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HomeMy WebLinkAbout09-8370Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA M TROUTMAN :NO. - 8370 l v' ( Tex m 700 Nailor Drive, Camp Hill PA 17011-7469 Defendant CIVIL ACTION -LAW Complaint - 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 (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 claim set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 C-29072 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD 57117 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 0 9- 93 7 6 CHRISTINA M TROUTMAN 700 Nailor Drive, Camp Hill PA 17011-7469 Defendant CIVIL ACTION - LAW Complaint 1. Plaintiff is CITIBANK (SOUTH DAKOTA), N.A., with place of business located at 701 East 60th Street North, Sioux Falls, South Dakota. 2. Defendant is Christina M Troutman, who resides at 700 Nailor Drive, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff is a national banking association, engaged in various types of banking business including consumer lending through the issuance of credit cards. 4. Plaintiff furnished consumer credit to the defendant by means of a(n) AT&T Universal credit card with account number ending in 4922 hereinafter referred to as the credit card account. 5. Plaintiff kept accurate running records of all debits and credits to the account. 6. Plaintiff mailed to defendant monthly statements for the account including the billing statement attached hereto as Exhibit A. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 7. Before plaintiff mailed Exhibit A, defendant had for many months made payments on account of the billing statement or retained the statement without payment. 8. Defendant's actions as set forth above constituted an account stated between parties for the sum of $11,591.44 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. Wherefore, plaintiff demands judgment against defendant for the sum of $11,591.44, and the costs of this action. Burton Neil & Asso O*s, P.C. The law firm of Burton Neil & Associates, P.C. is a debt collector. ? i By. E O rien, Esquire Attorney for Plaintiff a N ? N YY ?OX ?V M m C_ A V0. F 6 'O a j a P i 0 O Ila O to w • i a • IL v e o S ! ,,,4 0 .y 8 8 ? uPi u?i ,n O ?+ d° ?? 1 m N ° m N O O O p t{7? 8 8 >e C G ? O ? O ? 01 Z 6 ,w 7 , tr pp O 8 O C O rn } 62 :w ` N N O p ? a a 1 8 < ?7 a "g A q P6 J§ <L6 ?a ao? 0 0 0 0 O N O N ? r v+ 0. .ti uq g'cti N N m 3 7A au ?oY t o :$ a? m '" o o >$ £oa N 4 .1 1 NO C A A ON die, • y eT ar E E' dd° ? $ a y t ; c a $ H J „ d °; ? N st s eJe, q„d I o 7 O 0 (A •0 V CM V -.6 A o C A aain Z r? 2 A < sV icc Z, CL It 0 Y Li O 5 N o > M > owe dt n'o 'S 1f a r a v e row xHO> N 'salt Iw'7 ___-_ BngVM1I WM7 ______-_ chKk a oetaD eM takes ywewnt Ilwtteetwlw so reWMe wake etwek wrakle wAT&T Universal Card w balance: T l N t ?Y a e o =?'M / 4922 VV Enelasad: .t Minimum Amount Due: A4 :TUM Payment Due Date; PwTeet n"t ee react" w s:oo rw 00110/20" Wei tone on the p"Mat d1w Me. 000000 MC 32 A 0 CHRISTINA M TROUTMAN 700 NAILOR DRIVE AT&T UNIVERSAL CARD 108 P.O. BOX 162564 CAMP HILL PA17011.7469 COLUMBUS, OH 43218.2564 EXHIBIT 8 w a ? Oq V • X ? ?? m? a y O <O s. vain z 'o rc r f 4 i F- VI M SP U f W bi N v O Ea?? V 2 d L d N v „qy N O ?6 c 0 0 `c m r d p o ?- Z`o A V 7 i+ 4°c Verification I, Mark Molinarin , am employed by Citicorp Credit Services, Inc. (USA) (hereafter CCSI), a subsidiary of plaintiff, Citibank (South Dakota), N.A. CCSI is a service provider for plaintiff in that it services credit card accounts owned by plaintiff. I am authorized to make this verification on behalf of plaintiff. The statements of facts set forth in the complaint are true and correct upon my information and belief and are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. AMA Signature C-29072 Christina M Troutman Account number ending in 4922 1000 0 2009 DEC -3 Pl i f : g $'78.5o Pa A.l1ry &*4 103191 gr* a3y 47(0 L)oket.ua.-1j PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff V. CUMBERLAND COUNTY, PENNSYLV ANIA CHRISTINA M TROUTMAN 1230 Roberts Valley Rd 108, Harrisburg PA 17110 Defendant(s) NO. 09-8370 MEMBERS FIRST FCU a "? - - 1000 Bryn Mawr Road, Carlisle PA 17013-1588 u rr" C= . Garnishee(s) CIVIL ACTION -LAW ?%r- To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER _ 1. Directed to the Sheriff of Cumberland County, Pennsylvania C ' ° 2. against CHRISTINA M TROUTMAN , Defendant(sy" - 3. and against MEMBERS FIRST FCU , Garnishee(s) 4. and index this writ (a) against , Defendant(s) (b) against , Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows s (specifically describe property) 4aq.oo PAATlq NO LEVY - GARNISHMENT ONLY 41. so car 78. & of Serve interrogatories on garnishee at: 1000 Bryn Mawr Road, Carlisle PA 17013-1588 1q,00 a -so « 5. Amount Due $11,541.44 Interest from 01/20/2010 $ 1,585.33 ?(o5.5D -PA ATIV Credit $ 550.00 Total $12,576.77* / *Plus writ costs Dated: June 5, 2012 M)fard 4!O'Br n, Esquire a1, as >D Attorney for mtiff D ,5o U, NOTE: Under paragraph I when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. C? laaa.yy C-29072 Q*d??o598 61y&d WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-8370 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK (SOUTH DAKOTA) N.A., Plaintiff (s) From CHRISTINA M. TROUTMAN, 1230 Roberts Valley Rd 108, 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: MEMBERS FIRST FCU, 1000 Bryn Mawr Road, Carlsiel, PA 17013-1588 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 $10,991.44 Interest from 1/20/10 -- $1,585.33 Atty's Comm % Atty Paid $165.50 Plaintiff Paid Date: 6/11/12 (Seal) L.L. $.50 Due Prothy $2.25 Other Costs David D. Buell, Prothonotary .fly: ?(i? .L e C/A11L Deputy REQUESTING PARTY: Name : EDWARD J. O'BRIEN, ESQUIRE Address: BURTON NEIL & ASSOCIATES PC 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No. 32985 110 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32 1060 Andrew Drive, Suite 170 West Chester, PA 19380 WO 610-696-2120 i'll Y l V?'1? 1 JUN Is =I Attornev for Plaintiff CITIBANK (SOUTH DAKOTA), N.A Plaintiff CHRISTINA M TROUTMAN 1230 Roberts Valley Rd 108, Harrisburg PA 171 10 Defendant(s) MEMBERS FIRST FCU Garnishee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8370 CIVIL ACTION -LAW To: MEMBERS FIRST FCU 1000 Bryn Mawr Road, Carlisle PA 17013-1588 Interrogatories to Garnishee You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant or 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? 1/1S 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 owed solely or in part by the defendant? ?QS 3. If the answer to 1 and/or 2 is yes, pleas specs the nature of the property and, if money, the amount? V lC-f 2151_1;7 4. 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? P5, 2-W (e4 scJbrr Ton - roi r looq ?01010 ?s?s?l3. 75 E' 5. At the time you were served or at any subsequent time did you hold as fiduciary any property in which defendant had an interest? No 6. At any time before you were served did the defendant transfer or deliver any property to you or any person or place pursuant to your direction or consent and if so what was the consideration therefor? 7. 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? 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 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. no 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 funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. e5 C, C ZS 7. LC, 01V 6 4`60 Burton By: The firm of Burton Neil & Associates, P.C. is attempting to collect a de SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff "n ri ?tr Jody S Smith t' Chief Deputy ^,t 5 e+ i -s' _ FJl a Richard W Stewart Solicitor OFF C6' -'-F , -ERIF Citibank (South Dakota) N.A. Case Number vs. Christina M. Troutman 2009-8370 SHERIFF'S RETURN OF SERVICE 06/15/2012 11:20 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 15, 2012 at 1120 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Christina M. Troutman, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Lottie d. Loe, Head 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 June 18, 2012 to Christina M. Troutman, 1230 Roberts Valley Road, Harrisburg, PA 17110. SO ANSWERS, June 18, 2012 RON R ANDERSON, SHERIFF Noah Cline, Deputy (c) CountySuite Sheriff- Teiecsoft. Inc. Burton Neil & Associates P.C.? F JUN i $ 2Q1& By: Edward J. O'Brien, Esquire ID. NO. 398 t?Q 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Ef:'ldS Y1P, l ; ,? r Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. IN THE COURT OF COMMON PLEAS Plaintiff V. CHRISTINA M TROUTMAN 1230 Roberts Valley Rd 108, Harrisburg PA 17110 Defendant(s) MEMBERS FIRST FCU Garnishee CUMBERLAND COUNTY, PENNSYL ANIA k NO. 09-8370 rnm 2rr, G r- CIVIL ACTION -LAW .,C cJ a To: MEMBERS FIRST FCU _ C s 1000 Bry_ Mawr Road, Carlisle PA 17013-1588 o Interrogatories to Garnishee You are required to file answers to the following interrogatories within twenty (20) 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 money or were you liable to the defendant or any negotiable or other written instrument, or c defendant claim that you owed the defendant any money or were liable to the defendant for reason? eS 2. At the time you were served or at any subsequent time was there in your possessi custody or control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owed solely or in part by the defendant? S 3. If the answer to I and/or.2 is yes, plea specs the nature of the property and, if the amount? SA Ul c l?)&I ICS Z 57 7 3 3'A, 4. At the time you were served or at any subsequent time did you hold legal title to property of any nature owned solely or in part by the defendant or in which defendant held c any interest? ?s, Z? ? sc?vrn Zo ? -car i?a ? t?- r after the 300 tfxp claimed /(' rt CD 5. At the time you were served or at any subsequent time did you hold as fiduciary any property in which defendant had an interest? 03 6. At any time before you were served did the defendant transfer or deliver any prope to you or any person or place pursuant to your direction or consent and if so what was the considera ion therefor? 7. At any time after you were served did you pay, transfer or deliver any money or p operty to the defendant or to any person or place pursuant to the defendant's direction or otherwise di harge any claim of the defendant against you? 8. If you are a bank or other financial institution, at the time you were served or at y subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit e exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identi each account and state the reason for the exemption, the amount being withheld under each exem tion and the entity electronically depositing those funds on a recurring basis. n0 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 funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. es X 25 7.;-7 4--s cu Hwy r?L( Burton N By: The firm of Burton Neil & Associates, P.C. is attempting to collect a de LQ 1 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 328~ 1060 Andrew Drive, Suite 170 4 West Chester, PA 19380 =fir f 'Et i1L }1GI 610-696-2120 ??? S LVf, 1, Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. CHRISTINA M TROUTMAN 1230 Roberts Valley Rd 108, Harrisburg PA 17110 Defendant(s) MEMBERS FIRST FCU Garnishee /4A JUN 18 201t, REM JUL 1 2012 IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNS NO. 09-8370 CIVIL ACTION -LAW To: MEMBERS FIRST FCU 1000 Bryn Mawr Road, Carlisle PA 17013-1588 Ame.Ct6L 40 Interrogatories to Garnishee C rn, crs? > c i a You are required to file answers to the following interrogatories within twenty (20) 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 defenc money or were you liable to the defendant or any negotiable or other written instrdm ?, defendant claim that you owed the defendant any money or were liable to the dJgJ$d= reason? eS zm G cn r ..._ -<> rn 0 2. At the time you were served or at any subsequent time was there in Lm p s custody or control or in the joint possession, custody or control of yourself and;d& ora persons any property of any nature owed solely or in part by the defendant? ?, -, -< -- ANIA r rn Lvs after any id the LL?y . rn (fit 3. If the answer to 1 and/or 2'isf/yes, pleas speci the nature of the property and, i money, ?,a\ S the amount? ?? v 11 NIp ?i? ?(G?j f-?CQ? ?, ?? a 34b,1-1 ? o U J ?`' r ? 7 4. At the time you were served or at any subsequent time did you hold legal title to any property of an), nature owned solely or in part by the defendant or in which defendant held or claimed any interest? rs, 2-00 r(7, r lD?? lCf? C'D ??1?. <" RECEM® JUG 10 zn 5. At the time you were served or at any subsequent time did you hold as fiduciary any property in which defendant had an interest? )JO 6. At any time before you were served did the defendant transfer or deliver any prop rty to you or any person or place pursuant to your direction or consent and if so what was the conside Zn therefor? 7. At any time after you were served did you pay, transfer or deliver any money or the defendant or to any person or place pursuant to the defendant's direction or otherwise d any claim of the defendant against ;you? 8. If you are a bank or other financial institution, at the time you were served or at subsequent time did the defendant have funds on deposit in an account in which funds are electronically on a recurring basis and which are identified as being funds that upon deposi exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identi account and state the reason for the exemption, the amount being withheld under each exec the entity electronically depositing those funds on a recurring basis. n0 9. If you are a bank or other financial institution, at the time you were served or at subsequent time did the defendant have funds on deposit in an account in which funds on c including any otherwise exempt funds, did not exceed the amount: of the general monetary under 42 Pa.C.S. § 8123? If so, identify each account. -7 7-7 Burton N & As ?` E a d By: 1 3?0 e a ?--4s The fi.rrn of Burton Neil & Associates, P.C. is attempting to collect a de , P.C. Esquire to are y each ption and not ion Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. CHRISTINA M TROUTMAN Defendant and MEMBERS FIRST FCU Garnishee a iLL?-y tit r GL HE THONOTAni-I TAn 7012 JUL 23 PM 2: 17 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-8370 CIVIL ACTION - LAW Praecipe for Judgment Against Garnishee To the Prothonotary: Kindly enter judgment in favor of plaintiff, CITIBANK (SOUTH DAKOTA), N.A., against garnishee, MEMBERS FIRST FCU, for the amount admitted in its possession in the attached Answers to Interrogatories in the total sum of $2046.17. Burton Neil & By: AND NOW this 09 3 day of `?At EOV S J Attorney P.C. , Esquire , 201,% judgment is hereby in favor of plaintiff, CITIBANK (SOUTH DAKOTA), N.A. , and against garnishee, FIRST FCU, in accordance with the attached Answers to Inte atones in the total sum of $2046.17. Prothonotary In making this communication, we advise that our firm is a debt collector. C-29072 ann? •IL.Sbpd ON a 9 2qo ??? ?1a.Jeg SHERIFF'S OFFICE OF CUMBERLAND COUNTY Anderson ody S Smith Chief Deputy Richard W Stewart Solicitor a .r °r --F -jRiCF 1.7 7. f 11 F7 Citibank (South Dakota) N.A. vs. Christina M. Troutman ZDP AUC -3 PM I2: 41 ;.,CUMBERLAND COUPlI"i, PENNSYLVANIA Case Number 2009-8370 SHERIFF'S RETURN OF SERVICE 06/15/2012 11:20 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 15, 2012 at 1120 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Christina M. Troutman, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Lottie d. Loe, Head 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 June 18, 2012 to Christina M. Troutman, 1230 Roberts Valley Road, Harrisburg, PA 17110. 08/03/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per request of plaintiffs attorney. SHERIFF COST: $124.11 SO ANSWERS, August 03, 2012 RON R ANDERSON, SHERIFF (c) CountvSuite Sheriff, Teleosoft. Inc. 0? - -?S-? - e? - F LtO--OFFIC : THE PROTHONOTAR 2012 AUG -8 PM 1: 4 C1MBERLAND COUNTY PENNSYLVANIA Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. Plaintiff V. CHRISTINA M TROUTMAN Defendant and MEMBERS FIRST FCU Garnishee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-8370 CIVIL, ACTION - LAW Praecipe to Satisfy Judgment Against Garnishee To the Prothonotary: Kindly mark the judgment against garnishee MEMBERS FIRST FCU, in the above matter, SATISFIED on payment of your costs only. Burton it & As ciates, P.C. By: _ E O'Brien, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates is a debt collector. C-29072 / 315 ajjf s9.apdaNy ? icy Tom` C-29072 / 232 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) c c --� Pa.R.C.P. § 3103 to 3149 CITIBANK (SOUTH DAKOTA), N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff v. CHRISTINA M TROUTMAN 1230 Roberts Valley Rd, Harrisburg PA 17110-1764 Defendant(s) MEMBERS FIRST FCU 1000 Bryn Mawr Road, Carlisle PA 17013-1588 Garnishee(s) IN THE COURT OF COMMON PL CUMBERLAND COUNTY, PENNS,ANCLD '�� 1m w "' : NO. 09-8370 : CIVIL ACTION LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. against CHRISTINA M TROUTMAN , Defendant(s) 3. and against MEMBERS FIRST FCU , Garnishee(s) 4. and index this writ (a) against Defendant(s) (b) against Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) NO LEVY - GARNISHMENT ONLY Serve interrogatories on garnishee at: 1000 Bryn Mawr Road, Carlisle PA 17013-1588 5. Amount Due Credit Interest from January 20, 2010 Total *Plus writ costs Dated: March 20, 2014 $11,541.44 s $ 34S. 0�1 - 3,196.17 --� $ 2,542.31 $10,887.58* Edward J. O'Brien, Esquire Attorney for Plaintiff NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. OLVVi7E6F9. CO 176 &a? 11 1y D0 Dot(u 11 U a� 13s��u WiA of 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 CITIBANK (SOUTH DAKOTA), N.A. Vs. CHRISTINA M. TROUTMAN WRIT OF EXECUTION (Pa R.C.P. 3252) NO 09-8370 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against CHRISTINA M. TROUTMAN, 1230 ROBERTS VALLEY ROAD, HARRISBURG, PA 17110 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of MEMBERS 1ST FCUGARNISHEE(S), as garnishee, 1000 BRYN MAWR ROAD, CARLISLE, PA 17013-1588 (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 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 1 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 $8,345.27 Interest FROM JANUARY 20, 2010 - $2,542.31 Attorney's Comm. % Attorney Paid — ,?3Y.. 11 Date: 5/16/2014 (Seal) REQUESTING PARTY: Name : EDWARD J. O'BRIEN, ESQUIRE Address: BURTON NEIL & ASSOCIATES, P.C. 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No. PLAINTIFF Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs 1 "1.t.e_eL David D. Buell, Prothonotary MAJOR EXEMPTIONS UNDER.PENNSYLVANIA AND FEDERAL LAW L $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 Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 rs, West Chester, PA 19380 t,vA 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS Plaintiff v. : CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA M TROUTMAN 1230 Roberts Valley Rd Harrisburg PA 17110-1764 : NO. 09-8370 Defendant(s) MEMBERS FIRST FCU Garnishee : CIVIL ACTION -LAW RECEIVED MAY 27 2014 To: MEMBERS FIRST FCU 1000 Bryn Mawr Road, Carlisle PA 17013-1588 IMO Interrogatories to Garnishee You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant or 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 owed solely or in part by the defendant? co 3. If the answer to 1 and/or 2 is yes, please specify the nature of the property and, if money, the amount? 3jq.98 4. 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? u. - ack \Dr- - - 5. At the time you were served or at any subsequent time did you hold as fiduciary any property in which defendant had an interest? (.I, 6. At any time before you were served did the defendant transfer or deliver any property to you or any person or place pursuant to your direction or consent and if so what was the consideration therefor? N o , 7. 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? 1J 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 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. IQ O 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 funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. LV c9(4,98. Burton Neil & As ates, P.C. By: Edward J. Brien, Esquire This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFCE OF THE KK4ERiFr UF THE PROTHONOTARY 20 R -R fif Y 29 Ail `+: 27 CUMBERLAND COUNTY PENNSYLVANIA Citibank (South Dakota) N.A. vs. Christina M. Troutman Case Number 2009-8370 SHERIFF'S RETURN OF SERVICE 05/23/2014 11:35 AM - Tim Black, 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 Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Denise L. Harman, Assistant Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on May 28, 2014 to Christina M. Troutman at 1230 Roberts Valley Road, Harrisburg, PA 17110-1764. TIM BLACK, DEPUTY SO ANSWERS, May 28, 2014 RNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, inc. - Burton Neil & Associates, P.C. By: Edward J. O'Brien, Esquire ID. NO. 32985 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA), N.A. : IN THE COURT OF COMMON PLEAS Plaintiff v. : CUMBERLAND COUNTY, PENNSYLVANIA CHRISTINA M TROUTMAN Defendant : NO. 09-8370 and MEMBERS FIRST FCU Garnishee : CIVIL ACTION - LAW Praecipe to Dissolve Attachment To the Prothonotary: Dissolve the attachment against MEMBERS FIRST FCU, garnishee. Burton Neil & Associates, P.C. By: Z ar war O'Brien, Esquire Attorney for Plaintiff This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. C-29072 0 Jul sq sopci 1LI l 3 sseoP Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FFCE 7F THE $kERIFF LED-OFFiCL % 11:AN 13 PH 12: f 3 CUMBERLAND COUNTY PENNSYLVANIA Citibank (South Dakota) N.A. vs. Case Number Christina M. Troutman 2009-8370 SHERIFF'S RETURN OF SERVICE 05/23/2014 11:35 AM - Tim Black, 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 Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Denise L. Harman, Assistant Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on May 28, 2014 to Christina M. Troutman at 1230 Roberts Valley Road, Harrisburg, PA 17110-1764. 06/12/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED at request of plaintiffs attorney. SHERIFF COST: $89.26 SO ANSWERS, June 12, 2014 (c) CountySune Sheriff, Teleosoft. Inc. RONW R ANDERSON, SHERIFF