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Home My WebLink About10-5473Blatt, Hasenmiller, Lelbaker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney LD #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ext. 4151 CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, JOSEPH M LUND vs. 1037 COUNTRY CLUB RD CAMP HILL PA 17011-1049 Defendant. Attorney for Plaintiff, -- CITIBANK (SOUTH DAKOTA) N.A. aof o A06 ao PM a :a3 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10-5M73 a-wilTerm NOTICE TO DEFEND 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 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, 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. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET 2522400 PPTCPADI CARLISLE, PA 17013 O -0J.,60 PO 1077y e1 'w9a3 QV Ag710g AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Blatt, Hasenmiller, Lelbsker & Moore, LLC Daniel Santucci 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 CITIBANK (SOUTH DAKOTA) N.A. C/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, JOSEPH M LUND vs. 1037 COUNTRY CLUB RD CAMP HILL PA 17011-1049 Defendant(s). Attorney for Plaintiff, CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. COMPLAINT Plaintiff, CITIBANK (SOUTH DAKOTA) N.A. claims as follows: 1. The Defendant(s), JOSEPH M LUND, is a resident of Cumberland County, Pennsylvania. 2. Defendant opened a credit account with Plaintiff on or about June 30, 2006. 3. Defendant used the account to make purchases and charges and/or receive cash advances. 4. Plaintiff billed the Defendant for payment of charges on the account and Defenant has assented to the account. 5. Defendant has failed to make payment for the amounts due and owing. 6. There currently remains a balance due and owing of $9117.22. See Exhibit "A." 7. Defendant last made a payment, on or about August 27, 2009. 8. The Defendant's balance is now at $9117.22, and has failed to make payments upon that account as he had agreed to do. 2522400 PPTCCITI WHEREFORE, Plaintiff, requests Judgment in the amount of $9117.22, plus court costs and interest from the date of Judgment. Respectfully submitted, VERIFICATION Mark Molinario is an employee of Citicorp Credit Services, Inc., (USA) which is a subsidiary of Citibank and services credit card accounts owned by Citibank, including maintaining and recording information in Citibank's records as they relate to credit card accounts owned by Citibank. Citibank is a National Bank with its principal place of business in Sioux Falls, South Dakota. I am authorized to make this verification as custodian of records for Citicorp Credit Services Inc. (USA). The foregoing averments of fact in the within COMPLAINT and Exhibits are true to my information and belief. I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to the authorities. Date: I- '05-to Signature 2522400 PPTXCITI 11 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 CITIBANK (SOUTH DAKOTA) N.A. Gregory R. Dye, Attorney I.D. #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. JOSEPH M LUND 1037 COUNTRY CLUB RD CAMP HILL PA 17011-1049 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILLER, LEIBSKER Dated: June 25, 2010 2522400 PPTJCAMI I IIuu IIIINNII'I By Gregory R. Dye Exhibit "A" PPTXEXAI 04/07/10 $9117.22 $9117.22 SITE:KC-CL TM:CO-5000 ACID:IR84980 iir? 06/02/10 21:59:39: CITI CARDS PO BOX 183051 JOSEPH M LUND COLUMBUS, OH 1037 COUNTRY CLUB RD 43218-3051 CAMP HILL PA 17011-1049000 C it i® Home Rebate Platinum Select Card Account Number: 5309 0400 6257 8631 Customer Service: 1-800-638-1520 www.citicards.com po Row ASnn crnurn rm i c en c7„7-.r^^ Summary of Account Activity Previous Balance $8,9 2.65 Payments - 0.00 Other Credits - 0,00 alan e + ce Transfers B p;00 Cash Advances + ,00 InterestrCha d 2 .5 rge +: 14 7 New Balance $9,117.22 Past Due Amount ;2,268.08 Amt. Over Credit Limit ;1,617.22 Credit Limit ;7,5Q0 Available Credit i Cash Advance Limit ;2,3 0 Available Cash Limit 0 Statement Closing Date 03/10/2010 Days in Billing Cycle 29 C tie Information New Balance 9,117.22 Minimum Payment Due 9 14T.22 Payment Due Date 04/67/2010 Late Payment warning: If we do not receive your minimum pa went by the date listed above, you may have to pay up to a 139 late fee and your APRs may be increased up to the variable Penalty APR of 29.99%. Minimum Payment Warning: It you make only the minimum payment e VOachU period, ynou will day more in interest and it lnnnar nn? will take n! If you make no additional charges You will pay off the balance And you will end up paying an using this card shown on this estimated total and each month you statement in of... pay... about... Only the minlmum payment 1 month(s) $9,117 IT you wouto !1Ke inrormation about credit counseling services, call 1-8TT-337-8188. Fees TOTAL FEES FOR THIS PERIOD 0.00 Interest Chemaed 3/10 A 84 0000 0 DVANCES•INTEREST CHARGEsPERIODIC RATE 30.44 3/10 PURCHASES•INTEREST CHARGE•PERIODIC RATE 70000000000 84 184.13 TOTAL INTEREST FOR THISOPERIOD 70000000021 214.57 Help is available! Please call the toll-free number shown above to learn about our special payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am to 5 pm, Central Time. Please give us the opportunity to assist you. Contact us today - we can help! Go online at www.PaYment$olutions.citicares.com to login or register. JOSEPH M LUND sob -Daft port Dato Mfw M mSer AetMty Shan Lost Stat"Wat AWAMM Days This 51008 Pedft 29 Raft summary salaws, Subjoct to Pniodlc Nominal ANNUAL htbrast Chorus D.r. _-- S LM r%B%yjwmm d Purch $7,728.11 0.08216%(D) 29.990% 29.990% d Adv $1,277.71 0.08216%(D) 29.990% 29.990% Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. # 92800 Gregory R. Dye Attorney LD #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 610-902-0644 Attorney for Plaintiff, F CMBANK (SOUTH DAKOTA) N.A. ao?o A06 0 PM al -W CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. JOSEPH M LUND 1037 COUNTRY CLUB RD CAMP HILL PA 17011-1049 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. J() - Sg73 ?tV T?.rn1 PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF CITIBANK (SOUTH DAKOTA) N.A.. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Telephone Number: 1-610-902-0644 ext. 4151 Dated: June 25, 2010 2522400 PPTXPEAI loll] I Mil 1 Gregory R. Dye SHERIFF'S OFFICE OF CUMBERLAND 000N?- Ronny R Anderson 'T TH7 P:'--- °"'\,E')TAW Sheriff of?ttrrr?j Jody S Smith iU So --EP - 9 AM 8: 44 Chief Deputy Richard W Stewart CU II "" l?o+, lm Solicitor OFFIC PENNSYLVANA Citibank (South Dakota) N.A. Case Number vs. Joseph M. Lund 2010-5473 SHERIFF'S RETURN OF SERVICE 09/03/2010 04:58 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on September 3, 2010 at 1658 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Joseph M. Lund, by making known unto himself personally, at 1037 Country Club Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. STEP EN BENDER, DEPUTY SHERIFF COST: $41.50 September 07, 2010 SO ANSWERS, (5Z' x 2x??? RRONI`N R ANDERSON, SHERIFF .ci GountpSuite Snertt. ieieosott tnc -- ' r PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci CITIBANK (SOUTH DAKOTA) N.A. Attorney I.D. #92800 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. JOSEPH M LUND 1037 COUNTRY CLUB RD CAMP HILL PA 17011-1049 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10-5473-CIVIL TERM TO THE PROTHONOTARY: r" - Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT JOSEPH M LUND in this matter in the amount of $9,117.22 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 10/11/2010 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: November 5, 2010 2522400 PPTJPFJI I MEMO 11 INI111111111111 Respectfully subs BLATT, RASE & MOORE, C n cc! R 4I4.oo Pa A-Irt C*'13`9 A?'4' ?yrls? Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 CMBANK (SOUTH DAKOTA) N.A. Gregory R. Dye, Attorney I.D. #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. JOSEPH M LUND 1037 COUNTRY CLUB RD CAMP HILL PA 17011-1049 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10-5473-CIVIL TERM Defendant(s). AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASEj(M?CLER, LF?SKER & MOORE, L C Dated: November 5, 2010 By: Gread(v R: 2522400 PPTJCAMI I Effimm IN 10 1111IIIN1111111IN M I CITIBANK (SOUTH DAKOTA) N.A. Plaintiff, VS. JOSEPH M LUND 1037 COUNTRY CLUB RD CAMP HILL PA 17011-1049 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10-5473-CIVIL TERM TO: JOSEPH M LUND Date of Notice: October 11, 2010 IMPORTANT NOTICE By: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HA & MOORE, 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 x 4151 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2522400 PPTNLRSI I R milli 11mill IN SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson j Sheriffs Vow Jody S Smith' Chief Deputy Richard W Stewart Solicitor QMCE OiFTHE 6l14RlFF Citibank (South Dakota) N.A. Case Number j vs. Joseph M. Lund 2010..5473 SHERIFF'S RETURN OF SERVICE 09/03/2010 04:58 PM -'Stephen Bender, Deputy Sheriff, who being duly.swom according to law, states that on September 3, 2010 at 1658, hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Joseph M. Lund,, by making known, unto himself: personally, at 1037 Country Club Road, Camp. Hill, Cumberland County, .Pennsylvania 1,7011 its contents and at the same i. time handing to him personally the said true and correct copy of the same. i STEP EN BENDER, DEPUTY SHERIFF COST: $41.50 SO ANSWERS, G?• '?" "? 6Z September 07, 2010 RON R ANDERSON, SHERIFF i ra CITIBANK (SOUTH DAKOTA) N.A. Plaintiff, vs. JOSEPH M LUND 1037 COUNTRY CLUB RD CAMP HILL PA 17011-1049 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 10-5473-CIVIL TERM TO: JOSEPH M LUND NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. Dated: !r1 /d11 PROTHONOT RY u tL D ?.? ?. 1) RV.1 By: 42,011, t IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 P.O. Box C3800 Southeastern, PA 19398 800-850-1079 2522400 PPTNDJNI Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci, Attorney I.D. #92800 1835 Market Street, Suite 501 Philadelphia, PA 19103 610-902-0644 CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, vs. JOSEPH M LUND 1037 COUNTRY CLUB RD CAMP HILL PA 17011-1049 Defendant(s) AND SUSQUEHANNA VALLEY FCU 3850 HARTZDALE DRIVE CAMP HILL, PA 17011 Garnishee Attorney for Plaintiff, CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEA rn ov =rn CUMBERLAND COUNTY, PA cn r' CIVIL ACTION r CZ1 No. 10-5473-CIVIL TERM r% 'n --t rn-n -orn Xj= o? j -n a c.. -v Z 77 Cn PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly ISSUE a WRIT OF EXECUTION in the above matter, directed to the Sheriff of Cumberland County: (1) against JOSEPH M LUND defendant[s] (2) against SUSQUEHANNA VALLEY FCU garnishee[s] REAL DEBT $ 9117.22 INTEREST $ From 11-12-10 COST PAID $ Prothonotary SHERIFF $ STATUTORY $ COSTS DUE $ 2522400 PPTGPWEI Q4- S d ?sf Bj' 6 6 T. SO D L-i s 1q, 0 4 `u s/`7y, S6 PA- Y WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5473 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 JOSEPH M. LUND, 1037 COUNTRY CLUB RD., CAMP HILL, PA 17011-1049 (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: SUSQUEHANNA VALLEY FCU, 3850 HARTZDALE DRIVE, CAMP HILL, PA 17011 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$9117.22 Interest $353.70 -Ca, Atty's Comm % Atty Paid $174.50 Other Costs Plaintiff Paid Date: JULY 11, 2011 (Seal) L. L. $.50 Due Prothy $2.00 David D. Buell, Prothonotary By: Deputy REQUESTING PARTY: Name DANIEL SANTUCCI, ESQ. Address: BLATT, HASENMILLER, LEIBSKER & MOORE, LLC, 1835 MARKET STREET, SUITE 501, PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 610-902-0644 Supreme Court ID No. 92800 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?lLED-OFIC !?= THE PROTHIOW TAP, 2011 JUL 19 PM 3: 54 CUMBERLAND COUNTY PENNSYLVANIA Citibank (South Dakota) N.A. Case Number S. Joseph M. Lund 2010-5473 SHERIFF'S RETURN OF SERVICE 07/15/2011 01:09 PM - Amanda Cobaugh, 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, Susquehanna Valley FCU at 3850 Hartzdale Drive, Lower Allen Township, Camp Hill, PA 17011, Cumberland County, by handing to PATRICIA SHAFFER, SECRETARY, 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 July 15, 2011 to Joseph M. Lund at 1037 Country Club Road, Camp Hill, PA 17011-1049. SO ANSWERS, July 18, 2011 RON , R ANDERSON, SHER,I,FF obaugh, Deput ici CnunfySuite Shen'f. Teieosc't. !n;: CITIBANK SOUTH DAKOTA N.A. PLAINTIFF VS. JOSEPH M. LUND, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA w NO. 10-5473 CIVIL TERNV? CIVIL ACTION - LAW cni" r% x> r, GARNISHEE'S ANSWERS TO INTERROGATORI To: Citibank South Dakota N.A. c/o Daniel Santucci, Esquire Blatt, Hasenmiller, Leibsker & Moore LLC Suite 501 1835 Market Street Philadelphia, PA 19103 r...z W I .7 v O --? r .. 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. ANSWER: On the date the writ of execution was served on July 15, 2011 the account balance was $653.53. However, the primary account holder is the Defendant's wife, Lori A. Lund, and assets held jointly with a spouse are not subject to attachment. Furthermore, in accordance with Pa. R.C.P. 3123.1 and 3111.1 the funds on deposit in this account are from recurring payroll deposits from the West Shore School District and Novartis Pharmaceuticals and as such are exempt from levy and attachment. 2. At any time you were served or any subsequent time thereafter, was there in your possession, custody or control or in joint possession, custody and control, any property of the Defendant? ANSWER: On the date the writ of execution was served on July 15, 2011 the account balance was $653.53. However, the primary account holder is the Defendant's wife, Lori A. Lund, and assets held jointly with a spouse are not subject to attachment. Furthermore, in accordance with Pa. R.C.P. 3123.1 and 3111.1 the funds on deposit in this account are from recurring payroll deposits from the West Shore School District and Novartis Pharmaceuticals and as such are exempt from levy and attachment. 3. At any time you were served or 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 the Defendant held or claimed any interest? ANSWER: On the date the writ of execution was served on July 15, 2011 the account balance was $653.53. However, the primary account holder is the Defendant's wife, Lori A. Lund, and assets held jointly with a spouse are not subject to attachment. Furthermore, in accordance with Pa. R.C.P. 3123.1 and 3111.1 the funds on deposit in this account are from recurring payroll deposits from the West Shore School District and Novartis Pharmaceuticals and as such are exempt from levy and attachment. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant has any interest? ANSWER: On the date the writ of execution was served on July 15, 2011 the account balance was $653.53. However, the primary account holder is the Defendant's wife, Lori A. Lund, and assets held jointly with a spouse are not subject to attachment. Furthermore, in accordance with Pa. R.C.P. 3123.1 and 3111.1 the funds on deposit in this account are from recurring payroll deposits from the West Shore School District and Novartis Pharmaceuticals and as such are exempt from levy and attachment. 5. At any time before or after you were served did the Defendant 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? ANSWER: On the date the writ of execution was served on July 15, 2011 the account balance was $653.53. However, the primary account holder is the Defendant's wife, Lori A. Lund, and assets held jointly with a spouse are not subject to attachment. Furthermore, in accordance with Pa. R.C.P. 3123.1 and 3111.1 the funds on deposit in this account are from recurring payroll deposits from the West Shore School District and Novartis Pharmaceuticals and as such are exempt from levy and attachment. 6. At any time you were served did you pay or 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. ANSWER: On the date the writ of execution was served on July 15, 2011 the account balance was $653.53. However, the primary account holder is the Defendant's wife, Lori A. Lund, and assets held jointly with a spouse are not subject to attachment. Furthermore, in accordance with Pa. R.C.P. 3123.1 and 3111.1 the funds on deposit in this account are from recurring payroll deposits from the West Shore School District and Novartis Pharmaceuticals and as such are exempt from levy and attachment. 7. If you are a bank or other financial institution, at the time you were served or 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 and the entity electronically depositing those funds on a recurring basis? ANSWER: On the date the writ of execution was served on July 15, 2011 the account balance was $653.53. However, the primary account holder is the Defendant's wife, Lori A. Lund, and assets held jointly with a spouse are not subject to attachment. Furthermore, in accordance with Pa. R.C.P. 3123.1 and 3111.1 the funds on deposit in this account are from recurring payroll deposits from the West Shore School District and Novartis Pharmaceuticals and as such are exempt from levy and attachment. 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 exemption under 42 Pa. C.S.A. §8123? If so, identify each account. ANSWER: No. See prior answers. 9. How much is the value of any property in your possession belonging to the Defendant? 10. In the space below the Plaintiff may set forth additional appropriate interrogatories? ANSWER: No response is required. If a response were required the Garnishee incorporates by reference it prior answers as though fully set forth. Respectfully submitted, By: Steve ow sq" r P 6 ridge treet ew Cumberland, A 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Garnishee Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first class United States Mail addressed as follows: Citibank South Dakota N.A. c/o Daniel Santucci, Esquire Blatt, Hasenmiller, Leibsk:er & Moore LLC Suite 501 1835 Market Street Philadelphia, PA 19103 Joseph M. Lund 1037 Country Club Road Camp Hill, PA 17011 By; Date: August 2, 2011 -C -` 09:5 FFOM-SUSQ VALLEY FCU 717-737-0589 T-085 P0001/0001 F-428 VERIFICATION I/we verify that the statements made in the foregoing document are true and correct. Uwe understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A,. Section 4904 relating to wisworn falsification to authorities. BY: Stephen , Brindamour President and Chief Executive Officer Susquehanna Valley Federal Credit Union 3850 Hartz-dale Drive Camp Hill, PA 17011-7809 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci CMBANK (SOUTH DAKOTA) N.A. Attorney I.D. #92800 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 111E PROTHONOTAR'i 2011 AUG 12 AN 11: 52 CUMBERLAND COUNTY __PEMS YLVANI A CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, Vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION NO. 10-5473-CIVIL TERM JOSEPH M LUND Defendant(s). SUSQUEHANNA VALLEY FCU Garnishee PRAECIPE TO DISSOLVE ATTACHMENT To the Prothonotary: Kindly mark the Writ of Execution against JOSEPH M LUND and SUSQUEHANNA VALLEY FCU as DISSOLVED, and the attachment as DISSOLVED. Respectfully Daniel THIS MESSAGE IS FROM A DEBT COLLECTION FIRM. ANY INFORMATION OBTAINED FROM THIS COMMUNICATION MAY BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 2522400 PPTXPDAI Q ft'k-1 "0"?4 at? 6k'10 :53y9 S ?ab3f?3 any R Anderson ieriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY HE 40ROT` M012 FEB 22 PPS 3: CU 'ENINSYLVANIA Citibank (South Dakota) N.A. Case Number vs. Joseph M. Lund 2010-5473 SHERIFF'S RETURN OF SERVICE 07/15/2011 01:09 PM - Amanda Cobaugh, 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, Susquehanna Valley FCU at 3850 Hartzdale Drive, Lower Allen Township, Camp Hill, PA 17011, Cumberland County, by handing to PATRICIA SHAFFER, SECRETARY, 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 July 15, 2011 to Joseph M. Lund at 1037 Country Club Road, Camp Hill, PA 17011-1049. 02/22/2012 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: $96.85 SO ANSWERS, February 22, 2012 RON R ANDERSON, SHERIFF .6