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HomeMy WebLinkAbout08-6127IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifimd CCR, Plaintiff VS. CIVIL-LAW HARVIE F. SHRINER SR., DOCKET NO. 0 i%, G I Al Ccu;,, 4, Defendant ENTRY O„FAAPP:RANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, THE REMIT CORPORATION AAA -ij( i I Ill ? LAURINDA OELCKER, ESQUIRE Attorney No. 82706 36 W Main St Bloomsburg, PA 17815 570-387-1873 Fax 570-387-6474 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unif ind CCR, Plaintiff vs. CIVIL-LAW HARVIE F. SHRINER, SR., : DOCKET NO. 0 7- 4 I a `1.( I Q,.... Defendant COWLAINT The Plaintiff, Remit Corporation, by and through its attorney Laurinda J. Voelcker, Esquire, hereby files this Complaint of which the following is a statement: 1. The Plaintiff, The Remit Corporation is a Pennsylvania corporation doing business at 36 West Main Street, P.O. Box 7, Bloomsburg, Columbia County, Pennsylvania 17815 and is the assignee of Unifimd CCR Partners. Copies of the documents assigning all relevant rights with reference to the present action to the Remit Corporation are attached hereto, incorporated herein and referred to hereafter as Exhibits A and B. 2. The Defendant, Harvie F. Shriner, Sr., is an adult individual residing at 114 Hershey Road, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Defendant obtained a Mastercard credit card on or about September 27, 1999, from Chase Manhattan Bank USA, (hereinafter "original creditor"), Account number 5260 3642 9965 8504. 4. Unif ind CCR Partners purchased the account of Harvie F. Shriner, Sr. from Chase Manhattan Bank USA. A copy of the Affidavit of Indebtedness is attached hereto and labeled as Exhibit B. 5. Defendant used the extended credit leaving an unpaid balance of $4,123.83 with interest continuing to accrue at 60/oper annum. 6. Defendant's last payment on this account was made on or about August 31, 2005. 7. To date the balance is $3586.65 principal and $537.18 interest for a total of $4,123.83. COUNT11 BRgACH OF EXPRESS CONTRACT 8. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 9. In consideration of the extension of credit provided by original creditor through a credit card, Defendant agreed to pay for all charges for purchases, balance transfers, cash advances, fees and interest on his/her account. 10. The reasonable charges and expenses owing for the credit card purchases, cash advances, balance transfers, fees and interest is $4,123.83. 11. Defendant accepted the extension of credit and utilized the credit card without complaint, objection or dispute as to credit services provided, the prices charged for the same or the costs incurred. 12. Defendant is indebted to the Plaintiff in the amount of $4,123.83. Defendant has failed and refused to pay the aforesaid sum despite frequent demand to do so and the same is now due and owing. 13. Defendant's failure to pay is a breach of the express written agreement between the Defendant and original creditor. Pursuant to Pa.R.C.P. No. 1019(i), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit C. ASSIGNMENT OF CLAIM PURSUANT TO PENNSYLVANIA ACT 219 OF 1990 For value received, the undersigned: Unifund CCR Partners. State of Ohio. County of Hamilton. assigns to: The Remit Corporation doing business at: 36 W Main Street PO Box 7 Bloomsburg, PA 17815 a debt due to the undersigned from: SHRINER SR, HARVIE F 5260364299658504 # 571770 for the sum of $4123.83 arising from unpaid credit card services with interest accruing at 6.00% per annum. The said sum is justly due to the undersigned without offset or defense. The undersigned neither transfers to The Remit Corporation, nor expects The Remit Corporation to assume, any obligation or any liability of the assignor to the said debt. The undersigned has done nothing and will do nothing to discharge the debt or hinder its collection and hereby grants to The Remit Corporation the full power and authority, to bill and collect the aforesaid claim, in accordance with Pennsylvania Act 219 of 1990, Section 2, as it amends Title 18 regarding Section 7311, including to sue for, (in its own name, through a licensed attorney) and discharge the assigned debt. The Remit Corporation specifically agrees to comply with the Pennsylvania Act of December 17, 1968, P.L. 1224, No. 387 (known as the Unfair Trade Practices and Consumer Protection Law), and with the regulations promulgated under that Act pursuant to this assignment. Dated this 13th day of August, 2008. seph Lutz ed Signature Unifund CCR Partners. State of Ohio. County of Hamilton. misrur it A I AFFIDAVIT OF INDEBTEDNESS State of Ohio ) County of Hamilton ) ss. Kim Kenney, being sworn, deposes and says that she is an authorized representative of Unifund CCR Partners, servicer, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242, and that she is authorized to make-the following statements and representations which are within her personal knowledge, and that she is competent to testify to the matters stated herein. To the best of her knowledge the Defendant is not now in the Military Service as defined in the Soldier s and Sailor s Civil Relief Act of 1940 and amendments thereto. There is due and payable from HARVIE F SHRINER SR, Account Number 5260364299658504, the amount of $4099.65. This account was issued under the name of CHASE MANHATTAN BANK USA NA and acquired from Titan Recovery Group LLC. Said account has been forwarded to REMIT Corporation, as attorney for Plaintiff Unifund CCR Partners, for the purpose of the commencement of a legal suit, with full power and authority to do and perform all acts necessary for the collection, adjustment, compromise or satisfaction of said claim as permitted by law. I do solemnly declare and affirm under the penalties of perjury that the matters set forth above are true and correct to the best of my knowledge. DA,TFQ this 07/28/2008 By: Title 10625 Techwoods Circle- Cincinnati. OH 45242 Address I hereby certify that on 07/28/2008, before me, the subscriber, a Notary Public for the State/County aforesaid, personally appeared the above-stated affiant, and made oath in due form of law. \ l is commission Expires 634 OF 110??0 \\\\\ '111111 KATHRYN HALPIN NOTARY PUBLIC STATE OF OHIO Comm. Expires October 1 1 , 201 0 EXHIB - .8 jL7 t ?'d aX'f 'O y 'i .3 E i73 m X > w>'"?s a, E?sO1s 243 ;a MO w o t? s . acs a W a ' d co w ft r s tg ar (n cl ?s #.Ofa. all -S ws -IV lay It JV x V 1A s as R? 12 i 911-t 11 z- 31 L A&V "a rs At f fi ir ? C w ,??}L ? a E a,. f 11 1 $ IN I z W s AIR .. ' . EXHIBIT a 1155 b a co till i owe V I i a I 12 I? I ?$? 1 .6 t I, ro Ina a - VC, b. m tQL .. 9L c fig. f i 2 ? I W , v I . " ? I 1rT I g.? ? 7 1 c ? , B ob j 1s . j I i f I ?°. a _ t p]! . as. t 75 40 tai a?s JAI I ? .c s JAI. 'fill ' I's , a F' .; q ?.- E751 I J2 10 I fig gill s sic, It i I ?; ?g ?g a m to Z!jj 70 s? as A 9 182 see ? ? ?. sv ? s ? ? ? St 1B MIZE " ,??? ? ??,? ? ? is ?g• a B'°,?? ?? ??a?? ? ?? e ? • .? y 9 d o • Sa a f? r .c G a , • ..•1 Sr ..? 40 ? a n?re A $ ?? m 21.0 lawn Bill z If fill $ 9 g 2.0 ? ?a E as E ?a? ??- ?s? A i fit sill l$¢i9.?.F=?=N VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unworn falsification to authorities. Harry A. trausser, III, Re Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. : CIVIL-LAW HARVIE F. SHRINER, SR., DOCKET NO. Defendant AFFIDAVIT OF NON-MUJTARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, not has been in such service within thirty days hereof. Dated this 15 day of U4(/ 2008 Laurinda J. Voelck , Esquire Attorney For Remit Corporation Attorney ID 82706 36 West Main Street Bloomsburg, PA 17815 570-387-1873 Fax 570-387-6474 Request for Military Status Department of Defense Manpower Data Center 0 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 SEP-09-2008 10:43:19 Last Name First/Middle Begin Date Active Duty States Service/Agency SHRINER HARVIE F Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. A%4-4i691- Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain fiirther information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: bop://www.defenselink.mil faq/pis/PC09SLDR html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BUSZMV*WOGW https://www.dmde.osd.mil/scra/owa/scra.prc_Select 9/9/2008 . ? .?? , ?, ?? ?" ?? ?.. ,. . , ?? ?? V. ? Cam' ? N ? ? ?? 1 ` y VV;\ ?1? V SHERIFF'S RETURN - REGULAR CASE NO: 2008-06127 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REMIT CORPORATION VS SHRINER HARVIE F SR WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHRINER HARVIE F SR DEFENDANT the , at 0016:44 HOURS, on the 16th day of October , 2008 at 114 HERSHEY ROAD SHIPPENSBURG, PA 17257 by handing to DARLENE SHRINER WIFE OF 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 18.00 Service 19.00 Affidavit .00 Surcharge 10.00 °/da/,0p 0" .00 47.00 Sworn and Subscibed to before me this day of , So Answers: R . Thomas Kline ~H 10/17/2008 REMIT CORPORATION By Deputy Sheriff A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. : CIVIL-LAW HARVIE F. SHRINER, SR., DOCKET NO. 08-6127 Defendant PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment against Defendant in the above captioned matter as follows: Real debt $ 4,123.83 Attorney's Fees $ 1,030.95 Interest from Oct. 14, 2008 $ 20.61 Total: $ 5,175.39 Kindly assess damages against Defendant in the sum of $5,175.39 plus continuing interest at the statutory rate of 6%. BY: A,4,4 41 zi _'V _11?q Laurinda J. oe k r, squire Attorney for aintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW HARVIE F. SHRINER, SR., DOCKET NO. 08-6127 Defendant TO: Harvie F. Shriner, Sr. l 14 Hershey Road Shippensburg, PA 17257 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a. Judgment has been entered against you in the above proceeding as indicated below. _X Judgment by Default Money Judgment Judgment in Replevin Judgment of Possession Judgment on Award on Arbitration Judgment on Verdict Judgment on Court findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: LAURINDA J. VOELCKER, ESQUIRE AT THIS TELEPHONE NUMBER: 570-387-1873 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW HARVIE F. SHRINER, SR., DOCKET NO. 08-6127 Defendant CERTIFICATION OF TEN (10) DAY NOTICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: I, LAURINDA J. VOELCKER, ESQUIRE, hereby swear and certify that I served a copy of the Ten (10) Day Notice by regular mail to Defendant on November 11, 2008. BY: _ Laurinda J. V elcker, Esq. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. HARVIE F. SHRINER, SR., Defendant : CIVIL-LAW DOCKET NO. 08-6127 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO: Harvie F. Shriner, Sr. 114 Hershey Road DATE OF NOTICE: November 11, 2008 Shippensburg, PA 17257 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 RE ft n' . Laurinda J. V cker, Esquire 570-387-1873 Mailed to: Harold F. Shriner, Sr. 114 Hershey Road Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW HARVIE F. SHRINER, SR., DOCKET NO. 08-6127 Defendant AFFIDAVIT OF NON-MILITARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, not has been in such service within thirty days hereof n1. ,4- Dated this o bay of , 2008 Laurinda J. Voelcker, Vquire Attorney For Remit Corporation Attorney ID 82706 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 Rcq r.st forW;v,r S"t!s Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Last Name !First/Middle !Begin Date SHRINER ' HARVIE lmps: /Iwww.drrde.o-d.mil/scra/owo/scra.pm_SelecI Active Duty Status NOV-24-2008 09:21:43 Service/Agency Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. 14 Y64 a JM4 Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See 1 of 2 11/24/2008 12:21 PM Rco*test for 'vl;l tpr-v Stars bftps://www.dTndc.o,,zd.THII,;cm/owa/scra.prc_Select WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: YTSUZgSCKE 2 oiF2 11/24/2008 12:21 PM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW HARVIE F. SHRINER, SR., DOCKET NO. 08-6127 Defendant CERMCATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff: Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Defendant: Harvie F. Shriner, Sr. 114 Hershey Road Shippensburg, PA 17257 Respectfully submitted, 1.141 / V% /if, v 1// 0' Laurinda J. Voe ker, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 W ? Q?v c 0 o r-? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION Plaintiff CIVIL ACTION -LAW t , VS. : =r NO. 08-6127 -' r HARVIE F. SHRINER, SR. E3 -" Defendant ASSIGNMENT OF JUDGMENT KNOW ALL MEN BY THESE PRESENTS, that Remit Corporation in consideration of the prior contractual agreement between the parties, the receipt and sufficiency of which is acknowledged, does hereby grant, bargain, transfer, assign and make over to Unifund Corporation of 10625 Techwoods Cr, Cincinnati, Hamilton County, Ohio, 45242 (hereinafter "Unifund"), its successors and assigns, a certain Judgment recovered by Remit Corporation of 36 West Main St, Bloomsburg, Columbia County, Pennsylvania 17815, in the Cumberland Court of Common Pleas, Cumberland County, Pennsylvania, filed to docket number 08-6127 against Defendant, HARVIE F. SHRINER, SR., for the sum of $4,249.33 which constitutes damages and costs of suit, plus interest at 6.00% annum from 12/09/2008, together with all the benefits and advantages that may be obtained thereby, and full power to enforce and recover the Judgment to Unif end's own use. Remit Corporation, further authorizes and Empowers the Prothonotary or any attorney on behalf of the Assignee to mark said Judgment to the Assignee's use. co po ATty C?? ? X502 P,* am 4 IN WITNESS WHEREOF and intending to be legally bound hereby, Remit Corporation, as executed this Assignme t this day of '2010. Laurinda J. Vo er General Counsel Remit Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION Plaintiff VS. HARVIE F. SHRINER, SR. Defendant : CIVIL ACTION -LAW NO. 08-6127 PRAECIPE TO MARK JUDGMENT TO USE OF ASSIGNEE TO: PROTHONOTARY: Please mark the Judgment entered in the above captioned case against the Defendant(s), HARVIE F. SHRINER, SR., to and for the use of Unifund Corporation, Assignee, as per Assignment of Judgment, a copy of which is attached hereto and made a part hereof as Exhibit A. DATED: gy. Laurinda J. Voelc r, Remit Corporation JUDGMENT MARKED TO USE OF ASSIGNEE AND NOW, to wit, this day of the Judgment entered in the above captioned case against the Defendant (s), HARVIE F. SHRINER, SR., is hereby marked to and for the use of Unifund Corporation. Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. CIVIL-LAW HARVIE F. SHRINER SR., DOCKET NO. 08-6127 I I g t V'Sl?? y j&, Defendant PRAECIPE FOR WRIT OF EXECUTION W Personal Property Levy aM m To the Prothonotary: Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; N (2) against HARVIE F. SHRINER SR., defendant, c- (3) against N/A, garnishee; (4) and enter this writ in the judgment index a. against HARVIE F. SHRINER SR., defendant, and b. against N/A, as garnishee, as a lis pendens against real property of the defendant in name of garnish ee(s) as follows: N/A (5) Amount Due: $ 5,175.39 Interest from 12/09/2008 $ 725.69 Other: $ 8.00 Credits: $ 0 Costs to be added: Clerks Fee: $ 24.00 Sheriff: $ 150.00 Total: $ 6,083.08 Dated this ?y day of April, 2011 Q? "?Ijl q jo V?I'e ltleo- La rinda J. Voelc er, PA ID# 82706 i ntiff Attorney for Pla 117 ?"5r 36 West Main Street 0 -s w j, Bloomsburg, PA 17815 Telephone: 570-387-1873 o 1q &o f? Fax: 570-387-6474 -" SG' ?? t# A-/ 73 -7 rnf- -0i-n ;Vrn C:)7 --4c:) ?.-n WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-6127 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CORPORATION Plaintiff (s) From HARVIE F. SHRINER, SR. AT 114 HERSHEY ROAD SHIPPENSBURG, PA 17257 (1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL PERSONAL PROPERTY IN DEFENDANT'S POSSESSION INCLUDING BUT NOT LIMITED TO VEHICLES, ATV'S, BOATS, SNOWBLOWERS, GUNS, OTHER SPORTING GOODS AND EQUIPMENT, COMPUTERS AND EQUIPMENT, ELECTRONICS, COLLECTIONS AND FIGURENES, JEWELRY, RIDING TRACTORS, HOUSHOLD GOODS AND FURNISHINGS. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been. issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $5,175.39 Interest FROM 12/09/2008 -- $725.69 Atty's Comm % Atty Paid $174.00 Plaintiff Paid Date: 4/18/11 (Seal) L.L. 4t, SG) Due Prothy $2.00 Other Costs $8.00 David D. Buell, Prothonotary B Deputy REQUESTING PARTY: Name L.AURINDA J. VOELCKER, ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorney for: PLAINTIFF Telephone: 570-387-1873 Supreme Court ID No. 82706 RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy To Whom It May Concern: of Cuotbe", '?d RICHARD W. STEWART Solicitor May 16, 2011 Unifund Corporation s --? vs :zm y -? _ Harvie F. Shriner Sr cr -<> cn , . Writ No. 2008-6127 `- Property Claim Determin' Reference is made to Property Claim dated May 6, 2011, entered by Darlene Shriner, Writ of Execution No. 2008-6127 Civil Term, Unifund Corporation vs Harvie F. Shriner, Sr. Ronny R. Anderson, Sheriff, has determined that the claimant, Darlene Shriner, in the above mentioned property claim, is the owner of the property set forth in the claim. Laurinda J. Voelcker, Atty for Plaintiff Harvie F. Shriner, Sr., Defendant Darlene Shriner, Claimant cc G110ty OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 So Answers: Ro y . Anderson, Sheriff By T NOTICE OF PROPERTY CLAIM Unifund Corporation In the Court of Common Pleas Cumberland County, Pennsylvania VS Harvie Shriner Sr. No. 2008-6127 Civil Term Writ of Execution TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Darlene Shriner, claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 05-06-11 mberland County Oofff Cu Cc Laurinda J. Voelcker, Atty for Plaintiff Harvie Shriner, Sr., Defendant Darlene Shriner, Claimant By ,/I 10 . PROPERTY CLAIM In the Court of Common Pleas of j1 Cumberland County, Pennsylvania k- n A' V'CQ C4 S / Writ No. G' CP l -7 9 VS i 7'1 R (' t) ? e. EL ('I n v f .Sr TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE ?.e >^Ct `?ab lr s o _.? lames i? Sao f ?oc„?g chr??? a SinfL't 4 s t-n?sC/So 7-5 C OTT' e 12 d a THE LAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: F'1 P vi F- J Y-v K4 C o > > r n/ G Date '51(1111 Claimant State. of Perms lvania: County of Cumberland above list in the property claim are correct and true. Sworn and subscribed to before Carlisle Boro, Cumbefland County My Commission Expires April 4, 2015 being duly sworn according to law, deposes and says that the C h ;P,d 'e-- ))mss? zi, :6 R- ?\'Vi iioZ jn? ? J I e ?? C)O S f 'L?? rah -3eo C YT 141) ?G ,1`7. u 5 h Iy?U rv ? s 1Uc) Jl-p'fe?? CY1??rlJ S'p it?rn 5? 1S /O C / G ! v4 kA ! 1.C?195?e ? 7f _C'rA 5 r? ZVeldef SU 2-5 'AT 3 ??Pssc? ISv' «?,?rYl?r??(iGl?h+"S?" s? ? cv hl??? r ?'?? v r 64) nil) ess4) r C re ss? do _1 - t1i Y7,G1 j17 S`?r?r^G? J o D q car- NcC'u41) / a?5 ncr? Uu?S C/ r u? r? 3 I ? fcf ?Do ?C?N?F ? `? ? cC rPS? ? /' 261-v 4oY5 pUf ? -? ? _ ? 5? ; ,? ? ?? t ? S ?' ?. `?' Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor A?1,V1S4' 01 4lflfabf,ft?h,0 vs` HELP 0THTO.{I 1 3i-tfit}2011MAY27 PM 2: 14 ('SF€Ir."fiTF4 ---RIFF CUMBERLAND COUNTY PENNSYLVANIA Unifund Corporation i vs. Harvie F Shriner, Sr SHERIFF'S RETURN OF SERVICE Case Number 2008-6127 04/29/2011 10:50 AM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 29, 2011 at 1050 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Michael Barchuck, by making known unto Darlene Shriner, Adult in Charge, at 114 Hershey Road, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on 05-04-11. 05/06/2011 Property claim filed this date by Darlene Shriner. All parties notified by mail. 05/16/2011 Reference is made to Property Claim dated May 6, 2011, entered by Darlene Shriner, Writ of Execution No. 2008-6127 Civil Term, Unifund Corporation vs Harvie F. Shriner, Sr. Ronny R. Anderson, Sheriff, has determined that the claimant, Darlene Shriner, in the above mentioned property claim, is the owner of the property set forth in the claim. 05/27/2011 No objections filed in this case. 05/27/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ of execution is returned STAYED per Pennsylvania Rules of Court 3206(c) (pertaining to property claims). SHERIFF COST: $116.75 May 27, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 8 Sharon R. Lan z -?-06P'4' , L - GIZ 5?-")/e A0* ;2 S-.f r-F-5 SHERIFF'S OFFICE OF CUMBERLAND COUNTY M CounfySuite Shentf, I e eosoft. Inc