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Home My WebLink About11-0480 Our File No.: 305372 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff AMERICAN EXPRESS BANK, FSB 4315 SOUTH 2700 WEST SALT LAKE CITY, UT 84184 Plaintiff, VS. NICOLE COPELAND 750 VISTA DR CAMP HILL, PA 17011 Defendant. v i 1Ua. n n n;}J n?.,v ELI i , ";' 19 F'? T I ii L i+1 if t aiJ+ .1 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ? I - A480 a-N i1 Terry NOTICE 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 BAR ASSOCIATION 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 `l:/ -*9a .OD Po ATW C7 I4(o59 e a539ol / Our File No.: 305372 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff AMERICAN EXPRESS BANK, FSB 4315 SOUTH 2700 WEST SALT LAKE CITY, UT 84184 Plaintiff, VS. NICOLE COPELAND 750 VISTA DR CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICAN EXPRESS BANK, FSB, 4315 SOUTH 2700 WEST, SALT LAKE CITY, UT 84184. 2. Defendant(s) is/are NICOLE COPELAND, an adult individual residing at 750 VISTA DR CAMP HILL, PA 17011. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS BANK, FSB, issued to Defendant(s), Account # ending in 1000. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $27,977.51. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $27,977.51 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Enna! BY: Dated: 1/11/2011 CIATES, P.C. Debt David J. ApN? ker, Esquire Our File No.: 305372 VERIFICATION David J. Apothaker, Esquire, Esq. hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S."904 relating to unworn falsification to authorities. David J. Apotha Attorney for Esquire DATE: 1/11/2011 AMERICAN EXPRESS BANK, FSB NICOLE COPELAND 750 VISTA DR CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: NICOLE COPELAND Account Number: ending in 1000 Balance Due: $27,977.51 Our File No.: 305372 EXHIBIT "A" 305372 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiff/s: Court Number: AMERICAN EXPRESS BANK, FSB Expiration Date: Type of Action: Civil Action Defendants: NICOLE COPELAND Serve Upon: NICOLE COPELAND Address for Service: 750 VISTA DR CAMP HILL, PA 17011 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () Posting Special Service Instructions: * * If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 Our File No.: 305372 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 AMERICAN EXPRESS BANK, FSB Plaintiff vs. NICOLE COPELAND Defendant THE PRp HONG T M AIiY 2112 JUL -2 pH 4.. G2 CUt?#;ERLASO Wy I`? HNSYLVARIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 11-480-CIVIL, TERM Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, NICOLE COPELAND, in the default of an Answer, in the amount of $27,977.51 computed as follows: Amount claimed in complaint: $ 27,977.51 Less: Amount Paid: ( 0.00) Plus: Interest from January 11, 2011 to June 26, 2012 at the legal interest rate of 0.00% per annum 0.00 Attorney fees 0.00 TOTAL 27,977.51 I certify that Defendant, NICOLE COPELAl, I st known address is 750 VISTA DR Dated: June 26, 2012 CAMP HILL, PA 17011. I, David J. Apotfiaker, Esp. Attorney for Plaintiff a4}% Iso P d a4/' k-tF Ca1831 ?lohu M? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: NICOLE COPELAND 750 VISTA DR CAMP HILL, PA 17011 AMERICAN EXPRESS BANK, FSB Plaintiff vs. NICOLE COPELAND Defendant NOTICE: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 11-480-CIVIL, TERM Civil Action Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, EscF at this telephone number: 800-672-0215 Our File No.: 305372. 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 AMERICAN EXPRESS BANK, FSB COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. NICOLE COPELAND NO.: 11-480-CIVIL TERM Civil Action Defendant 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: June 26, 2012 Attorney for Plaintiff Our File No.: 305372: 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 AMERICAN EXPRESS BANK, FSB Plaintiff vs. NICOLE COPELAND Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 11-480-CIVIL TERM Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. 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 750 VISTA DR CAMP HILL, PA 17011. 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 Defen e M npower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in t e ilitary. David J. Apoth?aker, 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. Department of Defense Manpower Data Center Status R rt Pursuant to Servicemembers Civil Relief Act Last Name: COPELAND First Name: NICOLE Active Duty Status As Of: Jun-26-2012 Results as of : Jun-26-2012 06:55:06 SC RA 2.2.1 Active Duty Start Date Active Duty End Date Status Service Component On Active Duty On Active Duty Status Date NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Acti ve Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duly on Active Duty Status Date Order Notification Start Date Order No6fication End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the, Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Aal fill Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. Ti DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual leftActive Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive: days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 5021 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (Ai and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric: Administration (NOAH Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could re y on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name.. SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: F7SH1E0M77 AMERICAN EXPRESS BANK, FSB ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) NICOLE COPELAND ) NO. 11-480-CIVIL TERM To: NICOLE COPELAND 750 VISTA DR CAMP HILL, PA 17011 Date of Notice: June 14, 2012 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 BAR ASSOCIATION 34 S. BEDFORD ST. CARLISLE, PA 17013 717-249-3 166 DAVID J. APOTHAKER, 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 305372 Our File No.: 305372 AMERICAN EXPRESS BANK, FSB IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NICOLE COPELAND NO.: 11-480-CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: CD Issue a Writ of Execution in the above matter, .�� =Z = m (1) directed to the Sheriff of CUMBERLAND County; co v o �CD (2) against NICOLE COPELAND, defendant(s); and C) (3) against METRO BANK 65 ASHLAND AVE CARLISLE, PA 17013, Garnishee(s); -� to �K (4) and index this writ in the judgment index (a) against NICOLE COPELAND, defendant(s), and (b) against METRO BANK 65 ASHLAND AVE CARLISLE, PA 17013, as Garnishee(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 $27977.51 Interest from July 02, 2012 $689.86 Minus Payments made $0.00 Plus Costs $195.50 Total $28862.87 0 A C S David J. Apot aker, Esquire 0t) Attorney for Plaintiff(s) 11 � CP WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-480 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN EXPRESS BANK,FSB Plaintiff(s) From NICOLE COPELAND,750 VISTA DR Q,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: METRO BANK,65 ASHLAND AVENUE,CARLISLE,PA 17013-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$27,977.51 Plaintiff Paid$ Interest FROM JULY 2,2012-$689.86 Attorney's Comm. % Law Library$.50 Attorney Paid$179.00 Due Prothonotary$2.25 Other Costs$$195.50 Date: 4/30/13 David D. Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name :DAVID J. APOTHAKER,ESQUIRE Address: APOTHAKER& ASSOCIATES,P.C. 520 FELLOWSHIP ROAD C306 P.O.BOX 5496 MOUNT LAUREL,NJ 08054 Attorney for: PLAINTIFF Telephone: 856-780-1000 Supreme Court ID No. s Our File No.: 305372 AMERICAN EXPRESS BANK, FSB ) COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY vs. ) NICOLE COPELAND ) NO.: 11-480-CIVIL TERM 750 VISTA DR ) CAMP HILL, PA 17011 ) Civil Action XXX-XX-7100 ) Defendant ) w - METRO BANK vy —` o -G -� -,i. Garnishee n C) 0AsAers =�' INTERROGATORIES TO GARNISHEE 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. I. 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? Defendant has a joint spousal account with less than $300 exemption 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 defendant's 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 V 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:q 1J-� David J. Apo Cal�er,Es e 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 unsworn 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. J J(SIG TU ) , SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r,•/yd _Ot44'c-e Sheriff tvvvtr at Colwyn or .G Pi Oiw'kury Jody S Smith 4, Chief Deputy a°/3 bee_ .-, PM a='// Richard W Stewart ';, Cpunl�j Solicitor OFFICE OFYHE SKEW: Cu►nb�r lQ.�o( 'Pen nsylaaK :ci. American Express FSB Case Number vs. Nicole Copeland 2011-480 SHERIFF'S RETURN OF SERVICE 05/01/2013 02:42 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, Metro Bank, 20 Noble Boulevard, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Nicole Erickson,Assistant 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 May 2, 2013 to Nicole Copeland, 750 Vista Drive, Camp Hill, PA 17011. 12/03/2013 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: $89.19 SO ANSWERS, g 'Xi'l December 03, 2013 RONR ANDERSON, SHERIFF • SD LL-pd . a1 5t //4, RA .295161,T" (c)CountySui!e Sheriff,Teieosofi, !?,: WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-480 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN EXPRESS BANK,FSB Plaintiff(s) From NICOLE COPELAND,750 VISTA DR Q,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: METRO BANK,65 ASHLAND AVENUE,CARLISLE,PA 17013-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$27,977.51 Plaintiff Paid$ Interest FROM JULY 2,2012-$689.86 Attorney's Comm. % Law Library$.50 Attorney Paid$179.00 Due Prothonotary$2.25 Other Costs$$195.50 Date: 4/30/13 2/A-ae.-1 David D.Buell,Prothonotary (Seal) ) Deputy REQUESTING PARTY: Name: DAVID J. APOTHAKER,ESQUIRE Address: APOTHAKER& ASSOCIATES,P.C. 520 FELLOWSHIP ROAD C306 P.O.BOX 5496 MOUNT LAUREL,NJ 08054 TRUE COPY FROM RECORD Attorney for: PLAINTIFF In Testimony whereof,I here unto,set my hand Telephone: 856-780-1000 and the opal of said Court at Carlisle, Pa.2 This •3U day of r !,20 � Supreme Court ID No. Pr than-:.^ ,4Aplet Our File No.: 305372 Apothaker Scian P.C. By: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road Suite C306, PO Box 5496 Mt. Laurel, NJ 08054-5496 (800) 672-0215 Attorneys for Plaintiff AMERICAN EXPRESS BANK, FSB Plaintiff, vs. NICOLE COPELAND Defendant. Cl.il.fUE q 3. /4 RS�YL�tV,� TY PENNSYLVANIA EN , U �/U�� A COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 11 -480 -CIVIL TERM PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. Apothaker Attorneys A Law Firm Enga By: cian P or Plain ed in De C. iff t Collection David J. Apoth. er, Esquire 111111111111111111 3 N A T 1 - CIutt- IbuocoS