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HomeMy WebLinkAbout08-6746IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW KIMBERLY J. HILL, DOCKET NO. -7 V4 f" Defendant ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Remit Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, THE REMIT CORPORATION LAURINDA J/VOELCKER, 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 Unifund CCR, Plaintiff VS. CIVIL-LAW KIMBERLY J. HILL, DOCKET NO. 0 8 - 417 y L-can.{ / ¢?• - Defendant NOTICE TO DEFENDANT TO THE DEFENDANT: YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Pennsylvania Lawyer Referral Service 100 South Street, PO Box 186 Harrisburg, PA 17108 Cumberland County Bar Association 800-692-7375 2 Liberty Avenue 717-238-6807 Carlisle, Pa 17013 (717)249-3166 LAURINDA J. O LCKER, ESQUIRE Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. CIVIL-LAW KIMBERLY J. HILL, DOCKET NO. 6 k- G 7 4j- Defendant COMPLAINT 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 Unifund 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, Kimberly J. Hill, is an adult individual residing at 162 Ken Lin Drive, Carlisle, Cumberland County, Pennsylvania 17015. 3. Defendant obtained a Mastercard credit card on or about September 15, 2002, from Chase Manhattan Bank USA, (hereinafter "original creditor"), Account number 5490 9117 0041 9124. 4. Unifund CCR Partners purchased the account of Kimberly J. HILL 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 $12,548.33 with interest continuing to accrue at 6.00% per annum. 6. Defendant's last payment on this account was made on or about April 27, 2005. 7. To date the balance is $10,207.41 principal and $2,340.92 interest for a total of $12,548.33. COUNT 1 BREACH 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 $12,548.33. 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 $12,548.33. 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(1), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit C. WHEREFORE, Plaintiff, Remit Corporation, assignee of Unifund CCR Partners, demands judgment against the Defendant in the amount of $12,548.33 together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT II BREACH OF IMPLIED CONTRACT 14. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 15. It is averred, in the alternative, in the paragraphs set forth above, if an express contract between original creditor and Defendant did not exist, that a contract implied by fact or implied within the law exists. 16. At all times relevant hereto, Defendant was aware that the original creditor was extending credit services to Defendant and that the original creditor expected to be paid for the Defendant's use of this credit. 17. Defendant used the credit card to purchase items, and/or transfer balances, and/or obtain cash advances and he received the same to Defendant's benefit. 18. The total reasonable value of the Defendant's use of the credit extended by original creditor is $12,548.33. 19. In breach of the implied contract, Defendant has failed and refused to pay the outstanding sum for the credit card use and the same is now due and owing. 20. The Defendant has failed and refused to pay the aforementioned sum despite frequent demand to do so. 21. By virtue of Plaintiff's assignment of this account, Defendant is indebted to the Plaintiff in the amount of $12,548.33. WHEREFORE, Plaintiff, Remit Corporation, assignee of Unifimd CCR Partners, demands judgment against Defendant in the amount of $12,548.33, together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT III QUANTUM MERIUT/UNJUST ENRICHMENT 22. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 23. Original creditor provided the extension of credit as set forth above with the expectation of receiving payment for all use of this credit including, but not limited to, purchases, cash advances, balance transfers, fees and interest. 24. The credit extended by original creditor benefited Defendant. 25. The Defendant will be unjustly enriched if Defendant is allowed to retain the benefit resulting from Defendant's use of the credit card provided by original creditor without having to make reasonable payment for the value of the benefits received from the original creditor's provision of credit. 26. The original creditor was not a volunteer in providing the credit services set forth above and the Defendant understood that original creditor was entitled to compensation based upon Defendant's use of the credit card. 27. The reasonable value of the Defendant's use of the credit card including purchases, balances transfers, cash advances, fees and interest is $12,548.33. 28. By virtue of the Plaintiff's assignment of this account, Plaintiff, Remit Corporation is entitled to $12,548.33 from the Defendant and frequent demand for said sums has been made and the Defendant has failed and refused to pay the same. WHEREFORE, Plaintiff, Remit Corporation, assignee of Unifund CCR Partners demands judgment against the Defendant in the amount of $12,548.33 together with interest, costs, attorney fees and such further and additional relief, as this Honorable Court deems just and equitable. Respectfully submitted, 4J'IA J Laurinda J. Voelc er, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-1873 Fax 570-387-6474 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: HILL, KIMBERLY J # 574352 5490911700419124 for the sum of $12548.33 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 11 th day of September, 2008. Joseph Lutz, Record Specialist & Account Manager. onzed Signature Unifund CCR Partners. State of Ohio. County of Hamilton. 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 KIMBERLY J HILL, Account Number 5490911700419124, the amount of $12482.88. This account was issued under the name of CHASE MANHATTAN BANK USA NA and acquired from Chase Bank USA NA. Said account has been forwarded to REMIT Corporation, as attorney for Plaintiff Unifund CCR Partners assignee of Palisades Collection LLC, 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. this 08/22/2008 CCR PARTNERS By: Title 10625 Techwoods Circle, Cincinnati, OH 45242 Address I hereby certify that on 08/22/2008, 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. Notary Public My commission Expires 634 EXHIBIT p \, $A.Q Lr E m ? m ? a CCn` a I Iacs Z h m o° O N ?0 ?g N sit om fig all a tartp a? air allr -4 rL Bill 't M 3 a $ t all all ?,. 414 -Z I Sit ii0i f 1 a_' s ILI rFl r" PL :0 zT ?9Sn ?, m mC) .> S o '" in d 6?i „ x ai of 3 d N 5a Z D EXHIBIT 2-1 Z) 51 v d ? •? 3 ??CN _? r?,ggJ, o. c $ GL CA I n1 PR ? o o-a am?? 2z;; F Q a? a T$ if f ? a A JZ ar 'T ni N g Lm A M-4 -p{ s f- '• asst at •sr c$ i #s elffill- 10.1 -crk. F QL or SL l 11 Rif a 19 ?ir It" QL i f IT m#$ 'T S ct lab ? F M?K?? ?Q H9 03 ab si. 11.4 -71 .1 1 11 - d 1 r +R Hit 1 1 1 Joe j 9 1 2 L S ?g a ?q 3F qr o s a8 t?S9 ?? s' Bfa fat 10 !I-zw11FI? ?. ! a 7 Sd M lux.- UI a 8 g it " 4 o? ji 91 if if I W Ili g ? a if r V T 5.1 F1 $ a a h sr git t I I it -1 a,.a Ir a 31 e 7r jR 9' S41i 1 fit ??? Ica 0 3? ?? ii '?• ? ,? a 9; . ER 3 ffpp ? ? ?? 1x3 ?: ? ? d f 4 fag b plizil .d a $ S ?? . a all ?$I L, !i 4 17 f ;z cr T $$ fit Q s UZ or rg fillet Ica, - i ,. ?a a f SL SL lea fit gig > S cr z . Z or ? r-f s Ili's cr :_ +t III-Ali R or v 17 a s r? ?e ?s 'T RINI ill I? ?. a I .? ? ?v rma W3 fit +f s 1 ?? F fig 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 unsworn falsification to authorities. F?A' z Harry A. S r, III, Rem rporation 'TO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff VS. : CIVIL-LAW KIMBERLY J. HILL, DOCKET NO. 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. Dated thi day of e5Z kOL--- , 2008 Laurinda J. Voelcker squire 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 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 OCT-14-2008 11:50:25 Last Name First/Middle Begin Date Active Duty Status Service/Agency HILL KIMBERLY J 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. Alt 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: hgp://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: BJYYQMGBMTF https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/14/2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW KIMBERLY J. HILL, DOCKET NO. Defendant CERTIFICATION 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: Kimberly J. Hill 162 Ken Lin Drive Carlisle, PA 17015 Respectfully submitted, Laurinda J. Voelc r, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 570-387-1873 Fax 570-387-6474 Ni r?? SHERIFF'S RETURN - REGULAR CASE NO: 2008-06746 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REMIT CORPORATION VS HILL KIMBERLY J KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HILL KIMBERLY J the DEFENDANT at 0018:28 HOURS, on the 14th day of November-, 2008 at 162 KEN LIN DRIVE CARLISLE, PA 17015 by handing to TED HILL HUSBAND OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 . 00 1 Jb ! f D (_)^^ V 3 0 Sworn and Subscibed to before me this day So Answers: R. "Thomas Kline 11/17/2008 P7MTT ('0P1Dl11:?ATT0NT B? of A.D 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. KIMBERLY J. HILL, Defendant CIVIL-LAW DOCKET NO. 08-6746 PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment against Defendant in the above captioned matter as follows: Real debt $ 12,548.33 Attorney's Fees $ 2,551.85 Interest from Nov. 13, 2008 $ 125.48 Total: $ 15,225.66 Kindly assess damages against Defendant in the sum of $15,225.66 plus continuing interest at the statutory rate of 6%. BY: Laurinda J. V lcker, Esquire Attorney for Plaintiff a t e ? r. 1:r 4l } s, C>el ^3?c. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifand CCR, Plaintiff vs. CIVIL-LAW KIMBERLY J. HILL, DOCKET NO. 08-6746 Defendant : TO: Kimberly J. Hill 162 Ken Lin Drive Carlisle, PA 17015 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 KIMBERLY J. HILL, DOCKET NO. 08-6746 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 December 12, 2008. BY: 10 Laurinda J. V e cker, Esq. Attorney fo Plaintiff C\j # L LtJ Z [-z ? 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. KIMBERLY J. HILL, CIVIL-LAW DOCKET NO. 08-6746 Defendant NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO: Kimberly J. Hill DATE OF NOTICE: December 12, 2008 162 Ken Lin Drive Carlisle, PA 17015 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 11-1E ; ICE SE FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH F YOU CANNOT AFFORD TO HIRE A LAWYER, • - :., .. BE . _ sLz : ; : '"T I; E, YOU wTTH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL. SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. yl : a::ia Lawyer Referral Service Nn»rn wt_rPet, P.O. Box 186 Z7? -`ul.» PA 1 71 OR T44 11, 1-(l?7 1- 1 ? ! 1 Cumberland County Bar Association 2 Liberty Avenue !?µ`1_?1V _nA 1'7n11 i !-249- j i Oti 717-238-6807 RE ORP ? Mailed to: ?2 Kimberly J. Hill aurinda J. Voel e , squire 162 Ken Lin Drive 570-387-1873 Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW KIMBERLY J. HILL, DOCKET NO. 08-6746 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. Dated this Hday of J AWy r 2009 Laurinda J. Voelc)er, Esquire Attorney For Remit Corporation Attorney ID 82706 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 i= ' t r 65 l (?-:. F-- " am Li kf i .ate _ (7) V Request for Military Status Department of Defense Manpower Data Center ,,. Military Status Report Pursuant to the Servicemembers Civil Relief Act trttps: //www.4T"dc. osd.mil/scra/0wa/scro.prc_Selcc! JAN-14-.2009 10:12:57 .._.... _ Last Name First/Middle Begin Date Active Duty Status Service/Agency HILL KIMBERLY Based on the information you have furnished, the DMDC does not -possess any information indicating that the individ?jal 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. 41 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 1/14/2009 1:12 PM Request for Military Status btps://www.dmdc.osd.mi.1/scralowa/scra.prc_Sclecf 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: RIPAFMYPN 2 of 2 1/14/2009 1:12 PM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Assignee of Unifund CCR, Plaintiff vs. CIVIL-LAW KIMBERLY J. HILL, DOCKET NO. 08-6746 Defendant CERTIFICATION 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: Kimberly J. Hill 162 Ken Lin Drive Carlisle, PA 17015 Respectfully submitted, Laurinda J. Voelcker, Esquire Attorney for Plaintiff PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 -. 7 t i ^Y u tee, ?.i C-4 r_ - T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION Plaintiff .. CIVIL ACTION -LAW =' `? VS. n? t , -tr N0.08-6746 KIMBERLY J. HILL _ c? t 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 assignee of Palisades Collection, LLC 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 08-6746 against Defendant, KIMBERLY J. HILL, for the sum of $12,799.31 which constitutes damages and costs of suit, plus interest at 6.00% annum from 01/26/2009, together with all the benefits and advantages that may be obtained thereby, and full power to enforce and recover the Judgment to Unifund'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. $8.00 P 0 ATN cr" ?as4s .39(46 IN WITNESS WHEREOF and intending to be legally bound hereby, Remit Corporation, s executed this Assignment this 93 day of , 2010. Laurinda J. Vo cker General Counsel Remit Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION Plaintiff VS. KIMBERLY J. HILL Defendant : CIVIL ACTION -LAW : NO. 08-6746 PRAECIPE TO MARK JUDGMENT TO USE OF ASSIGNEE TO: PROTHONOTARY: Please mark the Judgment entered in the above captioned case against the Defendant(s), KIMBERLY J. HILL, to and for the use of Unifund Corporation assignee of Palisades Collection, LLC, Assignee, as per Assignment of Judgment, a copy of which is attached hereto and made a part hereof as Exhibit A. DATED: ?/? G BY: Laurinda J. Voelck , Remit Corporation JUDGMENT MARKED TO USE OF ASSIGNEE AND NOW, to wit, this A* day of Maneh '0101f) , the Judgment entered in the above captioned case against the Defendant (s), KIMBERLY J. HILL, is hereby marked to and for the use of Unifund Corporation assignee of Palisades Collection, LLC. Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. KIMBERLY J. HILL, (&a lCerl Lin W a Defendant CAX (t Sle l PW 1761S : CIVIL-LAW : DOCKET NO. 08-6746 PRAECIPE FOR WRIT OF EXECUTION Personal Property Levy c a n =-n rn- ?r 0 -+a z -? C :)-n ;EE o rr, D To the Prothonotary: Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against KIMBERLY J. HILL, defendant, (3) against N/A, garnishee; (4) and enter this writ in the judgment index a. against KIMBERLY J. HILL, defendant, and b. against N/A, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: N/A I'? (5) Amount Due: Interest from 01/26/2009 Other: Credits: Costs to be added: Clerks Fee: Sheriff: Total: $ 15,225.66 $ 1,774.52 $ 8.00 $ 0 Dated this 5 day of January, 2011 N O n? c.a Laurinda J. Voel9ker, PA ID# 82706 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: 570-387-1873 Fax: 570-387-6474 • 3?? 60 Clap o ?. $ . Oo `?teif- '?E> a d ? QO ? Co S o LL O-LA 1157 ?,?,?g50 d ' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-6746 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CORPORATION, Plaintiff (s) From KIMBERLY J. HILL, 162 Ken Lin Drive, Carlisle, PA 17015 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all personal property . (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 $15,225.66 Interest -- $1,774.52 DIM )I "VJ ( pq Atty's Comm % Atty Paid $160.00 Plaintiff Paid Date: 01/11/2011 (Seal). REQUESTING PARTY: L.L.$.50 Due Prothy $2.00 Other Costs $8.00 Da ' u r tary By: Deputy Name LAURINDA J. VOELCKER, ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorney for: PLANTIFF Telephone: 570-387-1873 Supreme Court ID No. 82706 RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy °0tv OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 March 4, 2011 Unifund Corporation RICHARD W. STEWART Solicitor vs Kimberly J. Hill Writ No. 2008-6746 Property Claim Determination To Whom It May Concern: Reference is made to Property Claim dated February 22, 2011, entered by Theodore L. Hill, Writ of Execution No. 2008-6746 Civil Term, Unifund Corporation vs Kimberly J. Hill. Ronny R. Anderson, Sheriff, has determined that the claimant, Theodore L. Hill, in the above mentioned property claim, is the owner of the property set forth in the claim. cc Laurinda J. Voelcker, Atty for Plaintiff Kimberly J. Hill, Defendant Theodore L. Hill, Claimant (A ?d So Answers: R An erson, Shen By .GU t NOTICE OF PROPERTY CLAIM Unifund Corporation In the Court of Common Pleas Cumberland County, Pennsylvania VS Kimberly J. Hill No. 2008-6746 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 Theodore L. Hill, 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 02-22-11 Cc Laurinda J. Voelcker, Atty for Plaintiff Kimberly J. Hill, Defendant Theodore L. Hill, Claimant S n of Cumberland Cou~ n B /; 1:?&A PROPERTY CLAIM i ,. TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. ? (? 1 Th e 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 C3?C,?? ??11 air l5 ?rh b??1 So - (y) ? c ?? d ? C -dam 60, lid ??? ? o 00 '?-?? C C? 3(D' oo UJ 1 I ?i . l;n Date " / S '- ?7 d l I Claimant State of Pennsylvania: County of Cumberland I /9?QA2)n- L 811 being duly swom according to law, deposes and savs that tl:e above list in the property claim are correct and true. _ Sworn and subscribed to before me T 's { day of tl \ Claimant COMMONW F PENNSYLVANIA Notary Pu is Notarial Seal Mary E. Wha014r, Notary Public Carlisle Born, Cumberland County ? - Commissign MEMNtr April 30, '%A em"r, , PennrylVania Association of Notaries l? (? jb(Yo oc, V'?lC? ?ll?Y(AX ?V LV ? C?.ll,?(? C ?P? ??a? C ?CAU2cl J ?Q ,OCR ?.l?Ct1?`?'? ?15yrh aid ? oZ5.0U ?'Cl, [1'?yr5old) o??J 0? 3U.oo lo.oo ?c Vh, 4W I?,vo lino 'oCh ? (??? S.oU h-OL- b66 5"??VeS Cad io?x? ?olk(6 cu ???uum -CnD+ 5Cb aA 4 { C ?fe v2 v2 ?zy -9, l A Sn?u //ac.-?- FC s? DO - ~ 7 '??k?`! ?? /n l ? (K_---- ?l/? L_._....?k.!_U ? ? ?,.VIJ • l/LJ /_ ?JCri'1.? SC..C..'. _ C ?'???c(`? ? V '00 /- l /oleo )_ 14 C -- - J - ----- lJ C 15 r __ i 5c /lel,:( $ ?e - - 5 ?0 c MA I it 7 BA V 5A) cal) P } i.l?? c{e5?. TDO SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFIC?;' Sheriff Jody S Smith '00%t,p at t*rerraf"? 1--iF THE DTHONQT?r , Chief Deputy .. I MAY 27 AM 9: Richard W Stewart Solicitor OFF E ??=u, r CUMBERLAND UNTY PENNSYLVAN Unifund Corporation vs. Case Number Kimberly Hill 2008-6746 SHERIFF'S RETURN OF SERVICE 05/25/2011 12:18 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 25, 2011 at 1214 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kimberly Hill, in the hands, possession, or control of the within namec garnishee, Sovereign Bank, 269 Penrose Place, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Tracey E. Conant, 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 May 26, 2011 to Kimberly Hill at 162 Ken Lin Drive, Carlisle, PA 17015. SO ANSWERS, May 26, 2011 RON R ANDERSON, SHERIFF it iam Cline, Deputy tol Coup TYSuite She tf, 1'el0'0"-oft I;,, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. KIMBERLY J. HILL, Defendant VS. SOVEREIGN BANK, Garnishee CIVIL - LAW ?`: : s^yW -- - r+ DOCKET NO. 08-6746 - = i v -T PRAECIPE TO DISCONTINUE ATTACHMENT To the Prothonotary: Kindly Discontinue the Attachment of the Defendant's bank account with Sovereign Bank. SUBMITTED BY: aurinda Voe c er, PA ID# 82706 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: (570)387-1873 Fax: (570)387-6474 ?. oo pit. 12 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,my R Anderson ?Lt Lf neriff 'HE Jody S Smith " X14 Chief Deputy 2 12 JAN 19 AM $: 35 Richard W Stewart CUMBERLAND COUNT y SOiICItOI > rrr ..??=.c t PENNSYLVANIA Unifund Corporation Case Number vs. Kimberly Hill 2008-6746 SHERIFF'S RETURN OF SERVICE 05/25/2011 12:18 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 25, 2011 at 1214 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kimberly Hill, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 269 Penrose Place, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Tracey E. Conant, 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 May 26, 2011 to Kimberly Hill at 162 Ken Lin Drive, Carlisle, PA 17015. 01/18/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.60 January 18, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF rc! C0i1'1..tyS,A0, Snerff. Teleosott [tic SHERIFF'S OFFICE OF CUMBERLAND COUNTY Anderson S Smith ,ef Deputy .4ichard W Stewart Solicitor V'' ?i Cwube", r E€ Irr #= IL E 0 "' t i t ?r ')F' THE 2 12 JAN 19 AM 8:35 IDMBERLAND CCIUfq t ,. PENNSYLVANIA Unifund Corporation Case Number vs. Kimberly Hill 2008-6746 SHERIFF'S RETURN OF SERVICE 02/04/2011 11:51 AM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on February 4, 2011 at 1040 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Kimberly Hill, by making known unto Kimberly Hill, at 162 Ken Lin Drive, Carlisle, Cumberland County, Pennsylvania 17013 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 February 8, 2011. 02/22/2011 Property claim filed this date by Theodore L. Hill. All parties notified. 03/16/2011 No objections filed in this case. $25.00 refunded back to claimant. 01/18/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $102.36 SO ANSWERS, January 18, 2012 RON R ANDERSON, SHERIFF 106 CIO c; CcuntySuite Sheriff. Te eosoft Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. CIVIL-LAW c a c C KIMBERLY J. HILL, :' �()?a � DOCKET N0. 08-6746 Defendant `1 VS. 0415 r mac; METRO BANK p °=-4. Q5 �5h1a�� Garnishee =° 5;c 00is P G:m i PRAECIPE FOR WRIT OF EXECUTION N' < (MONEY JUDGMENT) To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of Cumberland County,Pennsylvania (2) against Kimberly J. Hill,defendant; and (3) Against Metro Bank, Garnishee; (4) and index this Writ in the judgment index and (a) against Kimberly J. Hill,defendant(s),and (b) against Metro Bank, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: N/A (5) Amount Due: $ 12,799.31 Interest from 01/26/2009 $ 3,256.99 Credits $ 0.00 Costs to be added: { Clerks Fee: $ Sheriff: $ S' Total: $ Dated this O day of , 2013 �'� �p t� t. Raymon W. Kessler,PAID#309802 O D 3LD t ,� Attorney for Plaintiff • i 36 West Main Street -Ica . SO Bloomsburg,PA 17815 tq,Do « Phone: (570) 387-1873 cc Fax: (570)387-6474 . (W �l f � ��i �d9b9SI � �,� TSS� WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-6746 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due UNIFUND CORPORATION Plaintiff(s) From KIMBERLY J.HILL, 162 KEN LIN DRIVE,CARLISLE,PA 17015 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: METRO BANK,65 ASHLAND AVENUE,CARLISLE,PA 17013 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, (2) 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$12,799.31 Plaintiff Paid$ Interest FROM 1/26/2009-$3,256.99 Attorney's Comm. % Law Library$ Attorney Paid$408.96 Due Prothonotary$2.25 Other Costs$ Date: May 10,2013 f- ; David D.Buell,Prothonotary ..Q��. Deputy REQUESTING PARTY: Name : RAYMOND-W.KESSLER,ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG,PA 17815 Attorney for: PLAINTIFF Telephone: 570-387-1873 Supreme Court ID No.309802 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, M Plaintiff w" ryi 51. VS. CIVIL-LAW u�t" "" KIMBERLY J. HILL, DOCKET NO. 08-6746 �-- Defendant � { WITHDRAWAL OF APPEARANCE I, Laurinda J. Voelcker, Esquire hereby withdraw my appearance as counsel in the above stated matter. Date: ` By: Laurinda J. Voelck ,Esquire ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Unifund Corporation, Plaintiff, in the above-captioned matter. Date: By: Raymond W. Kessler,PA ID#309802 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: 570-387-1873 Fax: 570-387-6474 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, U c_ Plaintiff 2 � �-- C�_ vs. CIVIL-LAW KIMBERLY J. HILL, DOCKET NO. 08-6746 n? �"j Defendant vs. METRO BANK, Garnishee INTERROGATORIES TO GARNISHEE TO: Metro Bank 65 Ashland Avenue Carlisle, PA 17013 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. If you need additional information such as a social security number, contact the attorney listed at the end of this document. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? Defendant has a joint spousal account with less than $300 exemption 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration thereof? 6. 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 against you? 7. If you are a bank or other institution, at the time you were served or at any subsequent time did the defendant 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 exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 8. If you are a bank or other institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. 9. If your answer to any of the above is in the affirmative, state the amount on deposit or owed or describe the property in detail and provide any other particulars of the transaction as may be relevant to this attachment. COMPLETED BY: Signature Name (print) Title Interrogatories submitted to garnishee by: Raymond W. Kessler, PA ID#309802 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: 570-387-1873 Fax: 570-387-6474 r ^ 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) Levy 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. (SI ATURE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �x� of try �' Jody S Smith �a;i✓ [HOW) Er Chief Deputy Richard W Stewart ' DM JUN 27 AM IU: 'J Solicitor ogg,cE-g-fl-f, �.Et= CUMBERLAND COUNTY PENNSYLVANIA Unifund Corporation vs. Case Number Kimberly Hill 2008-6746 SHERIFF'S RETURN OF SERVICE 05/17/2013 10:20 AM-William Cline, Deputy,who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Nicole Erickson, Assistant Store Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on May 20, 2013 to Kimberly J. Hill at 162 Ken Lin Drive, Carlisle, PA 17013. SHERIFF COST: $86.03 SO ANSWERS, June 26, 2013 RONNY R ANDERSON, SHERIFF uu^tySuiie she'if Tele aseft ...,,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, • Plaintiff • • çfl rrt , vs. : CIVIL-LAW Z473 - cr) , ;.• KIMBERLY J. HILL, : DOCKET NO. 08-6746 , Defendant () • r,3 vs. • • • METRO BANK, Garnishee • PRAECIPE TO DISCONTINUE ATTACHMENT To the Prothonotary: Kindly discontinue the Writ of Execution against Metro Bank. SUBMITTED BY: Rapft2c(W. Kessler, PA ID #309802 Attorney for Plaintiff 36 West Main St. Bloomsburg, PA 17815 Tel (570)387-1873 Fax (570)387-6474 ()Kt. q, 6 6t$ cg ,f) ■ .9q91-161 J SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , r. Sheriff Jody S Smith � EC Chief Deputy ® fit:u Richard W Stewart �UMSERLAND C Solicitor PENNSYLVANIA Unifund Corporation Case Number vs. Kimberly Hill 2008-6746 SHERIFF'S RETURN OF SERVICE 05/17/2013 10:20 AM -William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Nicole Erickson, Assistant Store Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on May 20, 2013 to Kimberly J. Hill at 162 Ken Lin Drive, Carlisle, PA 17013. 12/03/2013 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST:$88.68 SO ANSWERS, December 03, 2013 RONW R ANDERSON, SHERIFF a pd, CO " A 32 U�eV'U vi F ').SJ� if1y,