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HomeMy WebLinkAbout08-7508 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA - C J ? Plaintiff No: 7so8 (21 (1 LT{ GZyl.. 'STS . STEVE W CLARK COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07019780 C N Pit CFR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. STEVE W CLARK Defendant Civil Action No COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA),NA is a corporation with offices at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238 . 2. Defendant is adult individual(s) residing at the address listed below: STEVE W CLARK 1392 LOWTHER RD CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX0517 . 4. Defendant made use of said credit card and has a current balance due of $4044.29 , as of October 29, 2008 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff . 6. Plaintiff is entitled to the addition of interest at the rate of 27.100% per annum on the unpaid balance from October 29, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , STEVE W CLARK , INDIVIDUALLY , in the amount of $4044.29 with continuing interest thereon at the rate of 27.100% per annum from October 29, 2008 plus costs. BERG & REIS CO., L.P.A. venue, S uite 1400 7FAX:22 ro t,42524 A 15219 55 -7130 Pit CFR This law firm is a debt collector attemp g to collect this debt for our client and any information obtained till be used for that purpose. FINANCE Previous Balance P"nts & Credits CHARGE Transactions New Baratta Minimum Payment Due Date $2,738 02 - $0 00 + $68 63 + $78 00 = $2,884 65 $384 65 Oct 05, 2007 Aug 10, 2007 - Sep 10, 2007 Page 1 of 1 PUASe MY AT LW7 7141 MOA I sh Visa Platinum Account 130ST221-?t81-0517 Your Account Information TOTAL CREDIT LINE $2,500 00 TOTAL AVAILABLE CREDIT $0 00 CREDIT LINE FOR CASH $2.50000 AVAILABLE CREDIT FOR CASH $0 00 Finance Charges (Please see reverse for rmporeot nfrmalow) Balance ra Periodic ding nNANCE appled b rate APR CHARGE Purchases $2,780 78 0 07712% D 2815% $6663 Cash $000 0 07712% D 2B 15% $000 ANNUAL PERCENTAGE RATE applied this period. 25.15% ® At Your Service 1400403.MT To cal COWNIF Relate or to report aknt rst*n card ® OWN One Bank P O Bos M184 Chedotte, NC 18272-0684 A Ssnd inquires to. Capra Ore P.0 BII 30185 Seit take City, UT 84130-0285 ® Have a question about a charge on your statement? please refer to the Billing Rights Summary m the be& of yar statement or wart You're beMd by three payments That means you are trmporarly unable to mace new purdiases or pet ca advances. But you an room !rout Capita One ds9rn9 Prtoile9es rid MM Your account back MW good standing by paying t* mount due on your statement if yt.ye having rnr+aat aRfudbes and youVe feeling Overwhemed - we ward to hap. Give one or our associates a call at 1800 9% 6600 You'd be surprised what we an do togettr to work this out pay me Credits & Ad ustmerb Trartsadbns $3900 1 03 SEP PAST DUE FEE $3900 2 1D SEP OVERLIMIT FEE SEP 10, 2001 Under temp previously disclosed to YOU, a" a rI Of your A"al Percentage Rates (APRs) have bean increased anal your amount uss_ pool due b"m " past `12 boiling CYd@s I your es exNnded the drshon of ft Increased rats ioRionard r Rawe receive ylyour ? nen'mrrll morlThy payment mot ant on urea to 12 consecutive bang cycles, the accountwd be reviewed for a possible return tD your Non-Irdrodudry APR You were asseasad a past due fee because your mrumum payment was not received by the due dale To avoid this fee in The future, we recommend that you allow at least 7 busnesa days for your mnmurn payment to reach Capra One ?./?s asv? C 910 PAGE oiDM6056 6056 506 1 ui 1 070 PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ONTO W WW CAPITALONE COM TO MAID: YOUR PAYMENT ONLINE .' f?0W I what's in your w?1e17" New Balance Minimum Payment Due Date C$2,884 65 $384 65 Oct 05, 2007 PLEASE PAY AT LEAST THIS AMOUNT 0 4305722143640517 09 2884650071000384651 Amount Enclosed C== Capital One Bank 'r'rrlrrl rlle1r?Irelr? P.O. Box 70884 Charlotte. NC 28272-0644 1 111111111 11n1e1aIloilo Isell Account Number. 4305-7221-4364-0517 Please print address or phone number changes below using blue or black ink address Heine Phone AAemate Phone E-mad address Q #9025473169182392# MAIL ID NOMDER STEVE W CLARK 1342 LOWTHER RD CAMP HILL, ph 17011-7534 7019780 Please write your account number on your check or money order made payable to capital one Bank and mall with this coupon in the enclosed envelope CAPITAL ONE BANK (USA), N.A., Plaintiff, V. STEVE W CLARK Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities, that he/she is an authorized agent of CAPITAL ONE BANK (USA), N.A., Plaintiff herein, and that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. Dated: A4%0&- S ame S' more A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Ek. ? ^` C c-? IM SHERIFF'S RETURN - REGULAR CASE NO: 2008-07508 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK USA NA VS CLARK STEVE W MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CLARK STEVE W the DEFENDANT , at 1010:00 HOURS, on the 3rd day of January , 2009 at 1392 LOWTHER ROAD CAMP HILL, PA 17011 KRISTI CLARK, WIFE 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 Service Affidavit Surcharge Sworn and Subscibed to before me this So Answers: 18.00 13.50 .00 10.00 R. Thomas Kline .00 41.50 01/05/2009 WELTMAN WEINBERG REIS By. day Depu y heriff 0 f A. D. ? ? _ ati.,? '-;? .. , :'I e Ew ', `'- i ' ?v ?- ?, _.... ;pia t .-- .^? i? t ?'Y r. p? ?. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. No.08-7508 CIVIL TERM STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT STEVE W CLARK Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#07019780 $4,418.56 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. Civil Action No. 08-7508 CIVIL TERM STEVE W CLARK Defendant PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, STEVE W CLARK, in the amount of $4,418.56 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By: A t t /me for Plaintiff STEVE W CLARK, By: De n nt WWR#07019780 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 08-7508 CIVIL TERM STEVE W CLARK Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, STEVE W CLARK, above-named, in the amount of $4,418.56 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $4,418.56 with continuing interest thereon at a rate of 6.00% per annum plus costs from Date of Judgment. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, STEVE W CLARK, in the amount of $4,418.56 plus continuing interest thereon at the rate of 6.00% per annum from Date of Judgment and costs. Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $155.00 due by June 26th, 2009; (b) $155.00 due on the 26t' day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "CAPITAL ONE BANK (USA), NA" s 5. The first payment due under this agreement is to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 436 Seventh Avenue, Suite 1400, Pittsburgh, PA 15219. All future payments are to be mailed to the offices of Weltman, Weinberg & Reis, Co., P.O. Box 5430, Cleveland, OH 44101-0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff's counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. d ?f' 9. Intending to be legally bound, the parties set their hands and seals thk-" day of ??, 20_d"-_. By: Def dant, STEVE W C ARK WELT WEINBERG & REIS CO., L.P.A. B Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 07019780 T"!E Li i ?+1 OF TH OV 2009 AJQ -7 Pli 0 I ${x,00 pa a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 08-7508 CIVIL TERM STEVE W CLARK Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $4,418.56 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary STEVE W CLARK 1392 LOWTHER RD CAMP HILL, PA 17011 By: PRO ONOTARY (OR DEPU bXA I . ? w F1LED- ?Ji!uE THI- 2 (0 MAR -8 PM 2: 31 J, i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. STEVE W CLARK Defendant McTp_.o 6W4. Vf I A COMMERCE BANK, Garnishee, "iJ U4.50 PO A-TTY 41• so CBF 18.50 Iq.00 a.so 1101 • 00 - Rb AlT`/ No. 08-7508 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#07019780 L.L 5 D.v.56 Pk -11, I1 %46 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. Civil Action No. 08-7508 CIVIL TERM STEVE W CLARK Defendant COMMERCE BANK, Garnishee TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: Lt,Pc` 1'70 r 2. against STEVE W CLARK, Defendant M ETRA 3. against eE+fM£ReC-BANK, Garnishee 301o?1'NAF?c?+2?+' 4. Judgment Amount C&t f sjl f( Pk (7 D 1'1 $ 4,418.56 Less payments of $ 1,033.50 Interest $ 122.69 Costs SUBTOTAL: Costs (to be added by Prothonotary): WELTMAN, WF?NBERG & REIS CO., L.P.A. By: / .- Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Sev6Wh Avemm Pittsburgh, PA 15219 (412) 434-7955 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-7508 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK (USA) NA, Plaintiff (s) From STEVE W. CLARK, 1392 Lowther Rd, Camp Hill, PA 17011 (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: METRO BANK f/Wa COMMERCE BANK, 3201 Trindle Road, Camp Hill, PA 17011 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 $3,385.06 Interest -- $122.69 Atty's Comm % Atty Paid $161.00 Plaintiff Paid Date: 3/8/10 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs 2-&6V David uell, Proth otary By: REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLb5NI, T; CIVIL DIVISION -T4r -i c-n CAPITAL ONE BANK. (USA), NA A_} _V .'. Plaintiff No. 08-7508 CIVIL TERM ? 43 ' ? 1 C)' _ Answers _Io vs. INTERROGATORIES IN ATTACHMENT COMMERCE BANK STEVE W CLARK Defendant and COMMERCE BANK Garnishee FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. 490963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#07019780 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. STEVE W CLARK Defendant and COMMERCE BANK Garnishee Civil Action No.: 08-7508 CIVIL TERM TO: COMMERCE BANK Suggested Reference No.: XXX-XX-9393 3201 TRINDLE ROAD CAMP HILL, PA 17011 RE: STEVE W CLARK 1392 LOWTHER RD CAMP HILL, PA 17011 IMPORTANT NOTICES 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. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason (including finds on deposit for checking or savings accounts and certificates of deposit)? Defendant has account 537059511 held jointly with Kristi Clark with a balance of $620.62. Account has direct deposit (payroll) Defendant did not receive $300 exemption. 1 a. If the answer to Interrogatory I is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof, the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. See answer to question 1 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. See answer to question I 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? See answer to question 1 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? no 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? no 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? no 7. If yoir afe-Vbank 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. See answer to question 1 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 the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. See answer to question 1 9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. 3/19/2010 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. See answer to question 1 1 1. If the response to Interrogatory 7 is in the affirmative are other funds comingled in the account which are not 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? 12. If the response to Interrogatory 1 1 is in the affirmative, state the amount of non-exempt funds on deposit in the account- WELTMAN, WEINBERG & REIS CO., I .P.A. Matthew D. Urban, Esquire PA I.D. 490963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR907019780 By: VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ( G TURE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor 4?n??. at ?u+i?6cx??c .?pTARY 2010 MAR 26 th 8.41 CUM?C? ? -'LINTY Capital One Bank (U.S.A.) N.A. vs. Steve W Clark SHERIFF'S RETURN OF SERVICE Case Number 2008-7508 03/19/2010 12:04 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 19, 2010 at 1159 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Steve W. Clark, in the hands, possession, or control of the within named garnishee, Metro Bank F/K/A Commerce Bank, 3201 Trindle Road, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Nina Landis, Assistant 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 03-25-10 to Steve W. Clark at 1392 Lowther Road, Camp Hill, PA 17011. SO ANSWERS, March 25, 2010 RON R ANDERSON, SHERIFF i Mm Cline, Deputy i.cj cour'ySuite .^erff. Tepecso't, Ins. r u7 ?'TA?Y 2010 JUH 28 FM 12: 4b- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. STEVE W CLARK Defendant(s) No. 08-7508 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA I.D. # 205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7019780 CFR sp;d0 p d-/ y?yk 7 3 7 R-4 4-IJy 3 37 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY., PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No. 08-7508 CIVIL TERM STEVE W CLARK Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTWN, WEINBERG & REIS CO., L.P.A. By: LyndsaylE Rowlan?j Esquire PA I.D. 205520 `` WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7999 WWR #7019780 Sworn to and subscribed before me this _-7 day of 10 -''NOTARY j?GBLIC COMIVG" She;;? i,iieynsnyCcuurity Comm?,cr Emo ......__r,, , ""-- .......:._._ _? f + Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 2T10 JJ-123 ; NTY Capital One Bank (U.S.A.) N.A. Case Number vs. Steve W Clark 2008-7508 SHERIFF'S RETURN OF SERVICE 03/19/2010 12:04 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 19, 2010 at 1159 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Steve W. Clark, in the hands, possession, or control of the within named garnishee, Metro Bank F/WA Commerce Bank, 3201 Trindle Road, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Nina Landis, Assistant 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 03-25-10 to Steve W. Clark at 1392 Lowther Road, Camp Hill, PA 17011. 06/28/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiff's attorney. SHERIFF COST: $138.02 SO ANSWERS, 6z x June 28, 2010 RONK'Y R ANDERSON, SHERIFF el24 7& 7,3 1,*4* 2 4?a-