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HomeMy WebLinkAbout01-6622IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, vs. RICHARD B. BUCHER, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 37 N. Baltimore Avenue Mt. Holly Springs, PA 17007 CIVIL DIVISION TYPE OF PLEADING: Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLICA & MURRAY Firm #952 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211-1205 (412) 381-7000 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. Plaintiff, vs. RICHARD B. BUCHER, Defendant. NOTICE TO DEFEND YOU HAVE BEEN SUED iN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 - 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. RICHARD B. BUCHER, Defendant. CIVIL DIVISION COMPLAINT AND NOW COMES, the Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPAA~Y, by its Attorneys, Mollica & Murray, with its Civil Action Complaint, the following of which is a statement thereof: 1. HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY is a Corporation, duly authorized to conduct business in the Commonwealth of Pennsylvania with its principal office situate at 2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred to as "Plaintiff". 2. RICHARD B. BUCHER is an adult individual residing at 37 N. Baltimore Avenue, Mt. Holly Springs, PA 17007. 3. On or about August 10, 1999, Defendant entered into a Loan Agreement with the Plaintiff, a copy of which is attached hereto as "Exhibit A" and incorporated herein. 4. Pursuant to the Agreement with Defendant, Plaintiff advanced funds to the Defendant. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 5. Defendant is in default under the terms and conditions of the aforementioned Agreement for failing to make payments when due, with the last payment having been made on or about May 31, 2001. 6. Pursuant to the terms of the Agreement, Plaintiff has the right to require payment of the entire amount owed upon default. The total amount due, including principal and interest, and owing by the Defendant is in the sum of Thirteen Thousand Four Hundred Forty Five and 33/100 ($13,445.33) Dollars as of October 5, 2001. 7. Numerous demands have been made upon Defendant by Plaintiff, but Defendant has failed or refused to pay. 8. Pursuant to the Agreement, Plaintiff is entitled to recover costs of collection and reasonable attorney's fees. W~EREFORE, Plaintiff claims damages in the sum of Thirteen Thousand Four Hundred Forty Five and 33/100 ($13,445.33) Dollars, with interest thereon at the rate of 21.991% from October 5, 2001, plus court costs and attorneys' fees. Respectfully submitted, MOLLICA & MURRAY By: CAT~ ANNh~ROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 Attorneys for Plaintiff 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, LOAN REPAYMENT AND SECURITY AGREEMENT [Page I o! 2) CREDITOR (called "We," "Us," "Our") HOUSEHOLO FINANCE CONSUMER OISCOUNT COMPANY 25 GATEWAY DRIVE GATEWAY SQUARE/SUITE 1DJ MECHANICSBURG PA 17055 BORROWERS (called "You," "Your") BUCHER. RICHARD B SS# 209641759 37 N BALTIMORE AVE BOILING SPRGS PA 17007 08110/88 LOAN NO: 3133°3-983189 257.52 ~7 ~fAt~ pA, YmJ~NTa 318.48 ,J/.. 318.48 NONE YOU ARE GIVING US 'A SECURITY iNTEREST IN THE REAL'EStATE LOCATED AT THE ABOVE ADDRESS, REQUIRED INSURANCe. Ynu must obtaia insurance for term of loan covering sacurity for ~s roan as ~d~at~ by t~ wozd 'YES' ~low. ~mln~ ~s &s Loss Poy~: Y ES ~xe end Q~nd~ covor~'i~a~ ~*r~t e~No s~urit~. Physical damage insurn~ ~ o~ ~operty mnrk~ "[nsured" ~r '~Ufity' a~ve. You may obte~ any r~u~ i~ran~ from anyoae you ch~se. NOTICE: THE FOLLOW~[NG PAGE CONTAINS ADDITIONAL CONTRACT TERMS. 0~J-25'97 LIs PA C.E~ MORT. ~tGI~L I PA065911 [ LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 2} . PAYMENT. In return[ for your loan described below, you sha 1 pay us the Amount Financed including the Fee {all shown on page one) plus ln'terest, in monthly payments, including any final Balloon Payment, as stated on page one. You may pay more at any tin'ir. You will pay at our business address or other address given you. If more than one Borrower is named on page one, iw.e may ~nforce this Agreement against all, or any, Borrowers, but not in.a combined amount greater than the amount oWe, d. Each payment will be first applied to F nance Charges at the Contract Rate shown on page one for the actual time unpaid and the remainder to your unpa{d Principal. For purposes o.f computing Einance Charges, a month shall be considered s4y period of 30 consecutive days. DATE ON WHICH .FINANCE CHARGE BEGINS. If you do not cancel this loan according to your "Notice of Right to Rescind," the date off which Finance Charge begins, payment date, and effective date of optional insurance purchased connection with this~i°an are postponed by thc number of days from this Agreement's date 'co date you r~eive this loan, PAY-OUTS. You ag!er to pay-outs of Amount Financed as shown on thc Truth In Lending disclosure form. Iff pay-ours change because loan c, losing is delayed, (a) you will pay additional amounts duc at closing, or (b) y0t~r cash or check will be reduced to cover additional pay-outs. PREPAYMENT. Yo~ may prepay any or all of your loan at any time. If you tully pay before thb final payment'due date, · thc amount you owe ~ill he re,:lur~l by unearned credit insurance charges. BAD CHECK CHARGE. We will charge you a handling fee of $20 if any payment check is returned because you had no account or for msufhcient funds. DEFAULT. Subject In applicable law and the mortgage on your re~l create ~uring this loan, if you don't pay on time or fail to k~ep required insurance in force, or if you sell or transfer all or any part of that real estate or any interest therein without our consent, ~1 your payments may become due at once. We will notify you of your Hght to correct such default before we enforce the real estate mortgage. We may sue you for thc total amount yo6 owe, and you will also pay our reasonable attorney fees (ff the attorney ts not our salaried employee), court costs, and fees incurred to collect this loan I ' EXCHANGE OF INFORMATION. You understand that from time to time we may ret, dye credit information concerning you froml othem, such as stores, other lenders, and credit reporting agencies. You authorize us to share any information, on a regular basis, we obtain related to your Account, including but not limited to credit reports and insurance informatio,'n, with any of our affiliated corporations, subsidiaries or other third parties. The uses of this information may include an inquiry to d~termine if you qualify for additional offers of credit. You also authorize us to share any mformat~o9 regarding your Account with any of our affiliated corporations, subsidiaries ut other third parties. After September 29, 1997, you may prohibit tho sharing of such information (except for the sharing of information about[transactions or experiences between us and you) by sending a written request which contains your full name, Social Security Number and Address to us at P.O~ Box 8602, Elmhurst, IL 60126. If 'GU fail to fulfill ]the terms of our ~,Tedit obli ation a ne t'v rt ~. .. . y g , ga ~ e repo renecting on your crenit record ma-~ he submttted to a CredLt Reporting Agency. You agre~ that the Department of Motor Vehicles (or your ~ate's equivalent of such department) ~nay release your residence address to us, should it become nec _,~t~__ry to locate you. You agree :hat our supervisory personnel may li~ten to .telephone calls between you and our reptesen~tives in order to evaluate the quality of our service to you. YOU HAVE RECEIVED A COMPLETED COPY OF THIS AGREEMENT AND THE TRUTH-IN-LENDING DISCLOSURES. ORIGINAL 09-29-97 LIS PA C.E. 1ST MORT. 4WERS: Iillllrmlllllllllllllllil lli llflllllllllilll (SEAL) (SEAL) (,SEAL) PAOB691Z I VERIFICATION Merrilee Mastrangelo, Recovery Specialist for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANy, a Household International Company deposes and says subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities, that the facts set forth in the foregoing Complaint are true and correct to the best of her knowledge, infoi-Jnation and belief. ITHIS IS AN ATfEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SHERIFF'S RETURN - CASE NO: 2001-06622 P COMMONWEALTH OF pENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER DIS VS BUCHER RICHARD B REGULAR CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPI~AINT & NOTICE was served upon BUCHER RICHARD B the DEPENDANT , at 1244:00 HOURS, at 37 N BALTIMORE AVE MT HOLLY SPRINGS, PA 17065 RICHARD B. BUCHER a true and attested copy of COMPLAINT on the 30th day of November , 2001 by handing to & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.90 Affidavit .00 Surcharge 10.00 .00 31.90 Sworn and Subscribed to before me this 7-- day of ~ ~/ A.D. ,t~rothonotary ' So Answers: R. Thomas Kline MOLLICA & By: Z/v Depu%!/ Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, vs. RICHARD B. Plaintiff, BUCHER, Defendant. CIVIL DIVISION No. 01-622 Civil Term TYPE OF PLEADING: Praecipe for Default Judgment TYPE OF CASE: CIVIL ACTION FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 Defendant's address: 37 North Baltimore Avenue Mt. Holly Springs, PA 17007 MOLLICA & MURRAY FIRM #952 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211-1205 (412) 381-7000 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. TO: PROTHONOTARY Please enter judgment by default against the defendant, RICHARD B. BUCHER, for failure to file follows: within-named an Answer as Amount claimed in Complaint: $13,445.33 Interest from 10/6/01 thru 1/03/02: 606.99 Costs of Collection thru 1/03/02: 554.50 TOTAL $14,606.82 With interest accruing on the total balance of $14,606.82 at the rate of 6% per annum, together with additional costs of suit. CATH~ 'A~' CHROMULAK, ESQUIRE MICHELLE D. SMITH, ESQUIRE Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATION OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared MICHELLE D. SMITH, ESQUIRE, attorney for and authorized representative of plaintiff who, being duly sworn according to law, deposes and says that the defendant is not in the military service of the United States of America to the best of her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed to defendant on December 21, 2001 by certificate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the attached copy. CATHY ANN CHROMULAK, ESQ. MICHELLE D. SMITH, ESQ. Sworn to and subs, gj~ibed before me this 7~ . day of~ 2002. Notarial Seal Yvonne, Gardner Jones. Notary Public Pittsburgh, Alle~lhen¥ County My Commission Expires .Jan. 29, 2005 Merntmr, PenssylvaniaAssociation olNotari ~I'HI$ IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, vs. RICHARD B. BUCHER, Defendant. CIVIL DIVISION No. 01~2~-CIVIL TO: RICHARD B. BUCHER 37 N. Baltimore Avenue Mt. Holly Springs, PA 17001 DATE OF NOTICE: December 21, 2001 IMpORTA/qT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166; 800-990-9108 By: CAT[{Y 'AI~ CHROMULAK, ESQ. MICHELLE D. SMITH, ESQ. Attorneys for Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION THAT PURPOSE. OBTAINED WILL BE USED FOR SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-06622 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER DIS VS BUCHER RICHARD B And now DOUGLAS DONSEN ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:29 Hours, on the 21st day of February , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , BUCHER RICHARD B , in the hands, possession, or control of the within named Garnishee COMMERCE BANK 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to WINI QUESENBERRY (BRANCH MANAGER) personally three copies of interogatories together with 3 and attested copies of the within COMPLAINT & NOTICE true and made the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 So an : R. Thomas Kline Sheriff of Cumberland County 00/00/0000 Sworn and subscribed to before me this ~7~ day of ~.~ /') Pro t'h-o~o~ y ~ By IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, vs. RICHARD B. Plaintiff, BUCHER, Defendant, Garnishee. and COMMERCE BANK, CIVIL DIVISION NO. 01-6622 TYPE OF PLEADING: Praecipe to Settle and Discontinue Against Garnishee ONLY TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLICA & MURRAY Firm #952 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211-1205 (412) 381-7000 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 01-6622 Plaintiff, PENNSYLVANIA vs. RICHARD B. BUCHER, Defendant, and COMMERCE BANK, Garnishee. PRAECIPE TO SETTLE AND DISCONTINUE AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please settle and discontinue this action against the above garnishee, COMMERCE BANK and mark the docket accordingly. By: Sworn to and subsGribed befor9 me. this /~ day ,o.,F 2002. ~otary Public Respectfully submitted, MOLLICA & MURRAY CATHY ANN CHROMULAK, ESQ. MICHELLE D. SMITH, ESQ. Attorneys for Plaintiff 1305 Trimont Plaza Suite 4504 Pittsburgh, PA 15211-1205 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. C~RTIFICATE OF SERVICE I, Michelle D. Smith, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY hereby certify that a true and correct copy of the foregoing Praecipe to Settle and Discontinue Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 13th day of MARCH, 2002: COMMERCE BANK 65 Ashland Avenue Carlisle, PA 17013 RICHARD B. BUCHER 37 North Baltimore Avenue Mt. Holly Springs, PA 17007 Mich~lle D. Smit , sq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, VS. Plaintiff, RICHARD B. BUCHER, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 CIVIL DIVISION No. 6622 Civil Term TYPE OF PLEADING: Praecipe to Satisfy Judgment TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLICA & MURRAY Firm #952 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211-1205 (412) 381-7000 ITHIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. CIVIL DIVISION No. 6622 Civil Term RICHARD B. BUCHER, Defendant. PRAECIPE TO SATISFY JUDGMENT TO: PROTHONOTARY Please satisfy the judgment against RICHARD B. BUCHER, at No. 6622 Civil Ten,, and mark the docket accordingly. Respectfully submitted, MOLLICA & MURRAY By: Sworn to and Subscribed to before me this /D day of ~002. v _ No~/l~b.l~c - CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 Attorneys for Plaintiff 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211 ITHIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Michelle D. Smith, Esquire, counsel for Plaimiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY hereby certify that a true and correct copy of the foregoing Praecipe to Satisfy Judgment was served upon the following by United States First Class Mail, postage prepaid on this ./,9/t-'day of September, 2002: RICHARD B. BUCHER 37 North Baltimore Avenue Mt. Holly Springs, PA 17007 Mich611e D. Smith, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-6622 Civil COUNTY OF CUMBERLAND) CIVIL ACTION LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONS. DISC. CO PLANTIFF(S) From RICHARD B. BUCHER (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 COMMERCE BANK, 65 ASHLAND AVE., CARLISLE PA 17013. GARNISHEE(S) as follows: ANY PROPERTY OF DEFENDANT 1N THE NAME OF GARNISHEE ANT) KINDLY SERVE INTERROGATORIES.. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined fi.om 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 $14,606.82 L.L. $.50 Interest $97.20 Due Prothy $1.00 Atty's Corem % Other Costs $.50 STATE TAX Atty Paid $103.90 Plaintiff Paid Date: FEBRUARY 19, 2002 REQUESTING PARTY: Name MICHELLE D. SMIITH, ESQ. Address: 1305 GRANDVIEW AVE. 45- TRIMONT PLAZA PITTSBURGH PA 15211 Attorney for: PLAINTIFF Telephone: (412) 381 7000 Supreme Court ID No. 74800/ CURTIS R. LONG Prothonotary, Civil Division R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Poundage 1.43 Advertising Law Library .50 Prothonotary 1.00 Mileage 3.45 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee 9.00 73.38 Advance Costs: 150.00 SheriWs Costs: 73.38 76.62 Refunded to Arty on 10 / 11/02 Sworn and Subscribed to before me this )$'* day of_(~e~__ 2002 A.D. (~.... ~.. ~t,~-~,~t~7,- So Answers; R. Thomas Kline, Sheriff