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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 tVt??? 0, i r- f.? 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 $2578.69 which is calculated as the original creditor's chargeoff balance less any payments received. The information that I reviewed were provided by the original creditor and or its assignees. 4. Based on my review of the foregoing documents, there are no payments that have not been credited to Defendant(s). 5. The facts set forth in this Verification are true and correct to the best of my knowledge, information and belief. This Verification is made subject to the penalties for making an unsworn falsification to authorites in violation of 18 Pa.C.S. Section 4904. Signature -M 115? fl PJAPS Print Signature b1qtW1() Date: PPTXNIVI 2527026 111011100'1111110'11 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. # 92800 Gregory R. Dye Attorney LD #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 610-902-0644 Attorney for Plaintiff, DELL FINANCIAL SERVICES L.L.C. DELL FINANCIAL SERVICES L.L.C. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. NICOLE DUNCIL 4564 MANOR DR MECHANICSBURG PA 17055-4932 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10 - ?bol Q 0'lvii-Fem PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF = - ! 7 w: W .. DELL FINANCIAL SERVICES L.L.C.. _ _ ;_? •-,? Papers may be served at the address set forth below:' r 4 .. Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Telephone Number: 1-610-902-0644 ext. 4151 Dated: July 7, 2010 By: BLATT, HASENM & MOORE, LLV Gregory R. Dye 2527026 PPTXPEAI 111111111 IIII 11111111111111 IN 11111 IN 111111111111111 IIII IIII CUMBERLAND COUNTY - ' S OFFICE OF SHERIFF =il Ronny R Anderson . 71 1 ,u y . Sheriff - ,,, E Jody S Smith . . Chief Deputy - V Richard W Stewart ra Solicitor FFIiE FrrE$ .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 ?? -? -cam CIVIL ACTION Cn N o ? No.10-7022-CIVILTERM y° -4 C C) C) C IS rT-, -t r'' cn - 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: / 14.0 ?D .1y31 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 - JIa.?ttti d 14-00 2527026 PPTXCMPI r -" -b• So u- G. ? ? 3 So3 ?- a T? log 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 r,- te --? -c tV 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. 2527026 PPTXPDAI f'jz/ AJ* 7 47