HomeMy WebLinkAbout09-0293Commonwealth Financial In the Court of Common Pleas of
Systems, Inc CUMBERLAND County, Pennsylvania
Civil Division
Plaintiff .
vs.
NO: Dq- a-3 OlvzlTeryv1
JERRY F WELCH
Defendant
PRAECIPE FOR ENTRY OF JUDGMENT
To the Prothonotary of CUMBERLAND County:
1) Enter Judgment on the attached Certified copy of Judgment from a District Justice.
A) Date of instrument: 01/03/2006
B) Amount of Judgment: $2,894.68
C) Interest From: 01 /03/2006
2) Enter the judgment in favor or the original holder, or (unless expressly forbidden in
the instrument) in favor of the assignee or other transferee;
3) I hereby certify that the address of the plaintiff is:
Commonwealth Financial Systems, Inc.
120 North Keyser Avenue
Scranton, PA 18504
4) I hereby certify that the address of the defendant is:
JERRY F WELCH
670 HEMPFIELD HILL RD LOT 32
COLUMBIA PA 17512
Michael F. Ratchford, Esquire
Edwin A. Abrahamsen & Associates, P.C.
1729 Pittston Ave,
Scranton, PA 18505
570-558-5510 Ext. 101
Attorney ID 86285
•
Commonwealt) of PennsNlvania,
CountN of Lancaster SS.:
I, Randall O. Wenger Prothonotary of the Court of Common Pleas in and for said County, do hereby certify that the
foregoing is a full, true and correct copy of the whole record of the case herein stated, wherein COMMONWEALTH
FINANCIAL SYSTEMS, INC. , plaintiff and JERRY F. WELCH, defendant, as the same remains of record before
the said Court at No. CI-06-02460 of JUDGMENT Term A.D. 2008.
Certified amount of the judgment is $2,894.68.
In TestimonN W ereo f , I have hereunto set my hand and affixed the seal of said the Court this
15TH day of DECEMBER A.D. 2008.
Exempli f iea Record
FROM LANCASTER COUNTY
Term, 2006 No.CI-06-02460
COMMONWEALTH FINANCIAL SYSTEMS, INC., Plaintiff
120 NORTH KEYSER AVENUE
SCRANTON, PA. 18504
vs.
JERRY F. WELCH, Defendant
670 HEMPFIELD HILL ROAD LOT 32
COLUMBIA, PA. 17512
Debt, $2,894.68
Entered and Filed MARCH 10, 2006
Randall O. Wenger, Prothonotary
M
Commonweafth of PennsV[vania,
CountN Of Lancaster, ss.:
Among tbC Records entered in the Court of Common Pleas in and for the County of Lancaster,
In the commonwealth of Pennsylvania, to Term 2006, No. CI-06-02460 is contained the following:
Docket -Entries:
SEE ATTACHED
Certified amount of the judgment is $2,894.68.
jUbgment Index Entq
DEFENDENT PLAINTIFF WHEN
ENTERED REAL DEBT TERM NO.
WELCH, JERRY F. COMMONWEALTH
FINANCIAL SYSTEMS, INC. MAR. 10, 2006 $2,894.68 CI-06- 02460
Report: CDRDOCT LANCASTER CO BANNER Run Date: 15-DEC-2008
User: LGREENAWALT Civil Docket Report Run Time: 09:20 AM
Instance: PRODS
Page: 1
Case ID: CI-06-02460
COURT LOCH CASE
CASE NUMBER CASE CAPTION FILING DATE TYPE TION TYPE TRIAL
CI-06-02460 (DJ) COMMONWEALTH FNCL SYSTEMS VS JERRY F WELCH 10-MAR-2006 CI CH 38 NJUR
TYPe Party Name End Date
PLTF COMMONWEALTH FINANCIAL SYSTEMS INC,
DEFT WELCH, JERRY F
PATY COBB, PATRICIA A
Filing Date Docket Ent
10-MAR-2006 CERTIFIED TRANSCRIPT - DJ COBB, PATRICIA
FILED BY: PATRICIA A. COBB, ESQ.
INSTRUMENT DATED: 1-03-2006
JUDGMENT AMOUNT: $2894.68
10-MAR-2006 PRAECIPE COBB, PATRICIA
TO ENTER JUDGMENT FOR THE PLAINTIFF, AGAINST THE DEFENDANT, IN THE AMOUNT OF
$2894.68.
CERTIFICATION OF ADDRESS OF PLAINTIFF AND DEFENDANT. FILED BY: PATRICIA A.
COBB, ESQ.
10-MAR-2006 AFFIDAVIT-NON-MILITARY SERVICE COBB, PATRICIA
FILED BY: PATRICIA A. COBB, ESQ.
10-MAR-2006 COPIES WITH RULE 236 NOTICES
MAILED TO DEFENDANT AND DISTRICT JUSTICE ON MARCH 17, 2006.
10-MAR-2006 CAPTION ENTRY IS:
COMMONWEALTH FINANCIAL SYSTEMS, INC. (MA) VS JERRY F. WELCH (MA)
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Commonwealth Financial In the Court of Common Pleas of
Systems, Inc CUMBERLAND County, Pennsylvania
Civil Division
Plaintiff '
VS. NO:
JERRY F WELCH
Defendant NOTICE OF FILING JUDGMENT
Notice is herby given that a money judgment in the above-captioned matter has been entered
against you in the amount of $ a S (?V. j.8 on a 16A
By:
If you have any questions regarding this notice, please contact the filing party:
Edwin A. Abrahamsen & Associates
1729 Pittston Avenue
Scranton, PA 18505
Telephone: (570)-558-5510
(Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236)
Commonwealth Financial Systems, Inc
120 North Keyser Avenue In the Court of Common Pleas of
Scranton PA 18504 CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
vs.
JERRY F WELCH
670 HEMPFIELD HILL RD LOT 32
COLUMBIA PA 17512
NO:
0106-024--
Defendant
vs.
MEMBERS 1 ST FCU
5000 LOUISE DR
MECHANICSBURG PA
Garnishee
Praecipe for Entry of Appearance
Kindly enter my appearance on behalf of Commonwealth Financial Systems, Inc in the
above-captioned matter.
Date: January 7, 2009
SigrIatur
74
Print Name:
Address: 17.
1
Telephone No: (570Y558-5510 Ext 120
Supreme Court ID No: 86285
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PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENT) RULES PA. R.C.P. 3252,3111 (a)
Commonwealth Financial Systems, Inc
120 North Keyser Avenue
Scranton PA 18504
vs.
JERRY F WELCH
670 HEMPFIELD HILL RD LOT 32
COLUMBIA PA 17512
vs.
MEMBERS 1 ST FCU
5000 LOUISE DR
MECHANICSBURG PA
In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
69 - oZU l:lv?l? `
NO:-C+06-924-60
Defendant
PRAECIPE FOR WRIT OF EXECUTION AND
ATTACHMENT
(MONEY JUDGMENT)
Garnishee
To the Prothonotary: TO SATISFY THE JUDGMENT, ISSUE WRIT OF EXECUTON IN THE ABOVE MATTER
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) Against: JERRY F WELCH 670 HEMPFIELD HII L RD LOT 32 COLUMBIA PA 17512
(3) And against: MEMBERS IST FCU 5000 LOUISE DR MECHANICSBURG PA
(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), any and all accounts of the
defendant(s), in the possession of Garnishee, including but not limited to savings account balances; checking account
balances; Certificates of Deposit; Money Market Accounts; contents of Safety Deposit Boxes. Defendant's SSN(s):
168-60-8132;
(5) Judgment Amount $2,894.68
Interest $
Clerks Fee $
Sheriff $
Poundage $
Total $
Date: January 7, 2009
Michael F. Ratchfor , Esquire
Edwin A. Abrah en & Associates, P.C.
Attorney for P tiff
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Commonwealth Financial In the Court of Common Pleas of
Systems, Inc CUMBERLAND County, Pennsylvania
Civil Division
Plaintiff :
vs.
JERRY F WELCH
State of Pennsylvania
County of CUMBERLAND SS:
NO:
Defendant AFFIDAVIT UNDER SOLDIERS AND SAILORS
RELIEF CIVIL RELIEF ACT OF 1940 AS
AMENDED
Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the
above named defendant(s): JERRY F WELCH is(are) not in the military service of the United
States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended;
That the defendant(s): JERRY F WELCH is(are) older than eighteen years of age;
That the employment status of the defendant(s): JERRY F WELCH is(are) unknown.
Commonwealth Financial Systems, Inc
120 North Keyser Avenue In the Court of Common Pleas of
Scranton PA 18504 CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
vs.
JERRY F WELCH NO: CI-06-02460
670 HEMPFIELD HILL RD LOT 32
COLUMBIA PA 17512
Defendant
vs.
MEMBERS 1 ST FCU
5000 LOUISE DR
MECHANICSBURG PA
AFFIDAVIT UNDER SOLDIERS AND SAILORS
RELIEF CIVIL RELIEF ACT OF 1940 AS
AMENDED
Garnishee
State of Pennsylvania
County of CUMBERLAND SS:
Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above
named defendant(s): JERRY F WELCH; is(are) not in the military service of the United States of
America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended;
That the defendant(s): JERRY F WELCH; is(are) older than eighteen years of age;
That the employment status of the defendant(s): JERRY F ?LCH;,k(are)
Michael F
Subscribed befo a is day o jLC"?
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Loeh- NoliVy Pub C p ?
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Esquire
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-293 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COMMONWEALTH FINANCIAL SYSTEMS, INC.,
Plaintiff (s)
From JERRY F. WELCH, 670 HEMPFIELD HILL RD., LOT 32, COLUMBIA, PA 17512
(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 MEMBERS 1sT FCU, 5000 LOUISE DRIVE, MECHANICSBURG, PA - ANY AND ALL
ACCOUNTS OF THE DEFENDANT(S), IN THE POSSESSION OF GARNISHEE, INCLUDING
BUT NOT LIMITED TO SAVINGS ACCOUNT BALANCES; CHECKING ACCOUNT
BALANCES; CERTIFICATES OF DEPOSIT; MONEY MARKET ACCOUNTS, CONTENTS OF
SAFETY DEPOSIT BOXES. DEFENDANT'S SSN(S): 168-60-8132
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $2,894.68
Interest
Atty's Comm %
Atty Paid $56.00
Plaintiff Paid
Date: JANUARY 22, 2009
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
C rtis R. Lon ono a
By:
REQUESTING PARTY:
Name MICHAEL F. RATCHFORD, ESQUIRE
Address: EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C.
1729 PITTSTON AVENUE
SCRANTON, PA 18505
Attorney for: PLAINTIFF
Telephone: 570-558-5510 EXT. 120
Supreme Court ID No. 86285
Deputy
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2009-00293 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
COMMONWEALTH FINANCIAL SYSTEMS
VS
WELCH JERRY F
And now ROBERT BITNER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0015:30 Hours, on the 27th day of January , 2009, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
WELCH JERRY F
hands, possession, or control of the within named Garnishee
MEMBERS 1ST FCU 1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
in the
BRIAN PETERS (MANAGER) ,
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to His .
Sheriff's Costs: So answers:
Docketing .00 Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
V V
01/28/2009
Sworn and Subscribed to
before me this day of By
Deputy Sheri
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RECEIVED
JAN 2 8 2009
Commonwealth Financial Systems, Inc
120 North Keyser Avenue In the Court of Common Pleas of
Scranton PA 18504 CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
VS.
JERRY F WELCH NO: CI-06-02460
670 HEMPFIELD HILL RD LOT 32
COLUMBIA PA 17512 04,A3 M4jjVS lie _ `
Defendant
INTERROGATORIES IN ATTACHMENT
VS.
MEMBERS 1 ST FCU
5000 LOUISE DR
MECHANICSBURG PA
Garnishee .
RE: Execution of Judgment against your depositor JERRY F WELCH SSN # 168-6u-8 t Jz
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 subseqent time, did the Defendant possess
any bank accounts, joint or individual, that were in your custody or control?
Please specify joint or individual account. Please list the legal title of any such
account(s) an dthe pri77 nt holder and if known whether joint account is
entireties property.
2At the time you were served or at any subsequent time, what was the balance and
account number of th bank accounts(s) identified in Interrogatory #1?
3At the time you were served or at any subsequent time, please list the average
daily balance in the past five (5) months for each such account identified in your
answer to Interrogatories number one (1) and two (2) above.
4) At the time you ere served or at any subsequent time, did the bank account(s)
that the Defendant possessed contain fund derived solely from social security
funds and/or disability funds?
N
5) At any time before or after you were served, did the Defendant(s) transfer or
deliver any property or money to you or to any person or place pursuant to your
direction or consent, and if so, what was the consideration therefore?
no
6) At any time after you were served, did you pay, transfer or deliver any money or
property to the Defendant(s) or to any person or place pursuant to the Depositor's
direction or otherwise discharge any claim of the Depositor against you?
no
7) At the time you were served or any subsequent time, did you have, share, or
utilize any safe-deposit boxes, pledges, documents of title, securities, notes,
coupons, receivable, license, or collateral in which there was an interest claimed
by Defendant(s)? n O
8) At the time you were served or at any subsequent time did the Defendant(s)accoount
contain funds deposited electronically on a recurring basis and which are identified
as being exempt from execution, levy or attachment. If so, state the reason for the
exemption, the amount being withheld and the entity electronically depositing
those funds on a recurring basis. n(3
9) At the time you were served or at any subsequent time did the defendant have funds
on deposit in an accoun 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. Section 8123? If so, identify each account. no
9) Identify every other account (not previously noted) titled in the name of the
Defendant(s) in which you believe the Defendant(s) have an interest in whole of
part, whether or not styled as a payroll account, individual retirement account, tax
acocunt, lottery account, partnership account, joint or tenants by entirety account,
insurance account, trust or escrow account, attorney's account, or otherwise.
r) ?(I,-
10) To the extent that you're above answers depend in whole or part on documents,
account records, or other papers or electronic data, describe each in exact detail
(or attach a copy of the same). tL ?Vj?
Edwin A. Abrahamsen & Associates, P.C.
atchford, Esquire
?dston Avenue
:on, PA 18505
558-5510
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 l an 1 c-, S lounq
(Name)
f McMbers 1st Federal Credit WIN
b AAAM '? M 0, qM1
( tie) (Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
jm'?40rw
(SIGNATURE U J
A
MEMBERS 1St
FEDERAL CREDIT UNION
January 28, 2009
Account Number: XXX163
Name: Jerry F Welch, Jr
Address: 904 Colonial Road
Harrisburg, PA 17112
Savings: $0.28
(0.281 Processing Fee
$0.00
Total in account: $0.00
$300.00 Statutory Exemption was not taken out.
Average Monthly Balance
ACCOUNT DEC 2008 NOV 2008 OCT 2008
Savings $5.28 $5.28 $5.28
Tania S Youn
Deposit Operation alyst
SEPT 2008 AUG 2008
$5.28 $5.28
5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • wwwmemberslst.org
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 M(Cks ?nong
(Name)
@PMA'A8 OJUJ*? of UmmemistmawcrWumon
(Title) (Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
(SIGNATU )
c;a
t
Commonwealth Financial
Systems, Inc In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
vs.
JERRY F WELCH
8 HARVESTVIEW APT C NO: 09-293-CIVIL
Mount Joy PA 17552
Defendant
Praecipe to Dissolve the Attachment against
vs. Garnishee
MEMBERS I ST FCU
5000 LOUISE DR
MECHANICSBURG PA
Garnishee
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Dissolve the Attachment against Garnishee.
Thank you,
kfi#el F. Ratchford, EsqXA
ociates, P.C.
s
Ed'wm A. Abrahamser
Lawyer ID # 86285
U ?
Sworn and subscribed before o this day of 20
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J ifer Loeh, tary Public, a'
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