HomeMy WebLinkAbout08-5794IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
NO. G$ • 5g4q D'-'; l lie-rm
v.
ANNA ECKARD
Defendant(s)
COMPLAINT IN CIVIL
ACTION
Filed on behalf of.
CAPITAL ONE BANK (U.S.A.),
N.A.
Counsel of Record for This Parry:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PF_PA_11 Cmplt Cvr Sht P&F File No. 08-22249
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
V.
ANNA ECKARD
Defendant(s)
NOTICE TO DEFEND
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 an 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.
NO.
Usted ha sido demandado en corte. Si usted desea defenderse
de las demandas que se presentan mas adelante en las
siguientes paginas, debe tomar accion dentro de los proximos
veinte (20) dias despues de la notificacion de esta Demanda y
Aviso radicando personalmente o por medio de un abogado
una comparecencia escrita y radicando en la Corte por escrito
sus defensas de, y objecciones a, las demandas presentadas
aqui en contra suya. Se le advierte de que si usted fall de
tomar accion como se describe anteriormente, el caso pude
proceder sin usted y un fallo por cualquier suma de dinero
reclamada en la demanda o cualquier reclamacion o remedio
solicitado por el demandante puede ser dictado en contra suya
por la Corte sin mas aviso adicional. Usted puede perder
dinero o propiedad au otros derechos importantes para usted.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER
AT ONCE.IF YOU DO NOT HAVE A LAWYER GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS
OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR
ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
USTED DEBE LLEVAR ESTE DOCUMENTO A SU
ABOGADO INMEDIATAMENTE. SI USTED NO TIENE
UN ABOGADO, LLAME O VAYA A LA SIGUENTE
OFICINA. ESTA OFICINA PUEDE PROVEERLE
INFORMACION A CERCA DE COMO CONSEGUIR UN
ABOGADO
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE
UN ABOGADO, ES POSSIBLE QUE ESTA OFICINA LE
PUEDA PROVEER INFORMACION SOBRE AGENCIAS
QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O
BAJO COSO A PERSONAS QUE CALIFICAN.
CUMBERLAND COUNTY BAR
ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
PA_21Notice to Defend P&F File No. 08-22249
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A. )
Plaintiff )
V. )
ANNA ECKARD )
Defendant(s) )
COMPLAINT IN .IVIL ACTION
NO. Of- S79I
AND NOW, comes Plaintiff, CAPITAL ONE BANK (U.S.A.), N.A., by and through its
attorney, GREGG MORRIS, ESQUIRE and the law offices of PATENAUDE & FELIX, A.P.C.
and files the following Complaint in Civil Action, and in support thereof aver as follows:
1. Plaintiff, CAPITAL ONE BANK (U.S.A.), N.A., is a corporation and for the
purpose of this litigation, maintaining a place of business c/o PATENAUDE AND FELIX,
A.P.C., 213 East Main St Carnegie, Pennsylvania 15106.
2. Defendant is ANNA ECKARD, an adult individual, believed to currently reside
at 36 N 41ST ST CAMP HILL, PA 17011-6775.
3. Heretofore, the Defendant(s) opened a account with Plaintiff being Account No.
5178052627345693, for the purchase of good and services.
4. The Defendant(s) has/have made or authorized a number of purchases and as of
January 29, 2007, Defendant(s) owes $839.13 on said account plus interest at 20.40 %.
5. Plaintiff maintains accurate books of account recording all credits and debits for
this account.
PA_05 Civil Cmplt Crdt Crd P&F File No. 08-22249
6. The Defendant(s) have/has received monthly billing statements from Plaintiff
setting forth the nature and amount of all charges made by Defendant(s), and the transactions
between Plaintiff and Defendant(s) give rise to an account stated, upon which Plaintiff has relied.
7. The Defendant(s) made payments, but have/has refused to pay, and now refuses to
pay the balance due and owing on the aforesaid account in the sum of $839.13, plus interest and
costs.
8. By failing to object or dispute the statements, Defendant(s) have/has assented to
and agreed to the correctness of the balance due on the credit card account so as to constitute and
account stated.
9. Despite repeated demands, Defendant(s) have/has failed to make the required
installment payments when due and therefore the full amount of the account is now due and
payable.
PA 05 Civil Cmplt Crdt Crd P&F File No. 08-22249
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in
the amount of $839.13, plus interest as set forth herein from the date of breach, with continuing
interest at the legal rate thereon from the date of Judgment plus costs. The damages requested
are less than the maximum amount for compulsory arbitration as set by the Court.
submitted:
Felix, A.P.C.
Date: July 16, 2008
egg L. orris, Esquire
13 E. ain Street
t'?
PA 15106
(4
429-7675
PA-05 Civil Cmplt Crdt Crd P&F File No. 08-22249
VERIFICATION
The undersigned, Gregg L. Morris, hereby states that he is the attorney for Plaintiff in
this action and verifies that the statements made in the foregoing pleading are true and correct to
the best of his knowledge, information and belief. Counsel has signed the verification at the
request of Plaintiff as a matter of time and convenience. Plaintiff has represented to counsel that
there is a debt due and owing from Defendant to Plaintiff in the amount as set forth within the
foregoing pleading. Plaintiff has provided counsel with all relevant information in order to allow
counsel to sign this verification. Plaintiff agrees to provide a verification signed by Plaintiff
upon request by Defendant. The statements are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unworn falsification to authorities. I
Date: July 16, 2008
(ire g L. orris, Esquire
P e a e & Felix, A.P.C.
3 ain Street
Carnegie, PA 15106
(412) 429-7675
PA-01 Atty Verification P&F File No. 08-22249
[ 00
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-05794 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA N A
VS
ECKARD ANNA
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
ECKARD ANNA the
DEFENDANT , at 0009:09 HOURS, on the 4th day of October
at 36 N 41ST STREET
CAMP HILL, PA 17011
by handing to
ANNA ECKARD DEFENDANT
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
Service
Affidavit
Surcharge
R
So Answers:
18.00
14 . 0 0
.00
10.00 R. Thomas Kline
.00
J 42.00 10/07/2008
PATENAUDE ° FE IX
Sworn and Subscibed to By:
before me this day
of A.D.
2008
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
NO. 08-5794
V.
ANNA ECKARD
Defendant(s)
PRAECIPE FOR DEFAULT
JUDGMENT
Filed on behalf of:
CAPITAL ONE BANK (U.S.A.),
N.A.
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_119 Prcp Def Jg Both P&F File No. 08-22249
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
NO. 08-5794
V.
ANNA ECKARD
Defendant(s)
PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
Please enter a judgment against the defendant, above named, for failure to file an Answer
to Plaintiffs complaint.
Amount claimed in Complaint
Interest from January 29, 2007
Less payments received
Attorney's fees
TOTAL
$839.13
$294.58
$0.00
$0.00
$1,133.71
With continuing interest on the principal amount of $1,133.71, with interest at the legal
rate, plus costs of suit.
I hereby certify that a written notice of intention to file this praecipe was mailed to the
defendants and defendants' counsel (if known), after the default had occurred and at least ten
(10) days prior to the date of the filing of this praecipe. A copy of the Notice is attached.
Resp ctfu y submitted:
Pat aude Felix, A.P.C.
Date: November 05, 2008
Gr gg L. orris, Esquire
21 E. in Street
C eg', PA 15106
(41) 9-7675
PA_119 Prep Def Jg Both P&F File No. 08-22249
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
V.
ANNA ECKARD
Defendant(s)
NO. 08-5794
PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF
NOTICE PURSUANT TO PA.R.C.P. 1037(b)
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND
Before me, the undersigned authority, a Notary Public in and for said County and State,
personally appeared GREGG MORRIS, attorney for and authorized representative of Plaintiff,
who being duly sworn according to law, deposes and states that the defendant(s), ANNA
ECKARD, is not in the military service of the United States of America to the best of his
knowledge, information and belief and certifies that Notice of Intent to take Default Judgment
was mailed in accordance with Pa.R.C.P.237.1, as evidenced by the attached copy.
& Felix, A.P.C.
Date: November 05, 2008
Greg] L. Mom's, Esquire
21 Main Street
C egie, P 15106
(4 VA) 429-7675
Sworn to and subscribed before me this
day of WDV . , 200:K
Notary P lic
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Carolyn J. Stewart Notary Public
mwj" County
Cameoe
My Commission Fires Aug. 114 2011
Member, Pennsylvania Association of Notaries
PA-1 20 Aff of Non Mil P&F File No. 08-22249
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
NO. 08-5794
V.
ANNA ECKARD
Defendant(s)
IMPORTANT NOTICE
Filed on behalf of:
CAPITAL ONE BANK (U.S.A.), N.A.
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_113 10 Day Dl D2 P&F File No. 08-22249
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
NO. 08-5794
V.
ANNA ECKARD
Defendant(s)
To: ANNA ECKARD
36 N 41ST ST
CAMP HILL PA 17011-6775
Date of Notice: October 28, 2008
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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle PA 17013
717-249-3166
Date: October 28, 2008
PA-1 13 10 Day DI D2
Pate ,nude A.P.C.
/ le"', , ,
Esquire
213 reet
Ca
r 5106
reV9-7675
(412P&F File No. 08-22249
I, GREGG MORRIS, attorney for Plaintiff, CAPITAL ONE BANK (U.S.A.), N.A., hereby
certify that a true and correct copy of foregoing document was served this date by ordinary mail upon
the following:
Anna Eckard
36 N 41St St
Camp Hill PA 17011-6775
Date: October 28, 2008
Gr gg L. orris, Esquire
P enau e & Felix, A.P.C.
3 AE ain Street
gie, PA 15106
(412) 429-7675
PA_111 10 Day Dl P&F File No. 08-22249
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
NO. 08-5794
V.
ANNA ECKARD
Defendant(s)
NOTICE OF ORDER, DECREE
OR JUDGMENT
Filed on behalf of.
CAPITAL ONE BANK (U.S.A.),
N.A.
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_123 Ntc Jgmt Both P&F File No. 08-22249
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
V.
ANNA ECKARD
Defendant(s)
NO. 08-5794
NOTICE OF ORDER DECREE OR JUDGMENT
AGAINST ANNA ECKARD ONLY
TO: ( )Plaintiff ( x )Defendant ( )Garnishee ( )Additional Defendant
You are hereby notified that the following Order, Decree, or Judgment has been entered
against you on - k)cgj , J 3 .2 D?? _•
( ) Decree Nisi in Equity
( ) Final Decree in Equity
( X) Judgment of ( ) Confession ( ) Verdict ( ) Court Order
( X) Default ( ) Non-suit
( ) Non-Pros ( ) Arbitration Award
( X ) Judgment in the amount of $1,133.71, plus costs.
( ) 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.
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_123 Ntc Jgmt Both P&F File No. 08-22249
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 08-5794 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CAPITAL ONE BANK (U.S.A.) N. A. Plaintiff (s)
From ANNA ECKARD, 36 NORTH 41sT STREET, CAMP HILL, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
CITIZENS BANK OF PA, 665 NORTH EAST STREET, CARLISLE, PA 17013 - LIS PENDENS
AGAINST ALL REAL PROPERTY OF THE DEFENDANT IN THE NAME OF THE
GARNISHEE.
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$674.77 L.L. $.50
Interest from November 13, 2008 at 6.00% per annum - $91.06
Atty's Comm % Due Prothy $2.00
Atty Paid $161.50
Other Costs
Plaintiff Paid
Date: 6/24/11 -
David D. Buell, Prothon ary
(Seal) By:
Deputy
REQUESTING PARTY:
Name GREGG L. MORRIS, ESQUIRE
Address: PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-429-7675
Supreme Court ID No. 69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
V.
ANNA ECK
?36 ?, y 1 bTT ?.
Defendant(s)
NO. 08-5794
CITIZENS BANK OF PA )
U U $ wi. cccz6 S, Garnishee )
COx?S? ? P? i?o13
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, ANNA ECKARD Defendant(s);
(3) against, CITIZENS BANK OF PA, Garnishee;
(4) and index this writ
(a) against, Defendant(s) ANNA ECKARD, Defendant(s); and
(b) against CITIZENS BANK OF PA, Garnishee;
i..,
IV rv.a
?
2p
?;•x N
as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows:
(5) Amount due
Interest from November 13, 2008
At 6.00 % per annum
Court Cost
Less: Payment
Total
Gtnti? $ ay. so ?d a 1?
00 cer-
q a. So
1 Y. 00 u u
CD So u a
PA_134 Prcp Writ of Exe
$1,133.71
$91.06
$0.00
$550.00
$674.77 s costs
Attorvlevffof 1laintiff
&a•ovT" CJ6
..5a"
Ckasw;7
v P&I File No. 08-22249
100 C j
W, ,T 0 ? s Tsu 6
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A. )
Plaintiff ) NO. 08-5794
V.
ANNA ECKARD
Defendant(s)
CITIZENS BANK OF PA
Garnishee
WRIT OF EXECUTION NOTICE
Filed on behalf of:
CAPITAL ONE BANK (U.S.A.),
N.A.
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 136 Writ of Exe Ntc P&I File No. 08-22249
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson o 71
Sheriff `?tti,, of wa+,+Firry??l0 rrrIOD ` -?
Jody S Smith r-
--
Chief Deputy r
-Orr,
o
Richard W Stewart r- --to
Solicitor Co =s =--n
3
?G
Capital One Bank (U.S.A.) N.A. Case Number
vs. 2008-5794
Anna M Eckard
SHERIFF'S RETURN OF SERVICE
07/01/2011 03:30 PM - 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, Citizens Bank at 665 North East Street, Carlisle Borough, Carlisle, PA 17013,
Cumberland County, by handing to TABI STARZMAN TELLER, personally 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 July 5, 2011 to Anna Eckard at 36 N. 41 st
Street, Camp Hill, Pennsylvania, 17011.
SO ANSWERS,
July 05, 2011 RON R ANDERSON, SHERIFF
Denn ' Fry, D ut eri f f
(ci CountySuite `i "ei ff. Te!ecs'oft I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL DIVISION
CAPITAL ONE BANK USA NA,
Plaintiff(s),
vs.
ANNA ECKARD,
Defendant(s),
vs.
Citizens Bank of Pennsylvania,
No. 08-5794
Answers to InterrogatorieAc r-- c 'y :-
r -70
CD
Code: 200 Execution !Z: c7 0
-ta CD
? ,
c'
Filed on Behalf of Garnishee
, _
Citizens Bank of Pennsylvania
Counsel of Record for
this Parry:
Garnishee.
Stradley, Ronon, Stevens & Young
Great Valley Corporate Center
30 Valley Stream Parkway
Malvern, PA 19355-1481
(484) 323-1351
(610) 640-1965 fax
ndeenis(c,stradle com
www.stradley.com
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL DIVISION
Capital One Bank (USA), N. A.
Plaintiff(s),
VS.
Anna Eckard
Defendant(s),
and
Citizens Bank of Pennsylvania,
Garnishee.
No. 08-5794
ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK
The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of
the Plaintiff(s):
(NUMBERS 1 to 8) At the time of service of above-captioned Writ of Execution and to the
present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories:
The Garnishee, Citizens Bank of PA, states that it maintains no open accounts in the name of
the Defendant: Anna Eckard, accordingly, no funds are being held subject to this Writ of
Execution.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY SS:
Before me, the undersigned authority, a Notary Public in and for said
Commonwealth and County, personally appeared Laura Noel who being duly sworn
according to the law deposes and says that she is the Legal Clerk, Operations Services, and
that the statements set forth in foregoing Answers to Interrogatories are true and correct to the
best of her knowledge, information, and belief.
aura Noel
COMMONWEALTH OF PENNSYLVANIA
Notarlai Seal
Bruce D. Mountjo , Notary Public
City of Pittsburgh iheghenj County
My Commission Expires June 14, 2014
Member. Pennsvlvania Association of Notaries
Sworn and subscribed before
me this 07' day of
1-JVV-1 , 2011.
Certificate of Service
I, Laura Noel, hereby certify that a true and correct copy of the Answers to
Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage
prepaid, this day of U , 2011.
Gregg L. Morris
Patenaude & Felix, A. P. C.
213 E. Main St.
Carnegie, PA 15219
Laura oel
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff
V.
ANNA ECKARD
Defendants(s)
CITIZENS BANK OF PA
Garnishee
NO. 08-5794
,
--; r-
PRAECIPE TO SETTLE
AND DISCONTINUE WITHOUT
PREJUDICE AS TO
GARNISHEE ONLY
Filed on behalf of:
CAPITAL ONE BANK (U.S.A.),
N.A.
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 Pr do Garnishee only P&F File No. 08-22249
0,14 2 a,lb pbl a)?
C44 S(040
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CAPITAL ONE BANK (U.S.A.), N.A.
Plaintiff )
NO. 08-5794
V. )
ANNA ECKARD )
Defendant(s) )
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: July 28, 2011
Sworn to and subscribed before me this
,;V3 day of 20_ IA_.
Notary Public
F OTARIAL SEAL
LWOA S PERRY
Netrll y Public
MO..ALLEG"ENY COUNTY
sion Expires Jun 2, 204
PA_193 Prcp Disc with Pddc Gamishee only P&F File No. 08-22249
YA ? A CIPljW-
'.11WO'i Jt%Af V
I, GREGG MORRIS, attorney for Plaintiff, CAPITAL ONE BANK (U.S.A.), N.A.,
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:
CITIZENS BANK OF PA
665 NORTH EAST STREET
CARLISLE PA 17013
Date: July 28, 2011
?f
Gregg . 's, quire
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Ctrne 'e, PA 151
(412)A29-7675
PA_193 Prcp Disc with Pddc Garnishee only P&F File No. 08-22249
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Anderson
S Smith
;ef Deputy
I" ILED-OFFICi
rt, THE PROTHONOTAR'?
2012 FEB 17 PM 2: 23
Richard W Stewart
Solicitor
nFP1C-OP '. c -RFF
CUMBERLAND COUNT`'
PENNSYLVANIA
Capital One Bank (U.S.A.) N.A.
vs.
Anna M Eckard
Case Number
2008-5794
SHERIFF'S RETURN OF SERVICE
07/01/2011 03:30 PM - 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, Citizens Bank at 665 North East Street, Carlisle Borough, Carlisle,
PA 17013, Cumberland County, by handing to TABI S`TARZMAN TELLER, personally 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 July 5, 2011 to Anna Eckard at 36 N. 41st
Street, Camp Hill, Pennsylvania, 17011.
02/16/2012 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: $88.58 SO ANSWERS,
February 16, 2012 RON R ANDERSON, SHERIFF
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