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HomeMy WebLinkAbout08-7230Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JESSICA E HATHAWAY NO. C)8 - 17a5 C iviI 5312 Oxford Circle Apt.I Mechanicsburg PA 17055-4421 Defendant CIVIL ACTION -LAW Complaint - Notice 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 (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 claim 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-18345 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O f - 7a 30 JESSICA E HATHAWAY 5312 Oxford Circle Apt.l Mechanicsburg PA 17055-4421 Defendant : CIVIL ACTION - LAW Complaint &?? 7-t? 1. Plaintiff is Citibank (South Dakota), N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Jessica E Hathaway, who resides at 5312 Oxford Circle Apt. 1, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff is a national banking association, engaged in various types of banking business including consumer lending through the issuance of credit cards. 4. Plaintiff furnished consumer credit to the defendant by means of a(n) Sears credit card with account number ending in 1856 hereinafter referred to as the credit card account. 5. Plaintiff kept accurate running records of all debits and credits to the account. 6. Plaintiff mailed to defendant monthly statements for the account including the billing statement attached hereto as Exhibit A. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 7. Before plaintiff mailed Exhibit A, defendant had for many months made payments on account of the billing statement or retained the statement without payment. 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $3,460.26 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. Wherefore, plaintiff demands judgment against defendant for the sum of $3,460.26, and the costs of this action. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Sears Premier Carde JESSICA E HATHAWAY Account Number: 1856 Page 1 of 2 Your Account Summary Billing Cycle Closing Date 08/15/08 Amount Over Credit Line $180.26 Amount Past Due $677,78 Total Minimum Due $820.91 Previous Balance $3,352.13 Payments & Credits $0.00 Purchases & Debits $0.00 Other Charges $35.00 Total FINANCE CHARGES $73.13 Account Balance $3,460.26 Your Credit Summary Total Credit Line $3,280.00 Total Credit Available $0.00 Call us at 1-800-917-7700 Go to www.searscard.com Write to us at PO Box 6283 Sioux Falls, SD 57117-6283 Payment Due Date L09/12/08 y?JI . Activity Sale Date Post Date Description Amount 08/14/08 08/14/08 LATE PAYMENT FEE YOUR LATE FEE WAS BASED ON AN ACCOUNT BALANCE OF $3,352.13, WHICH WAS YOUR ACCOUNT BALANCE ON THE LATE FEE TRANSACTION DATE. YOUR ACCOUNT IS SERIOUSLY PAST DUE. AMOUNT PAST DUE IS SHOWN ABOVE. ARRANGEMENTS FOR FUTURE PAYMENTS SHOULD BE MADE IMMEDIATELY. Please follow payment instructions on reverse side. Payment must be received by 5:00 p.m. local time on Payment Due Date. Sears Premier Card® Account Number:' 1856 Payment Total Account Balance Due Date Minimum Due Amount Enclosed L_!1,46026 09/12108 $820.91 0088227 EX 11 A 08228 1 TRS006 FXG 001 7 N it VIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIItIIIiIIIVIIIIIIVIII JESSICA E HATHAWAY 5312 OXFORD CIR APT 1 MECHANICSBURG PA 17055-4421 Please make address changes on reverse side. III IIIIIII ItI lI111III11IIIIIII III VIII III IIIIIII IIIIIII111 Make check payable to SEARS CREDIT CARDS PO BOX 183081 COLUMBUS, OH 43218-3081 200 5049948521211856 0346026 0082091 0000000 1110 35.00 IXHINT A- Sears Premier Card® JESSICA E HATHAWAY Account Number: XXXX XXXX XXXX 1856 Page 2 of 2 88227 Average i Daily Rates `Rate Varies Balance Balance I Call us at 1-800-917-7700 Go to www.searscard.com Write to us at PO Box 6283 Sioux Falls, SD 57117-6283 Payment Due Date 09/12/08 sponding Periodic Rate Periodic JAL D--Day FINANCE TENTAGE RATE M=Month CHARGE SEARS REGULAR $3,460.26 $3,389.69 27.15%' .0744%(D)' $73.13 EXTERNAL REGULAR $0.00 $0.00 27.15% .0744%(D)• $0.00 CASH ACCESS REGULAR $0.00 $0.00 27.15%' .0744%(D)' $0.00 Days in Billing Period: 29 Effective ANNUAL PERCENTAGE RATE: 27.15% Minimum FINANCE CHARGE: $0.00 Cardmember News The Sale Date is the Transaction Date. Verification I Tiena Reynolds am an employee of Citicorp Credit Services, Inc., (USA) which is by contract the service provider for plaintiff CITIBANK (SOUTH DAKOTA), N.A. retained to perform services on its behalf. I am authorized to make this verification as attorney-in-fact for plaintiff under powers of attorney from plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing averments of fact in the within pleading are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. %Zto-, Signature C-18345 Jessica E Hathaway Account number ending in 1856 1031 N S 00 00 d C? n C: e SHERIFF'S RETURN - REGULAR CASE NO: 2008-07230 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK SOUTH DAKOTA NA VS HATHAWAY JESSICA E MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HATHAWAY JESSICA E was served upon the DEFENDANT , at 1935:00 HOURS, on the 2nd day of January.-, 2009 at 5312 OXFORD CIRCLE APT 1 MECHANICSBURG, PA 17055-4421 JESSICA HATHAWAY by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.00 Affidavit .00 Surcharge 10.00 .00 37.00 Sworn and Subscibed to before me this day So Answers: r, R. Thomas Kline 01/05/2009 BURTON NEIL & ASSOCIATES By: ep y eriff of A. D. `=?' -n ? -, _ ` :.? , r't r ;??" ? i t? - C?""J ` `_ ?, x s"'a ? ; , , w? : °) 1:3 t. CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. JESSICA E HATHAWAY 5312 Oxford Circle Apt.1 Mechanicsburg PA 17055-4421 Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-7230 civil term : CIVIL ACTION - LAW Praecipe for Default Judgment To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $3,460.26 $3,460.26 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTI GIVEN UN R PA.R.CIV.P. 236 Pro rothon Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff I.D. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. C-18345 CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. JESSICA E HATHAWAY Defendant : IN THE COURT OF COMMON PLEAS C-18345 CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-7230 civil term CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Jessica E Hathaway 5312 Oxford Circle Apt.I Mechanicsburg PA 17055-4421 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 (10) 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 your 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. This office can provide you with information about hiring a lawyer. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 DATE OF NOTICE: January 26, 2009 In making this communication, we advise our office is a debt collector. Burton Neil & Associates, P.C. By: Neil Sarker, Esquire Attorney for Plaintiff Identification No. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 -?, ?- ? ?- ? (? t'om' T? ??".?ry? =\ ?? ? ? ?? -r? _ t ` -? ? ?j ? . c ?i-s? t-- ? ...., ,: ? .. ?. . ° C _C .. _.._ frY Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. JESSICA E HATHAWAY Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-7230 civil term CIVIL ACTION - LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on a Im I A7 Prothonotary By: Deputy If you have any questions concerning the above, please contact: Neil Sarker, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-7230 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK SOUTH DAKOTA N.A. Plaintiff (s) From JESSICA E. HATHAWAY, 5312 Oxford Circle, Apt. 1, Mechanicsburg, PA 17055-4421 (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: M&T BANK, 1958 SPRING ROAD, 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; (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 $3,460.26 L.L. $.50 Interest from 2/12/2009 - - $437.85 Atty's Comm % Atty Paid $156.50 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 3/18/11 (Seal) //? --Z1 J --- Dav' e 1, Pr honotary By: Deputy REQUESTING PARTY: Name NEIL SARKER, ESQUIRE Addross: LAW OFFICES BURTON NEIL & ASSOCIATES, P.C. 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No. PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. CUMBERLAND COUNTY, PENNSYLVANIA JESSICA E HATHAWAY 5312 Oxford Circle Apt. 1, Mechanicsburg PA 17055-4421 Defendant(s) NO. 08-7230 civil term M&T BANK 1958 Spring Road, Carlisle, PA 17013 -YJ a Garnishee(s) CIVIL ACTION -LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER _"D 1. Directed to the Sheriff of Cumberland County, Pennsylvania u 2. against JESSICA E HATHAWAY , Defendant(s) .. 3. and against M&T BANK , Garnishee(s) 4. and index this writ (a) against , Defendant(s) (b) against , Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) NO LEVY - GARNISHMENT ONLY Serve interrogatories on garnishee at: 1958 Spring Road, Carlisle, PA 17013 5. Amount Due $3,460.26 Interest from 02/12/2009 $ 437.85 Total $3,898.11 *Plus writ costs Dated: February 24, 2011 Neil Sarker, Esquire Attorney for Plaintiff NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). The firm of Burto S ]t (&Q Associates, P.C. is attempting to collect a debt. C-18345 V aq* rd k_L 'V Cr3a / g-7. C6 79,spuu y cdt r r ?, OU-but 6. Soto 11 o TA a Mse. s r .7 S&SA7 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson OF ,???I-? FILED-OFFICE Sheriff ,A Jody S Smith Chief Deputy Richard W Stewart Solicitor 2011 MAR 29 AM 8: 22 CUMBERLAND COUNTY PENNSYLVANIA Citibank (South Dakota) N.A. vs. Jessica E Hathaway Case Number 2008-7230 SHERIFF'S RETURN OF SERVICE 03/25/2011 09:02 AM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on March 25, 2011 at 0902 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Jessica E. Hathaway, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Joan Crowl, Teller 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 March 28, 2011 to Jessica E. Hathaway at 5312 Oxford circle, Apt. 1, Mechanicsburg, PA 17044-4421. SO ANSWERS, March 28, 2011 RO R ANDE SON, SHERIFF 1 Michelle Gutshall, Deputy Burton Neil & Associates, P.C. By: Neil Sarker, Esquire ID. NO. 203465 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. GF THELPOTHQ iUyjF11 2011 APR -7 PM 1: 37 CUMBERLAND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA JESSICA E HATHAWAY 5312 Oxford Circle Apt. 1, Mechanicsburg PA 17055-4421 : NO. 08-7230 civil term Defendant(s) M&T BANK Garnishee : CIVIL ACTION -LAW To: M&T BANK 1958 Spring Road, Carlisle, PA 17013 tglgs w-?'Vs f6 Interrogatories to Garnishee 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: 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 or 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? qk 5 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 owed solely or in part by the defendant? 0,A 3. If the answer to 1 and/or 2 is yes, please specify the nature of the property and, if money, the amount? elaneas Provided 13 May not Renect Unposted 3"4u 0. au Transactions or Legal Document processing Fees 4. 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? v? r 5. At the time you were served or at any subsequent time did you hold as fiduciary any property in which defendant had an interest? 01? 6. At any time before or after you were served did the defendant transfer or deliver any property to you or any person or place pursuant to your direction or consent and if so what was the consideration therefor? P4 7. 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? 8. If you are a bank or other financial 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 the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. OA 9. If you are a bank or other financial 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 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. CATI lY S FISHER PA&T BANK APR 0 W 2011 Burton Neil & Associates, P.C. By: Neil Sarker, Esquire The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. CITIBANK (SOUTH DAKOTA) : IN THE COURT OF COMMON PLEAS OF N.A., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. ? rnW JESSICA HATHAWAY NO. 2008 - 7230 CIVIL TERM Z ; 32w ? =-n r r- CIVIL ACTION - LAW' CJ C-1 ORDER OF COURT` - AND NOW, this 6TH day of APRIL, 2011, a hearing on the claim for exemption filed by Jessica Hathaway is scheduled for THURSDAY, APRIL 14, 2011, at 1:30 p.m. in Courtroom # 3, Cumberland County Courthouse, Carlisle, Pa. Neil Sarker, Esquire 1060 Andrew Drive, Suite 170 CpPi??B rho West Chester, Pa. 19380 orb J Jessica E. Hathaway 366 Channing Drive Chambersburg, Pa. 17201 ? Office of the Sheriff -in bin By the Court, -le Edward E. Guido, J. sld Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor - ?' ILED-OFFICE L l T HE PROTHONOTARY 2011 APR 15 PM 1: 09 CUMBERLAND COUNTY PENNSYLVANIA Citibank (South Dakota) N.A. vs. Case Number Jessica E Hathaway 2008-7230 SHERIFF'S RETURN OF SERVICE 03/25/2011 09:02 AM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on Marcl, 25, 2011 at 0902 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Jessica E. Hathaway, in the hands, possession, or control o' the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Joan Crowl, Teller 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 March 28, 2011 to Jessica E. Hathaway at 5312 Oxford circle, Apt. 1, Mechanicsburg, PA 17044-4421. 04/04/2011 Claim for exemption filed this date. Taken to Court Administration to schedule hearing. 04/14/2011 Claim for exemption hearing held April 14, 2011. ORDER OF COURT And now, this 14th day of April, 2011, after hearing, Defendant's Claim for Exemption is GRANTED. All amounts in M&T Checking account ending in 3077 are exempt from levy. By the Court, Edward E. Guido, Judge 04/15/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED after Claim for Exemption Hearing. SHERIFF COST: $88.56 SO ANSWERS, April 15, 2011 RON R ANDERSON, SHERIFF R - Sharon R. Lan z SHERIFF'S OFFICE OF CUMBERLAND COUNTY c°J1? ,'Unun'vSuite SFe?i*fi. Te;le.,^,Sr't. In.; ?/y?.`,??, ;2 51?- 0 gar IL qj: LUII N?R' 25 P4 2? 43 PENNSYLVANIA Burton eil & Associates, P.C. By: Nei Sarker, Esquire ID. NO. 203465 1060 A rew Drive, Suite 170 West C ster, PA 19380 610-696 2120 Attorne for Plaintiff (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JESSICA E HATHAWAY M&T To the and NO. 08-7230 civil term shee : CIVIL ACTION - LAW Praecipe to Dissolve Attachment the attachment against M&T BANK, garnishee. Burton Neil & Associates, P.C. Bv: Neil Sarker, Esquire Attorney for Plaintiff The lave firm of Burton Neil & Associates is a debt collector. C-18345 0.?? ? S.oo Pct 4 ?k {'k IOC'7$l 124!-as? 913