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HomeMy WebLinkAbout09-8050J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY 32"d & Chestnut Streets Philadelphia, PA 19107 V. NICOLE M. MONAHAN 20 Johns Drive Enola, PA 17025 PRAECIPE CUMBERLAND COUNTY COURT OF COMMON PLEAS 04 Kindly docket the attached Judgment in the amount of $3,966.88 in favor of Plaintiff, Drexel University, and against the Defendant, Nicole M. Monahan, for execution purposes only. J. SCOTT TSON, ESQUIRE Attorney for Plaintiff J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY 32" & Chestnut Streets Philadelphia, PA 19107 V. NICOLE M. MONAHAN 20 Johns Drive Enola, PA 17025 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; that Defendant, Nicole M. Monahan, is over eighteen (18) years of age, and resides at 20 Johns Drive, Enola, Pennsylvania 17025. SWORN TO AND SUBSCRIBED BEFORE ME THIS 13"*'- DAY OF(?? 2009. NOTARY ' COMMONWEALTH OF' NSV VAN1A J,V OTARIAL SEAL [LA q A?? cord TMALONEY Notarypublic mmission E ?eleS are County Pri 29,2010 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 DREXEL UNIVERSITY 32" & Chestnut Streets Philadelphia, PA 19107 V. NICOLE M. MONAHAN 20 Johns Drive Enola, PA 17025 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT I, J. Scott Watson, Esquire, hereby certifies that the debt in the above matter is valid, enforceable and unsatisfied to date. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 1DAY OF 2009. NOTARY COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL LAURA AiVN UALONEY Notary Public Concord TNp., Delaware County My Commission Expires April 29, 2010 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY 32nd & Chestnut Streets Philadelphia, PA 19107 V. NICOLE M. MONAHAN 20 Johns Drive Enola, PA 17025 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT I, J. Scott Watson, Esquire hereby certifies that the name and the last known address of Plaintiff and Defendant are as stated below: Plaintiff: Drexel University 32nd & Chestnut Streets Philadelphia, PA 19107 Defendant: Nicole M. Monahan 20 Johns Drive Enola, PA 17025 v l J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 3-11- DAY OF 2009. NOTARY COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL LAURA ANN MALONEY Notary Public Concord Twp., Delaware County My Commission Expires April 29, 2010 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY 32nd & Chestnut Streets Philadelphia, PA 19107 V. NICOLE M. MONAHAN 20 Johns Drive Enola, PA 17025 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NO APPEAL I, J. Scott Watson, Esquire, hereby certifies that the District Court judgement in the above matter was not appealed into a higher court to date. SWORN TO AND SUBSCRIBED BEFORE ME THIS 13'f_"--DAY 2009. NOTARY COMMONWEALTH OF PENNSYLVANIIN ELAURA OTARIAL SEAL MALONEY Notary Public wp. Delaware County ion Expires April 29, 2010 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No.: 09-1-03 MDJ Name: Hon. RICHARD S. DOUGHERTY Address: 98 S ENOLA DR STE 1 ENOLA, PA Telephone: (717 ) 728-2805 17025 DREXEL UNIVERSITY 24 REGENCY PLAZA C/O J.SCOTT WATSON, PC GLEN MILLS, PA 19342 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF ® Judgment was entered for: (Name) Judgment was entered against: (Name in the amount of $ 3,9661 F1 Defendants are jointly and severally liable. ? Damages will be assessed on Date & Time 1-1 This case dismissed without prejudice. P Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $_ Amount of Judgment $ 3,870.38 Judgment Costs $ 96.50 Interest on Judgment $ .00 Attorney Fees $ Total $ 3,966.88 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. JUN 11 2009 Date I certify that this is a tr nrJ In 2 2009 Date My commission expires first Monday of January, 2012 AOPC 315-07 DATE PRINTED: 11/02/09 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 7DREXEL UNIVERSITY 24 REGENCY PLAZA C/O J.SCOTT WATSON, PC LGLEN MILLS, PA 19342 J VS. DEFENDANT: NAME and ADDRESS FRONAHAN, NICOLE M 20 JOHNS DRIVE ENOLA, PA 17025 L J Docket No.: CV-0000131-09 Date Filed: 4/27/09 = i (Date of Judgment) 6/11/09 DREXEL UNIVERSITY MONAHAN, NICOLE M , Magisterial District Judge containing the judgment. , Magisterial District Judge 10:38:00 AM SEAL COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No.: 09-1-03 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rDREXEL UNIVERSITY 24 REGENCY PLAZA C/O J.SCOTT WATSON, PC LGLEN MILLS, PA 19342 J VS. DEFENDANT: NAME and ADDRESS rMONAHAN, NICOLE M 20 JOHNS DRIVE ENOLA, PA 17025 L J Docket No.: CV-0000131-09 Date Filed: 4/27/09 ' F MDJ Name. Hon. RICHARD S. DOUGHERTY Address: 98 S ENOLA DR STE 1 ENOLA, PA Telephone: (7 1.7 ) 728-2805 17025 ATTORNEY FOR PLAINTIFF : J. SCOTT WATSON, P.C. 24 REGENCY PLAZA GLEN MILLS, PA 19342 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF ® Judgment was entered for: (Name) Judgment was entered against: (Name) in the amount of $ 3,966.8 ? Defendants are jointly and severally liable. Damages will be assessed on Date & Time ? This case dismissed without prejudice. ? Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 3,870.3 Judgment Costs $?- 5 Interest on Judgment $ 0 Attorney Fees $? Total $ 3,966.88 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. JUN 11 2009 Date agisterial District Judge I certify that this is a tru and co py gs containing the judgment. Dat Magisterial District Judge My commission expires first Monday of January, 2012 SEAL. (Date of Judgment) DREXEL UNIVERSITY 6/11/09 MONAHAN, NICOLE M AOPC 315-07 DATE PRINTED: 11/02/09 10:38:00 AM BLEU-0FF CE f7 THE Per='fi'n IOTARY 2009 NOY 19 PI! 1: 21 PENNSYLvp, a7.?s 2- rn-?? )Uv41e-,F- I . OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Nicole M. Monahan 20 Johns Drive Enola, PA 17025 DREXEL UNIVERSITY 32°d & Chestnut Streets Philadelphia, PA 19107 V. NICOLE M. MONAHAN 20 Johns Drive Enola, PA 17025 CUMBERLAND COUNTY COURT OF COMMON PLEAS NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. JUDGMENT BY DEFAULT X MONEY JUDGMENT JUDGMENT IN REPLEVIN JUDGMENT FOR POSSESSION If you have any questions concerning this Judgment, please call J. Scott Watson, Esquire at 610-358-9600. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson -j~~{j..,`t,.;::g,,;~ Sheriff ` ~''-I ~- '~'~~i,~tA~ Qj~4it+' at C~iiit~e~~~~~ . Jody S Smith ~` Chief Deputy - ~~ ~ ~ ~#,~~; ~~ ~ 2 ; '~ j: l; ~ Edward L Schorpp Solicitor ~ ~,~fi C~ - _.~:: ~ ~•_',~-~`' i ; ; ~. =~ '~ ~ .', Drexel University vs. Case Number Nicole M Monahan 2009-8050 SHERIFF'S RETURN OF SERVICE 01/14/2010 03:25 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 14, 2010 at 1525 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Nicole M. Monahan in the hands, possession, or control of the within named garnishee, M & T Bank, 423 N Enola Road, Enola, Cumberland County, Pennsylvania 17025, by handing to Anita Long, Branch 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. Y " ~/ """ NOAH CLINE, DEPUTY January 21, 2010 SO ANSWE S, RO ANDERSON, SHERIFF rr,)G~u Sate SnF t 7 i-s: ~t. Enc. v • ' c J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 V!~ ~~ ~~ y~T,TM, 20lOFE8 -5 PM is 47 CUIVJ~L.~~..~'~u t~r~~}~y Att~~i~'~~~ntiff DREXEL UNNERSITY 32°d & Chestnut Streets Philadelphia, PA 19107 v. NICOLE M. MONAHAN 20 Johns Drive Enola, PA 17025 S.S.N. XXX-XX-1585 and M&T BANK 423 North Enola Road Enola, PA 17025 14NSw ~s `Tv CUMBERLAND COUNTY COURT OF COMMON PLEAS N0.09-8050 INTERROGATORIES IN ATTACHMENT TO: M&T Bank 423 N. Enola Road Enola, PA 17025 You are required to file answers to the following interrogatorieswithin 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 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 ? ....~-e S 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 ? ~q 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 as fiduciary any property in wh``i~~ch the Defendant had an interest ? ~V~" 5. At the time before or after you were served did Defendant 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 therefor? ~r, 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to the Defendant's direction or otherwise discharge any claim of the Defendant against you? ~~1 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant have any 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 attachrrient tinder Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant 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. Section 8123? If so, identify each account and the amount available in each account. ~~ 9. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, exceeded the amount of the general monetary exemption under 42 Pa.C.S. Section 8123? If so, identify each account and the amount available in each account. M ealan ~c~:~~ ~ g~~~4a~~ a-~( ~ ~ ~~~,23 ~ Tan°tR yep"O`'lcy~a 4°cUm~n ap~ons °t ~ne °St~a cess/ngg~~~s ;-• J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff ~A7"F"-i~'` i FISHER M&T BANK ~r ~~ ~ ~~ i f'. ~;; L~;~a F Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?;, of Z?itntliFr? OFI _. ALED-OF CE » 71 10S" -. PM Z:48 CUMB r? , ?JUNTY PS?i.YANIA Drexel University Case Number vs. 2009-8050 Nicole M Monahan SHERIFF'S RETURN OF SERVICE 01/14/2010 03:25 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 14, 2010 at 1525 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Nicole M. Monahan in the hands, possession, or control of the withir named garnishee, M & T Bank, 423 N Enola Road, Enola, Cumberland County, Pennsylvania 17025, by handing to Anita Long, Branch 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. 09/09/2010 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: $95.76 September 09, 2010 SO ANSWERS, RbNK'V R ANDERSON, SHERIFF By ?Udl '?Le Sharon R. Lantz a o? Pd SHERIFF'S OFFICE OF CUMBERLAND COUNTY roi GoumySuite ShenH, Telaosott. inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Drexel University 32ND & Chestnut Streets Philadelphia, PA 19107 Nicole M. Monahan 20 Johns Drive Enola, PA 17025 and vs. M&T BANK 423 N. Enola Road Enola, PA 17025 (Garnishee) TO THE PROTHONOTARY OF THE SAID COURT: ( ) Confessed Judgment (X) Other C-) a C) File No. 09-8050 -o-? Amount Due $3,966.88 - r 5 Interest to 12/11/10 - $357.01 - u n mQ Atty's Comm 7 ?> --? ° o Costs CDn C^ C:) rn y C= C) D 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 to Act 6 of 1974 as amended. Issue Writ of execution in the above matter to the Sheriff of Cumberland , County, for debt, interest and costs, upon the following described property of the defendant(s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) All accounts savings accounts monies on deposit safety deposit boxes and any other realty or personalty which may be subject to lew in the possession of the Garnishee M&T Bank at 423 N Enola Road Enola PA 17025 and belon in to the Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ( ) (indicate) Index the writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date Signature: Print Name: _ .Scott Watson Esquire Address: 24 Regency Plaza Glen Mills PA 19342 ,U4,50 r 9 S.11, CBF 01).a? a4. SO ty. co u a Ail qu. 0 X10`' Attorney for: Plaintiff Telephone: 610-359-9600 Supreme Ct ID 041060 S a. 00"010 to wry ? ? ,TssUed #At g ?D ab? ?g4 5?06o 3 X53 33S WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-8050 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DREXEL UNIVERSITY, Plaintiff (s) From NICOLE M. MONAHAN, 20 Johns Drive, Enola, PA 17025 (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: M & T BANK, 423 N. Enola Road, Enola, PA 17025 All checking accounts, savings accounts, monies on deposit, safety deposit boxes, and any other realty or personalty which may be subject to levy in the possession of the Garnishee. 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 $3,966.88 Interest to 12/11/10 -$357.01 Atty's Comm % Atty Paid $194.01 Plaintiff Paid Date: 1/7/11 (Seal) L.L. Due Prothy $2.00 Other Costs Dav d D. Buell, othonotary By: Deputy REQUFSTING PARTY: Name J. SCOTT WATSON, ESQUIRE Address: J. SCOTT WATSON P.C. 24 REGENCY PLAZA GLEN MILLS, PA 19342 PITTSBURGH, PA 15219 Attorney for: PLANTIFF Telephone: 610-359-9600 Supreme Court ID No. 41060 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson n o -'n , Sheriff G Jody SSmith - rn Chief Deputy Richard W Stewart --4 c) Solicitor z-n Co --n zF3 C) Drexel University C N b vs. Nicole M Monahan SHERIFF'S RETURN OF SERVICE Clow um wr 2009-8050 01/12/2011 10:10 AM - Sheldon Marshall, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2011 at 1010 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Nkcole M. Monahan, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 West High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Donna Egolf, Teller, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on January 13, 2011 to Nicole M. Monahan at 20 Johns Drive, Enola, PA 17025. SO ANSWERS, January 13, 2011 RON R A ERSON, SHERIFF Sheldon Marshall, Deputy Cj Cou-ySuite fe;erosoft. li•.,;. J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 DREXEL UNIVERSITY V. NICOLE M. MONAHAN Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 09-8050 ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, M&T Bank, discontinued upon payment of your costs only. P?1 1 .6D C'6/dye J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff Cag y SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??uys1M qT c?rrir?br??t?t? QFTI ? -RWr IF THE PRO ? ON ?` -y Af? 2011 AUG 23 PM 3: 53 CUMERLAND COUNTY PENNSYLVANIA Drexel University vs. Nicole M Monahan Case Number 2009-8050 SHERIFF'S RETURN OF SERVICE 01/12/2011 10:10 AM - Sheldon Marshall, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2011 at 1010 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Nicole M. Monahan, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 West High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Donna Egolf, Teller, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on January 13, 2011 to Nicole M. Monahan at 20 Johns Drive, Enola, PA 17025. 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: $86.99 SO ANSWERS, August 22, 2011 RON R ANDERSON, SHERIFF L! kl-r cj i,rur?g5aile ?::^e^'f ie:ec; ;'i I? c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION n PRAECIPE FOR WRIT OF EXECUTION ?C=: mw o Drexel University 32ND & Chestnut Streets Philadelphia, PA 19107 Nicole M. Monahan 20 Johns Drive Enola, PA 17025 and VS. MEMBERS FIRST F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 (Garnishee TO THE PROTHONOTARY The undersigned herel contract, or account based on a proceeding filed pursuant to A amended. Issue Writ of execs for debt, interest and costs, ( ) Confessed Judgment Z? n (X) Other -y v r-? <c? File No. 09-8050 aZ?{ Q4+•44 Amount Due $3,966.88 (les $ 069A -t -- :Interest toll/11/11-$575.1, Atty's Comm Costs THE SAID COURT: M_ -or- z° Q Qom` --tom certifies that the below does not arise out of a retail installment sale, ?nfession of judgment, but if it does, it is based on the appropriate original 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as in the above matter to the Sheriff of Cumberland , County, i the following described property of the defendant(s) P CIPE FOR ATTACHMENT EXECUTION Issue writ of attachme t to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attac ment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ( ) (indicate) Index the writ against the garnishee(s) as a lis pendens against real estate of the defendant() described in the attached exhibit. Date f1 3 b ji I PC I. S'6 7• z S' d-q. SO - t( $ a - $CE $ Go 313_s'o- Signature: Print Name: Address: Attorney for: Telephone: Supreme Ct ID J. Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Plaintiff 610-359-9600 041060 Ck9* 1.127 a&4008 0.2.0,0 120 . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-8050 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DREXEL UNIVERSITY, Plaintiff (s) From NICOLE M. MONiAHAN, 20 JOHNS DRIVE, ENOLA, PA 17025 (1) You are directed to levy pon the property of the defendant (s)and to sell (2) You are also directed ?attach the property of the defendant(s) not levied upon in the possession of MEMBERS FIRST F.C.U., 1166 WALNUT BOTTOM ROAD, CARLISLE, PA 17013 - ALL CHECKING ACCOUNTS SAVINGS ACCOUNTS, MONIES ON DEPOSIT, SAFETY DEPOSIT BOXES, AND ANY OTHER REALTY OR PERSONALTY WHICH MAY BE SUBJECT TO LEVY IN THE POSSESSION OF THE GARNISHEE AND BELONGING TO THE DEFENDANT 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 th reof; (3) If property of the defe ant(s) not levied upon an subject to attachment is found in the possession of anyone other than a name 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 $2496.99 L.L. Interest TO 11/11/11 - $57$.19 Atty's Comm % Due Prothy $2.00 Atty Paid $313.50 Other Costs: Plaintiff Paid Date: DECEMBER 27, 2011 David D. Buell, Prothonotary (Seal) 'V P Deputy REQUESTING PARTY: Name J. SCOTT W ATTON, ESQ. Address: 24 REGENCY PLAZA GLEN MILLS, A 19342 Attorney for: PLAINTIFF Telephone: 610-359-9600! Supreme Court ID No. 04060 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Drexel University vs. Nicole M Monahan SHERIFF'S OFFICE OF CUMBERLAND COUNTY i . ""'AN -6 PA SY C LVAh T Y Case Number 2009-8050 SHERIFF'S RETURN OF SERVICE 01/04/2012 10:05 AM - Gerald Worthington, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st FCU at 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Paula Breitenback - Member Service Rep., personally 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 January 5, 2012 to J. Scott Watson at 24 Regency Plaza at Glen Mills, PA 19342. SO ANSWERS, January 05, 2012 RON R ANDERSON, SHERIFF n Gerald Worthin n, Deputy J. SCOTT WATSON, P.C. RECEIVED BY: J. SCOTT WATSON, ESQUIRE FILED-OFFICE JAN 05 2012 Identification Number 41060 OF THE PROTHONOTARY 24 Regency Plaza 2012 JAN -6 AM 11: 22 Glen Mills, Pennsylvania 19342 (610) 358-9600 CUMBERLAND t-M' for Plaintiff PENN SYLVANIA DREXEL UNIVERSITY CUMBERLAND COUNTY 32' & Chestnut Streets COURT OF COMMON PLEAS Philadelphia, PA 19107 V. NICOLE M. MONAHAN 20 Johns Drive Enola, PA 17025 S.S.N. XXX-XX-1585 and MEMBERS FIRST F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 NO. 09-8050 INTERROGATORIES IN ATTACHMENT TO: Members First F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 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 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 ? 1P 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 ? f) 0 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 had an interest ? nc 5. At the time before or after you were served did Defendant 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 therefor? no 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to the Defendant's direction or otherwise discharge any claim of the Defendant 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 have any funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. nti 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant 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. Section 8123? If so, identify each account and the amount available in each account. n 01 9. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, exceeded the amount of the general monetary exemption under 42 Pa.C.S. Section 8123? If so, identify each account and the amount available in each account. T D J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff A MEMBERS 1st FEDERAL CREDIT UNION January 4, 2012 Nicole M. Monahan Shorey 409 Mountain Street Enola, PA 17025-2696 Review Dates (60 Days): November 6, 2011 - January 4, 2012 Total Writ of Execution: $3,385.68 Cumberland County Docket Number: 09-0850 File 4 Account Number: XXX773-0000 Name on Account: Nicole M. Shorey Savings: $5.00 -5.00 (Membership Fee) $0.00 Account Number: XXX773-0011 Name on Account: Nicole M. Shorey Checking: $1,430.15 -50.00 (Processing Fee) $1,380.15 Payroll: Newport School D - Jason Shorey $300.00 Statutory Exemption was not taken out. Tania S. Young Deposit Operations lyst Rev: 06/11 5000 Louise Drive - P.O. Box 40 - Mechanicsburg, Pennsylvania 17055 - (800) 283-2328 - www.memberslst.org A 1 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is Ta n is S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. J06". l' (SIGNAT RE) J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY CUMBERLAND COUNTY COURT OF COMMON PLEAS V. I- -) II C NICOLE M. MONAHAN NUMBER 09-8050 rnc" , T1- NO CD ORDER TO SATISFY JUDGMENT AGAINST GARNISHEE C-, TO THE PROTHONOTARY: ?' =T r? Kindly mark the judgment against Garnishee, Member's IS` Federal Credit Union, in the above matter as satisfied upon payment of your costs only. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff 4Q.50 Po ATW aIt 7862 8 01'a IRM7 f (610) 358-9600 Attorney for Plaintiff J. SCOTT WATSON, P.C. J THE PRO I HUNQTAR i BY: J. SCOTT WATSON, ESQUII2 AUG -I AM 9:31 Identification Number 41060 24 Regency Plaza CUMBERLAND COUNTY Glen Mills, Pennsylvania 19342 PENNSYLVANIA H LED-OFFICE DREXEL UNIVERSITY CUMBERLAND COUNTY COURT OF COMMON PLEAS V. NICOLE M. MONAHAN NUMBER 09-8050 PRAECIPE TO REASSESS DAMAGES TO THE PROTHONOTARY: Kindly reassess the damages in the above-captioned matter to reflect the following: Judgment Amount Post Judgment Interest Court Costs Payments Current Balance $ 3,966.88 $ 552.94 $ 630.75 2 750.04 $21400.53 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff 1 r J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 92218 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY CUMBERLAND COUNTY COURT OF COMMON PLEAS V. NICOLE M. MONAHAN NUMBER 09-8050 CERTIFICATION OF SERVICE I do hereby certify that service of a true and correct copy of the within Praecipe to Reassess Damages was made on the 3`a day of August, 2012, to the below-named individual by United States Mail, postage pre-paid. Nicole M. Monahan 409 Mountain Street Enola, PA 17025 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff J. SCOTT ~"A l VC~'~, P.C• BY: J. SCO"F~T WATS0~1, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Penns~-lyania 19342 (61.0) 3~8-9600 DREXEL UNIVERSITY { _ _ n. .. ,;, _ - - ~ .er{ ~ ~.~~ k Attorney for Plaintiff CUMBERLAND COU~;iTY COURT OF COMMON PLEAS v. NICOLE M. ?VIONAH.4~r NUMBEF; 09-805v ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE 1?ROTHONOTARY: Kindly mark the attachment against the Garnishee, Members First F.C.U,, discontinued upon payment of your costs only. _.-? J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff ~~sQ.sgx~a 1 C~ i~~os ~,~a8aa~~ ._........... i SHERIFF'S OFFICE OF CUMBERLAND COUNTY .,nny R Anderson Sherifft :rar Jody S Smith Chief Deputy Richard W Stewart Solicitor OFPCEOF��r �JMITBEF�L A ice.`T 'PMSYL1VAf41 ,,. r Drexel University Case Number vs. 2009-8050 Nicole M Monahan SHERIFF'S RETURN OF SERVICE 10/09/2012 11:08 AM-William Cline, Deputy Sheriff,who being duly sworn according to law, states that on October 9,2012 at 1108 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant,to wit: Nicole M. Monahan, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania, by handing to Merlinda Wilkins, Member Service Representative, 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 October 10, 2012 to Nicole M. Monahan at 409 Mountain Street, Enola, PA 17025, 06/03/2013 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: $88.35 SO ANSWERS, a June 03, 2013 RON _ R ANDERSON, SHERIFF ;cu^?y o;' Sheriff.7e;snso`.'...,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Drexel University : ( ) Confessed Judgment 32ND&Chestnut Streets : (X)Other Philadelphia,PA 19107 n vs. : File No. 09-8050 MCC rn— Nicole M. Monahan : Amount Due $2,400.53 ? M, 20 Johns Drive : Interest to 7/7/13 - $1.32.02 Enola,PA 17025 : Atty's Comm and : Costs n C54, __ CD M&T BANK rQ 423 N. Enola Road s n Enola,PA 17025 (Garnishee) ' 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 to Act 6 of 1974 as amended. Issue Writ of execution in the above matter to the Sheriff of Cumberland , County, for debt, interest and costs, upon the following described property of the defendant(s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the Garnishee, M&T Bank, 423 N. Enola Road, Enola, PA 17025 for the following property(if real estate, supply six copies of the description; supply four copies of lengthy personalty list) All checking accounts,savings accounts,monies on deposit, safety deposit boxes,and any other really or personalty which may be subject to levy in the possession of the Garnishee,M&T Bank,423 N.Enola Road, Enola,PA 17025 and belonging to the Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ( )(indicate)Index the writ against the garnishee(s)as a lis pendens against real estate of the defendant(s)described in the attached exhibit. Date I? Signature: l Print Name: J. Scott Watson,Esquire Address: 24 Regency Plaza 60/p Glen Mills,PA 19342 f'11 '�`�' Attorney for: Plaintiff is.-7(p OF Telephone: 61.0-359-9600 U.99 It 0 Sol' Supreme Ct ID 041060 tj p g.00 h t, � •�� a4,so<<p . . �S8. 35" " k(o .So« Via h 'aS "�"� a S N 44 C.5044 of 4. 00 12# QqsRug WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-8050 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due DREXEL UNIVERSITY Plaintiff(s) From NICOLE M.MONAHAN,20 JOHNS DRIVE,ENOLA,PA 17025 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: M&T BANK,423 N.ENOLA ROAD,ENOLA,PA 17025,ALL CHECKING ACCOUNTS, SAVINGS ACCOUNTS,MONIES ON DEPOSIT,SAFETY DEPOSIT BOXES,AND ANY OTHER REALTY OR PERSONALTY WHICH MAY BE SUBJECT TO LEVY IN THE POSSESSION OF THE GARNISHEE,M&T BANK,423 N.ENOLA ROAD,ENOLA,PA 17025 BELONGING TO THE DEFENDANT and to notify the garnishees)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; (2) 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$2,400.53 Plaintiff Paid$ Interest TO 7/7/13-$132.02 Attorney's Comm. % Law Library$ Attorney Paid$582.96 Due Prothonotary$2.25 Other Costs$ Date: 8/1/13 31 , David D.Buell,Prothonotary Deputy REQUESTING PARTY: Name :J.SCOTT WATSON,ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS,PA 19342 Attorney for: PLAINTIFF Telephone: 610-359-9600 Supreme Court ID No.41060 SHERIFF'S OFFICE OF CUMBERLAND COUNTY =, Ronny R Anderson -v , Sheriff ��;�1�,� Jody S Smith 61 Chief Deputy CO , Richard W Stewart "V CD Solicitor- OFFICE OF THE Vr_R!rF, T C") CA) Drexel University vs. Case Number Nicole M Monahan 2009"8050 SHERIFF'S RETURN OF SERVICE 0810712013 10:50 AM-William Cline, Deputy,who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts,.credits, and-.monies of the Defendant, in the hands, possession, or control of the within named garnishee, M&T Bank, 1 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Donna Egolf, Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The-writ of execution and notice to defendant was mailed on August 8, 2013 to Nicole M. Monahan at 409 Mountain Street, Enola, PA 17025(attorney provided envelope with their return address). NOTE: Mail sent to this address in 2012 was returned back by the Post Office marked"unable to forward": It is unknown whether defendant will receive paperwork. WILLIAM CLINE, DEPUTY SO ANSWERS, August 08, 2013 ANDERSON, SHERIFF (c)CountySuite Sheriff,Teteosoit,Inc. J.SCOTT WATSON,P.C. BY: J. SCOTT WATSON,ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills,Pennsylvania 19342 (610)358-9600 Attorney for Plaintiff DREXEL UNIVERSITY CUMBERLAND COUNTY 32"&Chestnut Streets COURT OF COMMON PLEAS Philadelphia,PA 19107 V. NICOLE M. MONAHAN Z5 MW 20 Johns Drive -M C= rr4 Enola,PA 17025 ;0;:' C:) S.S.N.XXX-XX-15 85 and M&TBANK E 423 North Enola Road Enola,PA 17025 N0. 09-8050 7-7 INTERROGATORIES IN ATTACHMENT TO: 'M&T Bank 423 N. Enola Road '-&AA(!K Enola, PA 17025 PO4 N4 ASOV 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 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? �->- 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? M At T BANK HAS NO OPEN ACCOUNTS FOR ABOVE NAMED 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 as fiduciary any property in which the Defendant had an interest? 5. At the time before or after you were served did Defendant 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 therefor? 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to the Defendant's direction or otherwise discharge any claim of the Defendant against you? 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant have any funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption,the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. M &T BANK HAS NO OPEN ACCOUNTS FOR ABOVE NAMED Y 8. If you are a bank or other financial institution, at the time you were served or at any. subsequent time did the Defendant 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. Section 8123? If so, identify each account and the amount available in each account. ) 9. If you are a bank or other financial institution,at the time you were served or at any subsequent time did the Defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt.funds, exceeded the amount of the general monetary exemption under 42 Pa.C.S.Section 8123? If.so,identify each account and the amount available in each account. Melissa Ba eters J. SCOTT WATSON,ESQUIRE Attorney for Plaintiff M & TBANK HAS No OPEN ACCOuwTs i FOR ABOVE NAMED 'AUG 1 Z1013 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills,Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY • CUMBERLAND COUNTY• OF COMMON PLEAS v. • e:: a NICOLE M. MONAHAN • NUMBER 09-8050 'y ORDER TO DISCONTINUE ATTACHMENT EXECUTION -jr L c) TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, M & T Bank, discontinued upon payment of your costs only. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff y d/4- . (- /7/9G -ti4/5fq SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,2 Anderson t' ;0 3 xt ai rrrrrta ,t46. S Smith f t _ ief Deputy ' ' <ichard W Stewart 3E;Lhs t± 1 F f . . n - Solicitor �E r'+i�S Y LYA t�l;� Drexel University Case Number vs. Nicole M Monahan 2009-8050 SHERIFF'S RETURN OF SERVICE 08/07/2013 10:50 AM -William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, M&T Bank, 1 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Donna Egolf, Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on August 8, 2013 to Nicole M. Monahan at 409 Mountain Street, Enola, PA 17025 (attorney provided envelope with their return address). NOTE: Mail sent to this address in 2012 was returned back by the Post Office marked "unable to forward". It is unknown whether defendant will receive paperwork. 03/03/2014 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: $88.75 SO ANSWERS, March 03, 2014 RONNY R ANDERSON, SHERIFF .2. a,r . Cep . -� 9,SA3y ,per 3d.2 1173 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION -0Z rnco zr tnr D Amount Due: $2,400.53 ..?C -)..c) Interest to 7/7/14 - $276.oz Costs $191.71 -< DREXEL UNIVERSITY 32nd & Chestnut Streets Philadelphia, PA 19107 v. NICOLE M. MONAHAN 550 Yorkshire Place Enola, PA 17025 TO THE PROTHONOTARY OF THE SAID COURT: Money Judgment No. 09-8050 p co 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 to Act 6 of 1974 as amended. Issue Writ of execution in the above matter to the Sheriff of Cumberland , County, for debt, interest and costs, upon the following described property of the defendant(s) All contents of Defendant's residence, including but not limited to all furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, televisions, tools, and any other property which may be subject to levy. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ( ) (indicate) Index the writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date -$38.50 PD 4-rN 8G, .Q4 613F' • 87, (o( " • 88.3r 11 es. 75 '► d'7.(25 64.50 " , 14.00 " a$.Oo t' 8. oo " . aLt. so up.so " 9.50 " aa.cou► f V /47/Signature: a-1. co - CBF 4.50 - '► -71-0F47;77-1711f f�iurrn-r 9S.z(0- ? - Pr 'mg Print Name: Address: Attorney for: Telephone: Supreme Ct ID c.#1.3t049.2 I,06-1-oE4 aw d J. Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Plaintiff 610-359-9600 041060 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717)240-6195 www.ccpa.net DREXEL UNIVERSITY 32' & Chestnut Streets Philadelphia, PA 19107 Vs. NO 09-8050 Civil Term CIVIL ACTION — LAW NICOLE M. MONAHAN WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against NICOLE M. MONAHAN, 550 Yorkshire Place, Enola, PA 17025, Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; All contents of Defendant's residence, including but not limited to all furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, televisions, tools and any other property which may be subject to levy.. (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as 1 determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $2,400.53 Interest to 7/7/14 -- $276.06 Attorney's Comm. % Attorney Paid $709.71 Date: 8/8/14 REQUESTING PARTY: Name : J. SCOTT WATSON, ESQUIRE Address: J. SCOTT WATSON, P.C. 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-359-9600 Supreme Court ID No. 041060 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs $191.71 "Itx,eC David D. Buell, Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2