HomeMy WebLinkAbout09-1558IN THE COURT OF COMMON PLEAS OF CUMBERLAND
AMERICAN EXPRESS CENTURION BANK
200 VESEY ST
NEW YORK NY 10285
Plaintiff
VS.
ROBERT SMITH
1256 ALMA LN
MECHANICSBURG PA 17055
Defendant (s)
COUNTY, PENNSYLVANIA
NO. QQ - ksfss ?44-r"
CIVIL ACTION - LAW
Civil Complaint
Filed on behalf of:
Plaintiff, AMERICAN EXPRESS CENTURION BANK
Counsel of record for this party.
Y p o
Date: Uuzo r
DLa?
avid R. Galloway # 326/ ip C. Warholic
Sarah E. Ehasz # 6469/Robert N. Polas, Jr. #201259
Amy F. Doyle #87062
Mann Bracken LLP / Counsel for Plaintiff
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: (717) 303-6700 Fax: (717) 737-9051
Telephone: (717) 303-6700
Counsel for Plaintiff
Cover - General
PACVR/PACVR FILE # 183684733
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK NO.
200 VESEY ST
NEW YORK NY 10285
Plaintiff
VS. '
CIVIL ACTION - LAW
ROBERT SMITH
1256 ALMA LN
MECHANICSBURG PA 17055
Defendant (s)
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 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 or any other claim or relief requested by the Plaintiff.
You may lose money or property 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 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 Referral Service
Cumberland County Bar Assn.
32 S. Bedford St.
Carlisle PA 17013
800-990-9108
CVRNOT/PACP7 FILE # 183684733
• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK NO.
200 VESEY ST
NEW YORK NY 10285
Plaintiff
VS. CIVIL ACTION - LAW
ROBERT SMITH
1256 ALMA LN
MECHANICSBURG PA 17055
Defendant (s)
NOTICIA
Le han demandado a used en la corte. Si used quarere defensas de esas demandas
expuestas en las paginas, siguientes, used tiene viente (20) dias de plazo al partir
de la fecha de lademanda y la notifiation. Used debe presentar una apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus
defensas o sus objeciones a last demandas en corta de su persona. Sea avisado que
si used no se defienda, la corte tomara medidas y psedido entrar una orden contra
used sin previo aviso o notificacion y por cualquier queja o alivio que es pedido
en la peticion de demanda. Used puede perder dinero o sus propledades o otros
derechos importantes para used.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE
EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELEFONO A
LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASSITANCIA LEGAL.
Lawyer Referral Service
Cumberland County Bar Assn.
32 S. Bedford St.
Carlisle PA 17013
800-990-9108
CVRNOS/PACP7 FILE # 183684733
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK . NO. 09- ISS P ( Al'
200 VESEY ST
NEW YORK NY 10285
Plaintiff
VS.
ROBERT SMITH
1256 ALMA LN
MECHANICSBURG PA 17055
Defendant (s)
CIVIL ACTION - LAW
COMPLAINT
AND NOW, comes the Plaintiff, by and through its attorneys and the law firm
of Mann Bracken LLP, and files this Complaint and in support avers as follows:
1. Plaintiff, AMERICAN EXPRESS CENTURION BANK
located at, 200 VESEY ST
NEW YORK NY 10285
2. Defendants, ROBERT SMITH
is/are adult individual(s) with last known address(es) of
1256 ALMA LN
MECHANICSBURG PA 17055
COUNTY OF CUMBERLAND
3. It is averred that Defendant(s) was/were issued an open end credit card
account (hereinafter - Account).
4. At all relevant times material hereto, Defendant(s) has/have been a regular
user(s) of said Account for the purchase of products, goods, and/or for obtaining
services.
5. Defendant(s) was/were provided with monthly statements showing all debits
and credits for transactions on the Account to which there was no bona fide objection
by Defendant(s). A Statement of Account summarizing the Account is attached hereto
as Exhibit "A".
1
PAC101/PACP7 FILE # 183684733
6. Defendant(s) did not object to the above-mentioned statements submitted
by Plaintiff and/or its assignors to Defendant(s).
7. As of the date of this Complaint, the remaining balance due, owing and
unpaid on Defendant's credit card account as a result of the charges made by said
Defendant(s) and/or any authorized users is the sum of $ 31387.57.
8. Interest has accrued on the aforementioned balance at that rate of 6.00°
per annum.
9. As of the date of the filing of this Complaint, the amount of interest which
has accrued is the sum of $ 918.41.
10. Despite reasonable and repeated demands for payment, Defendant(s) has/have
refused and continue to refuse to pay all sums due and owing on the aforementioned
account balance, all to the damage and detriment of the Plaintiff.
11. Plaintiff performed any and all conditions precedent to the bringing of the
this action.
12. The amount in controversy exceeds the jurisdictional amount requiring
compulsory arbitration.
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgmen
in favor of the Plaintiff and against Defendant(s) in the amount of $ 31387.57,
plus interest in the amount of $ 918.41 , plus costs of this action and any other
relief as this Court deems just and reasonable.
Respectfully Submitted,
David R. Gallowal?i #87326 ip C: Warholic #863
Sarah E. Ehasz rr #86469/ o e was; -rr-?r?
Amy F. Doyle #87062
MANN BRACKEN LLP / Counsel for Plaintiff
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011 /
(717) 303-6700
2
PACl02/PACP7 FILE # 183684733
VERIFICATION
The undersigned hereby states that he/she is the attorney for the Plaintiff
who is located outside of this jurisdicition and in order to file the within document
in an expedient and timely manner, he/she is authorized to take this verification on
behalf of said Plaintiff in the within action and verifies that the statements made
in the foregoing Complaint are true and correct to the best of his/her knowledge,
information, and belief, based upon information provided by the Plaintiff.
The undersigned understands that false statements herein are made subject to
the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification
to authorities.
X ? 7
David R. Galloway #8 26/ ip . Warholic 863
Sarah E. Ehasz 469 . Polas, Jr. #201
Amy F. Doyle #87062
Mann Bracken LLP / Counsel for Plaintiff
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: (717) 303-6700 Fax: (717) 737-9051
PAVERF/PACP7 FILE # 183684733
567
EXHIBIT "A"
EIHA (10/09/08)
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Co
Sheriffs Office of Cumberland County
R Thomas Kline mt cnmber4, Edward L Schorpp
Sheriff '° Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy W M of T?* SHERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
03/14/2009 12:35 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 14,
2009 at 1235 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Robert Smith, by making known unto himself, defendant at 1256 Alma Lane
Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him
personally the said true and correct copy of the same.
SHERIFF COST: $33.40 (PAID)
March 16, 2009
2009-1558
American Express Centurion Bnk
VS
SO ANSWERS,
R THOMAS KLINE, SHERIFF
By
r I/ Deputy Sheriff
Robert Smith
C7
.s
-'
rr r 3
CO
c?a
?
117
-4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK NO. 09-1558
200 VESEY ST CIVIL ACTION - LAW
NEW YORK NY 10285
Plaintiff
VS.
ROBERT SMITH
Defendant (s)
PRAECIPE FOR JUDGMENT
Please enter Judgment in favor of Plaintiff and against Defendant(s),
ROBERT SMITH and ,
for failure to answer the Complaint.
( X ) Amount due
TOTAL
$ 32305.98
$ 32305.98 , plus interest and costs
( X ) I certify that the foregoing assessment of damages is for specified
amounts alleged to be due in the complaint and is calculable as a sum certain from
the complaint.
( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or
decree), I certify that a copy of this praecipe has been mailed to each other party
who has appeared in the action or to his/her Attorney of Record.
( X ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the
intention to file this praecipe was mailed or delivered to the party against whom
judgment is to be entered and to his/her Attorney of Record, if any, after the
default occurred and at least ten days prior to the date of the filing of this
praecipe and a copy of the notice is attached.
DATE: 30 U Signature: L /
David R. Gallowa #87326/ ip arholic
Sarah E. Ehasz #86469/Robert N. Po as, r.
Amy F. Doyle #87062
Mann Bracken LLP / Counsel for Plaintiff
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: 866-253-0128 Fax: (717) 737-9051
NOW, 2009, JUDGMENT IS ENTERED AS ABOVE.
/ e I . A-- ", -1) V/- 2.
, n- 0
P?f o honotary/Clerk, Civi visiotZZ 41
By:
Deputy
PRAECJ/PACPDJ FILE # 183684733
iL7
•
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK
200 VESEY ST
NEW YORK NY 10285
Plaintiff
VS.
ROBERT SMITH
Defendant (s)
No. 09-1558
CIVIL ACTION - LAW
CERTIFICATE OF RESIDENCE
PA. R.C.P. 236
I hereby certify that the precise residence of Plaintiff is:
AMERICAN EXPRESS CENTURION BANK
200 VESEY ST
NEW YORK NY 10285
and certify that the last known address of the within Defendant(s) is:
ROBERT SMITH
1256 ALMA LN
MECHANICSBURG PA 17055
U.,L ( ?414/u? -Im
David R. Callow y #87326 ' ip . Warholic
Sarah E. Ehasz #86469 o o as, r.
Amy F. Doyle #87062
Mann Bracken LLP / Counsel for Plaintiff
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: 866-253-0128 Fax: (717) 737-9051
PCRES/PACPDJ FILE # 183684733
REGIONAL OFFICES
TEMPS, A?
AGOURA HILLS, CA
CONCORD, CA
GREENWOOD VILLAGE, CO
WILMINGTON, DE
BOCA RATON, FL
ATLANTA, GA
ROCKVILLE, MD
Nom, MI
CHAMPLIK MN
HUNTERSVILLE, NC
CARBON CITY, NV
ROCHESTER, NY
LAW OFFICES
MANN BRACKEN LLP
Altomr ys in tM Practice of Do& Cabcftn
(A Notional Cakebon AM"" NNwork Firm)
4000 TRINDLE ROAD
SUITE 300
CAMP HILL, PA 17011
THE SUCCESSOR BY MERGER TO WOLPOFF & ABRAMSON, LLP AND ESKANOS 6 ADLER, P.C.
(TOLL FREE)
1-8002703
FACSIMILE (800) 2814028
PLEASE DIRECT OORRESPOND84CE TO CAMP HILL 09gM
183684733
ROBERT SMITH
1256 ALMA LN
MECHANICSBURG PA 17055
Re: AMERICAN EXPRESS
vs. ROBERT SMITH
Docket No. 09-1558
Dear ROBERT SMITH
04/17109
REGIONAL OFFICES
INDEPENDENCE ON
PORTLAND, OR
CAW HILL FA
PITTSSURMH, PA
CLINTON,TN
NASH"AE, TN
HOUSTON, TX
IRVING, TX
SAN ANTONIO. TX
FAiRFAIC VA
RICHMOND. VA
VIRGINIA BEACH, VA
Haas of opwsim:
8 Lm. 0 p.m. EST M•F
File No. 183684733
Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the
Pennsylvania Rules of Civil Procedure.
Sincerely,
Enclosure
CC: ROBERT SMITH
Sarah E. Ehasz ' #86469/
Amy F. Doyle #87082
Mann Bracken LLP / Counsel for Plaintiff
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: 866-253-0128 Fax: (717) 737-9051,
BME)j7
This is an attempt by a debt collector to collect a debt and any information obtained
will be used for that purpose.
NOT10D/PANOTC
a , ft
Lawyer Referral Service
Cumberland County Bar Assn.
32 S. Bedford St.
Carlisle PA 17013
800-990-9108
David R. Gallo y #87326/ 1 ip C. Warholic #863
Sarah E. Ehasz #86469/Rober o as, r. #261
Amy F. Doyle #87062
Mann Bracken LLP / Counsel for Plaintiff
The Successor by Merger.to Wolpoff & Abramson, LLP
and Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: 866-253-0128 Fax: (717) 737-9051
IMPNOT/PANOTC FILE # 183684733
IN THE COURT OF COLON PLEAS OF CUMBERLAND
AMERICAN EXPRESS CENTURION BANK : NO. 09-1558
200 VESEY ST
NEW YORK, NY 10285
Plaintiff
va.
ROBERT SMITH
Defendant (a)
TO: ROBERT SMITH
1256 ALMA LN
MECHANICSBURG PA 17055
DATE OF NOTICE: 04/17/09
I-
IMPORTANT NOTICE
COUNTY, PENNSYLVANIA
YOU ARE IN DEFAULT BECAUSE YOU HAVE'FAILED TO.EVTER 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.
FILED-c =F iCE C
THE
2009 MAY -4 Nil 2, 29
C 1S ?Ji?
* 14• gao y
o t aa?It.?ly
1L1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK NO. 09-1558
Plaintiff
VS. CIVIL ACTION - LAW
ROBERT SMITH
Defendant (s) .
NOTICE OF JUDGMENT
( x ) Notice is hereby given that a Judgment in the above-captioned matter
has been entered against you in the amount of $ 32305.98, plus interest,
on (U[1 2009.
( x ) A copy of all documents filed with the Prothonotary in support of the
within judgment is/are attached.
By:
If you have any questions regarding this Notice, please contact the
filing party.
David R. Gallowf #87326/ Fftpj- C. Warholic
Sarah E. Ehasz #86469/Robert N. Polas, Jr. #201259
Amy F. Doyle #87062
Mann Bracken LLP / Counsel for Plaintiff
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: 866-253-0128 Fax: (717) 737-9051
(This Notice is given in accordance with Pa.R.C.P. 236.)
NOTICE SENT TO:
ROBERT SMITH
1256 ALMA LN
MECHANICSBURG PA 17055
STNTCI/PACPDJ FILE # 183684733
1 J 1
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 TO 3149
AMERICAN EX+PMSS CENTURION BANK
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS.
ROBERT SMITH
Defandant(s)
JUDGMENT NO. 09-1558
PRAECIPE FOR WRIT OF EXECUTI-ON
To the Prothonotary: Please issue the Writ of Execution in the above-captioned
matter, in the amount of $ 32305.98.
(1) Directed to the Sheriff of CUMBERLAND
County, Pennsylvania;
(2) against, ROBERT SMITH
1256 ALMA IN
PA 17055
Defandant(s);
(3) and against MEMBERS FIRST FCU
located at 1000 BRYN MAWR RD
CARLISLE PA 17013-1588
(4) And index this writ
(A) against ROBERT SMITH
Defandant(s) and
(B) against, MEMBERS FIRST FCU
Garnishee(s);
,Garnishee(s),
as a lis pendens against the real property of the Defandant{s) in the name of
the Garnishee(s) as follows: (Specifically describe property)***GARNISH ONLY***
You are directed to attach the property of the Defendant(s) not levied upon in
the possession of MEMBERS FIRST FCU , Garnishee(s)
All accounts including but not limited to all savings, checking and other
accounts, certificates of deposit, notes receivables, collateral, pledges,
documents of title, securities, coupons and safe deposit boxes.
Amount Due: $ 32305.98
Interest From: 05/04/2009 To Be Determined
At an interest rate of 6% per year
Total: $ 32305.98 Plus casts & interest
David R. Gal owa ilip C. Warholic #86341
3a. Ehas #86469/Robert N. Polas, Jr. #201259
Amy F. Doyle #87062
Mann Bracken LLP / Counsel for Plaintiff
Attorneys in the Practice of Debt Collation
46,60 Trindle Road, Suite 3`00, Camp Hill, PA 17011
Telephone: 866-253-0128 Fax: (717) 737-9051
PABGAR/PABANK FILE # 183664733
ILEA.
-
1 1, 2603 "'JA I ''J F`f'i (l'-2, * v
a4. so Po Am
33.40 &air
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114-00 a,
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$ Asa .q0 - Pb Airy
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.50 LC
er.? a4G,Roo
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-1558 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due AMERICAN EXPRESS CENTURION BANK,
Plaintiff (s)
From ROBERT SMITH, 1256 Alma Ln, Mechanicsburg, PA 17055
(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:
MEMBERS FIRST FCU, 1000 Bryn Mawr Rd, Carlisle, PA 17013-1588
All accounts including but not limited to all savings, checking and other accounts, certificates of
deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit
boxes.
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 $32,305.98
L.L. $.50
Interest from 5/04/09 at an interest rate of 6/5 per year - to be Determined
Atty's Comm %
Atty Paid $152.90
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: 6/17109
(Seal)
4t544
C s R. Long o on to
By:
Deputy
REQUESTING PARTY:
Name DAVID R. GALLOWAY, ESQUIRE
Address: MANN BRACKEN LLP
4660 TRINDLE ROAD, SUITE 300
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 866-253-0128
Supreme Court ID No. 87326
i J J
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK
Plaintiff
VS
ROBERT SMITH
Defendant (s)
TO: MEMBERS FIRST FCU
1000 BRYN MAWR RD
CARLISLE PA 17013-1588
No. 09-1558
CIVIL ACTION -,LAW
INTERROGATORIES TO GARNISHEE
RECEIVED
JUN 2 5 2009
PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES
HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF
THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING
INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE
ABOVE REFERENCED DEBTOR(S).
IMPORTANT NOTICES AND INSTRUCTIONS 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. The term "Defendant(s)" means the individual(s) or entity against whom the Writ
Execution was issued.
C. "You" means the main office and all branch offices, representatives, employees
and agents of your organization.
D. By service of the Writ of Execution upon you, all property of the Defendant(s)
subject to attachment which is in your possession, custody or control is attached,
including all property of the Defendant(s) which comes into your possession thereafter.
E. These Interrogatories are considered to be continuing and therefore should be
modified or supplemented as you receive further or additional information.
F. Where exact information cannot be furnished, estimated information is to be
supplied. When an estimate is to be used, it should be identified as such, an explanation
should be given as to the basis on which the estimate is made, and the reason the exact
information cannot be furnished.
G. Where knowledge or information in possession of a party is requested, such request
includes knowledge of the party's agents, representatives, and attorneys.
SS# xxx-xx- Ip 140
INTERROGATORIES TO GARNISHEE
DEFENDANT(S) - ROBERT SMITH
1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time,
state whether or not the Defendant(s) maintains any checking, savings, lines of credit,
certificate of deposit's or other depository accounts with your institution. If so, state
the identification numbers of those accounts, and the amount or amounts the Defendant(s)
has in each account. If the Defendant(s) maintains an of these jointly with any other
person, or persons, give their name and address.
Ja ofachec( daeumeNts
1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct
deposit accounts? If yes, please state the identification numbers of those accounts.
qks maxis I
2. If you are a bank or other financial institution, at the time you were served or at
any subsequent time did the Defendant(s) 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.
0V
3. If you are a bank or other financial institution, at the time you were served or at
any subsequent time did the Defendant(s) have funds on deposit in an account in which funds
on deposit, not including any otherwise exempt funds, did not exceed the amount of general
monetary exemption under 42 Pa.C.S. 8123? If so, identify each account.
0
xX005 Xq0
qts
X xxX15i
X X?((Z
4. TRANSFER OF PROPERTY: 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(s) against you?
no
S. SAFE DEPOSIT BOX: At the time you were served or at any subsequent time, state
whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include
the identification number or other designation of the box or boxes. Include a full
description of the contents and also the amount of cash among those contents. If the
Defendant(s) maintains any of these jointly with any other person or persons give their
full name and address.
no
lYl
6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time,
state whether or not the Defendant(s) own any personal property that was in your possession
and/or control. If so, include a full description of all personal property giving full
value and present location. State also whether or not there are any encumbrances or liens
holders, the present balance of the encumbrance. State where and when encumbrances or liens
was recorded. If the Defendant(s) owns any personal property jointly with any person or
persons, give names and address.
no
7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know
of the existence of any other asset (s) of the Defendant{s) which are not disclosed in the
preceding Interrogatories. If so, please set forth all details concerning those asset'(s).
h0
A. PROP-ERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent
time, did you hold as a fiduciary any property in which any Defendant(s) had an interest?
If so, please describe for each Defendant(s) the nature of the property including its value
and the interest of Defendant(s).
no
9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees
charged by you against the Defendant(s) or account(s) of the Defendant(s) for the completion
of this Answer? If yes, outline the exact amount of any fees due and owing to the garnishee
or the attorney for the garnishee for the preparation of the Answer.
25 Fu- has btw 1-0-keAnt f
David R. Galloway #87326/Philip C. Warholic #86341
Sarah E Ehasz #86469/Robert N. Polas, Jr. #201259
Amy F. yle #87062
Mann Bracken LLP / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: 866-253-0128 Fax: (717) 737-9031
. + •
June 25, 2009
I
MEMBERS 1st
FEDERAL CREDIT UNION
Name: Robert W Smith III
Address: 1256 Alma Lane
Mechanicsburg, PA 17055
Account Number: XXX412
Name on Account:
Savings:
Checking:
Account Number: XXX905
Name on Account:
Savings:
Account Number: XXX400
Name on Account:
Savings:
Account Number: XXX151
Name on Account:
Savings:
Holiday Club:
Checking:
Semoy T Smith
Robert W Smith III (Joint)
$35.85
25.00 Processing Fee
$10.85
$6.05
Robert W Smith III
$0.00
Robert W Smith III
Dallas A Smith (Joint)
$0.66
Emilee A Smith
Robert W Smith III (Joint)
$0.00
$4.01
$0.00
$300.00 Statutory Exemption was not taken out.
:&-t?j "k?ZA61j-
Becky Mars all
Deposit Operations Analyst
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
Becky Marshall
(Name)
to unsworn falsifications to authorities, that he/she is
Deposit Operations Analyst o (Members 1 st Federal Credit Union
(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.
-S?a"ku
(SIG A )
OF
Sheriffs Office of Cumberland County
'' Edward L Schorpp
R Thomas Kline of C11+r1hr,yr
Sheriff ` Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy " Civil Process Sergeant
American Express Centurion Bank Case Number
vs.
Robert Smith 2009-1558
SHERIFF'S RETURN OF SERVICE
06/25/2009 10:19 AM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 25,
2009 at 1020 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Robert Smith, in the hands, possession, or control of the within
named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland
County, Pennsylvania 17013, by handing to Marisol Barber, Assistant Branch 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 June 29, 2009 to Robert Smith at 1256 Alma
Lane, Mechanicsburg, PA 17055.
2009-1558
American Express Centurion Bank
As
Robert Smith
So Answers,
R. Thomas Kline, Sheriff
By
Deputy Sheriff
N
*z
-
' 114
C
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK
Plaintiff
vs.
ROBERT SMITH
Defendant
NO. 09-1558
CIVIL ACTION -LAW
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
To the Prothonotary:
Kindly mark the attachment against the Garnishee, MEMBERS FIRST FCU ,discontinued,
upon payment of your costs only.
Dated: ~ "~ v
Amy )Doyle #87062
Philip C. Wa olic #86341
David R. Galloway #87326
Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259
MANN BRACKEN LLP
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, PC
Attorneys in the Practice of Debt Collection
4660 Trindle Rd., Suite 300
Camp Hill, PA 17011
(866) 253-0128
MB File No. 183684733
r' ~;~ !~
~,
r:
L. `,F~
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,,
~8.0o PD ACT/
C.~,yt 334 ~ ~8
P_T'~` a a9o~ o
F~~i;~_~:~:; !u~
IN THE COURT OF COMMON PL~~ ~ ~ ~ ~ ~,~ ! ~ ; ~ ~
CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK NO. 09-T55~8 = -` '~"'~+~
4315 SOUTH 2700 WEST rL'•,"' ••~''•~-1~~' F•~i~~
SALT LAKE CTTY, UT
Plaintiff
vs. :CIVIL ACTION -LAW
ROBERT SMITH
1256 ALMA LANE
MECHANICSBURG, PA 17055
Defendant
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Plaintiff, American Express Centurion Bank,
with regard to the above matter.
Amy F. Doyle, quire
PA Supreme Court ID 8 62
Doyle Legal Services, LLC.
204 St. Chazles Way, Unit E#177
York, PA 17402
717-812-1672
877-202-9420
206-203-3878 (facsimile)
Counsel for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK NO. 09-1558
4315 SOUTH 2700 WEST
SALT LAKE CITY, UT
Plaintiff
vs. :CIVIL ACTION -LAW
ROBERT SMITH
1256 ALMA LANE
MECHANICSBURG, PA 17055
Defendant
CERTIFICATE OF SERVICE
The undersigned does hereby certify that a copy of the foregoing
Entry of Appeaz~nce has been served upon the Defendant, by First Class Mail,
Postage Pre-Paid, a copy thereof on this day of February, 2010, to:
ROBERT SMITH
1256 ALMA LANE
MECHANICSBURG, PA 17055
Amy F. Doyle, qu
PA Supreme Court ID 87062
Doyle Legal Services, LLC.
204 St. Charles Way, Unit E#177
York, PA 17402
717-812-1672
877-202-9420
206-203-3878 (facsimile)
Counsel for Plaintiff
~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson , ;,~__~-.,
Sheriff ''- ~ ~ - ;i:~iY
~~t~rY~M ui ~au;~~a~~,~~~t4
Jody S Smith ,,
Chief Deputy ~~, ~ i .. , L ~ FS i C~' ~
Edward L Schorpp Lii`~t ~ 'viY
Solicitor n~~;~E ~ - ~;~~ - -
American Express Centurion Bank
vs.
Robert Smith
Case Number
2009-1558
SHERIFF'S RETURN OF SERVICE
06/25/2009 10:19 AM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 25,
2009 at 1020 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Robert Smith, in the hands, possession, or control of the within
named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland
County, Pennsylvania 17013, by handing to Marisol Barber, Assistant Branch 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 June 29, 2009 to Robert Smith at 1256 Alma
Lane, Mechanicsburg, PA 17055.
05/25/2010 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: $87.94
May 25, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF f
4
tt '~,!,~~r' ,.
S aron R. Lantz
(~i Cou+i}pSuite Shen`F. ~fec~csoft. Inr
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
American Express
Centurion Bank
PLAINTIFF
VS.
Judgment No. 09-1558
ROBERT SMITH
DEFENDANT(S) PRAECIPE FOR WRIT OF EXECUTION
To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $32,305.98
(1) Directed to the Sheriff of CUMBERLAND County, Penna.;
(2) against ROBERT SMITH .?
1256 Alma Lane ,-
Mechanicsburg PA 17055
cz?
Defendant(s); '.
=:;o
-
(3) and against MEMBERS 1ST FCU 1 r-
located at 1711 SPRING ROAD
-1
CARLISLE, PA 17013 Garnishee(s); "
5; It
(4) And index this writ Z7
-;
(a) against ROBERT SMITH J
Defendant(s) and
(b) against MEMBERS 1ST FCU, Garnishee(s),
as a lis pendens against real property of the defendant(s) in name of Garnishee(s) as follows: (Specifically Describe Property)
****GARNISH ONLY****
You are directed to attach the property of the Defendant(s) not levied upon in the possession of MEMBERS I ST FCU, Garnishee(s)
All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral,
pledges, documents of title, securities, coupons and safe deposit boxes.
Amount due: $32,305.98
Interest From: May 4, 2009 To Be Determined
At an interest rate of 6% per year
Total: $32,305.98 Plus costs & interest (total includes post judgment credits).
Amy F. oyle,
PA Supreme Court ID 87062
Doyle Adler, LLC/ Counsel for Plaintiff
11 East Market St., Suite 102
ek* i9 ?? York, PA 17401
y ?? Jet1
33 717-885-0718 / 877-202-9420 Fax: 206-203-3878
4
yD
5 /'7 . ?V
06
Wo
0`70,!q "
a- 06 fir, &-
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-1558 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due American Express Centurion Bank Plaintiff (s)
From Robert Smith 1256 Alma Lane Mechanicsburg, PA 17055
(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 1" FCU 1711 Spring Rd. Carlisle, PA 17013
GARNISHEE(S) as follows:
All accounts including but not limited to all savings, checking and other accounts, certificates of
deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit
boxes.
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$32,305.98
L.L.
Interest from May 4, 2009 to be determined At an interest rate of 6% per year
Atty's Comm %
Atty Paid $270.84
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: November 2, 2011
(Seal)
REQUESTING PARTY:
Name Amy F. Doyle, Esq.
Address: Doyle Adler, LLC
11 East Market St., Suite 102
York, PA 17401
Attorney for: PLAINTIFF
Telephone: 717-885-0718 / 877-202-9420
Fax: 206-203-3878
Supreme Court ID No. 87062
aW4-eL?
David D. Buell, Prothonotary
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
American Express NO. 09-1558
Centurion Bank
PLAINTIFF AWED
NOV 07 2011
VS.
ROBERT SMITH
^-
DEFENDANT(S)
ksw is
INTERROGATORIES TO GARNISHEE ,
a
(Z; [4
TO: MEMBERS 1 ST FCU
> c-) :
1711 SPRING ROAD CD
,
CARLISLE, PA 17013
PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING
INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY
REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND
FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S
EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S).
IMPORTANT NOTICES AND INSTRUCTIONS 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. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was
issued.
C. "You" means the main office and all branch offices, representatives, employees and agents of your
organization.
D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to
attachment which is in your possession, custody or control is attached, including all property of the Defendant(s)
which comes into your possession thereafter.
E. These Interrogatories are considered to be continuing and therefore should be modified or
supplemented as you receive further or additional information.
F. Where exact information cannot be furnished, estimated information is to be supplied. When an
estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which
the estimate is made, and the reason the exact information cannot be furnished.
G. Where knowledge or information is possession of a party is requested, such request includes
knowledge of the party's agents, representatives, and attorneys.
INTERROGATORIES TO GARNISHEE
DEFENDANT(S) - ROBERT SMITH
1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state
whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other
depository accounts with your institution. If so, state the identification numbers of those accounts, and the
amount or amounts the Defendant(s) has in each account. If the Defendant(s) maintains any of these jointly
with any other person, or persons, give their name and address. cav"
1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit
accounts? If yes, please state the identification numbers of those accounts.
0G
2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did
the Defendant(s) 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.
3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did
the Defendant(s) have funds on deposit in an account in which funds on deposit, not including any otherwise
exempt funds, did not exceed the amount of general monetary exemption under 42 Pa.C.S. 8123? If so, identify
each account.
11
4. TRANSFER OF PROPERTY: 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(s) against you?
C;
5. SAFE DEPOSIT BOX: At the time you were served or at any subsequent time, state whether or not
the Defendant(s) maintains any safe deposit box or boxes. If so, including the identification number or other
designation of the box or boxes. Include a full description of the content and also the amount of cash among
those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full
name and address. y]
6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state
whether or not the Defendant(s) own any personal property that was in your possession and/or control. If so,
include a full description of all personal property giving full value and present location. State also whether or not
there are any encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with
any person or persons, give names and address.
n L
7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the
existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so,
please set forth all details concerning those asset(s) and state the reason for the exemption, the amount being
withheld under each exemption, the amount of funds in each account, and the entity electronically deposition
those funds on a recurring basis. no
8. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did
you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each
Defendant(s) the nature of the property including its value and the interest of Defendant(s).
n
1 l0
9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees
charge by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer? If
yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the
preparation of the Answer.
wj-tVh?l,
Amy F. Do le, Esquire
PA Suprem ourt ID 87062
Doyle Adler, LLC
11 East Market St., Suite 102
York, PA 17401
717-885-0718/877-202-9420
206-203-3872 (facsimile)
Counsel for Plaintiff
ri(l' A
MEMBERS 1St
FEDERAL CREDrr UNION
November 4, 2011
Robert W Smith III
1256 Alma Lane
Mechanicsburg, PA 17055
Review Dates (60 Days): September 6, 2011 - November 4, 2011
Total Writ of Execution: $32,578.82
Cumberland County Docket Number: 09-1558
File # 09-1558
Account Number: XXX400-0000
Name on Account: Robert W Smith III
Dallas A Smith (Joint)
Savings: $5.00
-5.00 (Membership Fee)
$0.00
Account Number: XXX412-0000
Name on Account: Semoy T Smith
Robert W Smith III (Joint)
Savings: $5.00
-5.00 (Membership Fee)
$0.00
Account Number: XXX412-0011
Name on Account: Semoy T Smith
Robert W Smith III (Joint)
Checking: $0.00
$300.00 Statutory Exemption was not taken out.
Tania S. Youn
Deposit Operations Llyst
Rev: 06/11
5000 Louise Drive - P.O. Box 40 - Mechanicsburg, Pennsylvania 17055 - (800) 283-2328 - www.memberslst.org
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is Ta n i a S. Young
(Name)
Deposit Operations Analyst of Members 1st Federal Credit Union
(Title) (Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
JMWA dV
(SIGN
r) (I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
AMERICAN EXPRESS CENTURION BANK,
Plaintiff
VS.
ROBERT SMITH,
Defendant
No. 09-1558
M
_
C,
52: -
VS.
MEMBERS 1 ST FCU,
Garnishee
PRAECIPE TO DISSOLVE ATTACHMENT
TO THE PROTHONOTARY:
Please dissolve the writ of attachment filed against the Garnishee in the above-
entitled matter, without prejudice.
E e
Amy F. eC
PA Supre ID 87062
Doyle Adler, 11 East Market St, Ste 102
York, PA 17401
717-885-0718
877-202-9420
206-203-3872 (facsimile)
Counsel for Plaintiff
File # 10003275
OtntiV°4$`°?aHv?
C0r aoae
?.?-?lo? ga3
SHERIFF'S OFFICE OF,CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
. .
-Y
Y.
OFFiCEOF G?.
FILED-OFFICE
_fr i HE PROTHONOTAR?'
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
American Express Centurion Bank
vs.
Robert Smith
SHERIFF'S RETURN OF SERVICE
2011 NOV 17 AM 10: 46
CUMBERLAND COUNTY
PENNSYLVANIA
Case Number
2009-1558
11/04/2011 , 04:26 PM - Gerald Worthington, Deputy, who being duly sworn according to law, attached as herein
commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands,
possession, or control of the within named garnishee, Members 1 st FCU at 1711 Spring Road, North
Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Zach Chini - Teller,
personally three true and attested copies of the Writ of Execution and made the contents there of known
to him.
The writ of execution and notice to defendant was mailed on November 7, 2011 to Robert Smith at 1256
Alma Lane, Mechanicsburg, PA 17055.
11/15/2011 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: $86.70 SO ANSWERS,
November 15, 2011 WON R ANDERSON, SHERIFF
(Ci CountySuite Shenff, l eloosoft Inc