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Home My WebLink About11-0163Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney I.D #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ext. 4151 Attorney for Plaintiff, CITIBANK (SOUTH DAKOTA) N.A. CITIBANK (SOUTH DAKOTA) N.A. clo Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, ~S. KARA M MNICK 519 COLONY ROAD CAMP HILL PA 17011 Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACT/ION 9~ No.a~~! ... ~(0~ -~ 3 ~--;-~ c~ ~;, c.r>t-_ ,~> _a =~ c-, N ~ ~~ __~ S r'°`° ~r_ ~,. -t7 ~ _~ ~p c_~ ~ c~ _ -*i `~ o ~rl -~ r, ., ~m c~ ~' -,~ ~ -< 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 personalty 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. 1F 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 2120664 PPTCPADI $~a~~°a~ Ck~ c~c~ sg tz~~ 3 y ail 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. Hass 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 fiends la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso 0 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 0 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 Attorney for Plaintiff, Daniel Santucci CITIBANK (SOUTH DAKOTA) N.A. 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, vs. KARA M MNICK 519 COLONY ROAD CAMP HILL PA 17011 Defendant(s). 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), KARA M MNICK , is a resident of Cumberland County, Pennsylvania. 2. Defendant opened a credit account with Plaintiff on or about July 20, 2007. 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 $4578.67. See Exhibit "A." 7. Defendant last made a payment, on or about ~Q. ~~~ r~s 8. The Defendant's balance is now at $4578.67, and has failed to make payments upon that account as he had agreed to do. 2120664 PPTCCITI WHEREFORE, Plaintiff, requests Judgment in the amount of $4578.67, plus court costs and interest from the date of Judgment. Respectfully No. 92800 VERIFICATION Abbie Motley 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: ~ ~ '" ,~_ r Signature 2120664 PPTXCITI II~~I~~N111111111118N~1111111IIII Exhibit "A" PPTXEXAI ~ v 06/04/08 34578.67 34578.67 SITE:KC-CL TM:CO-5000 ACID:KCB0201 06/0.6/06 22:22:08: CITI PO BOX 183113 KARA M MNICK COLUMBUS, OH ATTNY ACCOUNT-CODE=LT03 43218-3113 NEWPORT pA 17074-8308000 ror Custemar SorNa call or write Citi® Flex Line 1-800-925-8871 ~ ~ I TO rcpat DlSinp arras, suRa PO Box 6248 "~'~"' 1 PA E ~ A ~ m this address; cauNp will S i oux Fa 1 1 s, S D N aUS Y D BY 5:00 PM LOCAL TIME ON 06/04/2008 ^OtPr+sarvayourrtghts 57117-624A Statement/ Total Crergt LMo AwtlaWe New Balance p°~w Dam Amount Over Past Dse Total Payment Dus crcan urea Crcdft Line 05/12/2008 :4000 50 54578.67 3578:67 51039.14 54578.67 E sting Transactions. Tra:utF/ Activity/ ANNUAL Payaant Of(ar Oriylnel PERCENTAGE T r Payasnt/ ealanea Nuaber of Paysant a a ~a~t RATE Credit Su6jact W Payaanta Duo Raoaivad Ftnanu charge Raaatninp 001/ 08/09/2007 MNICK,KARA M 004 :4,000.00 8.990% 060 X0.00 54,344.67 055 ;89.46 Finance Charge Transactions Trans# Post Dab 0(ter AeNvity Slnca Last Stabmant TC 91N# or MER# a SIC SLAG Amount 001 5/12 004 ADVANCES's84NAN0000HARGE'rPERIODICORATE 50.00 70000000000 Help is available! Please call the toll-free number shown above to learn about our special pa went options. Call Monday - Friday, 7 am to 9 pm, or Saturday, 8 am to 5 pm, ~entral Time. Please give us the opportunity to assist you. Account Summary Previous Balance (+) Trans _ (-) Payments Activit ~ C dit (+) FINANCE (_) New y re s CHARGE Balance TRANSACTIONS FEES =4 344.67 234 00 0.00 0.00 #0.00 s4 344.67 TOTAL . 54,578.67 0.00 0.00 0.00 0.00 0.00 0.00 234.00 ;4,578.67 Da Thts Bllltn Pert 32 Rate Summary Perlodfc Nominal ANNUAL Rate APR PERCENTAGE R~rE TRANSACTIONS Offer 4 0.74917%(M) 8.990% 8.990% Fees 0.00000%(M) 0.000% 0.000% SEND PAYMENTS T0: 9a6 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Danfel 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. KARA M MNICK 519 COLONY ROAD CAMP HILL PA 17011 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. Dated: July 22, 2010 2120664 PPTJCAMI III I~~IINIIIIIIIIBIIIIhlllllllll By: BLATT, HASENMIL & MOORE, LLC KER Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. # 92800 Gregory R. Dye Attorney I.D #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 610-902-0644 Attorney for Plaintiff, CITIBANK (SOUTH DAKOTA) N.A. CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. KARA M MNICK 519 COLONY ROAD CAMP HILL PA 17011 Defendant(s). IN THE COURT OF COMMON PLE~$ ~ o CUMBERLAND COUNTY, PA ~c~~v ~ _-~ CIVIL ACTION ~_~=~ ~~' .._. ~o n .~ 0 ~ ~_ _~ ~ ° ~ .~ "i ~ 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: July 22, 2010 By: BLATT, HASEN & MOORE, LLCM a 2120664 PPTXPEAI II~~ I~I~RIIIIIIIIIIIIIVIIIIIIIIIII Gregory R. Dye LEIB SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i=' LED-0FF ?E LE MT? Jody S Smith _ •• Chief Deputy „i I J N{ 9 A a 5 Richard W Stewart Solicitor PENNSYI.VA6I9. Citibank (South Dakota) N.A. vs. Case Number Kara M. Mnick 2011-163 SHERIFF'S RETURN OF SERVICE 01/12/2011 06:00 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2011 at 1800 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kara M. Mnick, by making known unto herself personally, at 519A Colony Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. STEPHEN BENDER, DEPUTY SHERIFF COST: $41.50 January 13, 2011 SO ANSWERS, ` RONW R ANDERSON, SHERIFF 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 CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, VS. KARA M MNICK 519 COLONY ROAD CAMP HILL PA 17011 Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD By: I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 2011-163-CIVIL TERM TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT KARA M MNICK in this matter in the amount of $4,578.67 plus court costs. 237.1(a)(2) was mailed separately to each defendant on 2/10/11 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: February 21, 2011 Respectfully submitte BLATT, HASEN ER, LEI & MOORE, L ntucci 2120664 PPTJPFJI 1111111111111111111111111111111111111111111111111111 IIII -41 R 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 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 CITIBANK (SOUTH DAKOTA) N.A. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. KARA M MNICK 519 COLONY ROAD CAMP HILL PA 17011 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 2011-163-CIVIL TERM 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. Dated: February 21, 2011 By: BLATT, HAS & MOORE, L Daniel n Grego R. R, LEIBSKER 2120664 PPTJCAMI 111111111111111111111111111111111111111111111111111111111 CI IBANK (SOUTH DAKOTA) N.A. Plaintiff, VS. KARA M MNICK 519 COLONY ROAD CAMP HILL PA 17011 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 2011-163-CIVIL TERM TO: KARA'M MNICK Date of Notice: February 10, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YO 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 FIRTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, ja 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 LAVNER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU W1TH'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, HASEN LUI;L ER, 'L' SKER MOOR'E, & .; 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. 2120664 PPTNLRSI. IIIINI?I?INNIN?NN?IINIIIINN?IIII?IINIIIIIIII CITIBANK (SOUTH DAKOTA) N.A. Plaintiff, KARA M MNICK vs. 519 COLONY ROAD CAMP HILL PA 17011 Defendant(s). TO: KARA M MNICK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 2011-163-CIVIL TERM 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: 31x7 /11 JL L PROTHONOTARY By: 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 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 2120664 PPTNDJNI INS 11111111 IN III 111111111111111111111111111 IN SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i, I L P I-; ?? X111 f'( y?? i 0t 1(bT ,;F H E P '", 49 Jody S Smith Chief Deputy E01( SEP 30 PEA 2: ?, Richard W Stewart _ Solicitor ?c zE? ?E1t'?iE3t:PALAt'lis PLE14tils l-vit'J3lp' Citibank (South Dakota) N.A. vs. Kara M. Mnick Case Number 2011-163 SHERIFF'S RETURN OF SERVICE 09129/2011 12:03 PM - 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, Members 1st FCU at 1171 SPRING ROAD, NORTH MIDDLETON TWP, CARLISLE, PA 17013, Cumberland County, by handing to DEB FLOURES, CSR, 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 September 30, 2011 to Kara M. Mnick at 519 Colony Road, Camp Hill, PA 17011. SO ANSWERS, September 30, 2011 RON R DERSON, SHERIFF Ti iam Cline, Deputy Cct?n b7e r :a a Anderson S Smith of Deputy dchard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ur THE °ROTHONO [ P1, " 2012 MAY -3 PM 2: 14 vOMIERLAND COUNTY PENNSYLVANIA Citibank (South Dakota) N.A. Case Number vs. Kara M. Mnick 2011-163 SHERIFF'S RETURN OF SERVICE 09/29/2011 12:03 PM - 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, Members 1 st RPLI at 1171 SPRING ROAD, NORTH MIDDLETON TWP, CARLISLE, PA 17013, Cumberland County, by handing to DEB FLOURES, CSR, 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 September 30, 2011 to Kara M. Mnick at 519 Colony Road, Camp Hill, PA 17011. 05/02/2012 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: $87.67 SO ANSWERS, ss?? May 02, 2012 RON R ANDERSON, SHERIFF lad. ?? _ ! Cou, -6ulte SMeriff . 1eleecoft, Inx:. Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 CITIBANK(SOUTH DAKOTA)N.A. Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 CITIBANK(SOUTH DAKOTA)N.A. c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS Plaintiff, vs. CUMBERLAND COUNTY, PA KARA M MNICK CIVIL ACTION 519 A COLONY ROAD CAMP HILL PA 17011 -3Z —� Defendant(s). No. 2011-163-CIVIL TERM moo AND _ m�' MEMBERS 1ST FCU � ' ...�> q' 5000 LOUISE DRIVE s- MECHANICSBURG, PA 17055 Garnishee CD 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) directed to the sheriff of Cumberland County; (2) against KARA M MNICK defendant[s]; and (3) against MEMBERS 1ST FCU garnishee[s]; (4) and enter this writ in the judgment index (a) against KARA M MNICK Defend apt 3a- 33 = 3 �� •3�k (5) Amount due $ 4578.67 Interest from $— CDC�3 08 03-02-11 Costs to be added $ Morris Scott#83587 ^ � ( Syretta Martin#309370 044 (�! Q( Attorney for Plaintiff d 1 :50 r cy?. 0 Cl 1). 6 C) h bc 2120664 PPTGPWEI �. Q C L# ��63q WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO I1-163 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK(SOUTH DAKOTA)N.A.C/O BLATT, HASENMILLER,LEIBSKER&MOORE,LLC Plaintiff(s) From KARA M.MNICK,519 A COLONY ROAD,CAMP HILL,PA 17011 (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 1sT FCU,5000 LOUISE DRIVE,MECHANICSBURG,PA 17055 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$3,146.34 Plaintiff Paid$ Interest FROM 3-2-11 -$603.08 Attorney's Comm. % Law Library$ Attorney Paid$296.67 Due Prothonotary$2.25 Other Costs$ Date:AUGUST 12,2013 David D.Buell,Prothonotary (Seal) B : IF 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILEO-O F I:ICE ��tta,at t arursLr� Jody S Smith �xF OF THE PROTHONOT R"I r� Chief Deputy rte, Richard W Stewart Solicitor Q,F.FI'EE OFTPc.S;"CRJr= CUMBERLAND CbU!J1"Y PENNSYLVANIA Citibank(South Dakota) N.A. Case Number vs. Kara M. Mnick 2011-163 SHERIFF'S RETURN OF SERVICE 08/20/2013 10:45 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, Members 1 st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Kathleen Nissley, Sales Assistant, 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 August 23, 2013 to Kara M. Mnick at 519 A Colony Road, Camp Hill, PA 17011. AT'LIW CLINE, DEPUTY SO ANSWERS, x August 23, 2013 RON R ANDERSON, SHERIFF (c)CountySuito Sheriff:Tdeoso't, nc. Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 CITIBANK.(SOUTH DAKOTA)N.A. Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 CITIBANK(SOUTH DAKOTA)N.A. IN THE COURT OF COMMON PLEAS c/o Blatt, Hasenmiller, Leibsker& Moore, LLC CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. No. 2011-163-CIVIL TERM C-- KARA M MNICK 519 A COLONY ROAD CAMP HILL PA 17011 Defendant(s). GN 0 MEMBERS 1ST FCU 5000 LOUISE DRIVE ;in CD c; MECHANICSBURG,PA 17055 Garnishee Interrogatories to Garnishee To MEMBERS 1ST FCU, Garnishee: You are required to file Answers to the following Interrogatories within 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 on any? 2. At the time you were served or any subsequent time thereafter, was there in your possession, custody, control or in joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? �A-o 3. 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 defendants) 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? 2120664 PPTGBKCI 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 if so what was the consideration therefore? 0-0 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 defendant's direction or otherwise discharge any claim of the defendant(s) against you? tj-0 7. 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 amount of funds in each account, and the entity electronically depositing those funds on a recurring basis.' 0 0 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 monetary exemption under 42 Pa.C.S Sec.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 appro r' a interrogatories. Morris Scott, Attorney No. 83587 Syretta Martin, Attorney No. 309370 Verification 1, the undersigned representative of MEMBERS 1 ST FCU, 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. d— 1' P q �d Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 CITIBANK(SOUTH DAKOTA)N.A. Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 CITIBANK(SOUTH DAKOTA)N.A. c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS Plaintiff, Vs. CUMBERLAND COUNTY, PA KARA M MNICK 519 A COLONY ROAD CIVIL ACTION CAMP HILL PA 17011 Defendant(s). No. 2011-163-CIVIL TERM AND MEMBERS 1ST FCU _ 5000 LOUISE DRIVE -vim MECHANICSBURG, PA 17055 Zm rM*'ta Garnishees--- A , PRAECIPE TO DISSOLVE ATTACHMENT CD =--- �X 5 r To the Prothonotary: C, Kindly mark the Writ of Execution against MEMBERS 1ST FCU as DISSOLVED, and the attachment as DISSOLVED. Respectfully submitted, Kl�l Mor ' Scott Syretta rtin o 2120664 PPTXWPDI 2t�a�sy� SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ;_. _ wit 01 CltAt4bP,V Jody S Smith Chief Deputy °. 26111 M4 —4 PM 2: 29 Richard W Stewart Solicitor (,p: r MM m CUMBERL A ND Ll a l F; PENNSYLVANIA Citibank(South Dakota) N.A. Case Number vs. Kara M. Mnick 2011-163 SHERIFF'S RETURN OF SERVICE 08/20/2013 10:45 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, Members 1 s F p 1st Federal Credit Union, 1166 Walnut 9 Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Kathleen Nissley, Sales Assistant, 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 August 23, 2013 to Kara M. Mnick at 519 A Colony Road, Camp Hill, PA 17011. 03/03/2014 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: $88.25 SO ANSWERS, March 03, 2014 RoN0 R ANDERSON, SHERIFF �4s I 3 O z.? }