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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 c.7 L' Td ? V C Tj 'l ?J r, i G 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 70 8 y ? P?- r: y T 'l N ?n T K 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) L ?-?? ?? Q r' #? G ` .... -s? W ? d 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) V ?1 ,?9 op ?? C/? flT V-1 ? c 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 yy? (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 !.l f *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 C ? ?? w Co r co ;jrt, N 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 P011 FILED 1. 70TARY 2 0 0 9 Jd ? 28 A t"i 9: 2 f} cum 48.00 PO A-IT4 ex* 8(8'71 R.T* o2c?85CR Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor `vrd????tT of .tnti(,rryalr? 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