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Home My WebLink About09-4564191 IN THE COURT OF COMMON PLEAS OF CUMBERLAND AMERICAN EXPRESS BANK, FSB 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. CRAIG BACHIK 4 LEMOYNE DR #201 LEMOYNE PA 17043 Defendant (s) Civil Complaint Filed on behalf of: COUNTY, PENNSYLVANIA NO. OQ - qJ%q 0 vit-F 1'1 CIVIL ACTION - LAW Plaintiff, AMERICAN EXPRESS BANK, FSB Counsel of record for this party. Date: AaraE. to ay #873 hilip C. Warholic #86341 a z 86469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 Counsel for Plaintiff Cover - General PACVR/PACVR FILE # 188272297 201 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. 200 VESEY ST , NEW YORK NY 10285 Plaintiff VS. CIVIL ACTION - LAW CRAIG BACHIK . 4 LEMOYNE DR #201 LEMOYNE PA 17043 Defendant (s) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle PA 17013 800-990-9108 CVRNOT/PACP7 FILE # 188272297 204 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. 200 VESEY ST , NEW YORK NY 10285 Plaintiff VS. CIVIL ACTION - LAW CRAIG BACHIK 4 LEMOYNE DR #201 LEMOYNE PA 17043 Defendant (s) NOTICIA Le han demandado a used en la corte. Si used quarere defensas de esas demandas expuestas en las paginas, siguientes, used tiene viente (20) dias de plazo al partir de la fecha de lademanda y la notifiation. Used debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a last demandas en corta de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y psedido entrar una Orden contra used sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Used puede perder dinero o sus propledades o otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITANCIA LEGAL. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle PA 17013 800-990-9108 CVRNOS/PACP7 FILE # 188272297 207 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. d g " '4S-6 "f e-GA e4l 200 VESEY ST . NEW YORK NY 10285 . Plaintiff VS. CIVIL ACTION - LAW CRAIG BACHIK . 4 LEMOYNE DR #201 LEMOYNE PA 17043 Defendant (s) COMPLAINT AND NOW, comes the Plaintiff, by and through its attorneys and the law firm of Mann Bracken LLP, and files this Complaint and in support avers as follows: 1. Plaintiff, AMERICAN EXPRESS BANK, FSB located at, 200 VESEY ST NEW YORK NY 10285 2. Defendants, CRAIG BACHIK is/are adult individual(s) with last known address(es) of 4 LEMOYNE DR #201 LEMOYNE PA 17043 COUNTY OF CUMBERLAND 3. It is averred that Defendant(s) was/were issued an open end credit card account. 4. At all relevant times material hereto, Defendant(s) has/have used said charge card for the purchase of products, goods, and/or for obtaining services. 5. Defendant(s) was/were provided with monthly statements showing all debits and credits for transactions on the Account to which there was no bona fide objection by Defendant(s). A Statement of Account summarizing the Account is attached hereto as Exhibit "A". 1 PAC1M1/PACP7 FILE # 188272297 210 6. As of the date of this Complaint, the remaining balance due, owing and unpaid on Defendant's credit card account as a result of the charges made by said Defendant(s) and/or any authorized users in the sum of $ 34003.53. 7. Despite reasonable and repeated demands for payment, Defendant(s) has/have refused and continues to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 8. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 9. The amount in controversy exceeds the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant(s) in the amount of $ 34003.53, plus costs of this action, and any other relief as this Court deems just and reasonable. Respectfully Submitted, David R. to ??Philip C. Warholic #86341 Sarah E. Ehasz P86469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 MANN BRACKEN LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 866-253-0128 PAC1M2/PACP7 FILE # 188272297 2 VERIFICATION The undersigned hereby states that he/she is the attorney for the Plaintiff who is located outside of this jurisdicition and in order to file the within document in an expedient and timely manner, he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. vid R. Gal:oway #873 /Philip C. Warholic #86341 Sarah E. E asz 69/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 PAVERF/PACP7 FILE # 188272297 ` ? , 40 A W UI W o ?i y ' i ? d O IJ J FF'?JJI ' I N tit ?° ro ? I y Y QO$J o f ro ? ? ? I ? v !? q Z. r 1.4 (I[j??}yrI I ' i i + ?b : • n w ro II I I N O D ?y] p U1 I 1 N W J N Fo co co N J J O N N W co (A ? p N ? + r W ? e ? y y n +y P Yi n M ? n t7 ?1 Q ? y Y fA '°+1 , ? f4 f] I ; N A° a° ° ?+ o O? i I I ° A o yy? i I 1 71 A ? ? ` ro r W i ? ?j I I ? J ? H VVV w o y° to o O ~ , n yyY Q ? I [y+ to ? o tt ? 71 '? r r r ? • ro r r $ o H A W N o 00 O C p ? W •, M r ? C9 C9 cA? H H y 1 H y H '? N r O ? o • 1~O ro I tqn I b Rq Ci vJ W M : • • ' A M • N ??--II W O ? A i t r i i i t oa i FFLF lJ THr " t7 ?? i"i G • ?. U -$ 78 . so PD AIW Cr`" 3a.I qqS aa7lyy Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor O'FICE,-171,E `.,•.ERIFF FILED--C , 'F OF THE `'' MIRY 2009 JUL b- r a`e 1C- 0 n American Express Bank, FSB vs. Craig Bachik Case Number 2009-4564 SHERIFF'S RETURN OF SERVICE 07/14/2009 05:19 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on July 14, 2009 at 1719 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Craig Bachik, by making known unto himself personally, defendant at 4 Lemoyne Drive, Unit 201 Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing tc him personally the said true and correct copy of the same. SHERIFF COST: $42.40 July 15, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF r, Deputy Sheriff esm 2005 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. 2009-4564 200 VESEY ST CIVIL ACTION - LAW NEW YORK NY 10285 'Plaintiff VS. CRAIG BACHIK Defendant(s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), CRAIG BACHIK and , for failure to answer the Complaint. ( X ) Amount due $ 34003.53 TOTAL $ 34003.53 , plus costs and statutory interest from the date of Judgment. ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( X ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attAhed. _ DATE: Signature: David R. Galloway #87326/Philip C. Warholic #86341 Sarah E. Ehasz #86469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 NOW, 2009, JUDGMENT IS ENT ED AS ABOVE. Proth notary/Clef it ivision By: Deputy PRAECJ/PACPDJ FILE # 188272297 a RE(310NAL OFFICES TEMPE. AZ AGOURA HILLS. CA CONCORD, CA GREENWOOD VILLAGE, CO WILMINGTON. DE BOCA RATON. FL ATLANTA. GA ROCKVILLE, MD NOVI. MI CHAMPLIN. MN HUNTERSVILLE, NC CARSON CITY. NV ROCHESTER, NY 168272297 CRAIG BACHIK 4 LEMOYNE DR #201 LEMOYNE PA 17043 Re: AMERICAN EXPRESS vs. CRAIG BACHIK Docket No. 2009-4564 Dear CRAIG BACHIK REGIONAL OFFICES INDEPENDENCE,OH PORTLAND, OR CAMP HILL, PA PITTSBURGH, PA CLINTON, TN NASHVILLE, TN HOUSTON, TX IRVING, TX SAN ANTONIO, TX FAIRFAX. VA RICHMOND, VA VIRGINIA BEACH, VA Hours of operation: 8 am. 9 p.m. EST M-F File No. 188272297 Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, ip C. Warholic #86341 Irt N. Polas, Jr. #201259 Enclosure CC: CRAIG BACHIK 08/06/09 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 This is an attempt by a debt collector to collect a debt and any information obtained will be used for that purpose. NOT 10D/PANOTC LAW OFFICES MANN BRACKEN LLP Attorneys in the Practice of Debt Collection (A National Collection Attorney Network Firm) 4680 TRINDLE ROAD SUITE 300 CAMP HILL, PA 17011 (TOLL FREE) 1-868-375-1728 FACSIMILE (866) 281.9028 PLEASE DIRECT CORRESPONDENCE TO CAMP HILL OFFICE LTRHG 1 101 '291,w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. 2009-4564 200 VESEY ST , NEW YORK NY 10285 Plaintiff , VS. CRAIG BACHIK Defendant(s) TO: CRAIG BACHIK 4 LEMOYNE DR #201 LEMOYNE PA 17043 DATE OF NOTICE: 08/06/09 IMPORTANT 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 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. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. C x-U-sle PA 17013 David R. alloway #8711t7p flip C. Warholic #86341 ara asz #86469/R bert N. Polas, Jr. #201259 Amy F. Doy a #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 IMPNOT/PANOTC FILE # 188272297 2018 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB No. 2009-4564 200 VESEY ST CIVIL ACTION - LAW NEW YORK NY 10285 . Plaintiff VS. CRAIG BACHIK Defendant (s) . CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise residence of Plaintiff is: AMERICAN EXPRESS BANK, FSB 200 VESEY ST NEW YORK NY 10285 and certify that the last known address of the within Defendant(s) is: CRAIG BACHIK 4 LEMOYNE DR #201 LEMOYNE PA 17043 David R. Galloway #87326/Philip C. Warholic #86341 Sarah E. Ehasz #86469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 PCRES/PACPDJ FILE # 188272297 THE F,.,,„,.` „?TA?Y ?i , 2009 AUG 27 Pr6 3: 09 + 14.00 PQ A`rw CrIll BIT7 sa(,o U4- alai 84 40 ?)" kk 2011) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. 2009-4564 Plaintiff VS. CIVIL ACTION - LAW CRAIG BACHIK Defendant(s) NOTICE OF JUDGMENT ( x ) Notice is hereby given that a Judgment in the above-cap Toned matter has been entered against you in the amount of $ 34003.53, on 2009, plus costs and statutory interest from the date of Judgment. ( x ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. By: If you have any questions regarding this Notice, please contact the filing party. David R. Gdlloway #J87126/Philip C. Warholic #86341 Sarah E. Ehasz #86469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: CRAIG BACHIK 4 LEMOYNE DR #201 LEMOYNE PA 17043 STNTCI/PACPDJ FILE # 188272297 IN THE COURT OF COMMON ~~~ ~~~ ' ~ ; ~ CUMBERLAND COUNTY, PENN AMERICAN EXPRESS CENTURION BANK 4315 SOUTH 2700 WEST SALT LAKE CITY, UT Plaintiff vs. CRAIG BACHIK 4 LEMOYNE DRIVE #201 LEMOYNE, PA 17043 Defendant CIVIL ACTION -LAW ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appeazance on behalf of Plaintiff, American Express Centurion Bank, with regazd to the above matter. Amy F. Doyle, Es ' e PA Supreme Court ID 87062 Doyle Legal Services, LLC. 204 St. Chazles Way, Unit E#177 York, PA 17402 717-812-1672 877-202-9420 206-203-3878 (facsimile) Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS CENTURION BANK NO. 2009-4564 4315 SOUTH 2700 WEST SALT LAKE CTTY, UT Plaintiff vs. CNIL ACTION -LAW CRAIG BACHIK 4 LEMOYNE DRNE #201 LEMOYNE, PA 17043 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that a copy of the foregoing Entry of Appearance has been served upon defendant, by First Class Mail, Postage Pre-Paid, a copy thereof on this ~ day of February, 2010, to: CRAIG BACHIK 4 LEMOYNE DRNE #201 LEMOYNE, PA 17043 Amy F. Doyle, Esqu e PA Supreme Court 7062 Doyle Legal Services, LLC. 204 St. Charles Way, Unit E#177 York, PA 17402 717-812-1672 877-202-9420 206-203-3878 (facsimile) Counsel for Plaintiff PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA American Express Centurion Bank ' PLAINTIFF vs. Judgment No. a,p(~ - ~ J`~'1 CRAIG BACHIK DEFENDANT(S) PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $28,336.29 (1) Directed to the Sheriff of CUMBERLAND County, Penna.; (2) against CRAIG BACHIK r,, 4 Lemoyne Dr #201 C ° =ri Lemoyne PA 17043 ~ r'S-,-~ ~ -~ Defendant(s); (3) and against Metro Bank f/k/a Commerce Bank ,=~ 1_ `:-;' < , located at 1130 Carlisle Road ;> ~.... -t? , = - Camp Hill, PA 17011 Garnishee(s); ~ ~~_ ~ '''~ `° ~. (4) And index this writ _ ~ w y (a) against CRAIG BACHQ~ Defendant(s) and (b) against Metro Bank f/k/a Commerce Bank, Garnishee(s), as a lis pendens against real property of the defendant(s) in name of Garnishee(s) as follows: (Specifically Describe Property) ****GARNISH ONLY**** You are directed to attach the property of the Defendant(s) not levied upon in the possession of Metro Bank f/k/a Commerce Bank Garnishee(s) All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount due: $28,336.29 Interest From: July 14, 2009 To Be Determined At an interest rate of 6% per year Total: O $28,336.29 Plus costs & interest (total includes post judgment credits). s /] ~ a4.00 P p AT'Nl ya. ya CBF' ' 7'8. SO '' i~.oo '~ o~•SO a ~ t(ol.'~0 r ~ ATf~/ ~a. oo ~(A • s0 (..1, C~ I~'l0 Q,~ x452133 Amy F. Doyle,l~~squiie PA Supreme Court ID 8 2 Doyle Legal Services, . /Counsel for Plaintiff 204 St. Charles Way, Unit E#177 York, PA 17402 717-812-1672/877-202-9420 Fax:206-203-3878 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-4564 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN EXPRESS CENTURION BANK, Plaintiff (s) From CRAIG BACHIK, 4 Lemoyne Dr #201, Lemoyne, PA 17043 (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: METRO BANK f/Wa COMMERCE BANK, 1130 Carlisle Road, Camp Hill, PA 17011 All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe depposit boxes. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishees} 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 $28,336.29 L.L.$.50 Interest from 7/14/09 at an interest rate of 6% per year -- to be Determined Atty's Comm Atty Paid $161.40 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 7/14/10 (Seal) David D. Buell, Prothonotary By; Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: DOYLE LAW SERVICES, LLC 204 ST. CHARLES WAY, UNIT E#177 YORK, PA 17402 Attorney for: PLAINTIFF Telephone: 717-812-1672 Supreme Court ID No. 87062 •. • ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA American Express NO. ~q - ~~j (91.~ Centurion Bank PLAINTIFF V.S. C7 ~ rv 4 p _, '~r~ rn ~ . . C_ CRAIG BACHIK - . . ~°~ `" m r DEFENDANT(S) ._~ ~ ~ y , J ~' .,, ~ ~/I.~ ~~5~ 'v +." ~-- DTI Y r 1 - ~ INTERROGATORIES TO GARNISHEE zT ~ =- ~-== ~~ ., ~= TO: Metro Bank f/k/a Commerce Bank --~ ~- 1130 Carlisle Road Camp Hill, PA 17011 PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IlVIPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was issued. C. "You" means the main office and all branch offices, representatives, employees and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information is possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. INTERROGATORIES TO GARNISHEE DEFENDANT(S) -CRAIG BACHIK 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each account. If the Defendants} maintains any of these jointly with any other person, or persons, give their name and address. lA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. 2. If you aze 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 bn a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 3. If you aze a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds on deposit, not including any otherwise exempt funds, did not exceed the amount of general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. 4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? 5. SAFE DEPOSIT' BOX: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, including the identification number or other designation of the box or boxes. Include a full description of the content and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. 6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not the Defendant(s) own any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. 7. OTHER ASSETS: At the time you were served or at any subsequent time,-did you know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. ff so, please set forth all details concerning those asset(s). 8. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? ff so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees chazge by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer? If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. Amy F. Doyle, squ' PA Supreme Court ID 87062 Doyle Legal Services, LLC. 204 St. Chazles Way, Unit E#177 York, PA 17402 717-812-1672/877-202-420 206-203-3878 (facsimile) Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA American Express Centurion Bank PLAINTIFF VS. CRAIG BACHIK NO. DEFENDANT(S) ~4ns~~~ ~ INTERROGATORIES TO GARNISHEE TO: Metro Bank f/k/a Commerce B ank ~ sl-1, 1130 Carlisle Road Camp Hill, PA 17011 c~ ^,' c. ~, -~, ". '~1 .i .. ''' __ f i_ ~ _. ~ -~ ~ ~. . Q ... ~ -~~-G PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IlVIPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. issued. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was C. "You" means the main office and all branch offices, representatives, employees and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information is possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. INTERROGATORIES TO GARNISHEE DEFENDANT(S) -CRAIG BACHIK 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each account. If the Defendant(s) maintains any of these jointly with any other person, or persons, give their name and address. Defendant has no accounts lA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. 2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. no 3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds on deposit, not including any otherwise exempt funds, did not exceed the amount of general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. no 4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise dischazge any claim of the defendant(s) against you? no 5. SAFE DEPOSIT BOX: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, including the identification number or other designation of the box or boxes. Include a full description of the content and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. no 6. ~ REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not the Defendants} own any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there aze any encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. no 7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). no 8. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). no 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charge by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer? If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. no Amy F. Doyle, squ' PA Supreme Court ID 87062 Doyle Legal Services, LLC. 204 St. Charles Way, Unit E#177 York, PA 17402 717-812-1672 / 877-202-420 206-203-3878 (facsimile) Counsel for Plaintiff VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. JI (SIG ATURE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~~~,t~, at ~uruGrr/;~~~ ,`{ ~:, !. - ?~ -~ ~ `~ ^ f, ' n I ~~ ... j. li:U v.. ... ~u tla. ~ r~ J~~ 30 ~ a :~~ Cam..:. ~°r ~' a American Express Bank, FSB Case Number vs. Craig Bachik 2009-4564 SHERIFF'S RETURN OF SERVICE 07/29/2010 02:04 PM -William cline, Deputy Sheriff, who being duly sworn according to law, states that on July 28, 2010 at 1404 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Craig Bachik, in the hands, possession, or control of the within named garnishee, Metro Bank f/k/a/ Commerce Bank, 1130 Carlisle Road, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Allison Owen, Teller, 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 07-29-10 to Craig Bachik at 4 Lemoyne Drive, # 201, Lemoyne, PA 17043. SO ANSWERS, July 29, 2010 RON R ANDERSON, SHERIFF ~~ iam T. Cline, Deputy (ci Coui~, Suite Sheoff. Teeosoft. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS CENTURION BANK, Plaintiff vs. CRAIG BACHIK, Defendant No. 2009-4564 PRAECIPE TO DISSOLVE ATTACHMENT TO T14E PROTHONOTARY: ?i 's . d zi6 c ) 0 Please dissolve the writ of attachment filed against Metro Bank, f/k/a Commerce Bank, Garnishee in the above-entitled matter, without prejudice. Amy F. Doyle uire PA Supreme C ID 87062 Doyle Legal Services, LLC. 204 St. Charles Way, Unit E#177 York, PA 17402 717-812-1672 877-202-9420 206-203-3872 (facsimile) Counsel for Plaintiff File # BACHIK/CRAIG #8.00 Pb A" c5t 158 q O'aog3a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS CENTURION BANK, No. 2009-4564 Plaintiff vs. CRAIG BACHIK, Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that a copy of the foregoing Praecipe to Dissolve Attachment has,be n served upon the Garnishee, by First Class Mail, Postage Pre-Paid, a copy thereof on this 1b day of August, 2010, to: Metro Bank 3801 Paxton Street Harrisburg, Pa 17111 rr n 1 r' Amy F. Doyle, Esqu' PA Supreme Court ID 87062 Doyle Legal Services, LLC. 204 St. Charles Way, Unit E#177 York, PA 17402 717-812-1672 877-202-9420 206-203-3872 (facsimile) Counsel for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE 0F T E PROTHONOTARY 2011 NOY 17 AN 10: 4 6 CUMBERLAND COUNTY PENNSYLVANIA American Express Bank, FSB vs. Craig Bachik Case Number 2009-4564 SHERIFF'S RETURN OF SERVICE 11/15/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: TD Bank, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Garnishment as Not Found" at 1 West High Street, Carlisle Borough, Carlisle, PA 17013. M&T Bank is located at 1 West High Street, Carlisle, PA 17013. Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED. SHERIFF COST: $71.40 SO ANSWERS, j? November 15, 2011 RON R ANDERSON, SHERIFF (ci GoimtySuite ShenfY Teleosoft. Inc