HomeMy WebLinkAbout09-44342061380
THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES HEARING REQUIRED.
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
UNIFUND CORPORATION
10625 Techwoods Circle
Cincinnati, OH 45242
Vs.
ANTHONY DELBO
131 BRIDGE ST
NEW CUMBERLAND PA 17070
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.
NOTICE
04 - ?l4ay e«c?.?Erir.-L
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, 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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT IN CIVIL-ACTION
1. Plaintiff, Unifund Corporation is a debt buyer and
successor in interest to the original creditor, JP MORGAN CHASE
BANK.
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 creditor's 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
merchandise 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 June 8,
2009 in the amount of $7,815.08.
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.
7. Defendant's last payment on account was made on
11/13/2005.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$7,815.08 plus applicable costs, interest and attorney's fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I.
JOEL M. FLIN
Attorney for
OLERG, ESQUIRE
QUIRE
intiff
P01h
2061380
U3440069
Unifund Corporation
ANTHONY DELBO
4357871680003113
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 making this verification. This
verification is made subject to 18 Pa.C.S. §4904 which provides for certain
penalties for making false statements.
CHRIS BRYAN
EXHIBIT "A"
?. 1933
2061380
U3440069
Unifund Corporation
ANTHONY DELBO
4357871680003113
RWWTnAXTTM
I, Chris Bryan, being duly served sworn according to law, depose
and say that:
1. I am the agent for the Plaintiff herein and I have custody
and control of the files relating to this account;
2. I have personal knowledge of the facts and circumstances in
connection with this case;
3. Plaintiff's files are maintained in the usual and ordinary
course of business;
4. This action is based on a claim for breach of contract and
that damages are sought as a direct result of said breach;
5. There is now due and owing from defendant to plaintiff, the amount of $6,558.78
plus interest of $1,229.35 at the rate of 6% less credits in the amount of $.00 totaling $7,788.13 as
of May 20, 2009.
6. If called upon, affiant can testify at trial as to the facts
pertaining to this matter.
The above facts are true and correct to the best of my knowledge,
information and belief.
A 67?
AFFIANT
STATE OF OHIO
COUNTY OF HAMILTON
Sworn to and Subscribed
before me this 20th day
of ??Maay??, 2009
Chris BWft
Notary Public ?* *? NAry RNIc,St leofOhio
?;^,, My Corrani ft Expires 05-14-2011
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OF TN= K; _"? CRY
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Sheriffs Office of Cumberland County
R Thomas Kline
Sheri
?tta of t itnrbrr f
Ronny R Anderson ???
?a?
Chief Deputy
'Y
Jody S Smith
Civil Process Sergeant OFFICE OF 7"E SmERIFF
Edward L Schorpp
Solicitor
Unifund Corporation Case Number
vs.
Anthony Delbo 2009-4434
SHERIFF'S RETURN OF SERVICE
07/06/2009 05:22 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July 6,
2009 at 1722 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Anthony Delbo, by making known unto himself personally, defendant at 131 Bridge
Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $43.30
July 07, 2009
SO ANSWERS,
R THOMAS KLINE, HERIFF
Deep ty Sheri
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GORDON & WEINBERG, P.C. �'Ed �+��Q QQQ���
BY: FREDERIC I. WEINBERG, ESQUIREClitl.Yh'f
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
Unifund Corporation COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
ANTHONY DELBO
DOCKET NO. : 09-4434
PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER, ASSESSMENT
OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE
TO THE PROTHONOTARY:
Enter judgment for want of an
against defendant(s) ANTHONY DELBO
damages certified to be calculable
complaint, as follows:
answer for plaintiff and
above named only and assess
as a sum certain from the
Principal
Interest from 05/01/2009
@60
Costs (Complaint & Service)
Less: Payment on Account
Understanding the
penalty under 18 Pa.C.S.A. §4904,
Authorities, I verify that:
Total:
$6,558.78
$2,522.57
$121.80
( $3,800.00)
$5,403.15
false statements made herein are subject to
Unsworn Falsification to
3°PkOft"
Jq(/c(3
1. The last known addresses of the parties are: Unifund
Corporation and that the last known address of defendant, ANTHONY
DELBO, 131 BRIDGE ST, NEW CUMBERLAND PA 17070.
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 the coverage of
the Soldiers and Sailors Civil Relief Act and is (are) over 18
years of age. y
AND NOW, this �j I day of ,)on e , 20L�Judgment
is entered in favor of the plaintiff(s) and against defendant(s) b
p ( ) g ( )
default for want of an answer and damages apses awl e sum of
$5,403.15 as per the above certification.
Prothonotary
GORDON & WE. BERG, P.C.
BY:
FREDERIC I. ►+.INBERG, ESQUIRE
JOEL M. FLIN , ESQUIRE
Attorne f. Plaintiff
2061380
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
Unfund Corporation COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
ANTHONY DELBO
131 BRIDGE ST
NEW CUMBERLAND PA 17070
DOCKET NO. : 09-4434
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.
LIEL Judgment by Default $5,403.15
LI Money Judgment $
L_L Judgment on Award of Arbitrators$
LI Judgment on Verdict$.
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL
ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. INK ESQS AT THI
TELEPHONE NUMBER: 484/351-0500
PROTHONOTARY
�ol�gl�r
2061380
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
Unifund Corporation COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs. DOCKET NO. : 09-4434
ANTHONY DELBO
NOTICE OF INTENTION TO TAKE DEFAULT
TO/PARA
ANTHONY DELBO
131 BRIDGE ST
NEW CUMBERLAND PA 17070
DATE OF NOTICE/FECHA DEL AVISO: May 22, 2014
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 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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
GORDON & WEINBERG, P.C.
BY:
PlOD
FREDERIC/If WgINBERG, ESQUIRE
JOEL M. ;FLINK, ESQUIRE
, i
Department of Defense Manpower Data Center
Results as of : Jun -02-2014 07:54:18 AM
SCRA 3.0
Statu Rt out
Pursuant to Servicemembers Civil Relief Act
Last Name: DELBO
First Name: ANTHONY
Middle Name:
Active Duty Status As Of: Jun -02-2014
On Active Duty On Ac
ive Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA .
NA
No
NA
- - This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Da
of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This response
reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
- -
The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
No
NA
:
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
-05"An,
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting Sgstem (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you, See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date,
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This indudes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs), Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth,. and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: MA99TE03H05A990
PROTHIVTAi.-:'‘`
The Law Offices of Frederic I. Weinberg FIL ED -OFFICE
,F
& Associates, P.C. THE
RN
BY: Frederic I. Weinberg, Esquire
CUliDERL AND COUNTY
Identification No.: 41360 T14 OCT 1 4 2: 4 1
PENNSY
Joel M. Flink, Esquire
Identification No.: 41200
1001 E. Hector Street, Ste 220 LVANIA
___Conshohocken, PA 19428
55E484/351-0500
=m▪ mUnifund Corporation
1110111101111111
MINIM/
ININIMMINO
vs.
===
RERANTHONY DELBO
- --131 BRIDGE ST
=---=_NEW CUMBERLAND PA 17070
and
Citizens Bank of Pennsylvania
665 North East Street
Carlisle, PA 17013
GARNISHEE(S)
IIIIMMIMM
41111111MM
IIIIIIMMM
EllE_TO THE PROTHONOTARY:
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 09-4434
PRAECIPE FOR WRIT OF EXECUTION
Issue writ of execution in the above matter,
=== directed to the Sheriff of Cumberland County;
(1) against
ANTHONY DELBO
defendant(s)and
(2) against
Citizens Bank of Pennsylvania
garnishee(s)
===
(3) Amount Due $5,403.15
Interest from June 19, 2014 $93.26
Costs
Prothonotary fee
Sheriff fee
(4) Less: Payments on Account $3,800.00
TOTAL
c5CA CI‘i-thj\
L.ts '30 0.4.F-
" It
sep
0.3)
FREDERIC I. WEINBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
1961,966
ePc)S
2061380
A- ok 66 TssveA
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
UNIFUND CORPORATION
Vs. NO 09-4434 Civil Term
CIVIL ACTION — LAW
ANTHONY DELBO
WRIT OF EXECUTION
(Pa R.C.P. 3252)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against ANTHONY DELBO, 131 BRIDGE STREET, NEW
CUMBERLAND, PA 17070 Defendant (s)
(1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein;
(2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of
CITIZENS ANKGARNISHEE(S), as garnishee, 665 NORTH EAST STREET, CARLISLE, PA 17013
(Specifically describe property) and to notify the garnishee that
(a) an attachment has been issued;
(b) except as provided in paragraph (c), the garnishee 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;
(c) the attachment shall not include
(i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any
funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law.
(ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed
$10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being
funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law.
(iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If
multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as
determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general
exemption provided in 42 Pa.C.S. § 8123.
(3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added
as a garnishee and is enjoined as above stated.
Amount Due /I 1903. iS
Interest FROM JUNE 19, 2014 - $93.26
Attorney's Comm. %
Attorney Paid $167.30
Date: 10/14/2014
(Seal)
Plaintiff Paid
Law Library $.50
Due Prothonotary $2.25
Other Costs
o/ Pc41,14:1
David D. Buell, Prothonotary
By: Xe,4
Deputy
REQUESTING PARTY:
Name : FREDERIC I. WEINBERG, ESQUIRE
Address: THE LAW OFFICES OF FREDERIC I. WEINBERG
1001 E. HECTOR STREET, SUITE 220
CONSHOHOCKEN, PA 19428
Attorney for: PLAINTIFF
Telephone: 484-351-0500
Supreme Court ID No. 41360
MAJOR EXEMPTIONS UNDER PENNSYLVANIA
AND FEDERAL LAW
1. $300 statutory exemption
2. Bibles, school books, sewing machines, uniforms and equipment
•3. Most wages and unemployment compensation
4. Social Security benefits
5. Certain retirement funds and accounts
6. Certain veteran and armed forces benefits
7. Certain insurance proceeds
8. Such other exemptions as may be provided by law
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
1F'ILED-OFFsICE
OF THE PROTHONOTARY
cznutrfr4,,x
20R OCT 24 411 9 52
CUMBERLAND COUNTY
PENNSYLVANIA
OFFICE OF THE $!•tERIFF
Unifund Corporation
vs.
Anthony Delbo
Case Number
2009-4434
SHERIFF'S RETURN OF SERVICE
10/22/2014 02:55 PM - William Cline, 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, Citizen's Bank, 665 North East Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to Tabitha Zarichansky, Banker, 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 October 23, 201 tonthony Delbo at 131
Bridge Street, New Cumberland, PA 17070.
ILL A CLINE, DEPUTY
SO ANSWERS,
October 23, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuite Sheriff. Teieosoff, 'nc.
••
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
IHE
PP,OTHONO VARY
,NCtr DI ILI' iriber4,
2U!' NOV 10 PH 3: 22
CUMBERLAND COUNTY
PENNSYLVANIA
oFT t 14E *-MEIP,'
Unifund Corporation
vs.
Anthony Delbo
Case Number
2009-4434
SHERIFF'S RETURN OF SERVICE
10/22/2014 02:55 PM - William Cline, 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, Citizen's Bank, 665 North East Street, Carlisle
Borough, Carlisle, PA 17013, Cumberland County, by handing to Tabitha Zarichansky, Banker, 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 October 23, 2014 to Anthony Delbo at 131
Bridge Street, New Cumberland, PA 17070.
11/10/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned
SATISFIED.
SHERIFF COST: $119.57 SO ANSWERS,
November 10, 2014 RONrIY R ANDERSON, SHERIFF
.5D
e4 9k23'/
oe& 3/3,P
(c) CountySuiteSh�n, Teleosoft.
DISTRIBUTION
PLAINTIFF Unifund Corporation
WRIT NO. 2009-4434
Unifund Corporation
Vs
Real Debt $ 1,603.15
Interest 93.26
Attorney's Comm.
Writ Costs, Atty 167.30
Writ Costs, Pltff.
Miscellaneous
Attorneys Fees
TOTAL
$ 1,863.71
Sheriff's Costs
Docketing
Poundage
Law Library
Prothonotary
Service Mileage
Postage
Advertising
Garnishee
Postpone Sale
Bad Check Charge
Surcharge
Levy
TOTAL
18.00
32.06
.50
2.25
6.78
.98
9.00
30.00
20.00
$ 119.57
Remitter Paid to Sheriff
Advance Costs
Total Collected
Pd. To Pltff.
Refund of Adv. Costs
Sheriff's Costs
$
1,863.71
150.00
119.57
$ 1,983.28
150.00
$ 2,133.28
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
UNIFUND CORPORATION
Plaintiff(s),
vs.
ANTHONY DELBO
Defendant(s),
and
Citizens Bank of Pennsylvania,
Garnishee.
CIVIL DIVISION
094434
ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK
The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of
the Plaintiff(s):
(NUMBERS _1_ to _9 ) At the time of service of above -captioned Writ of Execution
and to the present, Citizens Bank of Pennsylvania, provides the following Answers to
Interrogatories:
The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a CHECKING
account in the name of the defendant, ANTHONY DELBO, held jointly by the entireties, and
therefore not subject to attachment.
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ALLEGHENY
Before me, the undersigned authority, a Notary Public in and for said
Commonwealth and County, personally appeared Penny Donaldson who being duly sworn
according to the law deposes and says that she is the Legal Clerk, Operations Services, and
that the statements set forth in foregoing Answers to Interrogatories are true and correct to
the best of her knowledge, information, and belief.
Sworn and subscribed before
me this 5th day of
December, 2014.
U\)1).
Notary Public
r'r•IriV ASIA
EA1T4 OF,..
�QilAM :Pl NOTARIAL : f.,AL I,
Data Wilkerson, Notary Pu isc
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RIES
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Penny Donaldson
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
UNIFUND CORPORATION,
Plaintiff(s),
vs.
ANTHONY DELBO,
Defendant(s),
vs.
Citizens Bank of Pennsylvania,
Garnishee.
CIVIL DIVISION
094434
Answers to Interrogatories
Code: 200 Execution
Filed on Behalf of Garnishee,
Citizens Bank of Pennsylvania
Counsel of Record for
this Party:
Nicholas Deenis, Esquire
PA I.D. No. 62378
Stradley, Ronon, Stevens & Young
2005 Market Street, Suite 2600
Philadelphia PA 19103
(215) 564-8672
(215) 564-8120 fax
ndeenis@stradley.com
www.stradley.com
Certificate of Service
I, Penny Donaldson, hereby certify that a true and correct copy of the Answers to
Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage
prepaid, this Stn day of December, 2014.
OFFICE OF THE PROTHONOTARY
ONE COURTHOUSE SQUARE
COURTHOUSE
CARLISLE, PA 17013-3387
FREDERIC I WEINBERG, ESQ
THE LAW OFFICES OF FREDERIC I WEINBERG &
ASSOCIATES, PC
1001 E HECTOR ST
CONSHOHOCKEN, PA 19428
ANTHONY DELBO
131 BRIDGE ST
NEW CUMBERLAND PA 17070
Penny Donaldson
The Law Offices of Frederic I Weinberg
& Associates, P.C.
BY: Frederic I. Weinberg, Esquire
Identification No.: 41360
Joel M. Flink, Esquire
Identification No.: 41200
375 E. Elm Street, Suite 210
Conshohocken, PA 19428
484/351-0500
Unifund Corporation
vs.
ANTHONY DELBO
and
Citizens Bank of Pennsylvania
Garnishee
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 09-4434
PRAECIPE TO DISSOLVE ATTACHMENT
TO THE PROTHONOTARY:
Kindly dissolve the attachment against Citizens Bank of
Pennsylvania, as Garnishee in the above entitled matter.
The Law Offices of Frederic I. Weinberg
& Associates, P.C.
BY:
P011
Frederic I. W nberg, Esquire
Joel M. Fli Esquire
Attorney for Plaintiff
Wci
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