HomeMy WebLinkAbout08-6804IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
see (Z
X60?`Azl 2C eC ei vables Corp,
Cpl 1 DL?0 f`? V1WAMG 0A4 NO. 08 - (08oq Civil J erw-
8875 AERO DRIVE
SAN DIEGO CA 92123
Plaintiff
VS.
CHARMAINE GRAYS
Defendant (s)
PRAECIPE FOR JUDGMENT
Please enter Judgment in favor of Plaintiff and against Defendant(s),
CHARMAINE GRAYS and
pursuant to the District Justice Transcript.
( X ) Amount due
TOTAL
$ 2180.44
$ 2180.44 , 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; f/ Signature:
David R. Galloway 7326/ iliarholic ??86
Sarah E. Ehasz 8N. Polas,
Amy F. Doyle #87062
Mann Bracken LLP / 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, J)pd /7 , 2008, JUDGMENT IS ENTERED AS ABOVE.
P.
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(Pilo
Deput ry/Cl erk, Ci it Division
By:
TZ60-
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PRAEDJ/PADJDJ FILE # 181366721
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. Dist.+No.:
09-3-03
MDJ Name: Hon.
SUSAN X. DAY
Address: 229 MILL ST, BOX 167
MT. HOLLY SPRINGS, PA
Telephone: 717 486-7672 17065
C/O VOLPOFF & ABRAMSON
4660 TRINDLE RD APT/STE 300
CAMP HILL, PA 17011
THIS IS TO NOTIFY YOU THAT:
Judgment: DBFAULT_ JODGMEUT _PLTF
Fx1 Judgment was entered for: (Name)
® Judgment was entered against: (Name)
in the amount of $ 2.180.4
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
rMRC RECEIVABLES CORP
4660 TRINDLE RD APT/STE 300
CAMP HILL, PA 17011
L J
VS.
DEFENDANT: NAME and ADDRESS
rGRAYS, CHARMAINE
30 TRINE AVE
MT HOLLY SPRINGS, PA 17065
L J
Docket No.: CV-0000220-08
Date Filed: 6/19/08
(Date of-Judgment) - 8/12/08
C/O WOLPOFF & ABRAMSON
GRAYS, CHARMAINE
Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
? This case dismissed without prejudice.
Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127
Portion of Judgment for physical damages arising out of
residential lease $i
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
$ 2,086.9
$
$?
$--?
$ 2,180.44
Certified Judgment Total $ 2,180.44
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
My commission expires first Monday of January,
AOPC 315-07
DATE PRINTED: 9/18/08 9:21:00 AM
, Magisterial District Judge
SEAL
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GIZ) lnldl--'pOf F 4 f9,,6ZftAA50A4 No.
8875 AERO DRIVE
SAN DIEGO CA 92123 .
Plaintiff
VS. CIVIL ACTION - LAW
CHARMAINE GRAYS
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,
CHARMAINE GRAYS , above-named, is over 21 years of age; is last
known to reside at 30 TRINE AVE
MOUNT HOLLY SP PA 17065
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.
OOMMCC)NW Ai p NN V VAWih
asl
Kimberly i.. ciaenhauer, NOt" Puaiic;
Hampden Two.. C=Wdw d Count
My Commissior iExpires Nov. 17.2009
Member, Penns*anls ASSW; fon o NNOWM
David R. Gall ay #87326 1 ar o is
Sarah E. Ehast #86469/Robert N. o as, r. 'l0I
Amy F. Doyle #87062
Mann Bracken LLP / 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
SWORN and SUBSCRIBED to before me this day of Qkmtklx'',_2008.
(,2_?A i A
Notary Public
PNMAFF/PADJDJ FILE #: 181366721
1152
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
?Io JAJDLp t4?3k1M510N
8875 AERO DRIVE
SAN DIEGO CA 92123
Plaintiff
VS.
CHARMAINE GRAYS
Defendant(s)
No.
CIVIL ACTION - LAW
CERTIFICATE OF RESIDENCE
PA. R.C.P. 236
I hereby certify that the precise residence of Plaintiff is:
MRC RECEIVABLES CORP
8875 AERO DRIVE
SAN DIEGO CA 92123
and certify that the last known address of the within Defendant(s) is:
CHARMAINE GRAYS
30 TRINE AVE
MOUNT HOLLY SP PA 17065
flz ? A? ,
David R. Gal way #87326 i ip C. Warholic #863
Sarah E. Eha z #86469/Rober o as,
Amy F. Doyle #87062
Mann Bracken LLP / 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 # 181366721
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1153
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
e_,1 D W L)1_ J_ f q( t9 31 S 6 NO.
8875 AERO DRIVE
SAN DIEGO CA 92123 ,
Plaintiff
VS. CIVIL ACTION - LAW
CHARMAINE GRAYS .
30 TRINE AVE
MOUNT HOLLY SP PA 17065 ,
Defendant (s)
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: CHARMAINE GRAYS
30 TRINE AVE
MOUNT HOLLY SP PA 17065
You are hereby notified that the following ORDER, DECREE or JUDGMENT has been
entered against you on ul?7?nR in accordance with the
provisions of Pa. R.C.P. 236.
( ) 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 $ 2180.44, plus costs.
( X ) District Justice transcript of judgment in civil action in the amount
of $ 1890.38, attorney's fees in the amount of $ 0.00, interest
in the amount of $ 196.56, 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:
r thonotary or-13
If you have any questions reghrling,thib Notice, please cAntact the filing party.
David R. Gal way //87326/ Warholic //863
Sarah E. Eha z //86469/Robert N. Polas, Jr. 20i;i9
Amy F. Doyle //87062
MANN BRACKEN LLP / 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 # 181366721
4-J L
MW R82ff1VA8LZS
LYV WMAFF 0 AwA n
Plaintiff
VS.
CHARMAINE GRAYS
Defandant(s)
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
JUDGMENT NO. 08-6804
PRAECIPE FOR WRIT OF EXECUTION
To the Prothonotary: Please issue the Writ of Execution in the above-captioned
matter, in the amount of $ 218,4.44.
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) against, CHARMAINE GRAYS
30 TRINE AVE
MOUNT HOLLY SP PA 17065
Defendant(s);
(3) and against MEMBERS FIRST FCU
located at 1000 BRYN MAWR RD
CARLISLE PA 17013-1588 Garnishee(s);
(4) And index this writ
(A) against CHARMAINE GRAYS
Defendant(s) and
(B) against, MEMBERS FIRST FCU ,Garnishee(s),
as a lis pendens against the real property of,thle Defendant(s) in the name of
the Garnishee(s) as follows: (Specifically desdfibe 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: $ 2180.44
Interest From: 11/17/2008 To Be Determined
At an interest rate of 6% per year
Total: $ 2180.44 Plus costs & interest
David R. Ga 1 hilip C. Warholic #86341
a E. Ehasz #86469/Robert N. Polas, Jr. #201259
Amy F. Doyle #87062
Mann Bracken LLP / Counsel for Plaintiff
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Canp Hill, PA 17011
Telephone: 866-253-0128 Fax: (717) 737-9051
PABGAR/PABANR FILE # 181366721
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 TO 3149
1ti1
R-ED-Ot`
OF THE PRMONOTPR1
1089 MAY -6 Phi 2: 5Z
CUmbb-.:, F a;j (."3. u
PENNS',VANI A
*44. 60 po AIW
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50
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-6804 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MRC RECEIVABLES c/o WOLPOFF & ABRAMSON,
Plaintiff (s)
From CHARMAINE GRAYS, 30 Trine Ave, Mount Holly Springs, PA 17065
(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 Rd, 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 $2,180.44
L.L. $.50
Interest from 11/17/08 at an interest rate of 6% per year - to be Determined
Atty's Comm %
Atty Paid $54.25
Plaintiff Paid
Date: 5/06/09
Due Prothy $2.00
Other Costs
Cudis R. LonA_Pxe on
(Seal)
By:
Deputy
REQUESTING PARTY:
Name DAVID R GALLOWAY, ESQUIRE
Address: MANN BRACKEN LLP
4660 TRINDLE ROAD, SUITE 300
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 866-253-0128
Supreme Court ID No. 87326
IN THE COURT OF COMMON PLEAS CUMBERLAND
ClD 11)11L-PDT--F 4? tq&2m-r),5cn
Plaintiff
VS„
CHARMAINE GRAYS
Defendant (s)
TO: MEMBERS FIRST FCU
1000 BRYN MAWR RD
CARLISLE PA 17013-1588
COUNTY, PENNSYLVANIA
No. 08-6804
CIVIL ACTION - LAW
Arvswe m 4
INTERROGATORIES TO GARNISHEE
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 !NTERROGATORIES SEPAnintY AND rUtLY. 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.
SS# XXX-XX- r7j `7Lf
PABINT/PABANR FILE # 181366721
AP -%.
INTERROGATORIES TO GARNISHEE
DEFENDANT(S) - CHARMAINE GRAYS
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, gives `1their name and addpress. - ?' i li Ic-i?[X E? 5_ ba - ?1,21
uXX 52(o ' Dd ? -t?v X.yX 0 2u - 06
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1A. DIRECT DEPOSIT ACCOUNTS: Are any of the acco?lnts you have listed above direct
deposit accounts? If yes, please state the identification numbers of those accounts.
h0
2. If you are a bank or other financial institution, at the time you were served or at
any subsequent time i the e en an 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.
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.
xyl5211-ot XVyF2t(_00
Xxxs - rt VXM-60
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?
fi o
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.
PO
PABIN2/PABANR FILE # 181366721
L01
6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time,
state whether or not the Defendant(s) own any personal property that was in your possession
and/or control. If so, include a full description of all personal property giving full
value and present location. State also whether or not there are any encumbrances or liens
holders, the present balance of the encumbrance. State where and when encumbrances or liens
was recorded. If the Defendant(s) owns any personal property jointly with any person or
persons, give names and address.
1? o
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).
no
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).
n6
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 completion
of this Answer? If yes, outline the exact amount of any fees due and owing to the garnishee
or the attorney for the garnishee for the preparation of the Answer.
t. ? leas *km Qs a- PR u ss 1n0 At-
Du?•
'?3D0 S?afu?D+n? PZmP'hon GUQS not
vid R. Gall ay #8732b .lip C. Warholic #86341
S`UTIM E. E y obert N. Polas, Jr. #201259
Amy F. Doyle #87062
Mann Bracken LLP / 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: 866-253-0128 Fax: (717) 737-9051
PABIN3/PABANR FILE # 181366721
.
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
Becky Marshall
(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.
-Bw?l '4&4ZIMU
(SIGNATURE)
r1LIZi J
Ofi r;-i "i Apy
2007 K A G I J pi 1 C: li Li
?M1
Sheriffs Office of Cumberland County
R Thomas Kline a?1?,tr at'Mtttrbrr?y Edward L Schorpp
Sheriff Solicitor
r
Ronny R Anderson Jody S Smith
Chief Deputy OFFICE OF THE S4ERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
05/13/2009 03:00 P - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on May 13,
2009 at 1500 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the w thin named defendant, to wit: Charmaine Grays, in the hands, possession, or control of the within
named garnishee, Members 1st Federal Credit Union, 5020 Louise Drive, Mechanicsburg, Cumberland
County, Pennsylvania, 17055 by handing to Kayla Irwin, Security Officer personally three copies of
interrog tories 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 18, 2009 to Charmaine Grays, 30 Trine
Avenue Mt. Holly Springs, PA 17065.
2008-6804
MRC Receivabl s
vs
Charmaine Gra s
So Answers,
R. Thomas Kline, Sheriff
By ,???0
Deputy Sheriff
?z N
t_
"?-'• `?,
C,5
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MRC RECEIVABLES CORP
C/O WOLPOFF & ABRAMSON
Plaintiff NO. 08-6804
VS.
CHARMAINE GRAYS
Defendant
CIVIL ACTION - LAW
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
To the Prothonotary:
Kindly mark the attachment against the Garnishee, MEMBERS FIRST FCU, discontinued,
upon payment of your costs only. -7 // 5-//j
Dated:
Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259
MANN BRACKEN LLP
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, PC
Attorneys in the Practice of Debt Collection
4660 Trindle Rd., Suite 300
Camp Hill, PA 17011
(866) 253-0128
MB File No. 181366721
Respectfully Submitted,
1-iL....',i?, .,.,....,r,
nr T!' C^ ;AFY
2009 J U L 17 P 1 2: 2 Q
0.00 Po ATTV
?+,?? 31 I?$y to
R? aoL815(a
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MRC Receivables Corp.
assignee of FCNB/NEWPORT NEWS
V.
CHARMAINE GRAYS
Plaintiff
NO. 08-6804
CIVIL ACTION - LAW
Defendant(s)
ENTRY OF APPEARANCE M
Rim
TO THE PROTHONOTARY:
(D
C: - rn
Kindly enter the undersigned as counsel for Plaintiff in the captioned matter. z u>
c:>
By: N& I
David R. Galloway 87326
Fulton Friedman Gullace, LLP
Counsel for Plaint
Attorneys in the Pr ce 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:
CHARMAINE GRAYS
30 TRINE AVE
MOUNT HOLLY SPRINGS PA 17065
David R. Ga
Attorney ID
FFG File #: 164776
Date
PA/PA_EOA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY', PENNSYLVANIA
MRC Receivables Corp.
assignee of FCNB/NEWPORT NEWS
v
CHARMAINE GRAYS
Plaintiff
Defendant(s)
NO. 08-6804
CIVIL ACTION - LAW
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter the undersigned as counsel for Plaintiff in the captioned matter.
4
By: "
David R. Gallo ay #87326
Fulton Friedma & Gullace, LLP
Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
130B Gettysburg Pike
Mechanicsburg, PA 17055
Tel: (866) 563-0809 Fax: (585) 546-4241
'C7 0:!
z t
Cf? r-.
CERTIFICATE OF SERVICE
471
w
CJ"
0r?4
-G
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:
CHARMAI EA GRAYS
30 TRINE AVE
MOUNT HOLLY SPRINGS PA 17065 n/1
5310
FFG File #: 164776
David R. Gal
Attorney ID
326
Date
PA/PA_EOA
- SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff of a?r?(ii ?? ? ~`? gy
Jody S Smith Chief Deputy 2010 MAY 14 P 2: [ j
Edward L Schorpp WWI.
I Nrry
Solicitor
sy, ,i i,4
MRC Receivables c/o Wolpoff & Abramson Case Number
vs. 2008-6804
Charmaine Grays
SHERIFF'S RETURN OF SERVICE
05/13/2009 03:00 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on May 13,
2009 at 1500 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Charmaine Grays, in the hands, possession, or control of the within
named garnishee, Members 1st Federal Credit Union, 5020 Louise Drive, Mechanicsburg, Cumberland
County, Pennsylvania, 17055 by handing to Kayla Irwin, Security Officer 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 18, 2009 to Charmaine Grays, 30 Trine
Avenue, Mt. Holly Springs, PA 17065.
05/14/2010 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: $85.09
May 14, 2010
SO ANSWERS,
RbNR'Y R ANDERSON, SHERIFF
B Sharon R. Lantz
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WRIT OF EXECUTION and/or ATTACHMENT
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COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-6804 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MRC RECEIVABLES c/o WOLPOFF & ABRAMSON,
Plaintiff (s)
From CHARMAINE GRAYS, 30 Trine Ave, Mount Holly Springs, PA 17065
(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 Rd, 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 $2,180.44
L.L. $.50
Interest from 11/17/08 at an interest rate of 6% per year -- to be Determined
Atty's Comm %
Atty Paid $54.25
Plaintiff Paid
Date: 5/06/09
(Seal)
Due Prothy $2.00
Other Costs
urtis R. Lon onot
By:
Deputy
REQUESTING PARTY:
Name DAVID R GALLOWAY, ESQUIRE
Address: MANN BRACKEN LLP
4660 TRINDLE ROAD, SUITE 300
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone : 866-253-0128
Supreme Court ID No. 87326