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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. L..' - (Pilo Deput ry/Cl erk, Ci it Division By: TZ60- y PRAEDJ/PADJDJ FILE # 181366721 ?(c ??. _? 3 0 00 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 R 3 io -2 77 ` v ty. IN - =, °`TP .? :V ' 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 aq. &5 a.bo 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 -- 1 - 0.00 Mud tJ19(JAQ- I" 6wru?o? ?v f ???e s Gds 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 J?'Co- C4.4 7 X93 ,Si 'agD3rT' (ci Countysuite shenft, Teleosoft. Inc. WRIT OF EXECUTION and/or ATTACHMENT t_- 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