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HomeMy WebLinkAbout10-6381SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~.~~~~_~~.~.~~~ Sheriff Jody S Smith ~~„~,tr or ~~a+a~Pr~~~ ~~ ~~ ~R~~~dl~~~~,~'~^ Chief Deputy ~ "~" ~~ ~~~~ ~~~ ~ 4 AM ~~~ ~~ dt ,- Richard W Stewart ~ °•- Solicitor f~~~ -~+e~~eaiF~ ~E1M$ER~.A~1D C~3~1~I~` ~'~hIk~SYL!/~+~E~ Advantage Assets II, Inc. vs. Case Number Lois Alston 2010-6381 SHERIFF'S RETURN OF SERVICE 10/11/2010 07:09 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 11, 2010 at 1909 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lois Alston, by making known unto Scott Ickes, Husband of defendant at 2 Ickes Lane, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. S A SHALL, EPUTY SHERIFF COST: $38.80 October 12, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj GountySuite Sheriff, 'ieleosoft. Inc. I " Our File No.: 286876 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ADVANTAGE ASSETS II, INC VS. LOIS ALSTON Plaintiff Defendant Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, LOIS ALSTON, in the default of an Answer, in the amount of $3,168.29 computed as follows: Amount claimed in complaint: Less: Amount Paid: Plus: Interest from September 30, 2010 to November 19, 2010 at the legal interest rate of 0.00% per annum Attorney fees TOTAL I certify that Defendant, LOIS ALSTON, last NEWVILLE, PA 17241-8631. Dated: November 19, 2010 FILED-OFFICE OF THE PROTHONOTARY 2010 NOV 30 PM 3: 18 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-6381 CIVIL TERM David J. Apc Attorney for $ 3,168.29 ( 0.00) 0.00 0.00 $ 3,168.29 address ' 2 ICKES LN er, Esq. do k 401k. 0'v ?- 11 9: Our File No.: 286876 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ) ADVANTAGE ASSETS II, INC. ) Plaintiff ) VS. ) LOIS ALSTON ) Defendant ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-6381 CIVIL TERM Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237. 1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Dated: November 19, 2010 Attorney for Plaintiff Our File No.: 286876 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff COURT OF COMMON PLEAS OF ADVANTAGE ASSETS II, INC. ) CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 10-6381 CIVIL TERM LOIS ALSTON ) Civil Action Defendant ) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 2 ICKES LN NEWVILLE, PA 17241-8631. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593 if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defens M power D a Center has sent back our inquiry indicated that the Defendant(s) is/are not in t +e mi itary. David J. Apoth r Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. 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Provi an eaaueaus name or SSN w* esste as e troneons cerAcaee to be proviciedd_ ReportB}PE W1459MVJ 286876 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY ADVANTAGE ASSETS II, INC. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) LOIS ALSTON ) NO. 10-6381 CIVIL TERM To: LOIS ALSTON 2 ICKES LN NEWVILLE, PA 17241-8631 IMPORTANT NOTICE 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. CUMBERLAND COUNTY ASSOCIATION 34 S. BEDFORD ST. CARLISLE, PA 17013 717-249-3166 BAR DAVID J. TH R, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 Date: November 03, 2010 Our File No.: 286876 ADVANTAGE ASSETS II, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. LOIS ALSTON NO.: 10-6381 CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Issue a Writ of Execution in the above matter, c (1) directed to the Sheriff of CUMBERLAND County; `= C Lo -v G:- (2) against LOIS ALSTON, defendant(s); and Zo --G q , (3) against METRO BANK 20 NOBLE BOULEVARD HARRISBURG, PA 17103, Garni h� . s);Z'. (4) and index this writ in the judgment index (a) against LOIS ALSTON, defendant(s), and (b) against METRO BANK 20 NOBLE BOULEVARD HARRISBURG, PA 17103, as Gamishee(s), as a lis pendens against the real property of the defendant(s) in the name of Garnishee(s) as follows: Bank Attachment Only - All assets and accounts, including, but not limited to, bank accounts brokerage firm accounts, stocks, cd's, insurance, safety deposit boxes, etc. (5) Amount Due $3168.29 Interest from November 30, 2010 $535.95 Minus Payments made -$ Plus Costs $193.00 Total $3897.24 a��'s oD '� ��' David J. Apothaker, Esquire Attorney for V Plaintiff�js�) �pIt � lea aa ,ta.a ALA . t # � WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-6381 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ADVANTAGE ASSETS II,INC. Plaintiff(s) From LOIS ALSTON,2 ICKES LANE,NEWVILLE,PA 17241 (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: METRO BANK,20 NOBLE BLVD.,HARRISBURG,PA 17103-ALL ASSETS AND ACCOUNTS, INCLUDING,BUT NOT LIMITED TO,BANK ACCOUNTS,BROKERAGE FIRM ACCOUNTS, STOCKS,CD'S,INSURANCE,SAFETY DEPOSIT BOXES,ETC. 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$3,168.29 Plaintiff Paid$ Interest 40-0,v% 1112-0116 — jr-M'.9S Attorney's Comm. % Law Library$.50 Attorney Paid$173.80 Due Prothonotary$2.25 Other Costs$ Date: 10/31/2013 David D. Buell,Prothonotary Deputy REQUESTING PARTY: Name : DAVID J.APOTHAKER, ESQUIRE Address: APOTHAKER& ASSOCIATES, P.C. 520 FELLOWSHIP RD C306 MT.LAUREL,NJ 08054 Attorney for: PLAINTIFF Telephone: 1-800-672-0215 Supreme Court ID No. �����U��"� o���K��� o�� CUMBERLAND �������� SHERIFF'S" ~� �°" " "~~~~ ~°" ~°��"°"��°~"^�~��"°�� COUNTY " ` ` Ronny RAnderson Z�| -�- Sheriff ` ^^~ /)FTA, pR0THO�OT8"Y Jody SSmdh �- ~v Chief Deputy 70 13 14 P (3: 3 3 Richard VVStewart ` ��:��*� CH T\/ So��n/ mnnswpnmmSosmFp �~�v��/���/ ~ . PENNSYLVANIA Advantage Assets U. Inc. vs. Case Number Lois Alston | 2010'8381 | SHERIFF'S RETURN OF SERVICE 11X07Y2013 11:21 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, orcontrol of the within named garnishee, N1atnu Bank, 20 Noble B|vd, Carlisle Bonuugh, Codio|e, PA 17013. Cumberland Counh/, by handing boTeryn Walters, Store N1anogar, 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 nn November 13 201 Lane, Newvi||e. PA17241'8G31. WI LLIAM CLINE, DEPUTY SO ANSWERS, November 12. 2U13 RDNNYR ANDERSON, SHERIFF � �CountySuim Shoriff.rmeosonmc Our File No.: 286876 ADVANTAGE ASSETS 11, INC. } COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY vs. ) } LOIS ALSTON ) NO.: 10-6381 CIVIL TERM 2 ICKES LN ) NEWVILLE, PA 17241-8631 ) Civil Action XXX-XX-8540 ) Defendant } cz METRO BANK r=j CD Garnishee �-' rD Q CD INTERROGATORIES TO GARNISHEE cs TO: METRO BANK, 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(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed defendant(s) any money or were liable to defendant(s) for any reason? No Accounts 2. At the time you were served or at any subsequent time was there in your possession, custody, control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the defendant(s)? 3. At the time you were served or any subsequent time did you hold legal title to any property of any nature owed solely or in part by the defendant(s) or in which the 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(s) had any interest? 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and what was the consideration thereof? 6. At any time after you were served did you pay. transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the defendants direction or otherwise discharge any claim of the defendant(s) against you? 7. If you are a bank or other financial institution. at the time you were served or any subsequent time did the defendant(s) 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. 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant(s) 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 42PA.C.S.§8123? If so, identify each account. 9. How much is the value of any property in your possession belonging to the defendant(s)? 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. Dated: ( � lam' David J. A othaker,Esquire APOTHAKER&ASSOCIATES. P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel,New Jersey 08054 (856) 780-1000 Attorneys for Plaintiff VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unswom falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy pecialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ( IG URE) f f _, d LIi..I.f Our File No.: 286876 ' FEB ` APOTHAKER& ASSOCIATES, P.C. NI 2: 2/ By: David J. Apothaker, Esquire CU MERLN D Attorney I.D.# 38423 PENNs Yt-Vq T Y 520 Fellowship Road C306 PO Box 5496 Mount Laurel,NJ 08054 (800) 672-0215 Attorneys for Plaintiff ) ADVANTAGE ASSETS II, INC. ) COURT OF COMMON PLEAS OF ) CUMBERLAND COUNTY Plaintiff ) vs. ) ) NO.: 10-6381 CIVIL TERM LOIS ALSTON ) ) Civil Action Defendant ) ) METRO BANK ) ) Garnishee ) ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, 9 0 BANK, dissolved. David iirir aker, Esquire Attorney for Plaintiff arthi 0 Qg1?1 p_41 0(C.139 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ;LE }-f1, t- 1 Sheriff .. Jody S Smith Chief Deputy Richard W Stewart Solicitor o TK7.; OF TN.„ S,IMSRIFF Ttl!t1 JUN 16 PM 2: 3L CUMBERLAND COUN- PENNSYLVANIA Advantage Assets II, Inc. vs. Lois Alston Case Number 2010-6381 SHERIFF'S RETURN OF SERVICE 11/07/2013 11:21 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, Metro Bank, 20 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Taryn Walters, Store 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 November 13, 2013 to Lois Alston, 2 Ickes Lane, Newville, PA 17241-8631. 06/13/2014 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: $89.26 SO ANSWERS, June 13, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. RON��R ANDERSON, SHERIFF