HomeMy WebLinkAbout04-2475THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES HEARING
REQUIRED.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
By: PAUL M. SCHOFIELD, JR.,ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
Palisades Acquisition IV,
LLC, as successor in interest
to OST, Inc. and First North
American National
vs.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET N0.: Oq - ay7S CuZ'?- ?
SueAnn Foushee
3-B Richland Ln - Apt # 208
Camp Hill, PA 17011
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 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
THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES HEARING
REQUIRED.
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
By: PAUL M. SCHOFIELD, JR.,ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
Palisades Acquisition IV, COURT OF COMMON PLEAS
LLC, as successor in interest CUMBERLAND COUNTY
to OST, Inc. and First North
American National
vs.
SueAnn Foushee
3-B Richland Ln - Apt # 208
Camp Hill, PA 17011
DOCKET NO.: Off{ - , dSj7
COMPLAINT IN CIVIL-ACTION
1. 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 plaintiff under the terms of
which the plaintiff agreed to extend to defendant(s)the use of
plaintiff's credit facilities.
2. 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 plaintiff for the use of said credit
card.
3. 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 Plaintiff. A true and correct copy
of the Statement of Account is attached hereto as Exhibit "A".
4. All the credits to which the defendant(s)is entitled have
been applied and there remains a balance due in the amount of
$1,785.07.
5. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $1,785.07 but the defendant(s)has
failed and refused and still refuses to pay the same or any part
thereof.
WHEREFORE, plaintiff claims of the defendant(s) the sum of
$1,785.07 at the rate of 6%- from the date of October 9, 2000,
together with costs and attorney fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I W NB ERG, ESQUIRE
PAUL M. S IELD, JR.,ESQUIRE
Attorney(s) for Plaintiff
P01A
VERIFICATION
FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the
attorney for the Plaintiff(s) in this action and verifies that the
statements made in the foregoing pleading are true and correct to
the best of his knowledge, information and belief.
The undersigned understands that the statements herein are
made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating
to unsworn falsification to authorities.
BY:
FREDERIC I. WEINB G, ESQUIRE
PAUL M. SC OF JR.,ESQUIRE
Attorney(s) for Plaintiff
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SHERIFF'S RETURN - REGULAR
CASE NO: 2004-02475 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PALISADES ACQUISITION IV
VS
FOUSHEE SUEANN
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
FOUSHEE SUEANN the
DEFENDANT at 1605:00 HOURS, on the 11th day of June , 2004
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
by handing to
SUE ANN FOUSHEE
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 10.35
Affidavit .00
Surcharge 10.00
.00
38.35
Sworn and Subscribed to before
pSo
me this day of
o2lfa y A`.pD D.
rothonootary ry
Answers:
R. Thomas Kline
06/14/2004
GORDON & WEINBERG
By:
Deputy Sheriff
GORDON & WEINBERG, P.C.
By: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
Palisades Acquisition IV, LLC, COURT OF C
as successor in interest to OST OMMON PLEAS
Inc., and First North American CUMBERLAND COUNTY
National
vs.
Sueann Foushee DOCKET NO.: 04-2475 CIVIL
PRAECIPE FOR JUDCDNT
The Prothonotary will please enter Judgment in the above
matter by default for want of an answer against the Defendant,
SUEANN FOUSHEE, and assesseg"2t ages as per statement below.
FREDERIC I WE BERG, ESQUIRE
Attorney o laintiff
Principal $1,785.07
Interest from October 9, 2000
@6$ $409.95
Total: $2,190.02
I hereby certify that written notice of the intention to
file this Praecipe was mailed or delivered to the parties against
whom judgment is to be entered and to his attorney of record, if
any, after the default occurred an t least ten (10) days prior
to the date of the filing of th' Pr Ea-
FREDERIC I. WEINB RG QUIRE
Filed: Attorney for Plaintiff
By the Prothonotary:
AND NOW, this day of J -- 2004
Judgment is entered in favor of the plaintiff s) and against
defendant, for want of an answer and damages Assessed at time of
trial.
Prothonotary
GORDON & WEINBERG, P.C.
By: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
Palisades Acquisition IV, LLC,
as successor in interest to OST,
Inc., and First North American
National
Vs.
Sueann Foushee
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.: 04-2475 CIVIL
NOTICE
PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU
ARE HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED
AGAINST YOU IN THE ABOVE PROCEEDING. IF YOU HAVE ANY QUESTIONS
CONCERNING THIS NOTICE, PLEASE CALL FREDERIC I. WEINBERG, ESQUIRE
AT 215/988-9600.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. WE ERG, ESQUIRE
Attorne Plaintiff
Dated: July 20, 2004
GORDON & WEINBERG, P.C.
By: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
Palisades Acquisition IV, LLC,
as successor in interest to OST COURT OF COMMON PLEAS
Inc., and First North American CUMBERLAND COUNTY
National
Vs.
Sueann Foushee DOCKET NO.: 04-2475 CIVIL
CERTIFICATION OF ADDRESS
I hereby certify that the precise residence of the holder of
the within judgment is; Palisades Acquisition IV, and that the
last known address of defendant, SUEANN FOUSHEE, 3-B RICHLAND
LN--APT # 208, CAMP HILL PA 17011-4825.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. BERG, ESQUIRE
Attorney for Plaintiff
GORDON & WEINBERG, P.C.
By: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
Palisades Acquisition IV, LLC,
as successor in interest to OST,
Inc., and First North American
National
V5.
Sueann Foushee
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.: 04-2475 CIVIL
AFFIDAVIT OF NON-MILITARY SERVICE
FREDERIC I. WEINBERG, ESQUIRE, being duly sworn according to
law, deposes and says that he represents the plaintiff in the
above-entitled case; that he is authorized to make this affidavit
on behalf of the plaintiff; and that the above-named defendant is
over twenty-one years of age; that the address of the defendant
is, 3-B RICHLAND LN--APT # 208, CAMP HILL PA 17011-4825; that the
occupation of the defendant is unknown; and that the defendant is
not in the Military Service of the United States, nor any State
or Territory thereof or its allies as defined in the Soldiers'
and Sailors' Civil Relief Act of 1940 and the amendments thereto.
Sworn to and Subscribed
Before me this
_ Day
of
2009.
Notary Public
SEAL
F-NNOOTARIAL
MEN L VAIOERA. Nd" PAC
n 'P F 25.20 C FREDERIC WEIN G, ESQUIRE
Attorney aintiff
GORDON & WEINBERG, P.C.
By: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
21 SOUTH 21 ST STREET
PHILADELPHIA, PA 19103
215/988-9600
Palisades Acquisition IV, LLC, as successor in interest
to OST, Inc., and First North American National
%s.
SueAnn Foushee
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.: 04-2475 CIVIL
NOTICE OF INTENTION TO TAKE DEFAULT
TO/PARA SUEANN FOUSHEE
DATE OF NOTICE/FECHA DEL AVISO: July 2, 2004
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:
PIOD FREDERIC I. WEINBE ESQ E
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2004-02475 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PALISADES ACOUISITION IV
VS
FOUSHEE SUEANN
And now CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0010:25 Hours, on the 25th day of January , 2005, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
FOUSHEE SUEANN in the
hands, possession, or control of the within named Garnishee
MEMBERS FIRST FEDERAL CREDIT UNI
00 LOUISE DRIVE
MECHANICSBURG, PA 17055
Cumberland County, Pennsylvania, by handing to
LOU V. HER ACCOUNT INVESTIGATOR
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to His .
Sheriff's Costs
Docketing .00
Service .00
Affidavit .00
Surcharge .00
nn
U0
R. Thomas Kline`
Sheriff of Cumberland County
00/00/0000
Sworn and subscribed to before me
this z,?e day cf.9,c_
?fao? A.D.
1
P t onotary '
By
Deputy Sheriff
4^
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQ. &
PAUL M. SCHOFIELD, JR., ESQ.
I.D.#41360 & 81894
21 SOUTH 2151 STREET
PHILADELPHIA, PA 19103
ATTORNEYS FOR PLAINTIFF
(215) 988-9600
PALISADES ACQUISITION IV, LLC, AS COURT OF COMMON PLEAS
SUCCESSOR IN INTEREST TO OST, INC., CUMBERLAND COUNTY
AND FIRST NORTH AMERICAN NATIONAL
2101 WEST BEN WHITE BLVD.
AUSTIN, TX 78704
VS.
SUEANN FOUSHEE
3-B RICHLAND LN - APT # 208
CAMP HILL, PA 17011
and
MEMBERS FIRST FEDERAL CREDIT UNION
5000 LOUISE DRIVE
MECHANICSBURG, PA 17055 - GARNISHEE
NO. 04-2475 CIVIL TERM
PRAECIPE FOR JUDGMENT UPON ADMISSION
TO THE PROTHONOTARY:
Please enter judgment in favor of the Plaintiff, PALISADES ACQUISITION IV, LLC, AS
SUCCESSOR N INTEREST TO OST, INC., AND FIRST NORTH AMERICAN NATIONAL and
against the Garnishee, MEMBERS FIRST FEDERAL CREDIT UNION, in the amount of $106.52,
admitted in the Answer to Interrogatories to be in the Garnishee's possession, together with interest
and costs. The amount of the judgment of the Plaintiff against the Defendant is $2,190.02.
DATED: ' 0
JR., ESQUIRE
Attorney for Plaintiff
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQ. &
PAUL M. SCHOFIELD, JR., ESQ.
I.D. #41360 & 81894
21 SOUTH 21s` STREET
PHILADELPHIA, PA 19103
ATTORNEYS FOR PLAINTIFF
(215) 988-9600
PALISADES ACQUISITION IV, LLC, AS COURT OF COMMON PLEAS
SUCCESSOR IN INTEREST TO OST, INC., CUMBERLAND COUNTY
AND FIRST NORTH AMERICAN NATIONAL
2101 WEST BEN WHITE BLVD.
AUSTIN, TX 78704
VS.
SUEANN FOUSHEE
3-B RICHLAND LN - APT # 208
CAMP HILL, PA 17011
and
MEMBERS FIRST FEDERAL CREDIT UNION
5000 LOUISE DRIVE
MECHANICSBURG, PA 17055 - GARNISHEE
NOTICE
NO. 04-2475 CIVIL TERM
PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE
HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED AGAINST
YOU IN THE ABOVE PROCEEDING.
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL PAUL M.
SCHOFIELD, JR., ESQUIRE 215-988-9600.
' GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQ. &
PAUL M. SCHOFIELD, JR., ESQ. ATTORNEYS FOR PLAINTIFF
I.D. #41360 & 81894
21 SOUTH 21" STREET
PHILADELPHIA, PA 19103
(215) 988-9600
PALISADES ACQUISITION IV, LLC, AS COURT OF COMMON PLEAS
SUCCESSOR IN INTEREST TO OST, INC., CUMBERLAND COUNTY
AND FIRST NORTH AMERICAN NATIONAL
2101 WEST BEN WHITE BLVD.
AUSTIN, TX 78704
vs.
SUEANN FOUSHEE
3-13 RICHLAND LN - APT # 208
CAMP HILL, PA 17011 NO. 04-2475 CIVIL TERM
and
MEMBERS FIRST FEDERAL CREDIT UNION
5000 LOUISE DRIVE
MECHANICSBURG, PA 17055 - GARNISHEE
INTERROGATORIES IN ATTACHMENT
TO: MEMBERS FIRST FEDERAL CREDIT UNION GARNISHEE
1. You are required to file answers to the following Interrogatories within twenty (20) days after
service upon you. Failure to do so my result in judgment against you.
2. At the time you were served or at any subsequent time did you owe the defendant(s) any money
or were you liable to him (her, them) on any negotiable or other written instrument, or did he (she,
they) claim that you owed him (her, them) any money or were liable to him (her, them) for any
reason?
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?
4. At the time you were served or at any subsequent time did you hold a fiduciary any property
in which the defendant(s) had any interest?
ifJO .
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 what
was the consideration thereof?
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? lx. .
7. How Nut I the value of any property in your posses n elonging t e'defendant(s)? eln6 $
DATE Attorney(s) for Plaintiff(s)
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GORDON & WEINBERG, P.C.
BY: FREDERIC L WEINBERG, ESQ. &
PAUL M. SCHOFIELD, 7R., ESQ. ATTORNEYS FOR PLAINTIFF
I.D.#41360 & 81894
21 SOUTH 21" STREET
PHILADELPHIA, PA 19103
(215) 988-9600
PALISADES ACQUISITION IV, LLC, AS COURT OF COMMON PLEAS
SUCCESSOR IN INTEREST TO OST, INC., CUMBERLAND COUNTY
AND FIRST NORTH AMERICAN NATIONAL
2101 WEST BEN WHITE BLVD.
AUSTIN, TX 78704
vs.
SUEANN FOUSHEE
3-13 RICHLAND LN - APT # 208
CAMP HILL, PA 17011 NO. 04-2475 CIVIL TERM
and
MEMBERS FIRST FEDERAL CREDIT UNION
5000 LOUISE DRIVE
MECHANICSBURG, PA 17055 - GARNISHEE
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
(2) against
SUEANN FOUSHEE
defendant(s) and
MEMBERS FIRST FEDERAL CREDIT UNION
garnishee(s)
(3) AMOUNT DUE $2.190.02
INTEREST
from $
(Costs to be added) $
J
TOTAL $
Attorney(s) for Plaintiff(s)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption: 4S4's 11visiliB Oki
VS.
Sveabn Foos4p-
va, Qtj-
(?eln 4(s Fr(Sf
( ) Confessed Judgment
( ) Other
File No. Amount Due a Fd
Interest
Atty's Comm
UAQuI Slff, costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant pto Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of {,otn .,(Jdf) - County,
for debt, interest and costs, upon the followng described property of the defendant(s)
9 n ill
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of P40 Lef( +&n County, for debt, interest and
costs, as above, directing attachment against the above-name arnishee(s or the following property (if real
estate, supply six copies of the description; supply four copies o y personalty list)
5?w of- Odnl6sbt(i I Pal 17655
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
I (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date I Signature:
Print Name:
Address:
Attorney for:
Telephone:
Supreme Court ID No.:
(over)
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 04-2475 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION-LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PALISADES ACQUISITION IV, LLC AS
SUCCESSOR IN INTEREST TO OST, INC., AND FIRST NORTH AMERICAN NATIONAL
Plaintiff (s)
From SUEANN FOUSHEE, 3-B RICHLAND LN - APT # 208, 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 MEMBERS FIRST FEDERAL CREDIT UNION, 5000 LOUISE DRIVE, MECHANICSBURG,
PA 17055
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 $2,190.02 L.L. $.50
Interest
Any's Comm % Due Prothy $1.00
Arty Paid $120.85 Other Costs
Plaintiff Paid
Date: JANUARY 18, 2005
CURTIS R. LONG
Prothon
tary
o
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(Seal)
Deputy
REQUESTING PARTY:
Name FRED WEINBERG, ESQUIRE
Address: 21 S 21sT ST.
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-988-9600
Supreme Court ID No. 41360
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
TXCO0326
Palisades Acquisition IV, LLC
Successor in Interest to OST,
Inc. and First North American
National
2101 WEST BEN WHITE BLVD
AUSTIN, TX 78704
vs.
SUEANN FOUSHEE
2544 Alessandro Blvd
Harrisburg PA 17110
and
Belco Community CU
5304 Carlisle Pike
Mechanicsburg, PA 17050
GARNISHEE
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 04-2475 CIVIL
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
SUEANN FOUSHEE
(2) against
defendant(s)and
Belco Community CU
garnishee(s)
(3) AMOUNT DUE $2,190.02
INTEREST
from July 26, 2004 $684.24
COSTS
Prothonotary fee
Sheriff fee
TOTAL
FREDERIC I. IN RG, ESQUIRE
JOEL M. FLINK, SQUIRE
Attorney for Plaintiff
O
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*a 4-so Po A-r'r/
38.35 CSF
55,50 w
q.Oo
15. 50 "
Q. oo •'
$ 151.85 - PD ATr-y
$a.oo l-ue Cc
mod- of &k .a,?
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
L.L.
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PALISADES ACQUISITION IV, LLC, Successor in
Interest to OST, INC., and FIRST NORTH AMERICAN NATIONAL, Plaintiff (s)
From SUEANN FOUSHEE, 2544 Alessandro Blvd, Harrisburg, PA 17110
(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:
BELCO COMMUNITY CU, 5304 Carlisle Pike, Mechanicsburg, PA 17050
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 $2,190.02
Interest from 7/26/04 -- $684.24
Atty's Comm %
Atty Paid $151.85
Plaintiff Paid
Date: 6/22/09
(Seal)
REQUESTING PARTY:
Name FREDERIC I. WEINBERG, ESQUIRE
Address: GORDON & WEINBERG, P.C.
1001 E. HECTOR STREET, SUITE 220
CONSHOHOCKEN, PA 19428
Attorney for: PLAINTIFF
Telephone: 484-351-0500
Supreme Court ID No. 41360
Due Prothy $2.00
Other Costs
By:
NO 04-2475 Civil
CIVIL ACTION - LAW
.AAAf.L k.
R. Long, Prothonotary
Deputy
Sheriffs Office of Cumberland County
R Thomas Kline Edward L Schorpp
Sheriff?? {d?# Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy Civil Process Sergeant
Palisades Qcquisition IV, LLC, Successor in Interest to OST, Inc., and Case Number
vs. 2004-2475
Sueann Foushee
SHERIFF'S RETURN OF SERVICE
06/26/2009 12:02 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June
26, 2009 at 1158 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Sueann Foushee, in the hands, possession, or control of the
within named garnishee, Belco Community Credit Union, 5304 Carlisle Pike, Mechanicsburg, Cumberland
County, Pennsylvania 17050, by handing to Christine M. Reidlinger, Branch Coordinator, 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 June 29, 2009 to Sueanne Foushee at 2544
Alessandro Blvd, Harrisburg, PA 17110.
2004-2475
Palisades Acquisitions IV., LLC
vs
Sueann Fourshee
So Answers,
R, lnomas F. ne, Sheriff
By ?-
Deputy Sheriff
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TX000326
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
Palisades Acquisition IV, LLC
Successor in Interest to OST,
Inc. and First North American
National
VS.
SUEANN FOUSHEE
and
Belco Community CU
Garnishee
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 04-2475 CIVIL
PRAECIPE TO DISSOLVE ATTACHMENT
TO THE PROTHONOTARY:
Kindly dissolve the attachment of the defendant's bank
account with Belco Community CU, as Garnishee in the above
entitled matter.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. E ERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
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Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Edward L Schorpp
Solicitor
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QFF7 :E ';' - RIFF
PLEI vE
a_ ,`NIOTAPY
2010 MAR 29 PM ?: 07
CUi? :AUNTY
Palisades Qcquisition IV, LLC, Successor in Interest to OST, Inc., and Case Number
vs. 2004-2475
Sueann Foushee
SHERIFF'S RETURN OF SERVICE
06/26/2009 12:02 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June
26, 2009 at 1158 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Sueann Foushee, in the hands, possession, or control of the
within named garnishee, Belco Community Credit Union, 5304 Carlisle Pike, Mechanicsburg, Cumberland
County, Pennsylvania 17050, by handing to Christine M. Reidlinger, Branch Coordinator, 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 June 29, 2009 to Sueanne Foushee at 2544
Alessandro Blvd, Harrisburg, PA 17110.
03/2912010 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: $90.66
March 29, 2010
SO ANSWERS,
&Z
`--?
RON R ANDERSON, SHERIFF
B
aron R. Lantgz
?? Ways
,P?'r a 3?G9/
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
(Ci CounrySuite Shenfl. I e eosoft, Inc.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-2475 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PALISADES ACQUISITION IV, LLC, Successor in
Interest to OST, INC., and FIRST NORTH AMERICAN NATIONAL, Plaintiff (s)
From SUEANN FOUSHEE, 2544 Alessandro Blvd, Harrisburg, PA 17110
(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:
BELCO COMMUNITY CU, 5304 Carlisle Pike, Mechanicsburg, PA 17050
and to notify the garnishee(s) ghat: (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 $2,190.02
Interest from 7/26/04 -- $684.24
Atty's Comm %
Atty Paid $151.85
Plaintiff Paid
Date: 6/22/09
L.L.
Due Prothy $2.00
Other Costs
(Seal)
REQUESTING PARTY:
Name FREDERIC I. WEINBERG, ESQUIRE
Address: GORDON & WEINBERG, P.C.
1001 E. HECTOR STREET, SUITE 220
CONSHOHOCKEN, PA 19428
Attorney for: PLAINTIFF
Telephone: 484-351-0500
Supreme Court ID No. 41360
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
Palisades Acquisition IV, LLC
Successor in Interest to OST,
Inc. and First North American
National
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS. DOCKET NO. :104-2475 CIVIL
SUEANN FOUSHEE
SUGGESTION OF BANKRUPTCY OF DEFENDANT
TO THE PROTHONOTARY:
AND NOW, this November 3, 2010, it is suggested of record
that Defendant, SUEANN FOUSHEE, filed a petition in bankruptcy
under Chapter 7 of the Bankruptcy Code on or about November 2,
2010, in the United States Bankruptcy Court for'-the Middle
District of Pennsylvania, docket number 10-08670. Therefore,
this matter should be stayed until further notice.
RG, ESQUIRE
IRE
Attorney for Plaintiff
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. WEI E
JOEL M. ESQU