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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 00 FiLCi:?-i :'3": OF TN= K; _"? CRY 2999 JUL -2 PH 12: ; 9 X78. ro?kA-l? CK? 83q" Mat LC 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 9-3 „- C ;c -F, C-" _.? v 4� r HE, ` � T 0 /9 tJ 1 �� � 'n J' E" 2061380 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 City of iissb+on Xpires rip 25, 201OF a A RIES tom A ASS°CIA VYA �gEtdBER, PENN 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 it .1 Dazi aaN3t,