HomeMy WebLinkAbout08-6285H - toag'5
IN
Credigy Receivables Inc.
VS.
VANESSA L HORNE
1605 AIRPORT DR
MECHANICSBURG PA
17050-2102
NO: 0031353civil
D3-i353
aivit i?
PRAECIPE FOR WRIT OF REVIVAL
TO THE PROTHONOTARY:
Please issue writ of evival of lien of judgment entered at this Court at
0031353civil and enter it in the jud ent index against VANESSA L HORNE in the amount of
$3,594.82 with interest from May 14, 2003.
& Associates,
E COURT OF COMMON PLEAS OF
;RLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
laintiff
Michael F. RJtchf
Attorney I.D. No.:
Attorney for Plain
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EXHHIBTT A
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(a) Fir Select, Inc., a Delaware corporation (" e 1 ' ), hereby
irrevocably constitutes and oints Credigy Receivables, Inc., a Nevada corporation
("Attormev'?, with full power f substitution, acting through any officer, employee or agent
appointed by Attorney, as its trio and lawful attorney-in-fact with full irrevocable power and
authority in the place and ste of Seller and in its own name, or, if specifically authorized
below, in the name of Seller, fro time to time, for the purpose of carrying out the terms of that
certain Purchase and Sale Agr ent, dated as of December 27, 2002, by and between Seller and
Attomey as Purchaser thereund (collectively, the " eemeat"; capitalized terms used herein
and not otherwise de&ned her ' shall have the meanings ascribed to such terms in the
Agreement) to take any and all propriate action to arcoinplish, anal to execute and deliver any
and all documents and instrum is which may be necessary or desirable to accomplish, the
purposes of the Agreement; and, without limiting the generality of the foregoing, Seller hereby
grants to Attorney, the power an right, at any time, to do the following:
(i) in the name of Seller or in its own, name, endorse Seller's
name upon any checks, craft notes, acceptances, money orders and other remittances
received by Seller or Purc er on account of the Acquired Assets;
(in) in Attorney's own name, direct any party liable for any
payment under or in resp of any of the Acquired Assets to make payment of any and
all monies due or to b ome due thereunder, directly to Attorney or Purchaser or as
Attorney shall direct;
C in Attorney's own name, in sign and endorse any invoices,
express bills, drafts again debtors, assigmnents, verifications, and notices in.oonnection
with accounts and other cements constituting or related to the Acquired. Assets;
(iv) in Attorney's own name, settle, compromise or adjust any
suit, action, or proceefttg described above and, in connection therewith, give such
discharges or.releases as Attorney may deem amopriate;
. (v)
commence any other art
deemed appropriate by
due under the Acquired A
(Vi)
suits, actions or proceedv
enforce any other right in :
I
proceeding brought aga
defend such suit, action
such defense in a mane
Assets; and
power of Attorney (Agreement)
in Attorney's own name, file any claim or take or
or proceeding in any court of law or equity or otherwise
aey for the purpose of collecting any and all such monies
s whenever payable;
in Attor:ney'a own name, commence and prosecute any
of law or equity in any court of competent jurisdiction to
Beet of the Acquired Assets;
in Attorney's own name, defend any suit, action or
,t Seller with respect to the Acquired Assets if Seller does not
proceeding or if Attorney believes that Seller is not pursuing
that will ma7dmize the recovery with respect to the Acquired
EXHIBIT A
O
In-fact is disclosed)
or desirable to (1) 1
the Accounts (2) sul
proceeding or (3) as
credit counseling si
pleadings, instrume
documents as Attor
Assets to Purchaser
and
(viii) (A) in Seller's name (provided Attorney's status as attorney-
in Attorney's own name, execute such documents as are necessary
Ign Seller's right, title and interest in and to judgments relating to
itute Purchaser for Seller as plaintiff in any litigation or bankruptcy
m Seller's right, title and interest in Accounts subject to consumer
rice agreements and (B) in Attorney's own name, execute such
i, assignments, bills, receipts, affidavits, certifications and other
y dooms necessary to effectuate the full transfer of the Acquired
to assist in the enforcement or collection of -any Acquired Asset;
O
(b)
with the Agreement, do or
protest and dishonor of any
or in connection with the b
granted pursuant to this Pi
irrevocable for a period coi
months thereafter.
Seller hereby authorizes Attorney shall lawfully, and in accordance
use to be done by virtue hereof and waives notice of presentment,
istrumment endorsed by Attorney pursuant to this Power of Attorney
isactions contemplated by the Agreement. The power of attorney
rer of Attorney is a power couple with an interest and shall be
aencing on the Service Transfer Date and ending twenty-four (24)
(c) The powers conferred on Attorney hereunder are solely-to protect
Purchaser's interest in the Ac uired Assets and shall not impose any duty upon it to exercise any
such powers. Attorney shall of be responsible to Seller for any act taken in good faith and with
due care to protect Purchaser' interest, or any failure to take such action.
(d)
Attorney is subject to the
IN WITNESS
day of July, 2004.
otwithstanding any other provision herein, this Power. of
and conditions of the Agmement.
the undersigned has executed this Power of Attorney this 30
FIRST SELECT, INC.
By:
Name: Anthony P. V oto
Title Vice Chairman &
Chief Financial Officer
_V I-L
(\. J) Name
CoI I toN * 1417067
MftWMAft
BOO CotMlyr
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EXHIBIT A
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CALIFORNIA ALL-PUR POSE ACKNOWLEDGMENT
State of California
I
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County of
?O 85.
I on JULY so, 2= before me JOA"We J. Jear IJryrAW i' 1bwC_-
,
' pats NBms WW Mb or o fh. " ow, NWq
personally appeared dWY ?• v DOrC?
Wuw(e) of 810MM
? personally known to me
X proved to me on the basis of satisfactory
evidence
to be the person(s) whose name(s) is/am
J..Iov subscribed to the within instrument and
# 1417067 acknowledged to me that he/shelthey executed
om CaMfanllo the some in his/her/thelr authorized
capecity(ies), and that by his/her/their
signature(s) on the instrument the person(s), or
the entity upon behalf of which the person(s)
acted, executed the instrument.
WITNESS my hand and official seal.
i
ft=Notwy8WA
gnBaeB d Nary Pu01o
bm
OP ONAL
Though the h?fvrmstion below s not required by law, P may prove valuable to persons relying on the document
and could prevent utent removal and reattachment of this form to another document
Signer's Name:
? Individual Top d 1W* hm
Corporate Officer - Title(); 1/10 GHAIPMAN ::-,How !"FNA*1?tAL
? Partner - ? Limited ? G neral
? Attorney In Fact
? Trustee
? Guardian or Conservator
? Other:
Description of Attached Document
Title or Type of Document: V" °r- AW
Document Date: JULY , Zc;04
Signer(s) Other Than Named bove: ?-
i
Capacity(les) Claimed by Signer
Signer Is Representing:
VIM tlolcnol NorgMooAoOon • Oi70 G Bob Aw., P.C#. Bm BIOQ • ClbrrioAl. CAY1S7?1104 • ?yx7 PMC W a" Radx: CA TdAft I-MF MW
FtA PC- IPWE AND aAW P4F49WhAVt4T
Number of Pages: 2
08 -1va8S oi v;1 T."
FIRST SELECT CORPORATION
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND, PENNSYLVANIA
VS.
: NO.0031353CIVIL
VANESSA L HORNE
CIVIL ACTION - LAW
GNMENT OF JUDGMENT
THIS INDENTURE, made this 27th day of December, 2002 between First Select Inc.
(the "Assignor"), 1600 Ormsby Station Court, Louisville, Kentucky 40223, and Credigy
Receivables Inc. (the "Assignee"), 2877 Paradise Road, Suite 303, Las Vegas, NV 89109.
WHEREAS, Judgment was
Inc., and against VANESSA L HO:
WHEREAS, the Assignee
NOW THEREFORE WIT
received, has sold, assigned, and b
that may be had or obtained by m
The assignee has the right to take a
become due on said Judgment; and
same. The Assignor hereby cov4
Assignor will not collect or receiv
Abrahamsen and Associates, PC, is
red in the above referenced Court in favor of First Select,
in the sum of $3594.82 plus interest on 5/14/2003; and
now the owner of said Judgment,
,MSSETH, that the Assignor, for valuable consideration
msferred to the Assignee the said Judgment and all monies
;ans thereof, or upon any proceedings to be had thereupon.
I lawful proceedings for the recovery of the money due or to
upon payment, to acknowledge satisfaction or discharge the
rants that said judgment remains unsatisfied and that the
the same or any part by the Assignee; and that Edwin A.
-etained as the attorney for plaintiff.
IN WITNESS WHEREOF,?this assignment has been duly executed by the Assignor and
Assignee the day and year first abo a written.
First Select, Inc., Assignor
By: Credigy Receivables Inc., Assi
Attorney in Fact for First Select, In
(Signature on Following
Credigy Receivables Inc., Assignee
as
(Signature on Following Page)
Assi--ninent cal"Ridgi-nent
Select Vs, VANT.ISSA L 1-10
L` ^ A
Credigy ReceivE
See Exhibit "A"
Dated:
BY: 491%Awo\-
Emilyods
Assistant Vice President
Credigy Receivables Inc.
Dated: ??Jtq
7l u
STATE OF GEORGIA ) SS:
COUNTY OF FORSYTH 1
The foregoing instrument was s, om to and subscribed before me this day of
U ti3 , 2008 by Katres Hughley and Emily Woods, personally known to me to be
the i dividual whose name is subsc 'bed to the within instrument.
Y"P,I7BtIC
?mission expires 3
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PUB
Pursuant to a Power of Attorney
Attorney.
July 30, 2004, see Attached Exhibit "X'- Power of
i irst Sclcct Vs. V \I',"SSA L 1-100 'l
R'tF r_ C 3
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08 - teas
FIRST SELECT CORPORATION
Plaintiff
VS.
VANESSA L HORNE
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND, PENNSYLVANIA
NO.0031353CIVIL
CIVIL ACTION - LAW
0-,t- vi t lex-M
TO THE PROTHONOTARY:
Kindly withdraw from appearance Willi arr? Molczan of Weltman, Weinberg, and Reis Co. LPA on behalf of plaintiff, First
Select Corporation, in connection with thellabove matter.
BY:-?4
William Molczan
Attorney I.D. # 4 437
Weltman, Weinberg, and Reis Co., LPA
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
TO THE PROTHONOTARY:
Kindly enter an appearance for Michael Ra
Select Corporation, in connection with the
ENTRY OF APPEARANCE
3 of Edwin A. Abrahamsen and Associates, PC on t
matter.
B .
Michael Ratchford
Attorney I.D. # 85
Edwin A. A amsen and Associates, PC
1729 Pittson Avenue
Scranton, PA 18504
of plaintiff, First
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IN THE COURT OF CO
CREDIGY RECEIVABLES
Vs.
VANESSA L. HORNE
PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
No 08-6285 CIVIL TERM
TO VANESSA L. HORNE
1605 Airport Drive
Mechanicsburg, PA 17,
You are notified that the Plain
the judgment entered to
The Plaintiff claims that the
2102
WRIT OF REVIVAL
has commenced a proceeding to revive and continue the lien of
No. 03-1353 Civil Term
due and unpaid is $3,594.82 with interest from 5/14/03.
You are required within twenty (20) days after service of this Writ to file an answer or otherwise,
plead to this Writ. If you fail to do so, Judgment of revival will be entered.
Costs $ 129.78 PD ATTY
2.00 DUE CO
Date 10/23/08
Cu is R. Long onota
(Seal)
Attorney for the Plaintiff
MICHAEL F. RATCHFORD, E
EDWIN A. ABRAHAMSEN &
1729 PITTSON AVENUE
SCRANTON, PA 18504
570-558-5510
ID #86285
Deputy
, P.C.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Credigy Receivables Inc.
Plaintiff
CIVIL DIVISION
VS.
VANESSA L HORNE
Defendant
NO: 08-6285-CIVIL
PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S RESPONSES TO
INTERROGATORIES IN AID OF EXECUTION
Plaintiff, Credigy Receivables Inc., 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:
1. Plaintiff, Credigy Receivables Inc.,obtained a judgment against the
Defendant in regard to an outstanding, past due and defaulted credit card account.
2. On June 01, 2009, Plaintiff served Defendant with Interrogatories in Aid
of Execution on the subject judgment. (See, Interrogatories in Aid of Execution dated
June 01, 2009, 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 July 27, 2009, 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 ". )
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 January 21, 2009, 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,
Edwin A, ahamsen & Associates, P.C.
Michaelef
atchford, Esquire
HeiK h K. 'Woodruff, Esquire
At.D. Nos: 86285/207805
12 Keyser Ave
Scranton, Pa 18504
Phone: 570-558-5510
Fax: 570-558-5511
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Credigy Receivables Inc.
Plaintiff
CIVIL DIVISION
VS.
VANESSA L HORNE
NO: 08-6285-CIVIL
Defendant
PLAINTIFF'S BRIEF IN SUPPORT OF ITS MOTION TO COMPEL
DEFENDANT'S RESPONSES TO INTERROGATORIES IN AID OF
EXECUTION
Plaintiff, Credigy Receivables Inc., 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, Credigy Receivables Inc., obtained a judgment against the Defendant in
regard to an outstanding, past due and defaulted credit card account. On June 01, 2009,
Plaintiff served Defendant with Interrogatories in Aid of Execution of the subject
judgment. (See, Interrogatories in Aid of Execution, dated June 01, 2009, 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 July 27, 2009, 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 January 21, 2009, 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,
dwin A. Ab sen & Associates, P.C.
Michael F. chford, Esquire
Attorney IN . No.: 86285
VERIFICATION
1, Michael F. Ratchford, Esquire, attorney for Plaintiff, Credigy
Receivables Inc. 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.
EDVM1 A APAAHAI ISEI I
M)CHAEL F. RAWHFOPU
HEs7FIER F . A'- --IN MFV
454) A I It l It EF• (•F Ft ?.I I
R?
THE LAW OFFICE OF
EDIVIN A. A I:I:.i ti3bl•>•F.N F.• A",*' ItIAT F. z. PC'
LYW W,t AA . t A W.1:14A
VANESSA I, HORNE
1028 dill Rd
MECHANIC:SBURG PA 17040-2102
June 1. 2009
RF:: Crc?liE;y Ruccivahles, Incr(:rcdi?y Rccc atd?Ics Inc. ?s. VANl:Stirt f, I[t)RtF.
file ti C:08-0158 R:thUlCV: $2,339.09
Dear SitA-ladant:
Inclosed please lind Interrogatories I'M Disco; en' of A%wt% in Aid of E\ectttitm, which base been
propounded in accurdance with the applicable }'ennfyl.,tnia Rules ut (Ii?•il f nitedure. full and cornplcte instructions
concerning; v0 ur kfuty to An,?ticr acid the penalties tiu failure to Ansacr ore contained in tht Interrogatories. Plea\L
read the inttructions Carefully.
You are to note %our answers on the original and return it to this oilice after ii is properly notarized.
Please be aware that tinder the Rules o( Court, %%e can and %%ill. Ita+e our attomi:5 's I'm and expenses ol'all
discovery Proceedings and Nano ion Hearings charimiJ against tiou as "additional costs" rin %hieh %oa will he
respltinsihlc,
Ill the altetna0vc, wit nuty make arrmpent ms to pay the lml. 1cc owed bethre I114 113411- (?O) days Iu
An5v er the Interrogatories expire, Either the balance must be paid w us or the Interroplorics anst?ered "chin thirty
(30) d-a}:s lirom the receipt ol-this (ester.
'('his is an attempt to coltect a debt and any information obtained will be used fur thm pu")w. This i'; a
communication lions a dcht collcclor.
U" in A. AhmImmscn R Associait:s, P.C'
Itcathcr K. 1h'uixintff, Esquire
lilt MitMN AriNuf SUANION. FA 11505 1P) Sig $58.5511 If 15 10.$SR.SSI I
IN THECOURT OFCOMMON 1'I.JiASOF t:IJMBER1,ANl) COUNTY PINNSYLVANfA
CIVIL DIVISION
Cre iigy Receivables. Inc, assignee of
Credigy Recei%ables Inc.
111nimliff
-?•s• LlT.Q7J?h?RS-CI?'ll.
VANESSA I, 1101{NI:
I kti ndant
1%TE:RR0(;,%TOR]FS 1:4 OR WNCOVQ(Y OFASSE:T:S IN AID 0E' E'\FC(JTI(0 ' 111RE:CTE;II'1I)
.1111K.-MENT UI;ILTUR
Because you have failed to pay the full amo unt of the Judgment PrO ithUSK entered against you. the
Judgment-Creditor. to who you we indebted. has a right to attempt to enforce tint Judgment bya Judicial Sale
(Sherills Sale) of)-rmr assets: and hatLa rig-hi to inquire concerning the eAislencc aad locatiorl jif those asset..
'I'll ercforc, pursuant ay the applicable Rulcs rtf'Court, Nutt are required to make Nil and complete Answers
to the questions set forth in the tuliooing pagrs. These Ansm em mum be made in u ritine_ under oath- within thine
(34) days Stier senicc u1xyn %ott
You are wm-mod that, should VOLE 1"ril 111 flu S0. lilt' CIAll1 1111~ make an tVdor irnposing ptarishmenl for
Cowrnpt orComi,
Please, if y ou do not understand,;our duty to anwer these questions. you should consult a lawyer. I kou do
not hive or know a lawyer, then you should find r+nt where y nU can Let legal !kelp, such as your local Caunly liar.
Assoriutiom or [m%vyi2r Iteferenee Scfvice.
Pi)RTIO.NS {)F THE r1PPLICAB.11E 1'LNISti't•I.VANIA kUI.ES (11.' (.I VI I. Pli()t P,I)U f'C:O-'1C :RItiFN
I)ISC'()WRY OI' - SS.1-j :5 11-, All) ()F F-----v,n )1'
" Rule 31 1 7. Discovery in Aid of Execution.
(a) Plaintiff, at am' tulle aAar judgment. hetbre or niter the i,suunce nfo writ orexecutum,
may. fire lltc pr;rpase 4 ,t disc,?very cor'assm. of u, dcl4ndant, take tite testis nt,;tm:
person, including a clelcndant ur a zirnishec. upon oral C\V[Tdflafinn or written
interruealOTies as pmvi(ted by 1110 roles rehaing to Dcpnsjli?ns 111cl Discovm ......
(b) All rcasonahle expenses ill comiection with the discovery ma" he lazed a?,aitlst the
defendant as WAS irit is ascerrlined by 111:. dise?ncrs proceedings that he has prrperty
liable to execution" (en>pltasis added)
Rule 4005. Wrilten 1mcrrwrat4sries to a Party.
(a) ......an% pttrn' may wrve alloy any (?fhcr p;trry u•ritlzn iulc:rrc,katorics to b ;insw red bV
the party scr%ed ,.... "ho shall Furnish ;ticfl jrtlormition m i5 trnilnhle...... '
Rule 4006. Answers to Writtcn InWlrolUl wrics I,% a 1'trrl\-.
(a) ( I ) Arrswu,,r to inlerrt}gan,rics;fr;Ill bi. in writing and under o;lth. The answers shall he
tiltisened isltlle spvtts pmvided in the acrrol aluries, lftliem is insufficient space to
Snswcr an intermptory, the remainder of the answer shall Ii,)low on a suppleutcntal
sheet.
rhl (2) Each inlerm;aMry shall bt: wiswureci fully acid compleldy unless objected co. in which
event the reasoRti lnr the oblitcekvn shall he ,lmcd Ill llctr of art '1 he allsvel-ing
pare shall file and scree a Ci+p? arfhe ;7psclc'rs and ob.jcclions, iraily, %tiidlin 330 davs
after the see vice tff fhe intei-rogatories._...
"Rule -1419, Sanctions.
(a) ( I ) 'Fhc couil may, on motion, make an appropriate order if
(i) n petty fails to scrv0 answers. sufficient antiwers, or ohjections to writren
imurruiralories under RLIle 400,
(c) •The COLI1't. „hen ;tcling under 4ubdiVisi4Ill(ti? Ol this rule. m;t% m;rke,.....
(4) an order imposing punishmenr lior contempt....." (emphasis added)
INTFRRfIGAI IRI
t. Please stale Ilu• 10IILMjjt g;
(a)Thr' iilII name, agu artd Roy ial Security nuulbur or'lIic INCrsnn ++ht', is Ilnvwring
thew Intcr7ogatories.
ANS" F: R:
(bJ Phone number. address and ht+u' lung at this adtlrucy.
ANS E:R:
?. REA I. ESTA r G: Do you have: an oNnerslrip or in1ere51 in any real estate an?'Wherc in floc United States? 11511, set
fottlf a briefdescrilitiun thereof. included oho structure and Iii siir and is pe of cl+trtU'nciiun; the Jocatit,n, induding
the stale, aluuty and ItnlnieipAty; Illy V411OR10 Mill l7aaX Rttlllh?l' rl1'tI1C 01richLI IWOrd tllt•reul` wd state tla'tlicr
whether yt+u own N solely or together with any other person ur Ilcr,;ons and give their dill names and addresses.
A ti514 ER:
(h) II'I1f11' 01 the ahuvc Prolicrlics is re riI0QLa_P(:d. ?ullIII Iltc rrnncs,In(I ,ItIjrrsus
of lenders, the late and anlututt.,I the nu+ttg?ls e, u'Ilurr it is recorded, die mowlily
payments and the balance n('%V clue.
AtiSWER:
3. f?(14'F.It\',tiil V'1' t7UNFI'IPA1, or t'(J RPORAT17 ILO.NDS; Stain whether ur tent P U own individually or
jointly any- curporate or governtrtent h0tld i. If so, include the f:teC Ltnrtllrnt, serial nuinkrr Und maturity date and state
the present location thereat: I f you own any of these Bonds jointly with any other person or persons, give their name
and address.
4. STOCKS tiltARES or-1-NI R-K. f: State whether ur not wit own any sttxks, shares or interest in any
corporation. or tonirtcorporated association or partnership interest, limited or general and state the location thereof.
Include the names and addrescrs vt'ihe organiratiow, and the serial numbers of the share-. or stocks. If sou nu n an?'
of the Stocks. Shares or Interest jointy u i I h an% other pennon or tk rsons, ;ive: their name and address. .
ANSWER
5. AC('01IN'T'`, State ahetheCor not ?ou maintain an• checking or savings accounts. II'so, state the dame and
location of the banks or sasin ,s and loan association or' building and Ivan association or credit union and the branch
or hunches thereol; the identificatim, numbr:rs of thosr aCCOUn15, and the amount or amounts Sou have in each
account- Ify'nu maintain any orthese jr+inUY wi111 nnother person, give their eta ne and address. Stan whefltiEr sai;:t?
dcpnsil,
ANSWER:
6. PERSONAL PROPERTY. `irate «hethorr er not you os%n am• per%tmal pro?pers., Include a full description el'all
furnishings and anti other items til'Ixrsonal pn)pert} tincludin, je?.cln ).?ith lull cfcuriPtion, ?alue and present
location. Slate also) vohelhcr or nol there are tin} cneamhrances tm Mitt property ;and if 50, the ncirne ami address tul
the enctunhrunce huller, the date td'the encumbrances, (fie 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 o?+n a personal
pmpem jointly with 8115. Other person or persons, gi?e I h 0 r name and address.
MOT M VFlllta.l:S: State whether or nut ; uu own motor vehicles. Include a full description of such motrs r
Vehicles includinO color, model. tidy number, serial number and re>tistrntion plate number. Also xhrnr the exact name
or names in which the major vehicles are registered. the present ?;aluc of those rnolor vehicles and their present
IL,catiOn ;rnd place of rvgUlar sttiragc, rnrtiging «r parking. date also whether rr not there are an?• cactnnhrances till
those mutor vehicles and if so, the name and ;address t f the rncurnhmace holkler, the date trl the encurtabrtnce. the
original amount of that encumbrance, the present balance of the encurnbrance and the transaction which have rise lo
the existence of the encumbrance.
ANS" Lk:
8. RENTAI. I?CU?1 'ti: Slalc kliether you are the rcCipienz. dirccth or indirectly, ol'any income for the i-cmal of
any real orprrnanal prnpenr:;In(l ifso. state specilicalI} the sourcet,f liasnirnt, the hersun Ito uhorn such pas-mems
arc ntatic wnd Al L:ann ounl and (Lat: %diev lhmq ltayinviiI ctrl recei% kl,
ANS Fly:
Edwin A. Abrahimsen & Asu?Cialcs, P.C.
I):4'I'I:D:.Imu• [fir
I>! ?} L
. unrncls liar I'1;iintiff
AF FIIL. ?
t'C1U:til'?' t1F' c_tl?[Rt•:Fi[.,?tiU
COMMON %%I;A1.1I1OFPE: NSVINAN1A
sS
Befun me, the undel'siped outlluritk ptrsnnaii% appcarcd
.rho, being dull mom according to Im". dcposcs and -,ays Thal the 1i?regoinb
Answers m InicrrugainrieS 1:41" 1)iccovcry ol'AsseIS ill Aid ul'Fxrrtrtioll urC true orld Correct iu the NS1 of dic
aR"tant'sknoAledge. intotmSliun and Ixlief,
IVORN'7U AN0 SIIHSCR111F1)
III?FC?RE; MF HIS DAY O
• 211
NOTARY PUBLIC
A!' I [AN 1 S SIGNATURE
AI IAti lti AW)RESS
1 ITI.F: IFF 0F•'VICIA1,
EOW?N A, ABRAW&M56N
MICnACL r. *^tCnrplio
nEATn EM a_ woop*4brr-
'ALSO ME-BEM or rt 0A0
VANFSSA I, I MIME
1028 Mill Rol
THE LAW ?FFICE OF
CUMN A. ABRAMAMSEN & ASSOCIATES, P.C.
WWW. EAA-LAW. COM
MECHANICSBURG PA 17050-2102
Rli: Crct itor: Credigy Receivable,., Inc
069inal Creditor: (:ruligy Rcccivablcs 111c.
(original Account Nultlher: 53 29000537005578
Balance Due: $2.77;.45
Our File 0: C08-0158
Dear VANI-SSA f. NORNE:
Juh• 27, 2tK19
You rceently received a series of Ir ieffoiwories in Aid of Execution fri1111 I'dwin A. Abrahamsen
R Associates, I .C. regardinga judgment that has been obtained again, you by C+edr l
Recerrnhlns hie, . According to the Pennsylvania Rules ot'Clvil Proccdure, y(?u had thirty days
to provide this otlice with your reply to the interrogalories. To date, my otlicu has not rccuivcd a
reply. t'lca.se provitic an answcr to Ihuse Interrogalt+ri4s, ell' (:oiita(;t (itlr {tl Ille within t11c 11axt 15
days, or appn1Itriatc stets may he token with the COUrt to wmpcl you U11 ;rrtswer thern_ This is un
important mater that requires your utiention.
Ve ruly Yvtlrs,
4 .I
4
Ile 7 h, x tuft: E.
\liellael F. Ratrhlord. Esq.
Fdwin A. Abralianisen R Asmwiales, ['.C,
This is a communicalion from a debt collector in an aticmpt to collet a debt. Any iriformaiion
obtained will he tuned for that rurpose.
1 20 NORTH KE:YSER AVENLrE • SCRANTON PA 1 4
t3 50a fP) 570.598,551 O l?1 570.558.551 1
EDWIN A. ASRAHAMSEN
MICHAEL F, RATCHFORD
HEATHER K. WOODRUFF'
'ALSO MEMBER OF FL BAR
THE LAW OFFICE OF
EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C.
WWW.EAA-LAW. COM
January 21, 2009
VANESSA L HORNE
1605 AIRPORT DR
MECHANICSBURG PA 17050-2102
Re. Credigy Receivables Inc. v. VANESSA L HORNE
CUMBERLAND County Civil Action No.:00313353civil
Our File #: C08-0158
Dear VANESSA L HORNE:
As you know, on November 26, 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.
Edw'n A. Aorahamsen & Associates, P.C.
Michael F. Ratchf0 , sq.
This is a communication from a debt collector in an atte? collect a debt. Any
information obtained will be used for that purpose.
1 729 PITTSTON AVE. 0 SCRANTON, PA 1 8505 0 (P) 570.558.551 0 - (F) 570.555.551 1
Credigy Receivables Inc.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
VANESSA L HORNE
Defendant
• CIVIL DIVISION
• NO: 08-6285-CIVIL
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:
VANESSA L HORNE
1028 Mill Rd
MECHANICSBURG PA 1 7050-2 1 02
Date:
Michael F. R chford,
Attorney I. o.: 86285
uire
OF THE PROS f O Z 1 AM
2009 OCT -2 PM 12: SO
A
NA
CREDIGY RECEIVABLES, : IN THE COURT OF COMMON PLEAS OF
INC., : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. CIVIL ACTION - LAW
VANESSA L. HORNE,
Defendant NO. 08-6285 CIVIL TERM
ORDER OF COURT
AND NOW, this 21" 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 20 days of the date of this order.
ichael F. Ratchford, Esq.
Heather K. Woodruff, Esq.
Edwin A. Abrahamsen & Associates, P.C..
120 North Keyser Avenue
Scranton, PA 18504
Attorneys for Plaintiff
.,-Vanessa L. Horne
1028 Mill Road
Mechanicsburg, PA 17050-2102
Defendant, pro Se
:rc
nn
t v 2.2.? Ug
BY THE COURT,
20P9 OCT 22 AM 11 ' 2
OU -J!
PRAECIPE TO =ISSUE WRIT OF EXECUTION - (MONEY JUDGMENT) RULES PA. R.C.P. 3252,3111
(a)
Credigy Receivables, Inc
3950 Johns Creek Court In the Court of Common Pleas of
Suwannee, GA 30024 CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
VS.
VANESSA L HORNE NO: 08-6285-CIVIL
1028 Mill Rd
MECHANICSBURG PA 17050-2102
Defendant
PRAECIPE TO REISSUE WRIT OF EXECUTION
VS. AND ATTACHMENT
TD BANK(COMMERCE BANK) W191R M4"
4860 CARLISLE PIKE
MECHANICSBURG PA (MONEY JUDGMENT)
Garnishee
To the Prothonotary: TO SATISFY THE JUDGMENT, ISSUE WRIT OF EXECUTON IN THE ABOVE MATTER
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) Against: VANESSA L HORNE 1028 Mill Rd MECHANICSBURG PA 17050-2102
of to me"
(3) And against: TD BANK(COMMERCE BANK) 4860 CARLISLE PIKE MECHANICSBURG PA
(4) and index this writ (a) against
Defendant(s) (b) against
Garnishee(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):
183-72-2195;
(5) Judgment Amount $3,594.82
Interest $ -ow
Clerks Fee $
Sheriff $
Poundage $
Total $
Date: October 16, 2009 V "
Michael F. Ratchford, Esqui
Edwin A. Abrahamsen & Associates, P.C.
Attorney for Plaintiff
mratchford@eaa-law.com
lij TJ?
23
?as+
?.S U
t{
?2.vv
? ? ?ss
Credigy Receivables, Inc
3950 Johns Creek Court In the Court of Common Pleas of
Suwannee, GA 30024 CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
VS.
VANESSA L HORNE NO: 08-6285-CIVIL
1028 Mill Rd
MECHANICSBURG PA 17050-2102
Defendant
VS.
TD BANK(COMMERCE BANK) W`Kl a
4860 CARLISLE PIKE
MECHANICSBURG PA
Garnishee
Praecipe for Entry of Appearance
Kindly enter my appearance on behalf of Credigy Receivables, Inc in the above-captioned
matter.
s WCkkVj
Date: October 16, 2009 SignaturePrint Name: Michael F. Ratc rd Es uire
Address: 120 North Keyser Avenue
Scranton, PA 18504
Telephone No: (570) 558-5510 Ext. 101
Supreme Court ID No: 86285
210 09 0 C! 2 3 i"ll` 11 1, 0: 51 i
Credigy Receivables, Inc
3950 Johns Creek Court In the Court of Common Pleas of
Suwannee, GA 30024 CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
vs.
VANESSA L HORNE NO: 08-6285-CIVIL
1028 Mill Rd
MECHANICSBURG PA 17050-2102
Defendant
vs.
AFFIDAVIT UNDER SOLDIERS AND SAILORS
TD BANK(COMMERCE BANK) RELIEF CIVIL RELIEF ACT OF 1940 AS
4860 CARLISLE PIKE AMENDED
MECHANICSBURG PA
Garnishee
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): VANESSA L HORNE; 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): VANESSA L HORNE; is(are) older than eighteen years of age;
That the employment status of the defendant(s):
VANESSA L O is are) u nown.
Michael F. Ratchford, E wire
before me this _J-'- _ay of 20O-
Loeh Meb6ittiIAnd ivener- Not Public
0
J??NtFNOia?y p?ti P??NNp 0 ?°Ng?
ScMV°mm
29 99 - } 2- 3 " '1 lYi
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-6285 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CREDIGY RECEIVABLES, INC., Plaintiff (s)
From VANESSA L. HORNE, 1028 MILL RD, MECHANICSBURG, PA 17050-2102
(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 TD BANK (COMMERCE BANK) NWA METRO BANK - 4860 CARLISLE PIKE,
MECHANICSBURG, PA
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 $3,594.82
Interest $1,388.68
Atty's Comm %
Atty Paid $164.78
Plaintiff Paid
Date: OCTOBER 23, 2009
(Seal)
REQUESTING PARTY:
Name MICHAEL F. RATCHFORD, ESQUIRE
Address: EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C.
120 NORTH KEYSER AVENUE
SCRANTON, PA 18504
Attorney for: PLAINTIFF
Telephone: 570-588-5510 EXT. 101
Supreme Court ID No. 86285
L.L.$.50
Due Prothy $2.00
Other Costs
Deputy
Sheriffs Office of Cumberland County
R Thomas Kline
Sheri
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
$?Ntitiq of C11146ErJ b
OFF : ,E ,F TrF
ALEQ-Q-'rICE
QF NE F _ Y'. 'NOTARY
2009 NOY -2 PM 2: 28
WUNTY
F[ NNSYLV,,NA
Credigy Receivables, Inc. Case Number
vs.
Vanessa L Horne 2008-6285
SHERIFF'S RETURN OF SERVICE
10/28/2009 10:48 AM - Timothy R. Black, Deputy Sheriff, who being duly sworn according to law, states that on
October 28, 2009 at 1045 hours, attached as herein commanded all goods, chattels, rights, debts, credits,
and monies of the within named defendant, to wit: Vanessa L. Horne, in the hands, possession, or control
of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County,
Pennsylvania 17013, by handing to Mary Morgan Kellenr, Customer Service Representative personally
three copies of interrogatories together with three true and attested copies of the writ of execution and
made the contents there of known to her.
The writ of execution and notice to defendant was mailed on November 2, 2009 to Vanessa L. Horne, at
1028 Mill Road, Mechanicsburg, PA 17050.
So Answers,
R. Thomas Kline, Sheriff
%
By;??
puty Sheriff
Credigy Receivables, Inc
3950 Johns Creek Court
Suwannee, GA 30024
VS.
VANESSA L HORNE
1028 Mill Rd
MECHANICSBURG PA 17050-2102
VS.
In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
Defendant
TD BANK(COMMERCE BANK) hi/14
4860 CARLISLE PIKE txe: do ?LNk-
MECHANICSBURG PA
Garnishee
NO: 08-6285-CIVIL
INTERROGATORIES IN ATTACHMENT
RE: Execution of Judgment against your depositor VANESSA L HORNE SSN # 183-72-2195
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) an dthe primary account holder and if known whether joint account is
entireties property. Defendant has account 536985971 held individually
with a balance of $.88. Defendant did not receive $300
exemption.
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?
See answer to question 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.
The avaerage daily balance for account 536985971 is $17.31
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?
Not to the knowledge of Metro Bank
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?
No
6) At any time after you were served, did you pay, transfer or deliver any money or
property to the Defendant(s) or to any person or place pursuant to the Depositor's
direction or otherwise discharge any claim of the Depositor against you?
no
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)?
no
8) At the time you were served or at any subsequent time did the Defendant(s)accoount
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.
no
9) At the time you were served or at any subsequent time did the defendant have funds
on deposit in an accoun 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.
no
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
acocunt, lottery account, partnership account, joint or tenants by entirety account,
insurance account, trust or escrow account, attorney's account, or otherwise.
no
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. Abrahamsen & Associates, P.C.
Michael F. Ratchfor Esquire
120 North Keyser Av nue
Scranton, PA 18504
(570) 558-5510
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 Jennifer Hilbish
(Name)
Lem Specialist 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/her knowledge, information and
belief.
(SIGNATURE)
r: Ti's ., J 1`DIAfY
2009 NOV -G PH Li. 1 I
Credigy Receivables Inc.
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
vs.
VANESSA L HORNE
1028 Mill Rd NO: 08-6285-CIVIL
MECHANICSBURG PA 17050-2102
Defendant
Praecipe to Dissolve the Attachment against
vs. Garnishee
TD BANK(COMMERCE BANK)
4860 CARLISLE PIKE
MECHANICSBURG PA _?. .?
r
Garnishee r-
- rn
0
S
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Dissolve the Attachment against Garnishee.
Michael F. Ratchford, s
Edwin A. Abrahams &
Lawyer ID # 86285
Sworn ana subs4pribed before
P.C.
000, day 20_0
- P-- Q?? pS1`- 6
4g.Op p a 1\T rn
cy-fl cosy
a364cpq
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff a??tt4' pt ??urrLrrf r ?? I?? r},r'?
Jody S Smith
Chief Deputy f, f 0 J ? "g R '1 8'. 43
Richard W Stewart
Solicitor
rb.4i
Credigy Receivables, Inc.
vs. Case Number
Vanessa L Horne 2008-6285
SHERIFF'S RETURN OF SERVICE
10/28/2009 10:48 AM - Timothy R. Black, Deputy Sheriff, who being duly sworn according to law, states that on
October 28, 2009 at 1045 hours, attached as herein commanded all goods, chattels, rights, debts, credits,
and monies of the within named defendant, to wit: Vanessa L. Horne, in the hands, possession, or control
of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County,
Pennsylvania 17013, by handing to Mary Morgan Kellenr, Customer Service Representative personally
three copies of interrogatories together with three true and attested copies of the writ of execution and
made the contents there of known to her.
The writ of execution and notice to defendant was mailed on November 2, 2009 to Vanessa L. Horne, at
1028 Mill Road, Mechanicsburg, PA 17050.
07/07/2010 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: $86.60
July 07, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
Sharon R. L n z
R .00 mac. C_.'o.
X12-# '76? >y
c1 countysuite sherft. Tei?"cso{t. Inc.
Credigy Receivables Inc.
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
vs.
VANESSA L HORNE
NO: 08-6285-CIVIL
Defendant
Praecipe to Satisfy the Judgment
PRAECIPE. TO SATISFY THE JUDGMENT
To the Prothonotary of CUMBERLAND County Pennsylvania: -z: _
Please enter the above Praecipe to Satisfy the Judgment. Crx r---
r, ?'
"?; _v ,
;
Thank you,
Michael F. Ratchford, Esqu' e
Edwin A. Abrahamsen & ssociates, P.C.
Lawyer ID # 86285
120 N. Keyser Avenue
Scranton PA 18504
,,I .
C 30 9'
?'
?3n,;