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HomeMy WebLinkAbout08-6604IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDLAND FUNDING LLC NO. Q$ - ?p(p0? &yl' l Tier" 1315 AERO DRIVE ST6XXX SAN DIEGO CA 92123 Plaintiff VS. ANGELA M PINCKNEY Defendant (s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), ANGELA M PINCKNEY and , pursuant to the District Justice Transcript. ( X ) Amount due TOTAL $ 1296.21 $ 1296.21 , plus interest and costs ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. DATE: Q Signature: David R. Galloway # 326 1 1p . Warholic 86 Sarah E. Ehasz J2469 o er N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLC / Counsel for Plaintiff The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, P. C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (717) 303-6700 Fax: (717) 737-9051 NOW, ?pV 2008, JUDGMENT IS ENTERED AS ABOVE. b d"a- 2. of onotary/Clerk, Civ Division By. Deputy PRAEDJ/PADJDJ FILE # 181388399 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No.: 09-3-01 MDJ Name: Hon. HAROLD E. BENDER Aftess: 35 W ORANGE ST SHIPPENSHURG, PA Telephone: (717 ) 532-7676 17257-0361 ATTORNEY FOR PLAINTIFF : 0 ? NOTICE OFrJUDGMENT/TRANI T CIVIL CASE PLAINTIFF: NAMEandADDRESS riXDLAND FLING LLC ? 4660 TRINDLE RD APT/STS 300 C/O NAM SRACKM LLC LCAMP HILL, PA 17011 J VS. DEFENDANT: NAME and ADDRESS rPXNCXNZY, ANGELA If 170 THORNY GROVE LN SHIPPENSSURG, PA 17257 DAVID R. GALLOWAY L J 4660 TRINDLS RD STE 300 Docket No.: CV-0000186-08 CAMP HILL, PA 17011 Date Filed: 7/25/08 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF (Date of Judgment) 8/19/08 © Judgment was entered for: (Name) MIDLAND FUMING LLC ® Judgment was entered against: (Name) PINC13MY• ANGELA M in the amount of It 1,296.21- Defendants are jointly and severally liable. Damages will be assessed on Date & Time ? This case dismissed without prejudice. F] 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 $ 1,217.21 Judgment Costs $ 79• Interest on Judgment $ .00 Attorney Fees $ 00 Total $ 1,296.21 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 JUDGMENTRRANSCRIPT 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. g /9 Uo Date District Judge I certify that this is a true and correct copy of the record of the proceedings containing the judgment. ?-L-94(1?9t Date , Magisterial District Judge My commission expires first Monday of January, 2012 SEAL AOPC 315-07 DATE PRINTED: 8/19/08 1:41:00 PM l''P 251 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDLAND FUNDING LLC No. 1315 AERO DRIVE ST6XXX SAN DIEGO CA 92123 Plaintiff VS. CIVIL ACTION - LAW ANGELA M PINCKNEY Defendant (s) . AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, ANGELA M PINCKNEY , above-named, is over 21 years of age; is last known to reside at 170 THORNY GROVE LANE SHIPPENSBURG PA 17257 County of CUMBERLAND , Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. rLL David R. Gall ay #9732 1 ip C. Warholic Sarah E. Ehas #86469/Ro er Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLC / Counsel for Plaintiff The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, P. C. CQM"WAULTHOFPENNSY,LIANIA 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Notarial Seal Telephone: (717) 303-6700 Fax: (717) 737-9051 Rachel Zeltmann, Notary Public Hampden Twp., cumbw%nd 0ourdy on Exom v 23, 2W91 Member Pennsylvania Assockft of Notedes SWORN and SUBSCRIBED to before me this a--y day of 2008. N tary Public PNMAFF/PADJDJ FILE #: 181388399 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDLAND FUNDING LLC 1315 AERO DRIVE ST6XXX SAN DIEGO CA 92123 Plaintiff No. CIVIL ACTION - LAW VS. ANGELA M PINCKNEY Defendant(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise residence of Plaintiff is: MIDLAND FUNDING LLC 1315 AERO DRIVE ST6XXX SAN DIEGO CA 92123 and certify that the last known address of the within Defendant(s) is: ANGELA M PINCKNEY 170 THORNY GROVE LANE SHIPPENSBURG PA 17257 David R. Gallow #87326??i . Warholic #863 Sarah E. Ehas2 #86469/Robert N. Polas, Jr.= Amy F. Doyle #87062 Mann Bracken LLC / Counsel for Plaintiff The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, P. C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (717) 303-6700 Fax: (717) 737-9051 PCRES/PADJDJ FILE # 181388399 a ? ? ? S? c ?' W 'C) ? ? J? ? n ?, ?? -z = rt. ? -? ? =` ?? : _ ..? r, c...? t } ?? ? 253 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND MIDLAND FUNDING LLC NO. 1315 AERO DRIVE ST6XXX SAN DIEGO CA 92123 Plaintiff VS. ANGELA M PINCKNEY 170 THORNY GROVE LANE SHIPPENSBURG PA 17257 Defendant (s) COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NOTICE OF ORDER, DECREE OR JUDGMENT TO: ANGELA M PINCKNEY A/K/A ANGELAM LITTLE 170 THORNY GROVE LANE SHIPPENSBURG PA 17257 You are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on 11tw Of) in accordance with the provisions of Pa. R.C.P. 23 ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( ) Judgment of ( ) Confession ( ) Verdict ( ) Default ( ) Non-suit ( ) Non-pros ( ) Arbitration Award ( X ) Judgment is in the amount of $ 1296.21, plus costs. ( X ) District Justice transcript of judgment in civil action in the amount of $ 1217.21, attorney's fees in the amount of $ 0.00, interest in the amount of $ 0.00, plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsylvania Department of Transportation. By: K . othonotary b44 t the filing party. If you have any questions regar ing this No ice, please conAc ! 1 / A X / f l? David R. WGallowa-# #87326dqlhilig C. Warholic #86341-?, Sarah E. Ehasz #86469 o ert N. Polas, r. ? 9 Amy F. Doyle #87062 MANN BRACKEN LLC / Counsel for Plaintiff The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, P. C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 / (717) 303-6700 (This Notice is given in accordance with Pa. R.C.P. 236.) DJNTC/PADJDJ FILE # 181388399 622 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 TO 3149 MIDLAND FUNDING LLC Plaintiff VS. ANGELA M PINCKNEY Defandant(s) : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 08-6604 PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $ 1296.21. (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against, ANGELA M PINCKNEY 170 THORNY GROVE LANE SHIPPENSBURG PA 17257 Defandant(s); (3) and against MEMBERS FIRST FCU located at 1000 BRYN MAWR RD CARLISLE PA 17013-1588 (4) And index this writ (A) against ANGELA M PINCKNEY Defandant(s) and (B) against, MEMBERS FIRST FCU Garnishee(s); ,Garnishee(s), as a lis pendens against the real property of the Defandant(s) in the name of the Garnishee(s) as follows: (Specifically describe property)***GARNISH ONLY*** You are directed to attach the property of the Defendant(s) not levied upon in the possession of MEMBERS FIRST FCU , Garnishee(s) All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount Due: $ 1296.21 Interest From: 11/07/2008 To Be Determined At an interest rate of 6% per year Total: $ 1296.21 Plu e s interest David R. Gal Ewa # /Philip C. Warholic #86341 Sarah E. Eha #86469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 PABGAR/PABANK FILE # 181388399 49 FI?E0-4t-ICE OF THE PROtI-',ONOTA#Y 2009 OCT -5 PM 12* 4 4 CUM t ? , OUNTY PENIINSYMNIA 4614.50 P-0 ArtY aT. as CAF $54 . oL5 - Pb Ai- y .*a.oo bw Co . 50 LL a" aal 431 or4&4S.W4 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-6604 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDLAND FUNDING, Plaintiff (s) From ANGELA M. PINCKNEY, 170 Thorny Grove Lane, Shippensburg, PA 17257 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS FIRST FCU, 1000 Bryn Mawr Road, Carlisle, PA 17013-1588 All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. 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 $1,296.21 L.L. $.50 Interest from 11/7/08 at an interest rate of 6% per year -- To be Determined Atty's Comm % Due Prothy $2.00 Atty Paid $54.25 Other Costs Plaintiff Paid Date: 10/5/09 (Seal) REQUESTING PARTY: Name DAVID R. GALLOWAY, ESQUIRE Address: MANN BRACKEN LLC 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 866-253-0128 C is R. Long, Prothonotary Deputy Supreme Court ID No. 87326 W.3 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MIDLAND FUNDING LLC No. 08-6604 RECEIVED Plaintiff CIVIL ACTION - LAW ou 2 0 2009 VS ANGELA M PINCKNEY Defendant (s) oults -?) . - , INTERROGATORIES TO GARNISHEE TO: MEMBERS FIRST FCU 1000 BRYN MAWR RD CARLISLE PA 17013-1588 PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE . A. 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. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ Execution was issued. C. "You" means the main office and all branch offices, representatives, employees and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the.Defendant(s) which comes into your possession thereafter. E. These Interrogatories.are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. CAL / INTERROGATORIES TO GARNISHEE DEFENDANT(S) - ANGELA M PINCKNEY 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each account. If the Defendant(s) maintains an of these jointly with any other person, or persons, give their name and address. IA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. XX Xqbq 2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being.funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. no 3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds on deposit, not including any otherwise exempt funds, did not exceed the amount of general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. A-t- 4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? 00 5. SAFE DEPOSIT BOX: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. /10 Q,S 1 At the time you were served or at any 6, REAL OR PERSONAL subsequent time, PROPERTY: ersonal property personal property that was in your possession state whether or not the Defendant(s) own any persona or liens and/or control. If so, include a full description of all giving full or liens value and present location. State also whether or not there are any encumbrances rs the resent balance of the encumbrance. Stat=owhererty and when when with any perencumbrancesson or holde P personal p P was recorded. If the Defendant(s) owns any p persons, give names and address. n 7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). ?0 8. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). no 0 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charged by you against the Defendant (s) or account (s) of the Defendant (s) for the completil of this Answer? If yes, outline the exact amount of any fees due and owing to the garnish or the attorney for the garnishee for the preparation of the Answer. ho N.. 1 owa 8732 ilip C. Warholic #86341 Sarah E. Eha z #86469 Robert N. Polas, Jr. #2012` Amy F. Doyle #87062 - - Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 A MEMBERS V FEDERAL CREDIT UNION October 20, 2009 Name: Angela M. Pinckney Address: 170 Thorny Grove Lane Shippensburg, PA 17257 Account Number: XXX909 Name on Account: Michael Pinckney Angela M. Pinckney (Joint) Savings: $0.00 Checking: $0.00 $300.00 Statutory Exemption was not taken out. CS?I?-D?, lJ Tania S Young Deposit Operations 1?st 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org 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 Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ?I J rV (SIGNA ) 0- FILED-: .rl ?i "T THE F_ 1 r R :'? 7-1plY 2009 QC T 2' 1 Ply! 3: 3 -14 Sheriffs Office of Cumberland County R Thomas Kline (F `? I MM Sheriff wtti pi ?jiu,t,r f Ronny R Anderson tt? jld 2119 OCT 26 A" i©: 3:4 Chief Deputy - COLM, Jody S Smith _ ?"„PV Civil Process Sergeant F`s F Edward L Schorpp Solicitor Midland Funding I Case Number vs. 2008-6604 Angela M Pinckney SHERIFF'S RETURN OF SERVICE 10/20/2009 09:39 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on October 20, 2009 at 0939 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Angela M. Pinckney, a/k/a Angelam Little, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Marisol Barber, Assistant Branch 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 October 22, 2009 to Angela M. Pinckney, a/k/a Angelam Little, 170 Thorny Grove Lane, Shippensburg, PA 17257. So Answers, :7 s f' R. Thomas Kline, Sheriff 'By JA D puty Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDLAND FUNDING LLC No. 08-6604 8875 AERO DRIVE, SUITE 200 SAN DIEGO, CA 92123 - Plaintiff VS. ANGELA M PINCKNEY 170 THORNY GROVE LANE SHIPPENSBURG PA 17257 Defendant (s) PRAECIPE TO DISCONTINUE ATTACHMENT PLEASE RELEASE THE WRIT OF ATTACHMENT ON A JUDGMENT FILED AGAINST MEMBERS FIRST FCU GARNISHEE IN THE ABOVE-ENTITLED MATTER WITHOUT PREJUDICE. Respectfully submitted, By: ?- - -p._ _s_ David R. Gal oway #87326 Philip C. Warholic #86341 /Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 cc: PAP6/PA209A FILE # 181388399 Zfll ? EC t= Y $ 5.00 PD ATN cl,* 4tooM8 a3H 53 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Midland Funding LLC assignee of COLUMBUS BANK AND TRUST V. ANGELA M PINCKNEY Plaintiff Defendant(s) NO. 08-6604 CIVIL ACTION - LAW o M ! -0 Fn- .?; ` C; - 3 tTi ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the undersigned as counsel for Plaintiff in the captioned matter By: / David R. Galloway 87326 Fulton Friedman 81 Gullace, LLP Counsel for Plaint f Attorneys in the Practice of Debt Collection 130B Gettysburg Pike Mechanicsburg, PA 17055 Tel: (866) 563-0809 Fax: (585) 546-4241 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office, first class mail, postage prepaid, addressed as follows: ANGELA M PINCKNEY 170 THORNY GROVE LN SHIPPENSBURG PA 17257 FFG File #: 168586 IIINI IINI IIIII IIIII IIIII IINI IIIII 111111 IN 111111 IIIII IIII IIII 0- David R. Gallowa Date Attorney ID #873 PA/PA_EOA t SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F-ji Sheriff k ! Jody S Smith 1 f` Chief Deputy A 2010 j;,jj_ Ah 6: 44 Richard W Stewart Solicitor Midland Funding LLC Case Number vs. Angela M Pinckney 2008-6604 SHERIFF'S RETURN OF SERVICE 10/20/2009 09:39 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on October 20, 2009 at 0939 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Angela M. Pinckney, a/k/a Angelam Little, in the hands, possession, or control of the within named garnishee, Members 1 st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Marisol Barber, Assistant Branch 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 October 22, 2009 to Angela M. Pinckney, a/k/a Angelam Little, 170 Thorny Grove Lane, Shippensburg, PA 17257. 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: $87.03 July 07, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF Sharon R. Lantz a -D6 r c ? ce, . S-0 Z-Z- "Pd' AW (GI CountySuite Shenff. T7eleosoft. Inc.