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Home My WebLink About09-5532Our File No.: 216025 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY Ocj; ff NO.: VICTORIA L REESE 418 E MAIN ST CAMP HILL, PA 17011-6322 Defendant. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a 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. 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 Our File No.: 216025 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. VICTORIA L REESE 418 E MAIN ST CAMP HILL, PA 17011-6322 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O4-, 5'3a e,v- ew'-- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are VICTORIA L REESE, an adult individual residing at 418 E MAIN ST CAMP HILL, PA 17011-6322. 3. Plaintiff, ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC, is the Assignee and Successor in Interest of Account #5176690013739185; and said account was issued to Defendant(s) by HSBC, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $2,238.46. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,238.46 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney fo tiff A Law Firm Emawd i Debt Collection Dated: 8/3/2009 BY: David J. AAoMaaker, Esquire Our File No.: 216025 VERIFICATION O URMU Q. Airnu hereby states that I am gzd Q--aegp nin tiy f for Plaintiff in this action., and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and convect to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa-C.SA 4904 relating to unworn falsification to authorities. Con, _ P1 DATE: ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC VICTORIA L REESE 418 E MAIN ST CAMP HILL, PA 17011-6322 STATEMENT OF ACCOUNT Debtor's Name: VICTORIA L REESE Account Number: 5176690013739185 Original Creditor: HSBC Balance Due: $2,238.46 Our File No.: 216025 EXHIBIT "A" 216025 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiff/s: Court Number: ATLANTIC CREDIT & FINANCE Expiration Date: INC. ASSIGNEE FROM HSBC Type of Action: Civil Action Defendant/s: VICTORIA L REESE Serve Upon: VICTORIA L REESE Address for Service: 418EMAIN ST CAMP HILL, PA 17011-6322 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () Posting Special Service Instructions: * * If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 CD 07 T' f. P?4 \ ?i V'1?P'i? 7 f ? 2009 1'040' - 1 1" 1 2' 1 's 7 ? 7s. so -;L(..Wl , ?K? ikY484 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant OFF1C."r. OF ` .:. -ERIFF OF THE ?"?THINOTARY 1009 AUG 19 AM 9: t 5 Edward L Schorpp Solicitor P&!#'VSYLVAN`W Atlantic Credit & Finance Inc. I Case Number vs. 2009-5532 Victoria L. Reese SHERIFF'S RETURN OF SERVICE 08/15/2009 09:54 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 15, 2009 at 0954 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Victoria L. Reese, by making known unto herself personally, at 418 E. Main Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 August 17, 2009 SO ANS S R THOMAS KLINE, SHERIFF Deputy Sheriff 10 Our File No.: 216025 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. VICTORIA L REESE Defendant Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, VICTORIA L REESE, in the default of an Answer, in the amount of $2,268.99 computed as follows: Amount claimed in complaint: Less: Amount Paid: Plus: Interest from August 3, 2009 to October 30, 2009 at the legal interest rate of 6.00% per annum Attorney fees TOTAL I certify that Defendant, VICTORIA L REESE, CAMP HILL, PA 17011-6322. $ 2,268.99 is 418 E MAIN ST David J. Apothaker, Esq. Attorney for Plaintiff NO.: 09-5532 $ 2,23 8.46 ( 0.00) 30.53 0.00 Dated: October 30, 2009 .. sI Our File No.: 216025 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ATLANTIC CREDIT & FINANCE INC ASSIGNEE FROM HSBC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. VICTORIA L REESE Defendant NO.: 09-5532 Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Dated: October 30, 2009 Attorney for Plaintiff i ' A. Our File No.: 216025 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ATLANTIC CREDIT & FINANCE INC ASSIGNEE FROM HSBC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. VICTORIA L REESE Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NO.: 09-5532 Civil Action . SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 418 E MAIN ST CAMP HILL, PA 17011-6322. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Def e Manpow Data Center has sent back our inquiry indicated that the Defendant(s) is/are not i t mili David J. Apothaker, Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. s Dcpartme . afDef apse Maspmer Data Center Oct-34-3449 0&0-415 Pursuant to the retire Mewbem M4 4 Relief Act < La31 vsaN>a & Regis Dare Acura Doty Status #tlivf Disfy tri DaOt Serene tiara S'1(?"IOR1,? Bzscd c? the aExrrtstion :ou hair finin:h??ci, the D\iL7+" &?cs n?•f Ewssc;; vr? a?i?rn?i?? L m&catmg the ixt-ku W stadus: LFpon the informabonNahabaal:s d the Depastued ofDefewe 1?laripower Data Center, braced ? ?' that you proki" the abac?e is the cored sW w of *e itsdn as to dbroacbes ofthe LWormed Servim Amy, N , a# Carps, An Farce, NOAA Pubk HeaW and Coast Guard)'. )f)jtkt?, ' . y j+ ' May K Smswby-Di%m Director Dqmhfted of Defense - tappoww Data Center 1604 Wilson Bbv d„ Suite W Afttow VA 22209-2191 The Defense Is wier Dam Center (D.MD? C) ins an+, orgesiamon of the cd`&c that mqWAW the e Etaohheeta and UpliTty Reportsp System EEILC) d e which is the afficial source of dista on cipWrf fix mk&T medical ewe and cstber ek*,bry system. The Doll smongl± -Tpom Ihe enFarcenumt of the S ict'sicm6c:s CR-3 RrwAn (50 L;SC App- 541 et so% as amended) (SCRA) (f-notch' kad" as the Sokters' and Sags' Cn$ R&TAct of 1940). aNM has is surd latndlreds of &Ammuh of 'dues not puma ern ' that the indivkiml is cwready active dude' teRwases. and has e:sperienced a small error rate. In the mmat The individual r6weaced above, or any famk nmriber> friend, or tepfrses asserts is any mgnuer that the in&idual is on active duty, or is othemtse carried to the Vtotections of the SC'ItA, you are stroooy tsceuaged to obtain hatter of the- ptx is tam by coawc* dot perms s SwAce via dte eta?' LW <wusv. _, #,yA mkt EssW I B$ had It you hem ?nidrace the pasaais on a d+ and y £al to obtaiat#us addifiowd Saaicr vri& abort, punitive provisions of the SCRA. may be in dwd 14*9 yra. Sec SQ USC App.. §531(c). V vcw obtain about the person (e.g , an SSN, i Wa ved accuracy of DCtT3, a aW& a ), ycas can wbtnit your rc*k%t again at that Web site and we wl provide a new certificate fix that quay. Tlis n-jpow runts, active tats oat" iach? dais the ` wars lash as active duty, irk was Within the preceding 36, days. For histor" iforination, pirwe contact the Swvice SCRA paw-cf=eo t- Mow i%&? on "Acdw Mirth-Stow' Active duty status as reported in this cat&an: is dc&zd in accordance rich 10 L; SC § 101(41) for a period of mare dean 34 +roits vdays- In the case ofa member cEthc National Crtsard kciodes "nice Cmder a rnh to err t ve sertitt _ authorizedbydie Prssi or the Seereraty of ? for a prod a?moce there 30 a days minx = X.'SC ? cr3.ifj fat set cf r to a slating c»cavcy s9erTared key die Presidrnt autd sigsfscxtcd tr; FcdcraD frstds. A/ Artie C?ra<d R.escnx (#1GR) members must be assigned ag-wnA an authorized mob&ta bi m imsAun ta the um the; sceppntt. This mckaks Navy TAU. Muni e Corps ARs and Coast Guard RPAs. Ac Dwq std abo q*ks to aUndamed Service member who is at artier duty voaonissicaed ofear of do US. P> c i~Tet $v%ice or hr National Octwir and Atmospheric Adatiistration (NOAA Cmmissioned Gawps) for a period of more than 34 co ve days. oftw me L'x kr hiss ScItA 13 ,t m4do M saw cam Coverage under the SCRA is broader a souse cases and i mAides some categories of persons on active dirty far purposes afthe SCRA who would rust be reported as co. oActive Duty ada &s cexhftcate. Mar tithes orders we amended to extend the period afactie daily; wbieh si oukl estrad SCr`RA protccbous. Persons seAM$ to achy c a dies wd3ite certifiatim should cheek to snake sus a the gadhets an which SCRA protection are based have not been. amended to esteem the i>dusive dates of senile. Fuc*harn m, a prcttsotiom of the $C PA my a ttendto persons srho hnv raeeikzd orders w report for active Any at to, be inducte& but who have aracra* begun active duty or actually reported fin wdoctieaa. The Last Date art Active fluty entry is " zopottant beta w e a of of SCRA extend beyond the I&A dates "f active duty, Those who wodd rely on this catiicate are trgr d to seek goaVwd k d cotmsa to ensue that at rights guaranteed ID SeMiCe membtrs, muter the SCRA are prctecte& WAP-NLdiCr This certificate was pmidcdbased on atm and. S%N provided by the requester- Prm c&ng an erroneous nnme or SSIX w1l cause an erroneous cute to be pms>vi&d ReportaWBFfa31v"l1A i 216025 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ATLANTIC CREDIT & FINANCE INC. ASSIGNEE ) COURT OF COMMON PLEAS FROM HSBC ) CUMBERLAND COUNTY VS. ) } NO. 09-5532 VICTORIA L REESE ) To: VICTORIA L REESE 418 E MAIN ST CAMP HILL, PA 17011-6322 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 08, 2009 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 V ID J. APOTHAKER, ESQUIRE THAKER & ASSOCIATES, PC I w Firm Engaged in Debt Collection L 520 Fellowship Road C306 ' Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 • r.h FLE1)4): ? - T" THE 41+.Oo pp, A7" ov,# ls8 359 p*d33a1.37 4 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: VICTORIA L REESE 418EMAIN ST CAMP HILL, PA 17011-6322 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff Vs. VICTORIA L REESE Defendant NOTICE NO.: 09-5532 Civil Action Pursuant to Rule 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. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 800-672-0215 f1/9/a9 r i? EO?OF?iC F THE PROTHONOTARY9 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan I.D. No. 47437 436 Seventh Avenue, 1400 Koppers Bldg Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9413022 2012 FEB -3 A 11: 38 Attorney for Plaintiff(s) CUMBERLAND COUNTY PENNSYLVANIA ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff vs. CUMBERLAND County Court of Common Pleas No.: 09-5532 VICTORIA L REESE Defendant(s) PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of the Plaintiff in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. B y William T. olcz Attorney for Plai ff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OFFeETi,E wERIFF Jody S Smith Chief Deputy Richard W Stewart Solicitor Atlantic Credit & Finance Inc. vs. Victoria L. Reese 7012 MAY 16 PM 2: 50 CUMBERLAND COON Y PENNSYLVANIA Case Number 2009-5532 SHERIFF'S RETURN OF SERVICE 05/14/2012 10:34 AM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on May 14, 2012 at 1030 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Victoria L. Reese, in the hands, possession, or control of the within named garnishee, Citizens Bank, 665 N East Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Janine Sheaffer, Teller Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on May 15, 2012 to Victoria L. Reese at 418 E Main Street, Camp Hill, PA 17011. SO ANSWERS, May 15, 2012 RON R ANDERSON, SHERIFF Ti lack, Deputy (C) GountySuite Sheriff, I eleosofit. Int.. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-5532 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ATLANTIC CREDIT & FINANCE INC SUCCESOR FROM HSBC Plaintiff (s) From VICTORIA L. REESE, 418 EAST MAIN STREET, CAMP HILL, PA 17011 (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: CITIZENS BANK, 665 NORTH EAST STREET, CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$2,110.77 L.L. $.50 Interest $65.58 Atty"s Comm % Atty Paid $165.50 Plaintiff Paid Due Prothy $2.25 Other Costs Date: MAY 8, 2012 (Seal) REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE David D. Buell, Prothonotary -_Bv• ? i / ?J Deputy Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT & FINANCE INC SUCCESSOR FROM HSBC Plaintiff vs. Civil Action No. 09-5532 r-: VICTORIA L REESE Lit (l PA DWI U) P Defendant(s) ':z - CITIZENS BANK (? ?j N /? 11013 IPA , Q ?? S+• l?r ?i SAC '< e :: Garnishee(s) A .- PRAECIPE FOR WRIT OF EXECUTION = c" o, TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against VICTORIA L REESE , Defendant 3. against CITIZENS BANK... Garnishee 4. Judgment Amount $ $2,268.99 Less Payments/credits received $ $158.22 -f a 110-77 Interest $ $65.58 Costs $ SUBTOTAL: $ $2,176.35 Costs (to be added by Prothonotary): WELTMAN, WEINBERG & REIS CO., L.P.A. a) P, 00 Pei 0 h? ?uu Iq >bit it a s o IQ ? (? 5. S0 P a I By:-1, Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 t4 57/4 P-It a-7q Yf7 WWR No. 9413022 W( ? b f & --Emu e.j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ATLANTIC CREDIT & FINANCE INC SUCCESSOR FROM HSBC Plaintiff vs. VICTORIA L REESE Defendant(s) CITIZENS BANK Garnishee(s) No. 09-5532 PRAECIPE FOR WRIT OF EXECUTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 9413022 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION C_k ... C!J ? _' r ATLANTIC CREDIT & FINANCE INC ti 5 CL) SUCCESOR FROM HSBC no rte.., ...._ ate- Plaintiff(s), _.; 09-5532 VS. VICTORIA L REESE Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS I to 12) 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, VICTORIA L REESE, with an available balance less than the Garnishee's Processing Fee of $125.00 and Statutory Exemption of $300.00, accordingly, no funds are being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Heather Zito who being duly sworn according to the law deposes and says that she is the Operations 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. ? ulL,??,- ? - --- Heather Zito Sworn and subscribed before me this day of &2 , 2012. L.UMMONWE,qLTM OF PENNSYLygNrq Bruce ?uotarlal Seal L D . ,'?oCin?o?; 1N0 Citr of Pi?Istxi - '?ublk M.. Y C'mrrtittiC,t (=xulre then Memntv ber, f'ennsvlva tan RlrcrraV?S Certificate of Service I, Heather Zito, 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 31 day of MAY, 2012. MATTHEW D URBAN, ESQ WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BLDG PITTSBURGH, PA 15219 Heather Zito 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION ATLANTIC CREDIT & FINANCE INC SUCCESOR FROM HSBC, Plaintiff(s), VS. VICTORIA L REESE, Defendant(s), VS. Citizens Bank of Pennsylvania, Garnishee. 09-5532 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 Great Valley Corporate Center 30 Valley Stream Parkway Malvern, PA 19355-1481 (484) 323-1351 (610) 640-1965 fax WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire I.D. No.47437 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9413022 Attorney for PlaintiTs) 111-10 +0 Tf''), ; ; CE2J `?I B P[4, 3:0I ter. BERLAND COUPS 3 4,_. ATLANTIC CREDIT & FINANCE INC. SUCCESSOR FROM HSBC VS. VICTORIA L REESE, and CITIZENS BANK Garnishee(s) CUMBERLAND County Court of Common Pleas NO. 09-5532 PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), CITIZENS BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By William T. Molczan, uire Attorney for Plainti OWN- sts?il?4 Ck-* 168 ?,?- a-1 lob S-