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HomeMy WebLinkAbout01-6613IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BIG BEAR MEMBERS FIRST CREDIT UNION, INC. F/K/A BIG BEAR EMPLOYEES CREDIT UNION ERIC JOBES Plaintiff, Defendant. CASE NO: OI --t~{~/~ COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR 02340760 (dumberlanct ~-ounty Dar ~ssoclauon 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 43212. COMPLAINT Plaintiff is a corporation with offices at 851 West Third Avenue, Columbus, Ohio 2. Defendant is an adult individual residing at 1397 Creek Road, Apt. 2, Boling Springs, CUMBERLAND County, Pennsylvania 17007. COUNT I - ACCOUNT NO. 4070-8200-0984-6351 3. Plaintiff incorporates by reference each of the preceding paragraphs of this Complaint as if the same were set forth more fully at length herein. 4. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 4070-8200-0984-6351. 5. Defendant made use of said Visa credit card and has currently a balance due and owing to Plaintiff, as of September 11, 2001, in the amount of $8,146.55, as shown by Plaintiff's Statement of Account attached hereto, marked as Exhibit "1" and made a part hereof. 6. Defendant is in default of the terms of the Cardholder Agreement having not made payment to Plaintiff as promised since September 11, 2001, thereby rendering the entire balance immediately due and payable. 7. Plaintiff avers that the written agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 18.90 percent per annum on the unpaid balance. 8. Plaintiff avers that finance charges calculated at the aforesaid rate from September 11, 2001 to October 10, 2001 amount to $122.33. 9. Plaintiff avers that the agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 10. Plaintiff avers that such attorneys' fees will amount to $1,629.31. 11. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges, attorneys' fees or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment on Count I against Defendant, Eric Jobes, individually, in the amount of $9,898.19 with continuing interest thereon at the rate of 18.90 percent per annum plus costs. COUNT II - ACCOUNT NO. 14090-B 12. Plaintiff incorporates by reference each of the preceding paragraphs of this Complaint as if the same were set forth more fully at length herein. 13. The Plaintiff is the holder of a Promissory Note and Security Agreement secured by a vehicle, having been duly executed by Defendant in favor of Big Bear Members First Credit Union Inc., f/k/a Big Bear Employees Credit Union, (the "Seller"), on or about April 30, 1999, a true and correct copy of said Note and Security Agreement is attached hereto, marked as Exhibit "2" and made a part hereof.. 14. Pursuant to said Note and Security Agreement, Defendant took possession of the vehicle more particularly identified in the Contract as a 1995 Plymouth Neon, Serial Number 1P3ES47C6SD136166. 15. Pursuant to the terms and condition of the parties' agreement, the Seller subsequently assigned its right, title and interest in the Note and Security Agreement to Plaintiff. 16. Pursuant to the Note and Security Agreement, Defendant was to make forty eight (48) consecutive monthly payments of $120.60 commencing June 4, 1999, for a total amount due to Plaintiff of $5,788.36. 17. Defendant is in default of the terms and conditions of the parties' agreement because Defendant has failed to make the required monthly payments to Plaintiff since September 11, 2001. 18. By the terms of the parties' agreement, more specifically the "acceleration clause" therein, Defendant's default made the entire balance of the loan immediately due and payable. 19. Plaintiff avers that the balance due amounts to $656.98. 20. Plaintiff avers that the written agreement between the parties provides that Plaintiff is entitled to interest at the rate of 6.99 percent per annum from September 11, 2001, the date of Defendant's last payment. 21. Plaintiff avers that the contract between the parties provides that Defendant will pay Plaintiff's reasonable attorneys' fees. 22. Plaintiff avers that such attorneys' fees amount to $131.40 to date. 23. Plaintiff avers that interest from September 11, 2001 to October 10, 2001 calculated at the aforesaid rate of 6.99 percent per annum amounts to $3.65. 24. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, interest or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment on Count II against Defendant, Eric Jobe, individually, in the amount of $792.03 with continuing interest thereon at the rate of 6.99 percent per annum plus costs. THIS LAW FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT THIS DEBT FOR OUR CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. l~Vil]'i~m T. ~vlolczan,,,~quire PA I.D. #47437 WELTMAN, WEfNBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR 02340760 S.£P 12 '01 Og:Si~£q BIG Br~R ECU P.B " BIG BEAR EMPLOYEES CREDIT UNION VISA CREDIT CARD APPLICATION Check here if for creait ACCOUNT NO. APPLICANT NAME' [crr'Y--~rATE~ZIP PREVIOUS HOME ~. _P~_~B,.~.T~._EE'~'~ &_._N?,.d~.,' H,O LONG? P/~)~'~''cJ~Iz.G ~v, ?..(,Io'1. HOME PHONE NO B RTH r~ATE NO, OF DEPENDENTB AGES JOC'AI. BECURITY NO. MOTHER'S MAligN NAME J ORIVERS LIC.E~SE NO. z~-zq-s~os I fl'2. Z- 0-/G I s ~al~O I~. lO r~ MONTHLY EMPLOYER ,, ~'. ,.I/3ppORiT~I::)N HOW LONG? BLitHEag ADDRESS PR~IOUS ENPLOYER '" POSITION J HOW LONG? PREVIOUS &US~E~ limit increase CO.,~PPLICANT NAME HOME ADORESS L3[~ · NO.)' [ HC:~N LONG'/ cr'r'Y--&TATE--ZIP PREVIOUS HOME &OOREes; {STREET · NO.) JHOW LONG? C, ITY--STAT E--ZIP HOME PHONE NO, J WRTH BATE j NO, OF DEPENDENTB sOCIAL SECuRIT~ NO. j ~OTHER'S M.aJOEN NAME J OPdVER$ LICE. NSE NO. -- ~ ~ M~THLY POSITION J HOW LONG~ EMPLOYER BU~INESG ADORE~ J PREVIOUS EMPLOYER POEITiON HOW LONG? PREVIOUS BUSINESS ADOAESS : Y~R LICEN~ NUMBER FINANCED BY : ~OTHEfl DEBTS) ACCOUNT NUMBER ORAJrT ACCT. NO LOCATION jSAVING9 ACCOUNT NOB. BALANCE DUE OCATION MO. PMT./RENT MONYHLY PMT. S TOTAL NAM,e OF NF. AREST RELATIVE NOT LIVING WITH YOU J ADDREq_q (CITY,STATE-ZIP) RELATIONSHIP If "yes" Are t~em eny u~tl~fl~ Ye~ No ~ Amounl ~ lQ wh~ owed? Other obllgepane,.--(E.g,, li~il~/ I~ pe¥ alimony, ch{Id supron..param maim~dnce. UM ~rale sheet ti n~.) APPUC~T'~ 81GNATU~ DATE CO-APpL~ANT'g SIGNATU~ OATE 11 :ga/o ~one ~lMim~ ~ di~, m mw pncl~ln. EX'qlBIT 1 "---'-'" S£P 12 '01 09:$2Afq BIG BEAR C~l~y,;8~t CtJNA ~ervl~ Cr~vp. I~., 1991 SEP 1~ '0i 0~:53AM BIG BEAR ECU 09:50Arq BiG BEAR ECU LOAN AGREEMENT AND CONSUMER CREDIT DISCLOSURE STATEMENT ("Agreement") Borrower(a) ERIC ,,lOBES 200 N MOATS AV HA~ISVILLE, WV 26362 =INANCE CHARQE AMOUNT FINANCED tOTAL OF PAYMENTS J CATE ACCOUNT NUMBER ,,,d, ,, · ,,~, --~. ~,~ ,~,,',- [ 04/3O/gg 14090 - 8 6.~0 ~ ~ 7B6.88 ~ H031.48 ~ B788.36 ~o? payment ech~le will be~ Number of Payees Amount of P~mente ~en Pakrite Are Due 47 S[20.60 Hon[h]y beginning June 04. ].999 I S120.16 as a final pa~t an or before Hey 04. 2003 ~ Requ;~d ~po.~: The Annual Parentage taqu~ed depae;t. Prape~y In=ut=nae: You soy obtain prope~ ;nsurance from anyone You ~epa~nt: If You pay off ~rly. Y~ w~ not ~=ve to pay a penal~. want that ]; acceptable to Ihs Cr~;t Un;~. Aseum~;l~y: Your loan;gnotalcu~ble. L~e Charge: If Your payment is 10 or mare days Fate. You will be eharg~ Secufky: You are giving a security intreat in: ~ The goodc or prape~ being purchase, ' See Your oantract document~ for any additional ;nformation about non ~ Your present and lucre ~hare: or depas~:= ;n tho Credit Un;on. payment, de,suit. ~ny required repayment ;n furl before the scheduled date. ~ Othe~ and prepayment refund~ ~fld p~alaee. Simple latorert Rate 6.99 ~, oor Annum. Itemization of Amount Financed al: $ 5031.4~1 Amount g;ven to You directly Amount pa;d on Your account 0.00 s 0.00 Amount Pa;d to Other~ an Your Behalf: Cred~ Insurance Company 0. O0 ~]0N AUTO 5031.48 Insurance: Credit Lie and Credit Dlaeb~;e~ Ine~lronca are nat required ta obtain credit and will not be b~ovlded unleaJ You agree to pay ~J~e additional oe;t end alga below, Type Premium JJ Please check one of tho boxes below. O. O0 . Cred~ O;.~;fiW rAcuranco SEcu~y letere~. To cecure all Qb~gadan{ of Borrower(si hereunder to ~e ~edlt Union. You ['--]You Want Acje/B;rth Date [~Yau ~o NotWant 25 / 06/19/72 / /} give a ~aeur;tv ;ntoreet and lien In sod upon 1he following property. ;naluding 1995 PLY~UTH NEON Other V.I.N.lSerial Number { Kay/Lie. Number lP3ES47CGSD136166 39561 EXHIBIT 2 Further pnraafapha of ~hia Loon Agreement me .et fo,h en tho page tklad "Additional P~ode;ane of Loan Agreement"..nd You agree te be bound by all of S~n~u~es: You have sl[~ed this Agraom~ this 3~ day of April ,19 99 and acknowledge that You have r~d ii, that You under=canal and the: You have r~oelv~d a completely fill~-ln copy m ,t. ' S;gnnture of Borrower C~ Owne¢ of Collators/(other ~han B~.ower) Si;nature of Borrows,' [~qv(~ef o! Conate~ald~...~,~ man Borrowed W;tnaooL.,/ I .... ADDITIONAL PROVISIONS OF LOAN AGREEMENT ~.=o 2 ~ 2 m se to a the amount borrowed plus Interest, other ps, mitred Gl~arges and fees to the order af Big Bear Employees 1, PROMISE TO PAY. You pro ' _ p V .. - ......... ~ ,~.:- A~reement (including th=es ~et forth In ~e Federal Tru~h-l~-Len~inq Credit Union. na (Lender or arae~, ~cara~g ~o ~.a,.~[,,,~ ~'~'~th~ ~ Ja masked, e g ~. tn th;s Agreement ~e Use af the word~ "Cradl~ Ual=n,' "~ '~ "U~" and "Our" mean Big Beer Employees Crod~,~?~-, , ..... ~'~-.- t.ln~ meeA~ ~t col ~ ' r lent a~ Borrower or Co-Borrower a~rees to be In~ vidu~ly and olntly o~llgated t~ pay 2. LIABILITY OF PARTIES. Each person who slgn~ ~? Ag ~e.~. ~ .... eat Any nercan w~,o Ci~PS th:= AGreement and =heo~s lb%box section ~n th~ Ag , ~T lntetes~ will be oharg~d an ~he unpaid ba~nce of Your Io n, ....... ~,, ~a~n tho ~esu~t of rodua~ng th~ ~otal amount af 3,~NTE~ ~'fu(I ma be made ear w~thout penalty, an= aqy eat,~ pay. ............ . . . to be made acc=re'ag to the Payment Schedule ;n thls_Agreemen[..Any port;el ~p~ Your loan will not 4. PAYMENTS, Your pay~e~t~,a~e ...... v ..... v~.. e=~ scheduled ~eyment~ t~e =meun~ ~ou pay exoeeu= .vu.,~.- b~lanoe. ~en You 5.cOLLAT~RAL- The Cred,~ ~ _ - ~ ........ , ...... edna T,u~t Deed or sim~ar document (the documen~ ~uch ~ a 5ecurlW Ag~e~ent,,~or~ag~, ~-,~,,,_,.;-,,;L~j_.~o~ .~. Credit Union's securIw ~ntareat or hen, ~ne uo,,a.e ............ . .... consent of the Credit Union. no other liens, secu~ ~tere~tl or encumbrances w[l[ be allowed to a~ach ~o ~e Collateral, You agree ~o inform the e~endcd cried from Your add,oas ah=wa n thle Agreemen~ et at such othe~ ~;~'~'~' You ~=ve nS=treed the Credit Union the Co[$at~rai_~= ~ ?=a,,~[._j,~.%~.~. f~'~nv un awful purpose. The cted,t ; loan You ~ndetetand tha~ the bolance in Your account(~) on 6 LIEN ON SHARES tf ahatec or deposits ere pledged a.~ secur~t~ for ~h ~ _-.;I v..r =an · re~a;d n full We lev, however, petm,t Yo~ to ~J~ce Your account balances below Your Io3n balance. 1, Tau ~re ,n oar=urn,, the ute .... nme ......... .,.- ..... res. _ _ ount that is at lea~ e ua to ~e unpaid bslanoe owed under this SURANCE You ~om aa to ma'ntaln g~operW 'nsu~ance m an am ..... .=~; n ~ eh ~su~ance shell protect against Io~ 7,PROPERTY I~ . ' ~ P -~ ~-~---:~1~ and w th Us named as Io~c payee fo~ 0~, . ....... o., u. . ..... ;~ ~nv. You mav ~g~eement win n,~ ~ore tn.an .,~ ~=~,?_~7~.:~. ~_. :...ra~ce in ~e case or alroraft or boats and ~cce. so[ms ~nere~, .-_;-~ ..... n chaos,ne. r ct ~ur ~nterest and add ~a coat~ to Your loan, ~ubject to the app ~ ~. · __L ....... ~,,, h~ f We have ~he euthor*~ ~o ~ men~ or ~ncreasln Your loon term}. We ara unde~ no obhqat~on to ~o~a~n e~ ............... I . [~iu=~le or can=e, ,nsu~anc, and may endorse any partY's name on any drat~. . ' ~ · You do no~ make any pa~ment er pe~orm an? obligation under , U . Your loan shall be in default if any of the follo~n~ tn~ng, pccu[, (~}_. ,~ v.. h.~ m~d~ a false o~ mi=~eedinq statement in Your,credit a DEFA ~ or an ath~ agreement ~at You may have.w~h.the Cr~d~nmn. ar ~'~T~'~-~' o~ ~¢1 You ~hould ale ~r be involved ~m any A~r~e~. __~,~ :- v ...... recantations to the Cra&= Unmn whmme ~ou owe m~.-~ 7'~ - ~ ;'-- -~-~ be fried aaainst You or any insolven=y, r=ceivershi~ o~ ¢ua~od,al p~oce~d,nq b~ought ~ or aga~.~..~ ...... e~{f[~llv ',ncludln~ any=ns start ng an ~ctmn or proceed~q~ indebtedness heround~r i~ or eoon will b~ impaired, t~mo being of th~ very · W ma dec are tho e~tlte balance of Your loan ;mmedatey due and pavablo. ~ on an occurrence nf default, and to the e~ent para,.ted b~ law, ,~ Y~' · ~ -*- ~a-me and i~ ~erm~ted by law. ~he Collateral shall ~;hou~ ?r ~ net{ce or demand, If ~he oat,re balance m~ no~ men p~o~m~e.~,~?~.~,~;~, to the ~ent permuted by law, the Credit Un,on ~'on of ~t and the Credit Union may a~ser~ th~ def.~nse of 3 superior rFght of ~ho Col azeral ,n any manner permi~ed by law, and any recoiling a~tcmncv on?~r ,o=22:,~jL~;,,;,.,~/~ .~.d by ,~w ,o p.y .~S =o.,~ .o~lo.tlon e _ .~__ : ..... :--.t-n fees or other costs incurt~ in collection an~ reasonable a~or~ey~ . cu_c_. ~-v- *ks r-hi to repress 3n~ enforce a lien upo~ {he ehar~; and dividends of any memo~ ,ndebted t~ *t, an~ ~,,e .... ,. ~,~v. ,,,~ ~ 9. ASSUMABILITY. Your Iaaa ~a not assumable. 10. DELAY IN ENFORCEMENT, We de not lose Our rlgh~= ~r th,s o..[~ ..~ :. ~lt' w haut o~in= any e~ Our H ht~ under this Ag?slant, ~:~ prav;.,~; of t~g~r any rela~e~Yegreement 'g a~crm~ed ,o be unenforceable or ,nv.,,a, a ..... er. ....... 1 1. GOVERNING LAW, YoU under.tend and agree that thi~ Agreemen~ will be governed by the laws of ~e state ;n which it ;s wr{~en excep{ to the e~ent that Federal law controls. VERIFICATION The undersigned does hereby v~rify subject to the penalties of 18 PA.C.S. §4904 authorities, that he/she is ~-r~o,"/' ~. relating unsworn falsifications to _ _ ~ (Name) -~:,~o,-~'/A,l.,~n,~.,j~-~' of /~,~ ~"//~'~J"~'~ ~""~ (.L.O.. plaintiff herein, (Title) - ~J (Company) that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing complaint are true and correct to the best of his/her knowledge information and belief. SHERIFF'S RETURN - REGULAR CASE NO: 2001-06613 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BIG BEAR MEMBERS FIRST CREDIT VS JOBES ERIC GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JOBES ERIC the DEFENDANT , at 0859:00 HOURS, on the 28th day of November , 2001 at 1397 CREEK ROAD APT 2 BOILING SPRINGS, PA 17007 by handing to ERIC JOBES 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 4.55 Affidavit .00 Surcharge 10.00 .00 32.55 Sworn and Subscribed to before me this 7~ day of ~ ~! A.D. thonotary ' ' So Answers: Thomas Kline 11/30/2001 WELTMAN WEINBERG REIS -- . Dep~ty-Sh~[z~iff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION Plaintiff VS. ERIC JOBES Defendant No. 01-6613 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02340758 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION Plaintiff VS. ERIC JOBES Defendant Civil Action No. 01-6613 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Amount claimed in Complaint Interest from 10/10/01 to 1/4/02 at the contract interest rate of 6.99% per annum TOTAL TOTAL COUNT I & COUNT II $792.03 $12.90 $8O4.93 $11,066.04 ~:OUNT II Kindly enter dudgment against the Defendant, Eric Jobes, above named, in the default of an Answer, in the amount of $804.93 computed as follows: TO THE PROTHONOTARY: COUNT I Kindly enter Judgment against the Defendant, Eric Jobes, above named, in the default of an Answer, in the amount of $10,261.11 computed as follows: Amount claimed in Complaint $9,898.19 Interest from 10/10/01 to 1/4/02 at the contract interest rate of 18.9% per annum $362.92 TOTAL $10,261.11 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. William T. Molczan, Esquire ,~ PA I.D. #47437 " WELTMAN, WEINBERG & REIS CO,, L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02340758 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2601 Koppers Building, 436 7t~ Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 1397 Creek Road, Apt2, Boiling Springs, PA 17007 iN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BIG BEAR MEMEBERS FIRST CREDIT UNION, INC. F/K/A BIG BEAR EMPLOYEES CREDIT UNION Plaintiff VS. ERIC JOBES Defendant Civil Action No. 01-6613 Civil Term IMPORTANT NOTICE TO: Eric Jobes 1397Creek Road, Apt. 2 Boiling Springs, PA 17007 Date of Notice: / ~,--/.,~---¢/~7t / / YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. Will~ar~'T. Molczan PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02340758 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. Ii , PA I.D. #4-7437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02340758 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BIG BEAR MEMBERS FIRST CREDIT UNION, 1NC. FKA BIG BEAR EMPLOYEES CREDIT UNION Plaintiff VS. ERIC JOBES Defendant No. 01-6613 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION M&T BANK, FIRST UNION NATIONAL BANK, COMMERCE BANK, PNC BANK AND WAYPOINT BANK Garnishees FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02340758 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BIG BEAR MEMBERS FIRST CREDIT UNION, 1NC. FI<LA BIG BEAR EMPLOYEES CREDIT UNION Plaintiff VS. ERIC JOBES Defendant M&T BANK, FIRST UNION NATIONAL BANK, COMMERCE BANK, PNC BANK AND WAYPOINT BANK Garnishees Civil Action No. 01-6613 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... directed to the Sheriff of Cumberland County: agamst Eric Jobes, Defendant against M&T Bank, Garnishee against First Union National Bank, Garnishee 2. 3. 4. 5. 6. 7. 4. against Commerce Bank, Garnishee against PNC Bank, Garnishee against Waypoint Bank, Garnishee Judgment Amount Interest from 1/4/02 to 2/4/02 SUBTOTAL: Costs (to be added by Prothonotar3'): $11,066.04 $169.49 $11,235.53 $ WELTMAN, WIjlNBERGa& REIS CO., L.P~A. BY:~~~/~ William T. Molczan, esquire // PA I.D. #47437 ~ WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02340758 WELTMAN, WEINBERG & REIS ATTORNEYS AT LAW 2601 Koppers BuHdlng 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 CLEVELAND. COLUMBUS o CINCINNATI o PITTSBURGH Februa~ 1,2002 RE: Big Bear Credit Union v. Eric Jobes COURT #: 01-6613 Civil Term TO THE SHERIFF OF CUMBERLAND COUNTY: PLEASE SERVE THE GARNISHEE(S) AT THE FOLLOWING ADDRESS(ES): Waypoint Bank 200 S. Spring Garden Street Carlisle, PA 17013 Commerce Bank 65 Ashland Avenue Carlisle, PA 17013 PNC Bank 6480 Carlisle Pike Mechanicsburg, PA 17055 First Union National Bank 604 E. High Street Carlisle, PA 17013 M&T Bank 1 Forge Road Boiling Springs, PA 17007 PLEASE CONFIRM SERVICE BY SENDING NOTICE TO: WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 (412) 434-7955 SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-06613 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BIG BEAR MEMBERS FIRST CREDIT VS JOBES ERIC And now BRIAN BARRICK ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:08 Hours, on the 12th day of February , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , JOBES ERIC , in the hands, possession, or control of the within named Garnishee WAYPOINT BANK 17 W. HIGH STREET CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to TINA MCCOMMON (HEAD TELLER) personally three copies of interogatories together with 3 and attested copies of the within COMPLAINT & NOTICE the contents there of known to Her true and made Sheriff,s Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 So answers: R. Thomas Kline Sheriff of Cumberland County t~his .~7~ day of 3~ .oo Sworn and subscribed to before me By Deputy Sheriff SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-06613 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BIG BEAR MEMBERS FIRST CREDIT VS JOBES ERIC And now CPL. MICHAEL BARRICK ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:06 Hours, on the 21st day of February , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT JOBES ERIC , in the hands, possession, or control of the within named Garnishee PNC BANK 2 EAST MAIN ST MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to ROB STOVER (INVESTIGATOR) personally three copies of interogatories together with 3 and attested copies of the within COMPLAINT & NOTICE the contents there of known to His true and made Sheriff.s Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 R. Thomas Kline Sheriff of Cumberland County .00 oo/oo/oooo Sworn and subscribed to before me this 76 day of Deputy Sheriff A.D. otno~t~ry SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-06613 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BIG BEAR MEMBERS FIRST CREDIT VS JOBES ERIC And now DAVID MCKINNEY ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:14 Hours, on the llth day of February , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT JOBES ERIC , in the hands, possession, or control of the within named Garnishee M & T BANK 1 FORGE ROAD BOILING SPRINGS, PA 17007 Cumberland County, Pennsylvania, by handing to SANDRA FAILOR (TELLER) personally three copies of interogatories together with 3 and attested copies of the within COMPLAINT & NOTICE the contents there of known to Her Sheriff,s Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 t rue and made So answel R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo Sworn and subscribed to before me t~his ~7~ day of ~~ By Deputy Sheriff SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-06613 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BIG BEAR MEMBERS FIRST CREDIT VS JOBES ERIC And now DAVID MCKINNEY ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:00 Hours, on the llth day of February , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT JOBES ERIC , in the hands, possession, or control of the within named Garnishee COMMERCE BANK 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to WINNI QUESENBERRY (MANAGER) personally three copies of interogatories together with 3 and attested copies of the within COMPLAINT & NOTICE the contents there of known to Her . Sheriff,s Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 true and made So answers: R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo Sworn and subscribed to before me this ~7~ day of 3~ By / - Dep~t~ Dheriff ~ SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-06613 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BIG BEAR MEMBERS FIRST CREDIT VS JOBES ERIC And now DAVID MCKINNEY ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:03 Hours, on the llth day of February , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT JOBES ERIC , in the hands, possession, or control of the within named Garnishee FIRST UNION NATIONAL BANK 604 E. HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to MARY LINS (MANAGER) personally three copies of interogatories together with 3 and attested copies of the within COMPLAINT & NOTICE the contents there of known to Her . Sheriff,s Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 true and made .00 Sworn and subscribed to before me t~7~A.D. day of ~~ R. Thomas Kline Sheriff of Cumberland County 00/00/0000 By ~ ~ v - ~, :~'~~/~~/'~'/L~ za' ~ ~4'~eput'~ ~heriff SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee BIG BEAR MEMBERS FIRST CREDIT UNION, : INC. FKA BIG BEAR EMPLOYEES : CREDIT UNION : VS. : ERIC JOBES : NO. 01-6613 and : FIRST UNION NATIONAL BANK, : GARNISHEE : COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TO THE PROTHONOTARY: ENTRY OF APPE, AR ANCE Kindly enter my appearance on behalf of First Union National Bank, Garnishee, in the above-captioned matter. Date: Attorney for Garnishee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA M&T Bank. Plaintiff(s) Petitioner(s) BIO BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT LrNION Case No. 01-6613 CIVIL TERM Vs Defendant(s) Respondent(s) ERIC JOBES Responses to Interrogatories Garnishee(s). Manufacturers and Traders Trust Company MANUFACTURERS AND TRADERS TRUST COMPANY, pro se, for its answer to the Interrogatories states: [Questions and Answers Pursuant to 14 Pa ¢.$.A. Rule 3255] 1. At the time you were served or at any subsequent time, did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written immanent, or did defendant(s) claim that you owed any money or were liable to defendant(s) for any reason.'? Yes No Denies knowledge or information sufficient to form a belief as to the answer to the question. 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 or one or more other persons any property of any nature owned solely or in part by the defendant(s)? Auswer~ Yes No Denies knowledge or information sufficient to form a belief as to the answer to the question. At any 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(s) or in which defendant(s) held or claimed any interest? Answer: Yes No Denies knowledge or information sufficient to form a belief as to the answer to the question. At any time you were served or at any subsequent time, did you hold as a fiduciary any property in which the defendant(s) had an interest? Yes No Denies knowledge or information sufficient to form a belief as to the answer to the question. At any time before or after you were served, did the defendant(s) 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 therefor? Answer: [] Yes. The consideration was No Denies knowledge or information sufficient to form a belief as to the answer to the question. At the time you were served or at any subsequent time, did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the direction of defendant(s) against you? Yes No Denies knowledge or information sufficient to form a belief as to the answer to the question. [Additional Questions and Answer (if any) l If any of the following reasons are checked, the account(s) in question are not subject to attachment because: Account(s) No(s). are escrow account(s) for real estate taxes and insurance. [Field 12] has a right of set off against the account(s) which it hereby elects to assert. [] Other: [Consult with Counsel's Office and type in reason] Dated: MANUFACTURERS AND TRADERS TRUST COMPANY Name: (J~ne S. Karlie Title: haSalyst Legal document Processing PO Box 708 Altoona, PA 16603 (814) 947-5831 SIRLIN GALLOGLY & LESSER, P.C By: Jori C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee BIG BEAR MEMBERS FIRST CREDIT UNION, 1NC. FKA BIG BEAR EMPLOYEES CREDIT UNION : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND VS. ERIC JOBES and PNC BANK, NATIONAL ASSOCIATION, GARNISHEE NO. 01-6613 CIVIL TO THE PROTHONOTARY: ENTRY OFAPPEARANCE Kindly enter my appearance on behalf of PNC Bank, National Association, Garnishee, in the above-captioned matter. Date: J~C~IN Attorney for Garnishee SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION VS. ERIC JOBES and PNC BANK, NATIONAL ASSOCIATION, GARNISHEE : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND : : : NO. 01-6613 CIVIL .. ANSWERS TO INTERROGATORIES IN ATTACHMENT TO: BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION, Plaintiff Dat~: 2. 3.-6. 7. No. No, Defendant has no relationship with PNC Bank, National Association. No. See answm- to number two above. ~lq L~. SIRLIN Attorney for Garnishee VERIFICATION Tyieshia M Hayes, being duly sworn according to law, deposes and says that she is the Writ, and Adminstr~tor, OF PNC Writ, herein, and verifies that the Statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made sugject to the penalties of 18 Pa.C.S. Section 4904, relating to sworn falsification to authorities. ~Tyieshia M. Hayes S1RLI~.~ GALL.OGLY .& LESSER, P.C. By: Jo~ C.. Sirlin, Esqmre IdentifiCation No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION VS. ERIC JOBES and FIRST UNION NATIONAL BANK, GARNISHEE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND NO. 01-6613 AN~W'F,R,~i TO INTF, RRC~C'.ATCIRIE~ IN ATTACI-IM~,NT TO: BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION, Plaintiff 1. No. 2. No, Defendant has no relationship with First Union National Bank. 3.-6. No. 7. See answer to number two above. Dated: ~/~vY // JO/}['~C .~IRLIN Atfomey for Garnishee First Union National Bank PA4418 Liens and Levies 5th and Market Streets Philadelphia, PA 19106 Kathleen Gormley, being duly sworn according to law, deposes and says that she is the Writ of Execution Administrator of First Union National Bank. Garni~'hee herein, and verifies that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made subject tO penalties of 18 Pa. C.S. Section 4904. relating to sworn falsification to authorities. ~ Dated:3' [9' {5 2../' SIRLIN GALLOGLY & LESSER, P.C. By: Jo!; C. Sirlin, Esquire IdentifiCation No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 8~4-9700 Attorney for Garnishee BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION COURT OF COMMON PLEAS COUNTY OF CUMBERLAND : VS. : ERIC JOBES : NO. 01-6613 end FIRST UNION NATIONAL BANK, : GARNISHEE : ANgVdERg TO 1NTF, RROGATORIi~,g IN ATTACIqMENT TO: BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION, Plaintiff Dated: 1. No. 2. No, Defendant has no relationship with First Union National Bank. 3.-6. No. 7. See answer to number two above. ~O~mC;y-S foll~Lr GINami s h ee 1 First Union National Bank PA4418 Liens and Levies 5th and Market Streets Philadelphia, PA 19106 verification Kathleen Gormley, being duly sworn according to law, deposes and savs that she is the Writ of Execution Administrator of First U ' , ' ~ mon National Bank, Garnishee herein, and verifies that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made subject tO penalties of 18 Pa. C.S. Section 4904. relating to sworn t:alsiflcation to authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BiG BEAR EMPLOYEES CREDIT UNION Plaintiff No. 01-6613 Civil Term ERIC JOBES VS. PRAECIPE TO SETTLE, DISCONTINUE AND END AS TO GARNISHEES ONLY Defendant M&T BANK, FIRST UNION NATIONAL BANK, COMMERCE BANK, PNC BANK and WAYPOINT BANK Garnishees FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. I.D.#-47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02340760 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BIG BEAR MEMBERS FIRST CREDIT UNION, INC., FKA BIG BEAR EMPLOYEES CREDIT UNION Plaintiff VS. Civil Action No. 01-6613 Civil Term ERIC JOBES Defendant M&T BANK, FIRST UNION NATIONAL BANK, COMMERCE BANK, PNC BANK and WAYPOINT BANK Garnishees PRAECIPE TO SETTLE, DISCONTINUE AND END AS TO GARNISHEES ONLY TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court and mark the costs paid as to garnishees, M&T Bank, First Union National Bank, Commerce Bank, PNC Bank and Waypoint Bank, only. SWO~'~:~C~ A~I~iBED before me this ~ day of , oo2 _ I~(~ TA'T~Y P U~I~-/ WELTMAN, WEINBERG & REIS CO., L.P.A. Attorney for Plaintiff ~J 2'718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION VS. ERIC JOBES and FIRST UNION NATIONAL BANK, GARNISHEE : COURT OF COMMON PLEAS COUNTY OF CUMBERLAND : NO. 01-6613 To: William T. Molczan, Esquire 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 NOTICE 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 PRAECIPE FOR RULE OF NON PROS JUDGMENT BY DEFAULT _ MONEY JUDGMENT JUDGMENT IN REPLEVIN JUDGMENT FOR POSSESSION _ JUDGMENT ON AWARD OF ARBITRATION _ JUDGMENT ON VERDICT _ JUDGMENT ON COURT FINDINGS SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION VS. ERIC JOBES and FIRST UNION NATIONAL BANK, GARNISHEE : COURT OF COMMON PLEAS : COUNTY OF CUMBERL~ : NO. 01-6613 TO THE PROTHONOTARY: PRAECIPE Kindly enter a Rule upon Plaintiff to either seek judgment agair~st Garnishee, First Union National Bank under Rule 3143(g) or to place the issue between Plaintiff ahd Garnishee upon the list for trial, or in the alternative, to suffer judgment of non pros against IPlaintiff and in favor of Garnishee, First Union National Bank. Date: J . SIRLIN Attorney for Garnishee SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION VS. ERIC JOBES and FIRST UNION NATIONAL BANK, GARNISHEE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND NO. 01-6613 m~,E TO THE PROTHONOTARY: AND NOW, this ]~6ay of2~.~, 200.~, a Rule is hereby granted upon Plaintiff to seek judgment against Garnishee, First Union National Bank, under RUle 3143(g) or to place the issue between Plaintiff, Defendant and Garnishee upon the list for trial within twenty (20) days after the service hereof or to suffer Judgment of Non Pros against Plaintiff. ' PROTHONOTARY, SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee BIG BEAR MEMBERS FIRST CREDIT UNION, INC. FKA BIG BEAR EMPLOYEES CREDIT UNION VS. ERIC JOBES and FIRST UNION NATIONAL BANK, GARNISHEE : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND : NO. 01-6613 : ATTORNEY ID# ORDER TO DIgCONTINIIE ATTACHMENT TO THE PROTHONOTARY: . Kindly mark the attachment against the Garnishee, First Union National Bank, discontinued, upon payment of your costs only. JON C. SLRLIN Attorney for Garnishee R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Poundage 6.49 Advertising Law Library .50 Prothonotary 1.00 Mileage Misc. Surcharge 60.00 Levy 100.00 Post Pone Sale Garnishee 45.00 Advance Costs: Sheriff's Costs: 300.00 228.99 71.01 Refunded to Atty on 3 / 25 / 03 Sworn and Subscribed to before me this/,~- day of qn~LO_ 003 ^.o. ro o ota y So Answers; R. Thomas Kline, Sheriff CPL.