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HomeMy WebLinkAbout09-0310f-. J Our,File No.: 183273 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. SOPHIE E NIBA 9 E GLENWOOD DR CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: (9 - 310 0'iya Imom 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 twenty (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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 `'' s Our,File No.: 183273 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. SOPHIE E NIBA 9 E GLENWOOD DR CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: b f - 316 (2.4;U 7-u,?.- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are SOPHIE E NIBA, an adult individual residing at 9 E GLENWOOD DR CAMP HILL, PA 17011. 3. Plaintiff, ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC, is the Assignee and Successor in Interest of Account #5491100014534690; and said account was issued to Defendant(s) by HSBC, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $2,654.08. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,654.08 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER &/ASSQbCIATES, P.C. A Law Firm Enjaged in Debt Collection BY: David J. Akthaker, Esquire Dated: 1/8/2009 Our File No.: 183273 VERIFICATION CQIJP.8nyj 0. C-xnf hereby states that I am ALA Jys i!Xi Q6 W ZQ it- C&Vp for Plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa_C.S.A. 4904 relating to unswom falsification to authorities. OfInQm (D. A PPlalatiff DATE: ATLANTIC CREDIT & FINANCE, INC. SEP 15 2008 ,E V. - L SOPHIE E NIBA ,,. AFFIDAVIT OF DEBT AND VERIFIED BILL OF PARTICULARS The undersigned being first duly sworn according to law, deposes and says that she is familiar with the policies and practices, as well as the books and records of the Plaintiff' with respect to the matters stated herein, and based on information and belief states as follows: 1. Plaintiff's principal business consists of purchasing charged off receivables. 2. The Defendant defaulted on HSBC Account No. 5491100014534690. Said Account was charged off on 12131/2007 and subsequently sold to Atlantic Credit & Finance, Inc with a balance of $2,500.36. 3. Plaintiff purchased or was otherwise assigned this charged off account along with other debts. As a result of the foregoing sale and assignment, the Plaintiff succeeded to all right, title and interest in the charged off account and it now owns the account. 4. Plaintiff conducted a due diligence investigation to determine, among other things, the accuracy of the account information provided to ascertain whether the statute of limitations was a bar to demand or institution of suit. Further, Plaintiff and/or its predecessor entered into a contract where the predecessor made representations and warranties that 1) it had clear right, title and interest in the account; 2) the account was free and clear of all liens and encumbrances; and 3) it had the power, authority, and full right to sell and convey its interest in the account. 5. According, to Plaintiff's records, the last payment date was5/612007 in the amount of $50.00. After application of all payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and owing on this indebtedness of $2,500.36. 6. The internal Account Statement of Plaintiff is attached hereto as Exhibit A and displays the account information that was provided to Plaintiff at the time of purchase and assignment. The foregoing is true and correct to the best of my knowledge and belief By: k*ktkk+k Carol Jo ey `??s`t kxr??? Authorized R sentative Subscribed and sworn before me, September 2, 2008. , A .. AMY rn Notary Public: Amanda Guthrie foy, ?t72 r RG`???MR, +i++ki{/ltjt?y THIS COMMUNICATION IS FROM A DEBT COLLECTOR Apothaker & Associates: CGAFF- 3401 852 - 0001673 CREW &FN#Wa WQRFN)RA7ED Account Statement PO Box 13388 . Roanoke, VA 24833 Original Creditor Last Pay Date: 5/6!2007 Original Creditor Last Payment Amount: $50.00 Original Creditor Charge Off Date: 12131/2007 ACF ID Number: 3401852 SSN: XXX-XX4682 CONFIDENTIAL PROPERTY OF ATLANTIC CREDIT & FINANCE, INC. j F. -3 9 00 ?b 3 X-1 rn ` 'T3 a SHERIFF'S RETURN - REGULAR CASE NO: 2009-00310 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ?- .NOW ATLANTIC CREDIT & FINANCE INC' VS NIBA SOPHIE E SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NIBA SOPHIE E the DEFENDANT , at 2016:00 HOURS, on the 23rd day of January , 2009 at 9 E GLENWOOD DR CAMP HILL, PA 17011 by handing to SOPHIE NIBA 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 of So Answers: 18.00 13.50 .00 10.00 R. Thomas Kline .00 41.50 01/26/2009 APOTHAKER & SOC ES lo- By: day Deputy Sheriff A.D. low* "Sam -..r n... ;.,sy ?^^°? + t?: ? -y' ??? -,'. ?y ? Our File No.: 183273 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apoihaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff, VS. SOPHIE E NIBA Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-310 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, SOPHIE E NIBA, in the default of an Answer, in the amount of $2,705.87 computed as follows: Amount claimed in complaint: $2,654.08 Amount Paid: - $(0.00) Interest from January 08, 2009 to 05/14/09 at the legal interest rate of 6.000 per annum $51.79 Costs $0.00 Attorney fees $0.00 TOTAL $2,705.87 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, SOPHIE E NIBA, last know APOTHAKER & A Law Firm By: 9 E GLENWOOD DR CAMP HILL, PA 17011. lainti. Debt .TES, P.C. David J. Apothaker Dated: 5/14/2009 OF THE ' r . ()TAW 2009 MAY 19 PH 3: 4 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: SOPHIE E NIBA 9 E GLENWOOD DR CAMP HILL, PA 17011 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff, VS. SOPHIE E NIBA Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-310 Civil Action } 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. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION 141 JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, EN. at this telephone number: 215-634-8920 7Zz"7 / 1. z "I Our File No.: 183273 APOTFLWR & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff, VS. SOPHIE E NIBA Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-310 . SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 9 E GLENWOOD DR CAMP HILL, PA 17011. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if tV Mary M. Snavely-Dixon, Director of the De indicated that the Defendant(s) is/are not in the mili David J\ Attorney Data Center, located at 1600 Wilson ,) is/are in any branch of the military. Center has sent back our inquiry The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. UAY-14-2009 lor03 Al 5 "C ztwr -- SewYC W?l' ?? tot ? y?i5+ t ? Of Ddm l? ?° abo*4e is *e Cwto eg Dom CO*+f 183273 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ATLANTIC CREDIT & FINANCE INC. ASSIGNEE ) COURT OF COMMON PLEAS FROM HSBC ) CUMBERLAND COUNTY vs. ) NO.09-310 SOPHIE E NIBA ) To: SOPHIE E NIBA 9 E GLENWOOD DR CAMP HILL, PA 17011 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: February 27, 2009 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 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 PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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. CUMBERLAND COUNTY ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DA APOTHAKER, ESQUIRE APOT R & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 1 T ? SHERIFF'S RETURN - REGULAR CASE NO: 2009-00310 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDI'T' & FINANCE INC VS NIBA SOPHIE E SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NIBA SOPHIE E the DEFENDANT at 2016:00 HOURS, on the 23rd day of January 2009 at 9 E GLENWOOD DR CAMP HILL, PA 17011 by handing to SOPHIE NIBA a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sher'iff's Costs: Docketing 18.00 Service 13.50 Affidavit .00 Surcharge 1.0.00 .00 41,50 Sworn and Subscibed to before me this day of r So Answers: R. Thomas Kline 01./26/2009 APOTHAKER & SOC ?ES r By- /911 Deputy Sheriff A.D. .i. FLED- CE 2TO9 €aY 19 f H 3, : 4 9 .40, e L?,t..? a /56 C/t) mac. /3 i 7 v p FILED - OI: Ct' O THE FROTNONOTAR WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan I.D. No. 47437 436 Seventh Avenue, 1400 Koppers Bldg Pittsburgh, PA 15219 Phone: 412.434.7955 2012 FEB - 3 AM 11: 3 7 Attorney for PI CUMBERLAND COUNTY PENNSYLVANIA Fax: 412.434.7959 File # 9412321 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff vs. CUMBERLAND County Court of Common Pleas No.: 09-310 SOPHIE E NIBA Defendant(s) PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of the Plaintiff in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. n By _ William T. Mole Attorney for Pla tiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-310 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ATLANTIC CREDIT & FINANCE INC. ASSSIGNEE FROM HSBC Plaintiff (s) From SOPHIE E. NIBA, 9 EAST GLENWOOD DRIVE, 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: CITIZENS BANK, 665 NORTH EAST STREET, 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 $2500.36 Interest $62.47 Atty's Comm % Atty Paid $165.50 Plaintiff Paid Date: March 27, 2012 (Seal) L.L.$.50 Due Prothy $2.25 Other Costs , leff David D. Buell, Prothonotary k-g??"?Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff vs. nn ?-- ``" Civil Action No. 09-310 Ii- SOPHIE E NIBA q . lr"W t? 'hp Ph U ?a( Defendant(s) CITIZENS BANK . U 5 1?( -?/1 r 5? ?C, lJd?1 UPS -e ( 0 ) -7 0 13 Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against SOPHIE E NIBA , Defendant 3. against CITIZENS BANK... Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): y 1. so e?? 7y iii. S.Sa-PaaIn $ c-' y, C sv xa. ca r:: r- rx- -t r" $2,705.87 $205.51 $62.47 $2,562.83 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Esquire/f PA I.D. #47437 V WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 16 a.a'S -ZUL A S . 14 j2 a 73o1S WWR No. 9412321 A) 0- zI( P, `1`?sl 1PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff vs. SOPHIE E NIBA Defendant(s) CITIZENS BANK Garnishee(s) No. 09-310 PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W" No. 9412321 SHERIFF'S OFFICE OF CUMBERLAND COUNTY r -- Ronny R Anderson , Sheriff ' ;. 7 10 Jody S Smith r-:<- Chief Deputy ^? - Richard W Stewart Solicitor „ - G7 _ Atlantic Credit & Fi nance Inc. Assignee from HSBC vs. Case Number Sophie E Niba 2009-3 10 SHERIFF'S RETURN OF SERVICE 03/29/2012 09:33 AM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on March 29, 2012 at 0930 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Sophie E. Niba, in the hands, possession, or control of the within named garnishee, Citizens Bank, 665 N East Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Janine Sheaffer, Senior Teller, 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 30, 2012 to Sophie E. Niba at 9 E Glenwood Drive, Camp Hill, PA 17011. SO ANSWERS, March 30, 2012 RON R ANDERSON, SHERIFF tephen Bender, Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION ATLANTIC CREDIT & FINANCE, INC ASSIGNEE FROM HSBC Plaintiff(s), VS. SOPHIE E NIBA Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. 09-310 C _ > ? GS T, CA) all - ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1 to 12) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SOPHIE E NIBA, with an available balance less than the Garnishee's Processing Fee of $125.00 and Statutory Exemption of $300.00, accordingly, no funds are being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Heather Zito who being duly sworn according to the law deposes and says that she is the Operations Clerk, Operations Services, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Heather Zito Sworn and subscribed before y` °'" eS by this day of Ilk I , 2012. Notary Public Certificate of Service I, Heather Zito, hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this 23 day of APRIL, 2012. WILLIAM T MOLCZAN, ESQ WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BLDG PITTSBURGH, PA 15219 Heather Zito IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION ATLANTIC CREDIT & FINANCE, INC ASSIGNEE FROM HSBC, Plaintiff(s), VS. SOPHIE E NIBA, Defendant(s), VS. Citizens Bank of Pennsylvania, Garnishee. 09-310 Answers to Interrogatories Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA I. D. No. 62378 Stradley, Ronon, Stevens & Young Great Valley Corporate Center 30 Valley Stream Parkway Malvern, PA 19355-1481 (484) 323-1351 (610) 640-1965 fax WELTMAN, WEINBERG & REIS CO., L.P.A. - BY: William T. Molczan, Esquire Attorney for Plaintiff(s) ` ' I.D. No.47437 436 Seventh Avenue, Suite 1400 i?? Pittsburgh, PA 15219 t° r =' Phone: 412.434.7955 `-=c-. Fax: 412.434.7959 - , File # 9412321 ATLANTIC CREDIT & FINANCE INC SUCCESSOR FROM HSBC CUMBERLAND County Court of Common Pleas vs. SOPHIE E NIBA, and CITIZENS BANK Garnishee(s) NO. 09-310 PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), CITIZENS BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By William 14. Molcza squire Attorney for Plain i OLO %9 . sbpd a K C?_q i o4 4 s ?-?a T-4a-7y-2as SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,iny R Anderson jheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor re °^ r ` ?13'I 4? 3? r Atlantic Credit & Finance Inc. Assignee from HSBC Case Number vs. Sophie E Niba 2009-310 SHERIFF'S RETURN OF SERVICE 03/29/2012 09:33 AM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on March 29, 2012 at 0930 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Sophie E. Niba, in the hands, possession, or control of the within named garnishee, Citizens Bank, 665 N East Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Janine Sheaffer, Senior Teller, 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 30, 2012 to Sophie E. Niba at 9 E Glenwood Drive, Camp Hill, PA 17011. 10/19/2012 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: $88.38 SO ANSWERS, October 19, 2012 RON R ANDERSON, SHERIFF acrd , ee • SV LL'O d- a? 5-" >/ I In: