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HomeMy WebLinkAbout08-5888Unifund CCR Partners In the Court of Common Pleas of c/o Edwin A. Abrahamsen & Assoc. CUMBERLAND County, Pennsylvania 1729 Pittston Avenue Civil Division Scranton, PA 18505 Plaintiff vs. RONALD A NEILL 212 E MAIN ST APT 1 CAMP HILL PA 17011 NO: M - 5898 Civit-Terw.. . PRAECIPE FOR ENTRY OF JUDGMENT Defendant . To the Prothonotary of CUMBERLAND County: 1) Enter Judgment on the attached Certified copy of Judgment from a District Justice. A) Date of Instrument: 4/18/08 B) Amount of Judgment: $6,542.63 C) Interest From: 4/18/08 2) Enter the judgment in favor or the original holder, or (unless expressly forbidden in the instrument) in favor of the assignee or other transferee; 3) I hereby certify that the address of the plaintiff is: Unifund CCR Partners c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 4) I hereby certify that the address of the defendant is: RONALD A NEILL 212 E MAIN ST APT 1 CAMP HILL PA 17011 Michael F. Ratchford„ EsquirpAttorney for Plaintiff Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Associates, P.C. 1729 Pittston Ave, Scranton, PA 18505 570-558-5510 Ext. 101 Attorney ID 86285 COMMONWEALTH OF PENNSYLVANIA COUNTY nF• C01®ERL111ND Mag. Dist. No.: 09-1-01 MDJ Name: Hon. cR> RLZS A. CLEUMT, sR Address: 400 BRIDGE ST OLDS TONNE COMONS -SUITE 3 NEW C`WMZRL zD, PA Telephone: (717 ) 774-5989 17070 0NIl0ND CCR PARTNERS 1729 PITTSTON AVE BEN i ASSOC PC SCRANTON, PA 18505 THIS IS TO NOTIFY YOU THAT: Judgment: FOR PLAINTIFF NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS r=XFM D CM PARTNERS ? 1729 PITTSTON AVE ABBAEAMOZIF A ASSOC PC LBCRA>INTON, PA 18505 J VS. DEFENDANT: NAME and ADDRESS rNEILL - , RONALD A I 212 E MAIN ST APT/STE 1 CAM HILL, PA 17011 L J Docket No.: CV-0000087-08 Date Filed: 2/11/08 (Date of Judgment) 4/18/08 T Judgment was entered for: (Name) ONIFOND CCR PARTNERS © Judgment was entered against. (Name) NEILL, RONALD A in the amount of $ 6, 542.6) F1 Defendants are jointly and severally liable. Damages will be assessed on Date & Time This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 5,110 50 Judgment Costs $-154.3b Interest on Judgment $ • Attorney Fees $ 1,277.63 Total $ 6,542.63 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. APR 18 2008 Date I certify that this is a true Date rrect/?copy o the cord of the p IA(L r the cord - -.<:Zs? My commission expires first Monday of January, 2014 AOPC 315-07 DATE PRINTED: 4/18/08 9s4900 AN Magisterial District Judge containing the judgment. , Magisterial District Judge SEAL ri*? 1353 Unifund CCR Partners c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division Plaintiff NO: vs. RONALD A NEILL 212 E MAIN ST APT 1 CAMP HILL PA 17011 AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED Defendant State of Pennsylvania County of CUMBERLAND SS: Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): RONALD A NEILL is(are) not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; That the defendant(s): RONALD A NEILL is(are) older than eighteen years of age; That the employment status of the defendant(s): RONALD A NEILL is(are) unknown. ?C C) # 8 w} L_ N `= rj Q -t -TI t "? r Co N `?j? CA) Unifand CCR Partners In the Court of Common Pleas of c/o Edwin A. Abrahamsen & Assoc. CUMBERLAND County, Pennsylvania 1729 Pittston Avenue Civil Division Scranton, PA 18505 Plaintiff NO: VS. RONALD A NEILL NOTICE OF FILING JUDGMENT 212 E MAIN ST APT 1 CAMP HILL PA 17011 Defendant Notice is herby given that a money judgment in the above-captioned matter has been entered against you in the amount of $ to 5 µo1,. Loa on tall ml By: If you have any questions regarding this notice, please contact the filing parry: Edwin A. Abrahamsen & Associates 1729 Pittston Avenue Scranton, PA 18505 Telephone: (570)-558-5510 (Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Unifund CCR Partners CIVIL DIVISION Plaintiff VS. NO: 08-5888 RONALD A NEILL Defendant PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S RESPONSES TO INTERROGATORIES IN AID OF EXECUTION Plaintiff, Unifund CCR Partners, by and through its attorneys, Edwin A. Abrahamsen &Associates, P.C., files its Motion to Compel the Defendant's Responses to Interrogatories in Aid of Execution as follows: I . Plaintiff, Unifund CCR Partners,obtained a judgment against the Defendant in regard to an outstanding, past due and defaulted credit card account. 2. On October 20, 2008, Plaintiff served Defendant with Interrogatories in Aid of Execution on the subject judgment. (See , Interrogatories in Aid of Execution dated October 20, 2008, attached hereto and marked Exhibit "A ". ) 3. Defendant failed to respond to the Interrogatories in Aid of Execution within the time permitted by the Pennsylvania Rules of Civil Procedure. 4. On November 26, 2008, Plaintiff sent a letter to remind the Defendant of the past due responses and his duty to provide the same. (See, Correspondence to Defendant, attached hereto and marked Exhibit "B ". ) 1 5. Defendant still failed and refused to respond to the Interrogatories in Aid of Execution or respond to Plaintiffs counsel in any manner. 6. On December 17, 2008, Plaintiffs counsel notified Defendant that he intended to present to the court the within Motion to Compel Defendant's Response to Interrogatories in Aid of Execution if Defendant continued to fail to provide the responses. (See, Correspondence to Defendant, attached hereto and marked Exhibit "C'.) 7. Pursuant to the Pennsylvania Rules of Civil Procedure Defendant should have responded to the Interrogatories within 30 days. 8. More than 30 days have passed since Defendant was served with the Interrogatories in Aid of Execution. WHEREFORE, Plaintiff request this Honorable Court to grant the within Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution and direct Defendant to provide full and complete response to the Interrogatories in Aid of Execution within 20 days upon penalty of sanctions, and that Plaintiff be awarded attorney's fees, costs and such other relief as the court deems just and appropriate. Respectfully submitted, BYy?/ / Edwin A. Abr sen & Associates, P.C. Michael F. R ford, Esquire Heather K. o druff, Esquire Attorney I . Nos: 86285/207805 120 No Keyser Ave Scrant , Pa 18504 Phone: 570-558-5510 Fax: 570-558-5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Unifund CCR Partners CIVIL DIVISION Plaintiff VS. NO: 08-5888 RONALD A NEILL Defendant PLAINTIFF'S BRIEF IN SUPPORT OF ITS MOTION TO COMPEL DEFENDANT'S RESPONSES TO INTERROGATORIES IN AID OF EXECUTION Plaintiff, Unifund CCR Partners, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., submits its Brief in Support of its Motion to Compel the Defendant's Responses to Interrogatories in Aid of Execution as follows: 1. STATEMENT OF FACTS Plaintiff, Unifund CCR Partners, obtained a judgment against the Defendant in regard to an outstanding, past due and defaulted credit card account. On October 20, 2008, Plaintiff served Defendant with Interrogatories in Aid of Execution of the subject judgment. (See, Interrogatories in Aid of Execution, dated October 20, 2008, attached hereto and marked Exhibit "A.') Defendant failed to respond to the Interrogatories in Aid of Execution within the time permitted by the Pennsylvania Rules of Civil Procedure. On November 26, 2008, Plaintiff sent a letter to Defendant concerning the past due responses. (See, Correspondence attached hereto and marked Exhibit "B.') Plaintiff still failed and refused to respond to the Interrogatories in Aid of Execution or respond to Plaintiffs counsel in any manner. On December 17, 2008, Plaintiffs counsel notified Defendant that he intended to present to the court the within Motion to Compel Defendant's Response to Interrogatories in Aid of Execution if Defendant continued to fail to provide the responses.(See Correspondence to Defendant, attached hereto and marked Exhibit "C.') Pursuant to the Pennsylvania Rules of Civil Procedure Defendant should have responded to the Interrogatories within 30 days. More than 30 days have passed since Defendant was served with the Interrogatories in Aid of Execution. II. QUESTION PRESENTED Whether Plaintiffs Motion to Compel Defendant's responses to discovery requests should be granted when the responses are more than 30 days past due. Suggested answers: Yes III. LEGAL ARGUMENT Pursuant to the Pennsylvania Rules of Civil Procedure Defendant should have responded to the Interrogatories in Aid of Execution within thirty (30) days after service thereof. More than thirty (30) days have passed since defendant was served with the Interrogatories in Aid of Execution, however, Defendant has not answered, objected or responded in any manner to the Interrogatories or to the notice sent by Plaintiffs counsel. IV. CONCLUSION Plaintiff requests this Honorable Court to grant the within Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution and direct Defendant to provide full and complete response to the Interrogatories in Aid of Execution within twenty (20) days upon penalty of sanctions, and that Plaintiff be awarded attorney's fees, costs and such other relief as the court deems just and appropriate. Respectfully submitted, B E win A. Abrah sen & Associates, P.C. ??Michael F. Rat ford, Esquire Attorney I.D. o.: 86285 VERIFICATION I, Michael F. Ratchford, Esquire, attorney for Plaintiff, Unifund CCR Partners am fully familiar with the facts set forth in the within Motion to Compel Defendent's Response to Interrogatories in Aid of Execution and am authorized to make this Verification on behalf of Plaintiff. I verify that the facts set forth in the within Motion are true and correct to the best of my knowledge, information and belief. I know that any false statements are punishable by law pursuant to 18 C.S.A. §4904. EDWIN A. ABRAHAtASEPI MICHAEL F. RA7CHFORE, HEATHER K. WOODRUFF" ' ALSO A MEMBER OF FL BAR iitt THE LAW OFFICE OF EDNA IN A. ABPATLVALSEN & AE cO(M--U E4. PC WWW.EAA-LAW.COkI October 20, 2008 RONALD A NEILL 212 E MAIN ST APT 1 CAMP HILL PA 17011 RE: Unifund CCR Partners/CHASE MANHATTAN BANK USA vs. RONALD A NEILL File # U07-1353 Balance: $6,741.61 Dear Sir/Madam: Enclosed please find Interrogatories for Discovery of Assets in Aid of Execution, which have been propounded in accordance with the applicable Pennsylvania Rules of Civil Procedure. Full and complete instructions concerning your duty to Answer and the penalties for failure to Answer are contained in the Interrogatories. Please read the instructions carefully. You are to note your answers on the original and return it to this office after it is properly notarized. Please be aware that under the Rules of Court, we can and will, have our attorney's fees and expenses of all discovery Proceedings and Sanction Hearings charged against you as "additional costs" for which you will be responsible. In the alternative, you may make arrangements to pay the balance owed before the thirty (30) days to Answer the Interrogatories expire. Either the balance must be paid to us or the Interrogatories answered within thirty (30) days from the receipt of this letter. This is an attempt to collect a debt and any information obtained will be used for that purpose. This is a communication from a debt collector. Edwin A. Abrahamson & Associates, P.C. .,/ ,..A r 1 /mjw//J,' ems,,, Heather K. Woodruff, Esquire 1729 PITTSTON AVENUE SCRANTON, PA 18505 (P) 570.550.5510 . (F) 570.558.5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Unifund CCR Partners, assignee of CHASE MANHATTAN BANK USA Plaintiff -vs- NO.08-5888 RONALD A NEILL Defendant INTERROGATORIES FOR DISCOVERY OF ASSETS IN AID OF EXECUTION DIRECTED TO JUDGMENT DEB'T'OR Because you have failed to pay the full amount of the Judgment previously entered against you, the Judgment-Creditor, to who you are indebted, has a right to attempt to enforce that Judgment by a Judicial Sale (Sheriffs Sale) of your assets, and has a right to inquire concerning the existence and location of those assets. Therefore, pursuant to the applicable Rules of Court, you are required to make full and complete Answers to the questions set forth in the following pages. These Answers must be made in writing, under oath, within thirty (30) days after service upon you. You are warned that, should you fail to do so, the Court may make an Order imposing punishment for Contempt of Court. Please, if you do not understand your duty to answer these questions, you should consult a lawyer. If you do not have or know a lawyer, then you should find out where you can get legal help, such as your local County Bar Association or Lawyer Reference Service. PORTIONS OF THE APPLICABLE PENNSYLVANIA RULES OF CIVIL PROCEDURE CONCERNING DISCOVERY OF ASSETS IN AID OF EXECUTION " Rule 3117. Discovery in Aid of Execution. (a) Plaintiff, at any time after judgment, before or after the issuance of a writ of execution, may, for the purpose of discovery of assets of the defendant, take the testimony of any person, including a defendant or a garnishee, upon oral examination or written interrogatories as provided by the rules relating to Depositions and Discovery ...... (b) All reasonable expenses in connection with the discovery may be taxed against the defendant as costs if it is ascertained by the discovery proceedings that he has property liable to execution" (emphasis added) " Rule 4005. Written Interrogatories to a Party. (a) ......any party may serve upon any other party written interrogatories to by answered by the party served...... who shall furnish such information as is available. " Rule 4006. Answers to Written Interrogatories by a Party. (a) (1) Answers to interrogatories shall be in writing and under oath. The answers shall be inserted in the spaces provided in the interrogatories. Ifthere is insufficient space to answer an interrogatory, the remainder of the answer shall follow on a supplemental sheet. (b) (2) Each interrogatory shall be answered fully and completely unless objected to, in which event the reasons for the objection shall be stated in lieu of an answer.... The answering party shall file and serve a copy of the answers and objections, if any, within 30 days after the service of the interrogatories....." "Rule 4019. Sanctions. (a) (l) The court may, on motion, make an appropriate order if . (i) a party fails to serve answers, sufficient answers, or objections to written interrogatories under Rule 4005.... (c) The Court, when acting under Subdivision (a) of this rule, may make...... (4) an order imposing punishment for contempt....." (emphasis added) INTERROGATORIES 1. Please state the following: (a) The full name, age and Social Security number of the person who is answering these Interrogatories. ANSWER: (b) Phone number, address and how long at this address. ANSWER: 2. REAL ESTATE: Do you have an ownership or interest in any real estate anywhere in the United States? If so, set forth a brief description thereof, included the structure and lot size and type of construction; the location, including the state, county and municipality; the volume and page number of the official record thereof; and state further whether you own is solely or together with any other person or persons and give their full names and addresses. ANSWER: (b) If any of the above properties are mortgaged, supply the names and addresses of lenders, the date and amount of the mortgage, where it is recorded, the monthly payments and the balance now due. ANSWER: 3 GOVERNMENT MUNICIPAL or CORPORATE BONDS: State whether or not you own individually or jointly any corporate or government bonds. If so, include the face amount, serial numbers and maturity date and state the present location thereof. If you own any of these Bonds jointly with any other person or persons, give their name and address. ANSWER: 4. STOCKS, SHARES or INTEREST: State whether or not you own any stocks; shares or interest in any corporation, or unincorporated association or partnership interest, limited or general and state the location thereof. Include the names and addresses of the organizations and the serial numbers of the shares or stocks. If you own any of the Stocks, Shares or Interest jointly with any other person or persons, give their name and address. ANSWER: 5. ACCOUNTS: State whether or not you maintain any checking or savings accounts. If so, state the name and location ofthe banks or savings and loan association or building and loan association or credit union and the branch or branches thereof, the identification numbers of those accounts, and the amount or amounts you have in each account. If you maintain any of these jointly with another person, give their name and address. State whether safety deposit. ANSWER: b. PERSONAL PROPERTY: State whether or not you own any personal property. Include a full description of all furnishings and any other items of personal property (including jewelry) with fiill description, value and present location. State also whether or not there are any encumbrances on that property and if so, the name and address of the encumbrance holder, the date of the encumbrances, the original amount of that encumbrance, the present balance of that encumbrance and the transaction which gave rise to the existence of the encumbrance. If you own a personal property jointly with any other person or persons, give their name and address. ANSWER: 7. MOTOR VEHICLES: State whether or not you own motor vehicles. Include a full description of such motor vehicles including color, model, title number, serial number and registration plate number. Also show the exact name or names in which the motor vehicles are registered, the present value of those motor vehicles and their present location and place of regular storage, garaging or parking. State also whether or not there are any encumbrances on those motor vehicles and if so, the name and address ofthe encumbrance holder, the date of the encumbrance, the original amount of that encumbrance, the present balance of the encumbrance and the transaction which gave rise to the existence of the encumbrance. ANSWER: 8. RENTAL INCOMES: State whether you are the recipient, directly or indirectly, of any income for the rental of any real or personal property: and if so, state specifically the source of payment, the person to whom such payments are made and the amount and date when those payments are received. ANSWER: Edwin A. Abrahamsen & Associates, P.C. ks"O(fj-k DATED:. BY; . It Attorneys for Plaintiff ) AFFIDAVIT COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA ) SS Before me, the undersigned authority personally appeared who, being duly sworn according to law, deposes and says that the foregoing Answers to Interrogatories For Discovery of Assets in Aid of Execution are true and correct to the best of the aftiant's knowledge, infonration and belief. SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF ,20 AFFIANTS SIGNATURE AFFIANTS ADDRESS NOTARY PUBLIC TITLE OF OFFICIAL EDWIN A. ABRAHAMSEN MICHAEL F. RATCHFORD HEATHER K. WOODRUFF' 'ALSO MEMBER OF FL BAR RONALD A NEILI_ 212 E MAIN ST APT CAMP HILL PA 17011 RE: Creditor: Unifund CCIZ Partners November 26, 2008 Original Creditor: CHASE MANHATTAN BANK USA Original Account Number: 521 1501223020281 Balance Due: $6,7$1.40 Our File #: U07-1353 Dear RONALD A NEILI..: You recently received a series of Interrogatories in Aid of Execution from Edwin A. Abrahamsen & Associates, P.C. regarding a judgment that has been obtained against you by Unifund CCR Parfners . According to the Pennsylvania Rules of Civil Procedure, YOU had thirty clays to provide this office with vour reply to the interrogatories. To date, my office has not received a reply. Please provide an answer to these Interrogatories. or contact ow' office within the next 15 days; or appropriate steps may be utken with the court to Compel VOU to answer them. This is an important matter that requires your attention. Verv truly yours, 1\13 Heather K. Woodruff, Esq. 0 Edwin A. Abrahamsen & Associates, C. This is a communication from a debt collector in an attempt to collect a debt. Any information obtained will be used for that purpose. THE LAW OFFICE OF EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C. WWW.EAA-LAW.COM 1 729 PITTSTON AVE. • SCRANTON, PA 1 8505 0 (P) 570.558.551 0 • (F) 570.556.551 1 EDWtN A. AORAHAMOEN MICHAEL F. RATCHFORD HEATHER K. WOODRUFF- •ALSO MEMBLR OF FL BAR THE LAW OFFICE OF EOWiN A. ABRAHAMBEN & ASSOCIATES, P.C. WWW.EAA-LAW.COM December 17, 2008 RONALD A NEILL 212 E MAIN ST APT I CAMP HILL PA 17011 Re: Unifund CCR Partners v. RONALD A NEILL CUMBERLAND County Civil Action No.: CV-0000087-08 Our File #: U07-1353 Dear RONALD A NEILL: As you know, on October 20, 2008, you were served with Interrogatories in Aid of Execution in regard to the above-noted matter, to which you have failed to respond. As a result, please be advised that if I do not receive your responses within ten (10) days of the date of this letter, I intend to file a Motion to Compel your Responses to Interrogatories in Aid of Execution in the CUMBERLAND Court of Common Pleas. If you wish to discuss this issue or a reasonable resolution of this matter, please contact me at 570-558-5510. Thank you. Edwin A. Abrahamsen & Associ Michael F. eRatcoh'f: . sa_ This is a communication from a debt collector in an attempt to collect a debt. Any information obtained will be used for that purpose. 1 729 PITTSTON AVE. 0 SCRANTON, PA 1 8505 • (P) 570.55B.551 0 • (F) 570.55B.551 1 MLED-t WE PRQTHMTARY 2009 OCT -2 PM 12: 4 9 y? Unifund CCR Partners Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. RONALD A NEILL Defendant CIVIL DIVISION NO: 08-_5888 CERTIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that I caused a true and correct copy of the within Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution, Brief in Support thereof, Notice of Presentation and Proposed Order via first class United States Mail, postage prepaid on the date set forth below upon the following: RONALD A NEILL 212 E MAIN ST APT 1 CAMP HILL PA 17011 Date: J HLE tFICE OF THE PROTHONOTARY 2009 OCT -2 P'M 12:4 9 PENNSYLVANIA UNIFUND CCR PARTNERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW RONALD A. NEILL, Defendant NO. 08-5888 CIVIL TERM ORDER OF COURT AND NOW, this 8 h day of October, 2009, upon consideration of Plaintiffs Motion To Compel Defendant's Responses to Interrogatories in Aid of Execution, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 21 days of service. BY THE COURT, J ? Michael F. Ratchford, Esq. Heather K. Woodruff, Esq. Edwin A. Abrahamsen & Associates, P.C. 120 North Keyser Avenue Scranton, PA 18504 Attorneys for Plaintiff .,- onald A. Neill 212 E. Main Street Apt. 1 Camp Hill, PA 17011 Defendant, pro Se :rc ?'F.S may ?v- 8 fd? C Ft- THE ARY 20D9 OC T µ8 PI 1 1 16 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy aa?ttt? at C1114br"`?4# 4 401 SEP 29 A 10: ?,, Richard W Stewart Solicitor OFF'CE ?1- THE 7-EP -c P EHV? SYL'/MIN I, Unifund CCR Partners vs. Ronald A Neill Case Number 2008-5888 SHERIFF'S RETURN OF SERVICE 09/27/2011 10:42 AM - Shawn Gutshall, 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 1510 Cedar Cliff Drive, Lower Allen Township, Camp Hill, PA 17011, Cumberland County, by handing to MARGO RICHARDSON - TELLER MANAGER, 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 September 28, 2011 to Ronald A. Neil at 212 E. Main Street, Apt. 1, Camp Hill, PA 17011. SO ANSWERS, September 28, 2011 RON R ANDERSON, SHERIFF w uts , Deputy ;C' Cou t 3LAIC Shc If c'.-:c;5oR. Irc Unif ind CCR Partners In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvanj? Civil Division Z Z VS. C,Wa RONALD A NEILL 212 E MAIN ST APT 1 c') NO: 08-5888 ? ? CAMP HILL PA 17011 = c? Defendant Praecipe to Dissolve the Attachment againstc vs. Garnishee CITIZENS BANK 1510 CEDAR CLIFF DRIVE CAMP HILL, PA 17011 Garnishee To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank you, Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Ass( Lawyer ID # 86285 C. G-1 Sworn and subscribed before me on this day of 20 1 otary Public WA X.g, to Pd a CIL got SA „? 10 n 3za SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,nderson J Smith x.,r `E PRC 1 ?(??{'?,? 1HO?t tNbi?.?n?^°f k 1?. t ?-'. .i Deputy 7 2 MAY "? ?M Zt 3 ,rchard W Stewart Solicitor 7, ZF CUMBERLAND COUNTY PENNSYLVANIA Unifund CCR Partners Case Number vs. Ronald A Neill 2008-5888 SHERIFF'S RETURN OF SERVICE 09/27/2011 10:42 AM - Shawn Gutshall, 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 1510 Cedar Cliff Drive, Lower Aller Township, Camp Hill, PA 17011, Cumberland County, by handing to MARGO RICHARDSON - TELLER MANAGER, 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 September 28, 2011 to Ronald A. Neil at 212 E. Main Street, Apt. 1, Camp Hill, PA 17011. 05/02/2012 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: $87.11 SO ANSWERS,, May 02, 2012 RbNWY- R ANDERSON, SHERIFF ,?r a ?y 3 3 ^•t l"?`JSill!n hfv l{(. 1?E31ep5'v'1t, InC. PRAECIPE FOR WRIT OF EXECUTION — (MONEY JUDGMENT) RULES PA. R.C.P. 3252,3111 (a) Unifund. CCR Partners vs. RONALD A NEILL 212 E MAIN ST APT 1 CAMP HILL PA 17011 -6316 vs. METRO BANK 3201 TRINDLE RD CAMP HILL, PA 17011 MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG, PA 17050 Plain Defendant Garnishee In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: 08 -5888 PRAECIPE FOR WRIT OF EXECUTIO1 r Ai D cv ATTACHMENT c� —a (MONEY J GMENT To the Prothonotary: TO SATISFY THE JUDGMENT, ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) Against: RONALD A NEILL (3) And against: METRO BANK 3201 TRINDLE RD CAMP HILL, PA 1701.1 And MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG, PA 17050 (4) and index this writ (a) against Defendant(s) (b) against METRO BANK 3201 TRINDLE RD CAMP HILL, PA 17011 and MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG, PA 17050Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s), any and all accounts of the defendant(s), in the possession of Garnishee, including but not limited to savings account balances; checking account balances; Certificates of Deposit; Money Market Accounts; contents of Safety Deposit Boxes. Defendant's SSN(s): ***_**4767 ; (5) Date: April 4, 2014 Judgment Amount Interest Payments Clerks Fee Sheriff Poundage Total a)9 " a 5, �.u0.Br cam $6.542.63 $780.83 $1361.53 ichael F ' atchford, Esquir Edwin A. Abrahamsen & As •ciates, P.C. Attorney for Plaintiff mratchford@eaa-law.com % .aSbU d. 7s7? L 3J / - ,/,sr THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240 -6195 www.ccpa.net UNIFUND CCR PARTNERS Vs. RONALD A. NEILL WRIT OF EXECUTION (Pa R.C.P. 3252) NO 08 -5888 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against RONALD M. NEILL, 212 E. MAIN STREET, APT. 1, CAMP HILL, PA 17011 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 METRO BANK, 3201 TRINDLE ROAD, CAMP HILL, PA 17011 MEMBERS 1sT FCU, 6280 CARLISLE PIKE, MECHANICSBURG, PA 170505GARNISHEE(S), as garnishee, ANY AND ALL ALL ACCOUNTS OF THE DEFENDANT(S), IN THE POSSESSION OF GARNISHEE, INCLUDING BUT NOT LIMITED TO SAVINGS ACCOUNT BALANCES; CHECKING ACCOUNT BALANCES; CERTIFICATES OF DEPOSIT; MONEY MARKET ACCOUNTS; CONTENTS OF SAFETY DEPOSIT BOXES. (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 1 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 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 $5,181.10 Interest $780.83 Attorney's Comm. % Attorney Paid 517S 31. Date: 4/29/14 (Seal) Plaintiff Paid Law Library Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary REQUESTING PARTY: Name : MICHAEL F. RATCHFORD, ESQUIRE Address: EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C. 120 NORTH KEYSER AVENUE SCRANTON, PA 18504 Attorney for: PLAINTFF Telephone: 570 -558 -5510 EXT. 101 Supreme Court ID No. 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 Unifund CCR Partners In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania : Civil Division VS. RONALD A NEILL 212 E MAIN ST APT ] CAMP HILL PA 17011-6316 Defendant : VS. METRO BANK 3201 TRINDLE RD CAMP HILL, PA 17011 MEMBERS 1ST ECU 6280 CARLISLE PIKE MECHANICSBURG, PA 17050 Garnishee NO: 08-5888 Praecipe for Entry of Appearance Kindly enter my appearance on behalf of Unifund CCR Partners in the above-captioned matter. Date:April 4, 2014 Signa Print Ad ess: 120 North Ke ser A Scranton, PA 185 Telephone No: (570) 558-5 Supreme Court ID No: 862 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Anderson 12-0-OF q. Jody S Smith 0A.J1 20I4 HAY —6 PH 2: VI Chief Deputy Richard W Stewart • j'`).` CUMBERLAND COUNTY Unifund CCR Partners Case Number 2008-5888 Ronald A Neill SHERIFF'S RETURN OF SERVICE 0505/2014 10:42AM 'WilliamCline, 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, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Joseph Schroeder, Teller, personally three copies of interrogatories together with three true and attested copies of the Wrof Executiod made to him. .4,- W LLI CLI , DEPUTY SO ANSWERS, gx0:' May 06, 2014 RDNNYRANDERSON, SHERIFF wCou=ySuli"Sheriff,��,Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson +C 3. Sheriff CUMBERLAND� f�1I '6 „C?4414t1� 6� IL�I'3+i',p�4,70. Eli(b Jody S Smith P{1 2: j:7 Chief Deputy •kqCOUNTY �' Richard W Stewart `- - PENNSYLVANIA Solicitor *rFcs,or THE SHERIFF Unifund CCR Partners vs. Case Number Ronald A Neill 2008-5888 SHERIFF'S RETURN OF SERVICE 05/05/2014 11:05 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Denise Harman, Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on May 6, 2014 to Ronald A. Neill at 212 E Main St, Apt. 1, Camp Hill PA 17011. // IAM CLINE, DEPUTY SO ANSWERS, May 06, 2014 RONO R ANDERSON, SHERIFF (C)Couruysu o Sheriff,Teieosori.ion. Unifund CCR Partners VS. RONALD A NEILL 212 E MAIN ST APT 1 CAMP HILL PA 17011-6316 vs. METRO BANK 3201 TR]INDLE RD CAMP HILL, PA 17011 MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG, PA 17050 In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania Civil Division Defendant Garnishee : NO: 08-5888 answers. rrri ..<= C> c N c INTERROGATORIES IN ATTACHMENT -7c,. �•y y RE: Execution of Judgment against your depositor RONALD A NEILL SSN # ***-**-1767 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: 1) At the time you were served or at any subseqent time, did the Defendant possess any bank accounts, joint or individual, that were in your custody or control? Please specify joint or individual account. Please list the legal title of any such account(s) and the primary account holder and if known whether joint account is entireties property. ,mo\\e !Ncc_ov,&A %e2, it 2) At the time you were served or at any subsequent time, what was the balance and account number of the bank accounts(s) identified in Interrogatory #1? 31:1V'"v\S \0 c>.VAN..K. 5 3) At the time you were served or at any subsequent time, please list the average daily balance in the past five (5) months for each such account identified in your answer to Interrogatories number one (1) and two (2) above.-OLcaa�3 Ara -134 euar ao�4 Fe ao�y 'j'a� dl`� �3 3-7��i .`Ja1n.1S moo. . ,o. p� a iP•i�i13• �' Ct lcI o��ta4.1-T o� a�i.) t 0S"l. tea. tA,sS-7 4) At the time you were served or at any subsequent time, did the bank account(s) that the Defendant possessed contain fund derived solely from social security funds and/or disability funds? �( 5) At any time before or after you were served. did the Defendant(s) transfer or deliver any property or money to you or to any person or place pursuant to your direction or consent, and if so, what was the consideration therefore? 1\L 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 the Depositor's direction or otherwise discharge any claim of the Depositor against you? . D 7) At the time you were served or any subsequent time, did you have, share, or utilize any safe-deposit boxes, pledges, documents of title, securities, notes, coupons, receivable, license, or collateral in which there was an interest claimed by Defendant(s)? 1,$) 8) At the time you were served or at any subsequent time did the Defendant(s) account contain funds deposited electronically on a recurring basis and which are identified as being exempt from execution, levy or attachment. If so, state the reason for the exemption; the amount being withheld and the entity electronically depositing those funds on a recurring basis. Np. 9) 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. Section 8123? If so, identify each account. p 10) Identify every other account (not previously noted) titled in the name of the Defendant(s) in which you believe the Defendant(s) have an interest in whole of part, whether or not styled as a payroll account, individual retirement account, tax account, Lottery account, partnership account, joint or tenants by entirety account, insurance account, trust or escrow account, attorney's account, or otherwise. IQ/A.. 11) To the extent that you're above answers depend in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). Edwin A br.. ar en, .: • crates, P.C. ael F. Ratc ' ord, Esquire 120 North Key er Avenue Scranton, PA 8504 (570) 558-55 1 Ext. 101 Unifund CCR Partners vs. RONALD A NEILL 212EMAINSTAPT1 CAMP HILL PA 17011-6316 vs. METRO BANK 3201 TRINDLE RD CAMP HILL, PA 17011 MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG, PA 17050 • In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania. Civil Division Defendant Garnishee NO: 08-5888 ax\Cv3Pic : INTERROGATORIES IN ATTACHMENT RE: Execution of Judgment against your depositor RONALD A NEILL SSN # ***-**-1767 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: 1) At the time you were served or at any subseqent time, did the Defendant possess any bank accounts, joint or individual, that were in your custody or control? Please specify joint or individual account. Please list the legal title of any such account(s) and the primary account holder and if known whether joint account is entireties property. Defendant has no accounts with Metro Bank 2) At the time you were served or at any subsequent time, what was the balance and account number of the bank accounts(s) identified in Interrogatory #1? 3) At the time you were served or at any subsequent time, please list the average daily balance in the past five (5) months for each such account identified in your answer to Interrogatories number one (1) and two (2) above. 4) At the time you were served or at any subsequent time, did the bank account(s) that the Defendant possessed contain fund derived solely from social security funds and/or disability funds? 5) At any time before or after you were served, did the Defendant(s) transfer or deliver any property or money to you or to any person or place pursuant to your direction or consent, and if so, what was the consideration therefore? 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 the Depositor's direction or otherwise discharge any claim of the Depositor against you? 7) At the time you were served or any subsequent time, did you have, share, or utilize any safe-deposit boxes, pledges, documents of title, securities, notes, coupons, receivable, license; or collateral in which there was an interest claimed by Defendant(s)? 8) At the time you were served or at any subsequent time did the Defendant(s) account contain funds deposited electronically on a recurring basis and which are identified as being exempt from execution, levy or attachment. if so, state the reason for the exern.ption, the amount being withheld and the entity electronically depositing those funds on a recurring basis. 9) 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. Section 8123? If so, identify each account. 10) Identify every other account (not previously noted) titled in the name of the Defendant(s) in which you believe the Defendant(s) have an interest in whole of part, whether or not styled as a payroll account, individual retirement account, tax account, lottery account, partnership account, joint or tenants by entirety account, insurance account, trust or escrow account, attorney's account, or otherwise. 11) To the extent that you're above answers depend in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). Edwin Aciates, P.C.. M'" iael F. Ratc ford, Esquire 120 North Key er Avenue Scranton, PA 8504 (570) 558-55 -0 Ext. 101. 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 Levy Specialist Jennifer Hilbish (Name) of Metro Bank, garnishee herein, (Title) (Company) that he/she 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/ belief. owledge, information and TURE Unifund CCR Partners vs. RONALD A NEILL 212EMAN STAPT 1 CAMP HILL PA 17011-6316 vs. MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG, PA 17050 : In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania : Civil Division : NO: 08-5888 Defendant : : Praecipe to Dissolve the Attachment against : Garnishee Garnishee To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank you, ichael F. Rate ord, Es uire Edwin A. Abrahamsen & Associates, P.C. Lawyer ID # 86285 49. so-?d,A41. , 1(z-1P'-1P'7siy 7 R, 364,4y%' r'r i — -13 1-73 - c: CDT Unifund CCR Partners vs. RONALD A NEILL 212 E MAIN ST APT 1 CAMP HILL PA 17011-6316 vs. METRO BANK 3201 TRINDLE RD CAMP HILL, PA 17011 : In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania : Civil Division : NO: 08-5888 Defendant : Praecipe to Dissolve the Attachment against Garnishee Garnishee : To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank you, ichael F. Ratch or Edwin A. Abraha Lawyer ID # 862 , Esquire en & Associates, P.C. 17>) C.11 °I. sup d k# --no Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF I;'ECFTFE WERIPF i.3 Jit,!: _ 6'1�ii 3: ) tE i LAND t�LJ r; 3w YL4 At, I Unifund CCR Partners vs. Ronald A Neill Case Number 2008-5888 SHERIFF'S RETURN OF SERVICE 05/05/2014 10:42 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, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Joseph Schroeder, 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 him. 05/05/2014 11:05 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Denise Harman, Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on May 6, 2014 to Ronald A. Neill at 212 E Main St, Apt. 1, Camp Hill PA 17011. 12/30/2014 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: $145.14 SO ANSWERS, December 30, 2014 BONN R ANDERSON, SHERIFF ad.e00 Wan' (c) CountySuiie Sheriff, Teleosott, Inc. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite] 00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net UNIFUND CCR PARTNERS Vs. RONALD A. NEILL WRIT OF EXECUTION (Pa R.C.P. 3252) NO 08-5888 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against RONALD M. NEILL, 212 E. MAIN STREET, APT. 1, CAMP HILL, PA 17011 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 METRO BANK, 3201 TRINDLE ROAD, CAMP HILL, PA 17011. MEMBERS 1sT FCU, 6280 CARLISLE PIKE, MECHANICSBURG, PA 170505GARNISHEE(S), as garnishee, ANY AND ALL ALL ACCOUNTS OF THE DEFENDANT(S), IN THE POSSESSION OF GARNISHEE, INCLUDING BUT NOT LIMITED TO SAVINGS ACCOUNT BALANCES; CHECKING ACCOUNT BALANCES; CERTIFICATES OF DEPOSIT; MONEY MARKET ACCOUNTS; CONTENTS OF SAFETY DEPOSIT BOXES. (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 1 -J multiple accounts are attached, a total of $300 in ail 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 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 $5,181.10 Interest $780.83 Attorney's Comm. % Attorney Paid $173,3/. Date: 4/29/14 (Seal) Plaintiff Paid Law Library Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : MICHAEL F. RATCHFORD, ESQUIRE Address: EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C. 120 NORTH KEYSER AVENUE SCRANTON, PA 18504 Attorney for: PLAINTFF Telephone: 570-558-5510 EXT. 101 Supreme Court ID No. MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and 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 equipment TRUE COPY FROM RECORD n Testimony whereof, { here unto set my hand and the�seaal of said Court at Carlisle, P ; This __an- day of Prothonotary