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HomeMy WebLinkAbout09-6496M 2055523 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 Atlantic Credit & Finance Inc. Assignee from Aspire 2727 Franklin Road Roanoke, VA 24014 COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. DONNY L THOMAS 106 E. GARFIELD STREET SHIPPENSBURG PA 17257-1906 DOCKET NO. (? - (pyQ(p C-v, I E 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT IN CIVIL-ACTION 1. Plaintiff is a debt buyer and successor in interest to the original creditor as set forth in the caption of this Complaint. 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 merchand- ise 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 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 September 9, 2009 in the amount of $2,180.12. 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 06/26/2006. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,180.12 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. INB G, ESQUIRE JOEL M. FLINK QUIRE Attorney for Plaintiff P01A.Db 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. 1193 2055523 Atlantic Credit & Finance Inc. Assignee from Aspire DONNY L THOMAS 4791070123121806 AFFIDAVIT I, CAMERON GRAY, 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. After allowing for all offsets and credits, a balance remains on the subject account having account number 4791070123121806in the amount of $2,180.12; and. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. n CAMERON orney Relationship Manager Atlantic Credit & Finance, Inc. Sworn to and Subscribed before me this day of _Mf/LLJ? 20 Notary Pd blic t?SLYN e?q00 `' G?' ''NOTARY '• Cy :, PUBLIC • ?a REG. 72?eoo1 k * •. MY COMIASSION : Q EXPIRES 2` • ?'? •. 6/30/2013 a ca, ???"NWEALTN ?????, oIloilo$W 0 ALL) IC 20`4 SI r 2'8 P ? J 12: 2 P.x?" d„3r r a9 Sheriffs Office of Cumberland County R Thomas Kline FLED-OPE F OF TH": 4ttit?tr p ;0T-?n1P\1DTAR SheriffY cat 4:i3n?rr/at? Ronny R Anderson 2009 OCT _7 F 3; Chief Deputy Jody S Smith Cw _ ;hy t?% Civil Process Sergeant 'Pv?Y! !/? ` Edward L Schorpp Solicitor Atlantic Credit & Finance, Inc. vs. Donny L. Thomas Case Number 2009-6496 SHERIFF'S RETURN OF SERVICE 10/05/2009 04:55 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 5 2009 at 1655 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donny L. Thomas, by making known unto himself personally, at 409 S. Fayette Street Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to hirr personally the said true and correct copy of the same. SHERIFF COST: $64.00 October 06, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Depot Sheriff dv ,NW GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2055523 Atlantic Credit & Finance Inc Assignee from Aspire VS. DONNY L THOMAS COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-6496 PRAECIPE FOR ENTRY OF JUDGMENT FOR WAN!' OF AN ANSWER, ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $2,180.12 Less: Payments on Account ( $.00) Total: $2,180.12 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: Atlantic Credit & Finance Inc.Assignee from Aspire and that the last known address of defendant, DONNY L THOMAS, 106 E. GARFIELD STREET, SHIPPENSBURG PA 17257-1906. 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. AND NOW, this 1Q4"- day of 2009 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer and damages assessed at the sum of , $2,180.12 as per the above certification. Prothonotary GORDON & WEINB G,,P. BY: FREDERIC''I.?'W NBERG, ESQUIRE JOEL M. LINK, ESQUIRE Attorn for Plaintiff 2055523 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 Atlantic Credit & Finance Inc. Assignee from Aspire Vs. DONNY L THOMAS TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-6496 NOTICE OF INTENTION TO TAKE DEFAULT DONNY L THOMAS 106 E. GARFIELD STREET SHIPPENSBURG PA 17257-1906 DATE OF NOTICE/FECHA DEL AVISO: October 27, 2009 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 : FREDERICf I. WEINBERG, ESQUIRE JOEL M: FLINK, ESQUIRE PLOD-2 pL ra OF TNc pROTHONOTARY 2009 NOV {9 PM l: 36 CUM, _ .. u;?uldl`Y PENNSYLVAPIA y IIti.od 3d. Aa-I e? 97o4y Z? a,338oI 2055523 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 Atlantic Credit & Finance Inc. Assignee from Aspire VS. DONNY L THOMAS 106 E. GARFIELD STREET SHIPPENSBURG PA 17257-1906 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-6496 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. /X/ , Judgment by Default $2,180.12 11 Money Judgment $ Judgment on Award of Arbitrators$ L1 Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 - 11-% U/14/0? GORDON & WEINBERG, P.C. 2055523 BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 FILED-OFFICE JOEL M. FLINK, ESQUIRE OF THE PROTHONOTARY Identification No.: 41200 1001 E. Hector Street, Ste 220 2010 DEC 15 AN 9:41 Conshohocken, PA 19428 484/351-0500 CUMBERLAND COUNTY PENNSYLVANIA Atlantic Credit & Finance Inc. COURT OF COMMON PLEAS Assignee from Aspire CUMBERLAND COUNTY 2727 Franklin Road Roanoke, VA 24014 vs. DOCKET NO. : 09-6496 DONNY L THOMAS 106 E. GARFIELD STREET SHIPPENSBURG PA 17257-1906 and Orrstown Bank 22 South Hanover St. Carlisle, PA 17013 GARNI$8SE PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against DONNY L THOMM defendant(s)and (2) against Orrstown Bank garnishee(s) (3) AMOUNT DUE $2,180.12 INTEREST from November 19, 2009 $136.74 COSTS Prothonotary fee Sheriff fee (4) Less: Payments on Account ( $.00) TOTAL ??/_ ??c?.Sb AJ wl, hbxry ? f?Nu? A8? a 7Sr -s& A+j 43, SO PG/ *i) '44 dttt 01, S61 It /L-? /___ -)- FREDERIC I. INB G, ESQUIRE JOEL M. FLINK, QUIRE Attorney for Plaintiff t38aSS tk4t c#d? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-6496 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ATLANTIC CREDIT & FINANCE INC. Plaintiff (s) From DONNY L. THOMAS AT 106 E. GARFIELD STREET, SHIPPENSBURG, PA 17257-1906 (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 ORRSTOWN BANK AT 22 SOUTH HANOVER STREET, CARLISLE, PA 17013 GARNISHEE(S) as follows: 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 $2,180.12 Interest FROM NOVEMBER 19, 2009 --$136.74 Atty's Comm % Atty Paid $183.50 FEE Plaintiff Paid Date: 12115/10 (Sea]) L.L. $.50 Due Prothy $2.00 Other Costs PROTHONOTARY FEE, SHERIFF David . Buell, Prothotg" By. U1 Im Deputy REQUESTING PARTY: Name FREDERIC I. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, P.C. 1001 E. HECTOR STREET, STE 220 CHONSHOHOCKEN, PA 19428 Attorney for: PLANTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?y Jody S Smith Chief Deputy 1, Richard W Stewart Solicitor t CU PEE S'f r 2'G W 11 P., Atlantic Credit & Finance, Inc. vs. Case Number Donny L. Thomas 2009-6496 SHERIFF'S RETURN OF SERVICE 01/03/2011 02:30 PM - Tim R. Black, Deputy Sheriff, who being duly sworn according to law, states that on January 3, 2011 at 1430 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Donny L. Thomas, in the hands, possession, or control of the within named garnishee, Orrstown Bank, 22 South Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Michael B. Byerly, Branch Executive Officer, 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 him. The writ of execution and notice to defendant was mailed on January 4, 2011 to Donny L. Thomas, 106 E. Garfield Street, Shippensburg, PA 17257-1906. SO ANSWERS, January 04, 2011 RON R ANDERSON, SHERIFF Ti R. Black, Deputy 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 tizlantic Credit & Finance Inc. COURT OF COMMON PLEAS Assignee from Aspire CUMBERLAND COUNTY 2727 Franklin Road Roanoke, VA 24014 vs. DOCKET NO. : 09-6496 DONNY L THOMAS 106 E. GARFIELD STREET SHIPPENSBURG PA 17257-1906 and Orrstown Bank 22 South Hanover St. Carlisle, PA 17013 GARNISHEE GARNISHEE'S ANSWERS TO INTERROGATORIES IN ATTACHl?NT TO: Orrstown Hank - GARNISHEE 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. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? No. 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest. No. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had an interest? 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefore? Yes. Deposits made to checking account. No consideration paid therefor. 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to his(her, their) direction or otherwise discharge any claim of the defendant(s) against you? No. 7. 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 of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. No. 8. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant(s) have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. §8123? If so, identify each account. No. 9. How much is the value of any property in your possession belonging to the defendant(s)? *SEE BELOW* FR . EDERIC I NBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff DATED: 9. $423.57 less garnishment fee of $135.00 AS TO OBJECTIONS , . David A. Baric, Esquire I.D. # 44853 Baric Scherer 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 VERIFICATION I verify that the statements made in the foregoing Garnishee's Answers To Interrogatories In Attachment are true and correct to the best of my knowledge, information and belief. This verification is signed by David A. Baric, Esquire, Attorney for Garnishee, Orrstown Bank and is based upon the statements provided by Garnishee, Orrstown Bank, as well as documents reviewed by the undersigned as attorney for Garnishee, Orrstown Bank. I undersigned that false statements herein are made subject to penalties of 18 Pa.C.S. §4904, relating to unsworn falsifications to authorities. r David A. Baric, Esquire Date: January 5, 2011 CERTIFICATE OF SERVICE I hereby certify that on January 5, 2011, I, David A. Baric, Esquire of Baric Scherer, did serve a copy of the Garnishee's Answers To Interrogatories In Attachment, by first class U. S. mail, postage prepaid, to the parties listed below, as follows: Frederic I. Weinberg, Esquire Gordon & Weinberg, P.C. 1001 East Hector Street, Suite 220 Conshohocken, Pennsylvania 19428 David A. Baric, Esquire 2055523 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 ; =i Conshohocken, PA 19428 484/351-0500 M Atlantic Credit & Finance Inc. COURT OF COMMON PLEAS--e> Assignee from Aspire CUMBERLAND COUNTY " ;7t : VS. DOCKET NO. 09-6496 DONNY L THOMAS and Orrstown Bank Garnishee PRAECIPE TO DISSOLVE ATTACffiMZNT TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant's bank account with Orrstown Bank, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. BY: FREDERIC I. W NBERG ESQUIRE JOEL M. FLIN , ES RE Attorney for intiff PO11 48.00 PA Arty a* 14!010 0 a,537gS- 7 H E- s'AROTHONOTARY GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2MM9013 -4 PM 1: 30 CUMBERLAND COUNTY PENNSYLVANIA Atlantic Credit & Finance Inc. COURT OF COMMON PLEAS Assignee from Aspire CUMBERLAND COUNTY VS. DOCKET NO. : 09-6496 DONNY L THOMAS SUGGESTION OF BAMMUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this 25Febll, it is suggested of record that Defendant, DONNY L THOMAS, filed a petition in bankruptcy under Chapter 13 of the Bankruptcy Code on or about February 22, 2011, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 11-01169. Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: FREDERIC EINBERG, ESQUIRE JOEL M. NK, ESQUIRE Attorney for Plaintiff L SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff NERFILED-OFFICE tsl,; J ?i{tA?FPf THE TAF?'' Jody S Smith OF Chief Deputy 2011 AUG 23 PM 3: 53 Richard W Stewart Solicitor OFD F CUMBERLAND COUNTY PENNSYLVANIA Atlantic Credit & Finance, Inc. Case Number vs. Donny L. Thomas 2009-6496 SHERIFF'S RETURN OF SERVICE 01/03/2011 02:30 PM - Tim R. Black, Deputy Sheriff, who being duly sworn according to law, states that on January 3, 2011 at 1430 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Donny L. Thomas, in the hands, possession, or control of the within named garnishee, Orrstown Bank, 22 South Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Michael B. Byerly, Branch Executive Officer, 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 him. The writ of execution and notice to defendant was mailed on January 4, 2011 to Donny L. Thomas, 106 E. Garfield Street, Shippensburg, PA 17257-1906. 08/22/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.50 SO ANSWERS, August 22, 2011 RONNrY R ANDERSON, SHERIFF ,;,r,'. Ccun?gSufte 5r:er.`.f. fei,,^soft. Inc. ,? 3 ?3