others, any property of any nature owned solely or in party by the Defendant(s)? If yes, please list and describe the property. YES, SEE ATTACHED 3. At the time you were served, or at any subsequent time, did you hold legal title to any property or any nature owned solely or in part by the Defendant(s)? If yes please list and describe the property. NO 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which the Defendant(s) had an interest? If yes, please list and describe the property. NO PA_139 Interogs Attch Exe P&F File No. 762.13003 5. At any time before or after you were served, did the Defendant(s) transfer or deliver any property to you; or,to any person,~or9place.pursuant to your directions or. consent? If yes, what was the consideration therefore?.: . j• NO 6. At any time after you were served, did you pay, transfer, or deliver any money or property to the Defendant(s) or to any person or place pursuant to their direction, or otherwise discharge any claim of the. Defendant(s) against you. NO 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 electroncially on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. NO PA_139 Interogs Atich Exe P&F File No. 762.13003 8. If you are a bank or other financial insitution, 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, indentify each account. NO Date: May 07, 2014 Respectfully submitted: Patenaude & Felix, A.P.C. Gregg L. Morris, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_139 Interogs Attch Exe P&F File No. 762.13003 ANSWERS TO INTERROGATORIES Account # 1791053092 Balance: $710.93 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $410.93. Account. Holder: CHRISTINA D FLOR 1449 ARCONA RD NT MECHANICSBURG, PA 17055-6722 Account # 7672685627 Balance: $0.01 Account Holder: CHRISTINA D FLOR 1449 ARCONA RD NT MECHANICSBURG, PA 17055-6722 VERIFICATION I, John S. Gomes, C.O.P. Lead Specialist of Santander, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment 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. Section 4094, relating to unsworn falsification to authorities. Santander By: John S. Gomes C.O.P. Lead Specialist IN .THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: CAPITAL ONE BANK vs. CHRISTINA D FLOR CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Gregg L Morris, Esquire Patenaude & Felix, A.P.C. 213 East Main St Carnegie, PA 15106 Service by certified mail addressed as follows: CHRISTINA D FLOR 1449 ARCONA RD NT , MECHANICSBURG, PA 170556722 ohn S. Gom C.O.P. Lead Specialist Santander MAI MB3-02-10. 2 Morrisey Boulevard Boston, MA 02125 June 17, 2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff v. CHRISTINA D FLOR 17 High Street Boiling Springs Pa 17007 Defendant(s) SANTANDER BANK, N.A 798 E Simpson St Mechanicsburg Pa 17055 Garnishee ) ) ) NO. 08-4427 ) ) ) ) ) ) ) ) ) NOTICE OF ORDER, DECREE OR JUDGMENT Filed on behalf of: CAPITAL -ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_121 Ntc Jgmt Dl P&F File No. 762.13003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK Plaintiff V. CHRISTINA D FLOR 17 High Street Boiling Springs Pa 17007 Defendant(s) SANTANDER BANK, N.A 798 E Simpson St Mechanicsburg Pa 17055 Garnishee ) ) ) NO. 08-4427 ) ) ) ) ) ) ) ) ) NOTICE OF ORDER, DECREE OR JUDGMENT TO: ( )Plaintiff ( )Defendant ( x ) Garnishee ( )Additional Defendant You are hereby notTied that the following Order, Decree, or Judgment has been entered against you on 9 (AIN ) Decree Nisi in Equity ( ) Final Decree in Equity ( X ) Judgment of ( ) Confession ( ) Verdict ( ) Court Order ( ) Default ( ) Non -suit ( ) Non -Pros ( ) Arbitration Award ( X ) Judgment in the amount of $410.94. ( ) District Justice Transcript of Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Prothonotary By If you have questions concerning the above, please Contact: Name of Attorney: GREGG MORRIS, Esquire 213 East Main St Carnegie PA 15106 (866)-772-7675 PA_121 Ntc igmt D1 P&F File No. 762,13003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK V. CHRISTINA D FLOR SANTANDER BANK, N.A Plaintiff Defendants(s) Garnishee NO, 08-4427 1/2 crk r -n PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY Filed on behalf of: CAPITAL ONE BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA 193 Prcp Disc with Prjdc Garnishee only P&F File No. 762.13003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK V. CHRISTINA D FLOR Plaintiff Defendant(s) NO. 08-4427 PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY TO: Prothonotary Please settle and discontinue the matter captioned above without prejudice as to Garnishee only. Thank you. Date: October 27, 2014 Swor to and subscribed before me this day ofWre)c(2% , 20 ILA Nota OF PENNSYLVANIA Notarial Seal Brandi Tucd, Notary Public City of Pittsburgh, Allegheny County My Commlssloi Expires Dec. 28, 2014 MEME3ER. oFNMSY1 VAN% ASSOCIATION OF NOTARIES Respectful ted: Patenaude elix, A.P.C. quire A 5106 -7675 PA_I 93 Prep Disc with Prjdc Garnishee only P&F File No. 762.13003 I, GREGG MORRIS, attorney for Plaintiff, CAPITAL ONE BANK , hereby certify that a true and correct of the foregoing document was served this date by US First Class Mail, postage prepaid upon the following: SANTANDER BANK, N.A 798 E SIMPSON ST MECHANICSBURG PA 17055 Date: October 27, 2014 orris, Esquire elix, A.P.C. eet , PA 15106 2 429-7675 PA_193 Prep Disc with Prjdc Garnishee only P&F File No. 762.13003