HomeMy WebLinkAbout10-7022Blatt, Hasenmiller, Leibsker & Moore, LLC
Daniel Santucci Attorney I.D. #92800
Gregory R. Dye Attorney LID #205316
5 Great Valley Parkway, Suite 100
Malvern, PA 19355
800-850-1079 ext. 4151
Attorney for Plaintiff,
DELL FINANCIAL SERVICES L.L.C.
DELL FINANCIAL SERVICES L.L.C.
c/o Blatt, Hasenmiller, Leibsker & Moore, LLC
5 Great Valley Parkway, Suite 100
Malvern, PA 19355
Plaintiff,
vs.
NICOLE DUNCIL
4564 MANOR DR
MECHANICSBURG PA 17055-4932
Defendant.
IN THE COURT OF COMMON PLEAS
c?
CUMBERLAND COUNTY, PA
CIVIL ACTION!
No. 10 - /?o A
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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
CARLISLE, PA 17013
qa. oo Pa arr>r
e'r 3gogq
& 6150 783
2527026
PPTCPADI
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, Leibsker & Moore, LLC
Daniel Santucci Attorney I.D. #92800
Gregory R. Dye Attorney #205316
5 Great Valley Parkway, Suite 100
Malvern, PA 19355
800-850-1079
Attorney for Plaintiff,
DELL FINANCIAL SERVICES L.L.C.
c/o Blatt, Hasenmiller, Leibsker & Moore, LLC
Plaintiff,
VS.
NICOLE DUNCIL
4564 MANOR DR
MECHANICSBURG PA 17055-4932
Defendant(s).
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION
No.
COMPLAINT
Plaintiff DELL FINANCIAL SERVICES L.L.C., claims as follows:
1. The Defendant(s), NICOLE DUNCIL, is a resident of Cumberland County,
Pennsylvania.
2. The Defendant(s) opened an account agreeing to make monthly payments as required by the
terms of the account, for purchases charged to the account.
3. The Defendant(s) did make purchases and charged same to the account but failed to make the
monthly payments called for on the account. There is a balance due and owing of $2578.69.
4. Plaintiff declared Defendant(s) to be in default and demands payment of the balance.
2527026
PPTCOCCI
WHEREFORE, the Plaintiff, DELL FINANCIAL SERVICES L.L.C.,
prays for judgment in its favor and against Defendant(s), NICOLE DUNCIL
in the amount of $2578.69, plus costs.
Respectfully submitte
DELL FINANCIA RVI S L.L.C.
One of its Attorneys
Daniel Santucci, Attorney No. 92800
Gregory R. Dye Attorney #205316
Blatt, Hasenmiller, Leibsker & Moore, LLC
5 Great Valley Parkway, Suite 100
Malvern, PA 19355
(800) 850-1079
Dated: July 7, 2010
VERIFICATION
the undersigned attorney for the Plaintiff, hereby verify that the
statements made in the foregoing Complaint are true and correct to the best of my knowledge,
information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is
presently located outside of this jurisdiction, and that in order to file the within document in an
expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsifications to aut
PPTXVERI
Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff,
Daniel Santucci, Attorney I.D. #92800 DELL FINANCIAL SERVICES L.L.C.
Gregory R. Dye, Attorney I.D. #205316
5 Great Valley Parkway, Suite 100
Malvern, PA 19355
800-850-1079
DELL FINANCIAL SERVICES L.L.C.
c/o Blatt, Hasenmiller, Leibsker & Moore, LLC
5 Great Valley Parkway, Suite 100
Malvern, PA 19355
Plaintiff,
vs.
NICOLE DUNCIL
4564 MANOR DR
MECHANICSBURG PA 17055-4932
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, HASEN
& MOORE, LL,9
Dated: July 7, 2010
By:
Gregory R. Dye
2527026
PPTJCAMI
111111111111111111111111111111111111111111111111111111111111 IN
Exhibit "A"
PPTXEXAI
VERFICATION
The undersigned hereby verifies that:
1. I am employed by Plaintiff and am authorized to make this Verification on behalf of
Plaintiff DELL FINANCIAL SERVICES L.L.C..
2. 1 reviewed the following [check all that are applicable]: [ ] (a) computerized documents;
[ ] (b) hard copy of documents; and [X] (c) other (specify) computerized account data
relating to Account No. 879450119045287574. The foregoing Account was opened on June 7, 2007
in the name(s) of Defendant(s) NICOLE DUNCIL.
Based on my review of the foregoing documents, there is due and payable the principal sum
of $2578.69 which is calculated as the original creditor's chargeoff balance less any payments received.
The information that I reviewed were provided by the original creditor and or its assignees.
4. Based on my review of the foregoing documents, there are no payments that have not been
credited to Defendant(s).
5. The facts set forth in this Verification are true and correct to the best of my knowledge,
information and belief. This Verification is made subject to the penalties for making an unsworn
falsification to authorites in violation of 18 Pa.C.S. Section 4904.
Signature -M
115? fl
PJAPS
Print Signature
b1qtW1()
Date: PPTXNIVI
2527026
111011100'1111110'11
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,
DELL FINANCIAL SERVICES L.L.C.
DELL FINANCIAL SERVICES L.L.C.
c/o Blatt, Hasenmiller, Leibsker & Moore, LLC
5 Great Valley Parkway, Suite 100
Malvern, PA 19355
Plaintiff,
vs.
NICOLE DUNCIL
4564 MANOR DR
MECHANICSBURG PA 17055-4932
Defendant(s).
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION
No. 10 - ?bol Q 0'lvii-Fem
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF = - ! 7
w: W ..
DELL FINANCIAL SERVICES L.L.C.. _ _ ;_? •-,?
Papers may be served at the address set forth below:' r 4
..
Blatt, Hasenmiller, Leibsker & Moore, LLC
5 Great Valley Parkway, Suite 100
Malvern, PA 19355
Telephone Number: 1-610-902-0644 ext. 4151
Dated: July 7, 2010
By:
BLATT, HASENM
& MOORE, LLV
Gregory R. Dye
2527026
PPTXPEAI
111111111 IIII 11111111111111 IN 11111 IN 111111111111111 IIII IIII
CUMBERLAND COUNTY -
'
S OFFICE OF
SHERIFF
=il
Ronny R Anderson
.
71
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y
.
Sheriff
-
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Jody S Smith .
.
Chief Deputy - V
Richard W Stewart
ra
Solicitor FFIiE FrrE$ .RTF ,
Dell Financial Services LLC
vs.
Nicole Duncil
Case Number
2010-7022
SHERIFF'S RETURN OF SERVICE
11/08/2010 03:36 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on November
8, 2010 at 1536 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Nicole Duncil, by making known unto Carol Hartwell, Mother of defendant at 4564 Manor
Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $37.00
November 09, 2010
RYAN BURGETT, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
,c? CountySuite Shenff. Telecwft. Inc.
Blatt, Hasenmiller, Leibsker & Moore, LLC
Daniel Santucci
Attorney I.D. #92800
1835 Market Street, Suite 501
Philadelphia, PA 19103
800-850-1079
Attorney for Plaintiff,
DELL FINANCIAL SERVICES L.L.C.
DELL FINANCIAL SERVICES L.L.C.
c/o Blatt, Hasenmiller, Leibsker & Moore, LLC
1835 Market Street, Suite 501
Philadelphia, PA 19103
Plaintiff,
Vs.
NICOLE DUNCIL
4564 MANOR DR
MECHANICSBURG PA 17055-4932
Defendant(s).
IN THE COURT OF COMMON PLEAS a °
CUMBERLAND COUNTY, PA rncu
rnF
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CIVIL ACTION Cn N o
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No.10-7022-CIVILTERM y° -4 C
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PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
FOR FAILURE TO PLEAD
TO THE PROTHONOTARY:
Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the
DEFENDANT NICOLE DUNCIL in this matter in the amount of $2578.69 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 12/15/10 by regular mail. A true and
correct copy of each Notice is attached hereto.
Dated: January 12, 2011
2527026
PPTJPFJI
I IM llmill111IIIN IIIIIN
Respectfully submitted,
C
21eint NMI
By:
/
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CQ1
Blatt, Hasenmiller, Leibsker & Moore, LLC
Daniel Santucci, Attorney I.D. #92800
Gregory R. Dye, Attorney I.D. #205316
1835 Market Street, Suite 501
Philadelphia, PA 19103
800-850-1079
Attorney for Plaintiff,
DELL FINANCIAL SERVICES L.L.C.
DELL FINANCIAL SERVICES L.L.C.
c/o Blatt, Hasenmiller, Leibsker & Moore, LLC
1835 Market Street, Suite 501
Philadelphia, PA 19103
Plaintiff,
VS.
NICOLE DUNCIL
4564 MANOR DR
MECHANICSBURG PA 17055-4932
Defendant(s).
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION
No. 10-7022-C I V I LT E R M
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, HA
& MOORE,
Dated: January 12, 2011
By:
LEIBSKER
2527026
PPTJCAMI
111 1 1Iffimm 111N111 III IN 1111111111111111
DELL FINANCIAL SERVICES L.L.C.
Plaintiff,
Vs.
NICOLE DUNCIL
4564 MANOR DR
MECHANICSBURG PA 17055-4932
Defendant(s).
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION
No. 10-7022-C I V I LT E R M
TO: NICOLE DUNCIL
Date of Notice: December 15, 2010
IMPORTANT NOTICE WRITTEN
APPEARANCE YOU ARE IN DEFAULT BECAUSE
AND FILEEN FAILED TO WRITING WITH THE COURT YOUR DEFE SES OR
PERSONALLY OR BY ATTORNEY
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
JUDGMENT MAY BE ENTERED AOGAINST`yOUIWITHODUT A
FROM THE DATE OF THIS NOTICE, A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. LAWYER YOU SHOULD TAKE THIS PAPER TO SYOUR LAER AT OCE. ET FORTH BELOW. THISIOFFOiCE CO NOPROVIDE YOU W TH
GO TO OR TELEPHONE THE OFFICE
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
THAT MAY OFFER LEGAL SERVICES TO EOL?IGIB EOU
WITH INFORMATION ABOUT AGENCIES
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, HASEN ILLER, LEIBSKER
& MOOR
By:
Daniel Santucci
1835 Market Street, Suite 501
Philadelphia, PA 19103
800-850-1079
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.
2527026
PPTNLRSI
{I I IIIII III "MIMI IS11IN
1
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-7022 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DELL FINANCIAL SERVICES, LLC Plaintiff (s)
From NICOLE DUNCIL, 4564 MANOR DRIVE, MECHANICSBURG, PA 17055
(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, 1 WEST HIGH STREET, CARLISLE, PA 17013
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $2,578.69
Interest $219.58
Atty's Comm %
Atty Paid $174.50
Plaintiff Paid
Date: 7/6/12
(Seal)
L.L. $.50
Due Prothy $2.25
Other Costs
David D. Buell, Prothonotary
lay: -Aal?p_ .
Deputy
REQUESTING PARTY:
Name : MORRIS SCOTT, ESQUIRE
Address: BLATT, HASENMILLER, LEIBSKER & MOORE LLC
1835 MARKET STREET, SUITE 501
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-564-1567
Supreme Court ID No. 83587
t
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA iLEG
F Ht PROTHO OTW
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION 2012 JUL - c AM p, 3 5
? Confessed Judgment CUMBERLAND COUNTY
DELL EINA QIA SERVICES L L C ? Other PENNSYLVANIA
Plaintiff File No. 10-7099-CIVILTERM
?,
vs. Amount Due.
NICOLE DUNCIL Interest
Defendant Atty's Comm
Address: Costs
fV\.ee'V' . ?> Pr -)65S
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 above-named garnishee(s) for the following property
(if real estate, supply six copies of the description: supply four copies of lengthy personalty list)
Isle (P?
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
? (Indicate) Index this writ against the gamishee(s) as a lis pendens against real a of the
defendant(s) described in the attached exhibit.
Date J7,L t Signature:
Print Name:
Address: ISC?!?L??' 31e SN
^ftjL.JSe 10" P/} L4lrij
d0 Pa 0 Attorney for:
Telephone: 2!5'" S'G Y- ! 57i J
LAD Supreme Court ID No: 435L fs 2 -
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2527026
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Blatt, Hasenmiller, Leibsker & Moore, LLC
Morris Scott Attorney I.D. #83587
1835 Market Street, Suite 501
Philadelphia, PA 19103
215-5641567
DELL FINANCIAL SERVICES L.L.C.
c/o Blatt, Hasenmiller, Leibsker & Moore, LLC
1835 Market Street, Suite 501
Philadelphia, PA 19103
Plaintiff,
VS.
NICOLE DUNCIL
4564 MANOR DR
MECHANICSBURG PA 17055-4932
Defendant(s).
Attorney for Plaintiff,
DELL FINANCIAL SERVICES L.L.C.
a
IN THE COURT OF COMMON PL -
G
CUMBERLAND COUNTY, PA 01 3;,
d
CIVIL ACTION ?Q a
Z
No. 10-7022-CIVILTERM
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF
DELL FINANCIAL SERVICES L.L.C..
Papers may be served at the address set forth below:
Blatt, Hasenmiller, Leibsker & Moore, LLC
1835 Market Street, Suite 501
Philadelphia, PA 19103
Telephone Number: 1-215-564-1567
Dated: June 22, 2012
By:
M?
:?o Q
-sue
aft
s
2527026
PPTXPEAI
I ? ?I??I?IIIIiIIIINNIIIIIIII
BLATT, HASENMILLER, LEIBSKER
& MOORE, LLC
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
?ti?7t14? of C11 nIt",?
al mr.:_
[HE -- RCTNC NO Ne° "'''
2€112 JUL 16 AN 8: 4 3
CUMBERLAND COUNTY
PENNSYLVANIA
Dell Financial Services LLC
vs. Case Number
Nicole Duncil 2010-7022
SHERIFF'S RETURN OF SERVICE
07/11/2012 10:13 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 11
2012 at 1010 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and mon
of the within named defendant, to wit: Nicole Duncil, in the hands, possession, or control of the within
named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, b
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 July 12, 2012 to Nicole Duncil at 4564 Mai
Drive, Mechanicsburg, PA 17055-4932.
SO ANSWERS,
July 12, 2012 RON R ANDERSON, SHERIFF
William Cline ?ty
(c) CountySuite ShenN, Teleosoft. Inc.
A
Blatt, Hasenmiller, Leibsker & Moore, LLC
Morris Scott Attorney I.D. #83587
1835 Market Street, Suite 501
Philadelphia, PA 19103
215-564-1567
DELL FINANCIAL SERVICES L.L.C.
c/o Blatt, Hasenmiller, Leibsker & Moore, LLC
Plaintiff,
Vs.
NICOLE DUNCIL
4564 MANOR DR
MECHANICSBURG PA 17055-4932
Defendant(s).
M&TBANK
1 WEST HIGH ST
CARLISLE, PA 17013
Garnishee
Attorney for Plaintiff,
DELL FINANCIAL SERVICES L.L.C.
IN THE COURT OF COMMON PLEig
:?c rya
CUMBERLAND COUNTY, PA -n _
CIVIL ACTION C
) :
No.10-7022-CIVILTERM
a c ? rm_?
interrogatories to Garnishee
To M & T BANK, Garnishee:
?:kcEEQ CCEAt0?? SQ t
You are required to file Answers to the following Interrogatories within 20 days after service
you.
At the time you were served or at any subsequent time did you owe the defendant any
or were you liable to the defendant? , ?0-
2. At the time you were served or any subsequent time thereafter, was there in your
custody, control or in joint possession, custody and control, any property of the dE
3. At the time you were served or any subsequent time did you hold legal title to any prope
of any nature owned solely or in part by the defendant(s) or in which the defendant held
claimed any interest? Ob
4. At the time you were served or at any subsequent time did you hold as fiduciary any
in which the defendant(s) had any interest? 0'--?
2527026
PPTGBKCI
G?QO&
1Q?i'ja;tg??y 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
N'4' was the consideration thereof?
6. At any time after you were served did you pay, transfer or deliver any money or property
the defendant(s) or to any person or place pursuant to the defendant's direction or
discharge any claim of the defendant(s) against you? ti)
7. If you are a bank or other financial institution, at the time you were served or any subseq
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
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 su
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 exen
under 42 Pa.C.S Sec.8123? If so, identify each account. `12- -)-j
9. How much is the value of any property in your possession belonging to the defendant(s)?
10. In the spaco below, the plaintiff may set forth additional appropriate i
ption
Morris Scot`' A`orney No. 83587
Verification
Melissa M. Peters
M&T Bank the undersigned representative of M & T BANK, hereby verify
that the answer to interrogatories are true and correct to the best of my knowledge, information,
and belief based upon information I have.
I understand that false statements herein are made subject to the penalties of 18 Pa-C.S.
Section 4904 relating to unsworn falsifications to authorities.
Melissa M. Peters
M&T Bank ti ?!
JUL I I
Blatt, HasennMIler, Lelbsker & Moore, LLC
Morris Scott At6wroey I.D. 883587
1835 met ShoK Sulte 501
Ph0~1a, PA 14193
8004160-1079
Attorney for Plaintiff,
DELL FINANCIAL SERVIM LLC.
DELL FINANCIAL SERVICES L.L.C.
cto Blatt, Hasenmiller, Leibsker & Moore, LLC
1835 Market Street, Suite 501
Philadelphia, PA 19103
Plaintiff,
Vs.
NICOLE DUNCIL
Defendant(s).
M&TBANK
Garnishee
IN THE COURT OF COMMON S
CUMBERLAND COUNTY, PA c
N -_
+
--
CIVIL ACTION r
NO.10-7022-CIVILTERM Z2
nu z
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te
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Ln
PRAECIPE TO DISSOLVE ATTACHMENT
To the Prothonotary:
Kindly mark the Writ of Execution against NICOLE DUNCIL and M & T BANK
as DISSOLVED, and the attachment as DISSOLVED.
Respectfully submitted,
Morris tt
THIS ANESSAW IS FROM A DEBT COLLECTION FIIIRM. ANY ORMATION OBT F
THIS COM CATICNV MAY BE USED FOR THE PUCE OF COLLECTING THE DEBT.
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