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HomeMy WebLinkAbout09-1164Our File No.: 196342 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. VANCE E BRETZ 317 STATE ST ENOLA, PA 17025-3179 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY / ?' NO.: 09 " /14- nn C.:t uiC. L F-R.*v 1, 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 fiuther 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 Our File No.: 196342 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. VANCE E BRETZ 317 STATE ST ENOLA, PA 17025-3179 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 9- l I G `f Cr, -Q tom.. 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 VANCE E BRETZ, an adult individual residing at 317 STATE ST ENOLA, PA 17025-3179. 3. Plaintiff, ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC, is the Assignee and Successor in Interest of Account #5254780001128486; 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 $3,956.36. 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 $3,956.36 and requests this Court award Plaintiff attorney's APOTHAKER Attom A Law Firm E? BY: David J. ? Dated: 2/19/2009 and costs to the extent permitted by applicable law. 'SOCIATES, P.C. Plaintiff in Debt-Collectioi Esquire Our File No.: 196342 VERIFICATION C'nUP SnU ( GIMI hereby states that I am y} }rte d?Pgpn?iy?_ 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 coned to the best of my knowledge, information, and belief The undersigned mnderstands that the statements therein are made subject to the penalties of 18 Pa.C.SA. 4904 relating to unswom falsification to authorities. DATE: ATLANTIC CREDIT & FINANCE INC. V. VANCE E BRETZ 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: I . Plaintiff's principal business consists of purchasing charged off receivables. 2. The Defendant defaulted on HSBC Account No. 5254780001128486. Said Account was charged off on 4/30/2008 and subsequently sold to Atlantic Credit & Finance, Inc with a balance of $3773.38. 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 was9/1/2007 in the amount of $ 100.00. After application of all payments, credits, adjustments, and lawful offsets, if any, there is still a balance due and owing on this indebtedness of $3,773.38. 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 convect to the best of my knowledge and belief. By: Carol Jodrey Authorized R sentative Subscribed and sworn before me, Dec Gray THIS COMMUNICATION IS FROM A DEBT COLLECTOR ??eykel177?11y? .4 1 ?a ?" I#tr#MF?X?t AFwthaker & Assmintes: CGAFF- 3525184 - 0001698 * Ak*lnin*;Ap iA"x&K%f PO Box 13386 • Roanoke, VA 24033 Account Statement Original Creditor Account Number: 5254780001128486 VANCE E BRETZ 317 STATE ST Original Creditor: HSBC ENOLA, PA 17025-3179 9? Original Creditor Last Pay Date: 91112007 Original Creditor Last Payment Amount: $ 100.00 Original Creditor Charge Off Date: 413012008 ACF 1D Number: 3525184 SSN: XXX-XX-6552 CONFIDENTIAL PROPEWrY of ATLAN rtC CRFDrr & F TNA.NcF, INC. JU rZ, rt ? a1 a Rmj N s t"? N 'i r'rl r.? all J ? 5 C6013 SHERIFF'S RETURN - REGULAR CASE NO: 2009-01164 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS BRETZ VANCE E SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BRETZ VANCE E was served upon DEFENDANT at 317 STATE ST the , at 0012:28 HOURS, on the 28th day of February-, 2009 ENOLA, PA 17025-3179 T.7?rm TT T nr.T1_1TT by handing to ADULT IN CHARGE 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 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 03/02/2009 APOTHAKER & SOC TES By: day ep y Sheriff of A. D. . ?, ? ? t- caD .? ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1164 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff (s) From VANCE E. BRETZ, 6 EAST GREEN STREET, 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: M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 WOODFOREST NATIONAL BANK, 60 NOBLE BLVD., 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 $3,773.38 L.L.$.50 Interest $90.56 Atty's Comm % Atty Paid $165.50 Plaintiff Paid Due Prothy $2.25 Other Costs Date: 3/16/2012 (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Daa ?'h RaYL David D. Buell, Prothonotary qJx: AW'2'e'p. - ( Deputy 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. Civil Action No. 09-1164 c -° $kkl?R VANCE E BRETZ C L7?P1'1 J'? Q ? • . 1. : ? d, ' Defendant(s) Cm =' h Sir ?iSle P? LSO! 3 ? I W r- - sC:, - M&TBANK I •? ? ip0 colole ,k-?Ivd-, lPA WOODFORESTNATIONALBANK C) n ? Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION -c rte ` TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against VANCE E BRETZ , Defendant 3. against M & T BANK, WOODFOREST NATIONAL BANK,, Garnishee 4. Judgment Amount $ $4,242.79 .. RJ Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): U6. SO Pd IL $ $469.41 C§)n?q,?Pd y1. 5o CYF -7 ?-, SO 11 11 114. 00 It It ?. U ill $ $90.56 $ $3,863.94 WELTMAN, WEINBERG & REIS CO., L.P.A. By: W ?f William T. Molczan, Es e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 t.0 at -bw 4. +Ot. Sd CL? e k. 6 ) 0405R I PV a-712S(1a WWR No. 9412708 0jf rt o6 Er Tssuccl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff vs. VANCE E BRETZ Defendant(s) M&TBANK WOODFOREST NATIONAL BANK Garnishee(s) No. 09-1164 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 WWR No. 9412708 -0/] INTERROGATORIES IN ATTACHMENT (Q _ f 1(o4 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 funds on deposit for checking or savings accounts and certificates of deposit)? 14c) r'1cLoLA ? C-- , rr W ?v _ 1 a. If the answer to Interrogatory I is in the affirmative, state the following: the at of money you owe or owed to defendant, and, if such money is in the form of a fund, the pre4 oc?n titefe- Ord 'en Pi* r*6er? the terms, face amount and amount you owe or owed to defendant on each of such negot instruments and the present location of each of such instruments; the amount or amounts thdend-ant c lBU-tts or claimed that you owe or owed to him; and the nature and amount of each of such liabilities.; N > C= 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. r\11A 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? N 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? IV / 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any erson or place pursuant to your directions or consent and if so what was the consideration thereof? Iv 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? t4/A 7. 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 amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 111A W WR No. 9412708 MAR 2 3 2012 V6r r- - 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 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. ?h 1 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. * (/ N. 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? ?V 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the accc ount. /j rA WELTMAN, WEINBERG & REIS CO., L.P.A. By. __4,,Z / ?4 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 WWR No. 9412708 MAR 2 3 2012 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 e???A,?Ik , (Name) Vje sh? ° L ' - , arms ee erein, (Title) (Company) that he/she is 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. (SIGNATURE) Woodforest National Bank Legal Dept Bryan Abraham Jessica Slack Cedrick Frazier '215231 Grogans Mill Rd., Suite 100 The Woodlands, TX 77380 832-375-2898 Phone 832-375-3071 Fax MAR 2 3 2012 WWR No. 9412708 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4100 t?„ ?i ?iur?Lc.l N E rv Jody S Smith Chief Deputy Richard W Stewart Solicitor Atlantic Credit & Finance Inc. Assignee from HSBC Case Number vs. Vance E Bretz 2009-1164 SHERIFF'S RETURN OF SERVICE 03/23/2012 10:25 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 23, 2012 at 1025 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Vance E. Bretz, in the hands, possession, or control of the within named garnishee, Woodforest National Bank, 60 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Ina Dimitrova, 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. 03/28/2012 12:15 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2012 at 1215 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Vance Bretz, 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 Yvette Shurgart, 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 29, 2012 to Vance E. Bretz at 6 E Green Street, Camp Hill, PA 17011. SO ANSWERS, March 29, 2012 RON R ANDERSON, SHERIFF William Cline, Deputy IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff vs. VANCE E BRETZ Defendant(s) M & T BANK WOODFOREST NATIONAL BANK Garnishee(s) . ? R.3 Civil Action No. 09-1164 „ M r.. ?- o C2 "`- -+ T= M . C:, rv ?. TO: M & T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013 WOODFOREST NATIONAL BANK, 60 NOBLE BLVD, CARLISLE, PA 17013 RE: VANCE E BRETZ, 6 E GREEN ST, CAMP HILL, PA 17011 Suggested Reference No.: XXX-XX-6552 XXX-XX- 4° ?SLUQrs 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. WWR No. 9412708 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 funds on deposit for checking or savings accounts and certificates of deposit)? files 1 a. If the answer to Interrogatory 1 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. 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. nL 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? Y1 ti? 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? I,-\ u 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? r1tJ 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? -? V 7. 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 amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. t-'\(_, WWR No. 9412708 . 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. 9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. 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. r, o Y`om'. 11. 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 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. WELTMAN, WEINBERG & REIS CO., L.P.A. .ice By: i? William T. Molczan, Esquire 61 PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 9412708 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 ? ,'.?,? h <, (Name) l? of -4 1 lhanr , garnishee herein, (Title) (Company) that he/she is 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. 202 (SIGNATURE) VAR 2 9 CATHY 8) T n , a s WWR No. 9412708 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9412708 ATLANTIC CREDIT AND FINANCE, INC, ASSIGNEE FROM HSBC VS. VANCE E BRETZ and ?7 Olt I ONOTAR Attorney for Plaintiff(s) 201;2 APR 16 AM 11: 3? CUMBERLAND COUNTY' PE'NINSYLVANIA Cumberland County Court of Common Pleas NO. 09-1164 M&T BANK AND WOODFOREST NATIONAL BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), M&T BANK AND WOODFOREST NATIONAL BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. .1 By James Attorr I hereby certify that the foregoing is a true and correct statement of This statement is made subject to the penalties of 18 Pa.C.S. 4904 armbrodt, Esquire r Plaintiff ove case. t to unsworn falsifications to authorities. ,,u+ * 9, sb pd aAy 0, t1-k- /6 1is3s?g 11 P-# 01 3TS3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY anny R Anderson Sheriff ?, :i tiunilrtjl,, Jody S Smith ° Chief Deputy 2 2 H Richard W Stewart Solicitor Atlantic Credit & Finance Inc. Assignee from HSBC Case Number vs. Vance E Bretz 2009-1164 SHERIFF'S RETURN OF SERVICE 03/23/2012 10:25 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 23, 2012 at 1025 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Vance E. Bretz, in the hands, possession, or control of the within named garnishee, Woodforest National Bank, 60 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Ina Dimitrova, 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. 03/28/2012 12:15 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2012 at 1215 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Vance Bretz, 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 Yvette Shurgart, 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 29, 2012 to Vance E. Bretz at 6 E Green Street, 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: $144.48 SO ANSWERS, October 19, 2012 RON R ANDERSON, SHERIFF a.a?Pol- CaI "Sv LL 1"al-