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HomeMy WebLinkAbout09-2790i 2056708 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDOI,& WEINBERG, P.C. BY:'/FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ASSET ACCEPTANCE LLC ASSIGNEE OF HSBC BANK NEVADA, N.A. 28405 VAN DYKE AVENUE Warren MI 48093 VS. MICHAEL E FRENGEL 7 INDEPENDENCE DRIVE SHIPPENSBURG PA 17257 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : OQ - a-796 C,V/l?exwrt 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 JUDGEMENT 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 I COMPLAINT IN CIVIL-ACTION 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 2. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the original creditor under the terms of which the original creditor agreed to extend to defendant(s)the use of original creditors credit facilities. 3. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the original creditor for the use of said credit card. 4. The defendant (s) received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the original creditor. A true and correct copy of the Statement of Account, if available, is attached hereto as Exhibit "A". 5. All the credits to which the defendant (s) is entitled have been applied and there remains a balance due as of 3/9/09 in the amount of $1,190.65. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. I 7. Defendant's last payment on account was made on 12/20/07. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,190.65 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EI ERG, ESQUIRE JOEL M. FLI ESQUIRE Attorney for Plaintiff P01A.DB V VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in malting this verification. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements. Name IOR-M {RANCHIDA ,W f6 09 STATE OF MICHIGAN ) ss COUNTY OF MACOMB ) ASSET ACCEPTANCE, LLC Plaintiff, vs MICHAEL E FRENGEL Defendant, I THOMAS TRANCHIDA AFFIDAVIT ) being first duly sworn deposes and states: That I am the Supervisor of ASSET ACCEPTANCE, LLC a Limited Liability company organized and existing under the laws of the State of Delaware and doing business at P.O. BOX 2041, WARREN, MI 48090. That there is justly due and owing on the account, the sum of $1182.40 representing the charged off amount and interest. That the said account originally with HSBC BANK NEVADA, N.A./, account number 6011380000678318, has been purchased by ASSET ACCEPTANCE, LLC, who now owns said account and has all rights connected therewith including the right to institute this action. Dated this 06th day of January, Supervisor Subscribed and sworn to before me, a Notary Public for the State of Michigan, the 06th of January, 2009 as certified by y and as set forth immediately below. Notary bi ' yr?••,? row 5 38002387 1064 GORDON & WEINBERG 0 0 3 8 0 0 2 3 8 7 M1s i i-t ASti Rt9-RS?... a. ASSET ACCEPTANCE LLC P.O. Box 2036 Warren, MI 48090 MICHAEL E FRENGEL 7 INDEPENDENCE DR SHIPPENSBURG,PA 17257 ACCOUNT NUMBER CURRENT BALANCE 6011380000678318 $1182.40 STATEMENT DATE DUE DATE JAN 06 2009 DUE ACCOUNT NUMBER DATE OF LAST PAYMENT 6011380000678318 12/20/07 DATE REFERENCE NO ACCOUNT INFORMATION BALANCE DUE JAN 06 2009 38002387 BALANCE DUE $1182.40 ASSET ACCEPTANCE LLC, A LIMITED LIABILITY COMPANY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF DELAWARE, ASSIGNEE OF 6011380000678318 P.O. Box 2036, Warren, MI 48090 DATE OF DELINQUENCY PURCHASED ON CHARGE OFF AMOUNT* INTEREST RATE 01/02/08 08/04/08 $1158.64 4.00% SERVICE ADDRESS (IF APPLICABLE) INTEREST DUE AS OF JAN 06 2009 $23.76 *For purposes of this Statement only, Charge Off Amount reflects credits for payments received by Asset, if any. THIS COMMUNICATION IS FROM A DEBT COLLECTOR e10638002387 4 GORDON & WEINBERG 0 r. ?T (.", to I1 tI 2009 Fi,."' -4 Fil l 2: 19 *?E . so Pb Pl-N C(?'? '1'108(0 Sheriffs Office of Cumberland County R Thomas Kline 4 jr ,at "ItIllb, t J?O Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy ! F ` "E = RIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/11/2009 08:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on April 11, 2009 at 2030 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael Frengel, by making known unto Michael Frengel, at 7 Independence Drive, Shippensburg, Cumberland County, Pennsylvania, 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $46.00 May 12, 2009 SO ANSWERS R THOMAS KLINE, SHERIFF uty Sheriff 2009-2790 Asset Acceptance v Michael Frengel r Ste'? •-7'j ti CID s GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 x:056708 ASSET ACCEPTANCE LLC ASSIGNEE OF HSBC BANK NEVADA, N.A. vs. MICHAEL E FRENGEL COURT OF COMMON PLEAS CUMBERLAND COUN'T'Y DOCKET NO. 09-2790 PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT OF DAMAGES VERIFICATION OF ADDRESS AND NON-MIL]:TARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal :?1,158.64 Less: Payments on Account ( $.00) Total: t~1,158.64 Understanding the false statements made herein are. subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: ASSET ACCEPTANCE LLCASSIGNEE OF HSBC BANK NEVADA, N.A. and that the last known address of defendant, MICHAEL E FRENGEL, 7 INDEPENDENCE DRIVE, SHIPPENSBURG PA 17257. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within t:he coverage of the Soldiers and Sailors Civil Relief Act and is I;are) over 18 years of age. ~~ ~" ~~~ AND NOW, this ~ day of 2009 Judgment 1 is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $1,327.85 as per the above certification. C~1 q~~--~~l Prothonotary CORDON & WEINBER P.C. BY: FREDERIC I. EI 3ERG, ESQUIRE JOEL M. FLI SQUIRE Attorney for Plaintiff 2056708 CORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FUNK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ASSET ACCEPTANCE LLC ASSIGNEE OF HSBC BANK NEVADA, N.A. vs. MICHAEL E FRENGEL TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 09-2790 NOTICE OF INTENTION TO TAKE DEFAULT MICHAEL E FRENGEL 7 INDEPENDENCE DRIVE SHIPPENSBURG PA 17257 DATE OF NOTICE/FECHA DEL AVISO: June 2, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A. WRITTEN APPEARANCE PERSONALLY OR BY AN 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 ENTERE',D 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 MA.Y 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 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 CORDON & WEINBERG, P.C. ~ / BY: FREDERIC'I: WEINBERG, ESQUIRE JOEL M;~ FUNK, ESQUIRE P10D-2 ~-t, ,.,~ -;a, I ~' i 1 J ~ ~. ~ . „~ C` ' r, ~".~ ~..' ~: ~(4:. - •- :. .... b.. ~ ~. ~~~i. ~6 ~~J ~,~~ D ~~/ 3~~ >Uo~~ ~ ~l~~Cr' ~ ' 2056708 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ASSET ACCEPTANCE LLC ASSIGNEE OF HSBC BANK NEVADA, N.A. vs. MICHAEL E FRENGEL 7 INDEPENDENCE DRIVE SHIPPENSBURG PA 17257 COURT OF COMMON PLEAS CUMBERLAND COUN'T'Y DOCKET NO. 09-2790 NOTICE Pursuant to Pa.R.Civ.P. 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. L~ Judgment by Default $1,156.64 ~l Money Judgment $ LL Judgment on Award of Arbitrators$ ~l Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 PROTHONOTARY /~~ /0%~/~9 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 4841351-0500 2056708 c? -"3 3: 23 Nc PENN iYLVr' N A? ASSET ACCEPTANCE LLC ASSIGNEE OF HSBC BANK NEVADA, N.A. 28405 VAN DYKE AVENUE Warren MI 48093 VS. MICHAEL E FRENGEL 7 INDEPENDENCE DRIVE SHIPPENSBURG PA 17257 and Sovereign Bank 921 Cavalry Road Carlisle, PA 17013 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-2790 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against MICHAEL E FRENGEL defendant(s)and (2) against Sovereign Sank (3) AMOUNT DUE INTEREST from June 25, 2009 COSTS Prothonotary fee Sheriff fee (4) Less: Payments on Account garnishee(s) $1,158.64 $84.66 ( $.00) !J ta4. 5o P 4 Ami/ 410.00 Cam' `18.5o u 14.(:)o a.5 „ 41&.S.,50 ` PO A7tY ?a. oo Duero TOTAL Cl la9945 FREDERIC I. WEI BERG ESQUIRE JOEL M. FLINK, S RE Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-2790 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSET ACCEPTANCE, LLC, Assignee of HSBC BANK NEVADA, N.A., Plaintiff (s) From MICHAEL E. FRENGEL, 7 Independence Drive, Shippensburg, PA 17257 (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: SOVEREIGN BANK, 921 Cavalry Road, 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 $1,158.64 Interest from 6/25/09 -- $84.66 Atty's Comm % Atty Paid $165.50 Plaintiff Paid Date: 9/8/10 (Seal) L.L.$.50 Due Prothy $2.00 Other Costs is/ David D uell, Prot By: REQUESTING PARTY: Name FREDERIC I. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, PC 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Deputy Supreme Court ID No. 41360 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy _'? FILED-OFFICE rflFFICE R 20 14 SEP 2 1 P1 2: 26 Richard W Stewart Solicitor r" t11 331ERi,..Ai' D COUNT`" Asset Acceptance LLC, Assignee of Home Depot/Citibank and Assignee of Case Number vs. Michael E. Frengel 2009-2790 SHERIFF'S RETURN OF SERVICE 09/20/2010 09:14 AM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 20, 2010 at 0912 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Michael E. Frengel, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania, 17013, by handing to Julie Myers, 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 September 21, 2010 to Michael E. Frengel at 7 Independence Drive, Shippensburg, PA 17257. SO ANSWERS, September 21, 2010 RON R ANDERSON, SHERIFF -2?' I'Z4?2 Mic ael Barrick, De c,'CountySir.:r: SFenft Te!eos;Nt. l..,;; 4 CORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FU NK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ASSET ACCEPTANCE LLC ASSIGNEE OF HSBC BANK NEVADA, N.A. 28405 VAN DYKE AVENUE Warren MI 48093 vs. MICHAEL E FRENGEL 7 INDEPENDENCE DRIVE SHIPPENSBURG PA 17257 and Sovereign Bank 921 Cavalry Road Carlisle, PA 17013 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-2790 aNSc~~s -ro INTERROGATORIES IN ATTACHI~NT TO: Sovereign Bank - GARNISHEE C~l?~ ~~~ -7 ~~~~ ~~ ~~ ''t;~3~~2Lfi;zD CUJT'~ ~~;~~Y~.{!~~lA You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so my result in judgment against you. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? NO 2. YES 3. NO 4. NO 5. At the time you were served or was there in your possession, the joint possession, custody and one or more other persons nature owned solely or in part SEE ATTACHED At the time you were served or did you hold legal title to an owned solely or in part by th defendant held or claimed any at any subsequent time custody or control or in or control of yourself any property of any by the defendant. at any subsequent time y property of any nature e defendant or in which interest. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had an interest? At any time before or after you were served did the defendant(s) transfer or deliver any property 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 his(her, their) direction or otherwise discharge any claim of the defendant(s) against you? NO 7. 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 of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. NO 8. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant(s) 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. 58123? If so, identify each account. NO 9. How much is the value of any property in your possession belonging to the defenda t(s)? SEE ATTACHED FREDERIC I. WE NBER ESQUIRE JOEL M. FLINK, IRE Attorney for Plaintiff ~~(~~ DATED: ANSWERS TO INTERROGATORIES Account # 3531004069 Balance: $0.00 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $0.00. Account Holder: Michael E Frengel Beth A Frengel 7 Independence Dr Shippensburg, PA 17257-8218 VERIFICATION I, John S. Gomes, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank 'John S. Gomes C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1N RE: Asset Acceptance LLC Assignee of HSBC Bank Nevada, N.A. vs. Michael E Frengel CERTIFICATE OF SERVICE hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Frederic I. Weinberg, Esquire Gordon & Weinberg, P.C. 1001 E Hector Street, Suite 220 Conshohocken, PA 19143 Service by certified mail addressed as follows: Michael E Frengel 7 Independence Dr Shippensburg, PA 17257-8218 J n S. Gomes C.O.P. Lead Specialist Sovereign Bank MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 September 30, 2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Asset Acceptance LLC Assignee of HSBC Bank Nevada, N.A. vs. Michael E Frengel CERTIFICATE OF SERVICE hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption have served a copy thereof on each of the fol{owing persons in the manner indicated below: Service by first class mail addressed as follows: Frederic I. Weinberg, Esquire Gordon & Weinberg, P.C. 1001 E Hector Street, Suite 220 Conshohocken, PA 19143 Service by certified mail addressed as follows: Michael E Frengel 7 Independence Dr Shippensburg, PA 17257-8218 J n S. Gomes C.O.P. Lead Specialist Sovereign Bank MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 September 30, 2010 ~_ ..~ s s ~_ .~ ~_ .~ ~_ CORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector. Street, Ste 220 Conshohocken, PA 19428 484/351-0500 ASSET ACCEPTANCE LLC ASSIGNEE OF HSBC BANK NEVADA, N.A. vs. MICHAEL E FRENGEL and Sovereign Bank Garnishee FIL~'~-Q~ FICE ~~. ~~iF ~?~:~ i -~J~~r ~'~~PY 20567b~ 2I~i~~d~~ -! AM i~: ~-~ ~1'~B~~LP~~#~ ~B~i R~' COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 09-2790 PRAECIPE TO DISSOLVE ATTACffi~NT TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant's bank account with Sovereign Bank, as Garnishee in the above entitled matter. CORDON & WEINBERG, P.C. BY: FREDERIC I. WE G, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff PO11 "' ~~ a~ ~$~53~~ 0~~~.~ So s~~ ~~ a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff h 1LEU`CFI+'ICE s}i'l'14? Oi 41131)11Cf,,In? Jody S Smith L41 THEE RRDTHONOTIARY Chief Deputy 2011 APR 15 PM 1: 10 Richard W Stewart Solicitor CUMBERLAND GOUNTY PENNSYLVANIA Asset Acceptance LLC, Assignee of Home Depot/Citibank and Assignee of Case Number vs. Michael E. Frengel 2009-2790 SHERIFF'S RETURN OF SERVICE 09/20/2010 09:14 AM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 20, 2010 at 0912 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Michael E. Frengel, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania, 17013, by handing to Julie Myers, 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 September 21, 2010 to Michael E. Frengel at 7 Independence Drive, Shippensburg, PA 17257. 04/14/2011 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: $87.50 SO ANSWERS, April 14, 2011 RON R ANDERSON, SHERIFF Sharon R. Lantz 0 -col 641 a.,. ? X57,3 !c Coun?vSuite Shenk Teieoso't. Ir.