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Home My WebLink About11-0895IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA f: ?? -- i ASSET ACCEPTANCE LLC assignee of EXPRESS / World Financial Network Plaintiff Np ri V. CIVIL ACTION - LAW "'? r ANITA R MAYBERRY - D : Defendant(s) 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 an 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 or any other claim or relief requested by the Plaintiff. You may lose money or property 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 HELP. 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 32 S BEDFORD ST. CARLSIL.E, PA 17013 (717) 249-3166 FFG File # 260743 IN IIII1 IIIII 11111111111111111111111111111 IN III IIII PA/PA_NTCDE sco, -A R, aa? VFUI ,? oWdrf IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC assignee of EXPRESS / World Financial Network Plaintiff V. ANITA R MAYBERRY Defendant(s) NO. CIVIL ACTION - LAW NOTICIA USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o objeciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 32 S BEDFORD ST. CARLSILE, PA 17013 (717) 249-3166 FFG File#: 260743 PA/PA_NTCDE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC assignee of EXPRESS / World Financial Network 28405 VAN DYKE WARREN MI 48093 v Plaintiff NO. CIVIL ACTION - LAW ANITA R MAYBERRY 586 ARIEL CT MECHANICSBURG PA 17055-5496 Defendant(s) COMPLAINT AND NOW, comes Plaintiff, by and through its attorneys, Fulton, Friedman & Gullace, LLP, and files this Complaint and in support avers as follows: 1. Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was assigned all rights, title and interest to defendant's EXPRESS / World Financial Network account XXXXXXXXXXXXXX8287 (ASSET ACCEPTANCE LLC Number 40633733) (hereinafter "the account"). 2. Upon information and belief, Defendant(s), ANITA R NIAY13ERRY , has a last known address(es) of: 586 ARIEL CT MECHANICSBURG PA 17055-5496 3. Upon information and belief, the account is based on a written credit agreement entered into between Defendant and the original grantor; as provided to Plaintiff, the material terms of the agreement applicable to accounts issued by EXPRESS / World Financial Network are attached hereto. 4. Upon information and belief, defendant(s) used or authorized the use of the account to obtain loans from the original credit grantor for the purpose of obtaining goods, and/or services and/or cash advances. 5. Defendant(s) failed to make full payment of the amount owed on the account. 6. Upon information and belief, the last payment posted to the account on 10/19/2008. 7. The account shows that the Defendant(s) owe(s) a balance of $1732.90. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant(s) in the amount of $1732.90, plus costs of this action, and any other relief as this Court deems just and reasonable. David R. Fulton Fi 130B Ge T Submitted, is oway # 87326 -ftan & Gullace, LLP sburg Pike burg, PA 17055 Number: (866) 563-0809 FFG File # 260743 VERIFICATION I verify that the facts set forth in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Because of my title, I am authorized to make this verification on behalf of Plaintiff. Date:1 Z. C V PAMELA McCULLOUGr, By Print Name , ?""? SUPERVISOR Title 1 C UNDEP ,"(tip: °rt.??ti ?pn Exp c- F o the Coun c ; ? FFG File # 260743 EXHIBIT A EXPRESS - Credit Card Terms and Conditions Credit Card Terms and Conditions Page I of 2 IMPORTANT RATE, FEE AND OTHER COST INFORMATION ANNUAL PERCENTAGE RATE (APR) Revolving Credit Plans: 22.8% FOR PURCHASES This rate may vary. VARIABLE, RATE INFORMATION For Revolving Credit Plans, your APR may vary each Billing Period. This rate is determined by adding 13.8% to the highest "Prime Rate" as published in The Wall S"er Journal for the calendar month preceding the month in which the Billing Period begins. Your APR will not decrease below 22.8% nor increase above 24.990A. GRACE PERIOD FOR REPAYMENT OF 25 days for Regular Revolving Purchases; BALANCES FOR PURCHASES METHOD OF COMPUTING THE Average Daily Balance (including new purchases) BALANCE FOR PURCHASES ANNUAL FEES None MINIMUM FINANCE CHARGE. $1.00 for any Billing Period in which a Finance Charge of less than $1.00 would otherwise be imposed. LA'Z'E PAYMENT FEE one if your Account Balance is less than $20.00; $20.00 if your Balance is $20.00 to $249.99; $25.00 if your Balance is equal to or greater than $250.00. CHANGES. We may add, change or delete any of the terms of your Account and the corresponding Credit Card Agreement (including, but not limited to, Annual Percentage Rate and fees), at any time with or without notice, except as may be required by applicable federal and Ohio law. If notice is required, it will be mailed to you at least fifteen (15) days prior to the effective date of the change. These additions, changes or deletions of terms wil apply to new purchases and to all amounts you already owe us. 'i'he information about costs of the credit card account described in this application is accurate as of August 1, 2008. This information may have changed after that date. To find out what may have changed, please call or writr us at: World Financial Network National Bank PO Box 330066 Notthglenn, CO 80233-8066 You agree that a credit report may be used in making the credit granting decision. The Ohio laws against discrimination require that all creditors make credit equally available to all creditworthy customers, and that credit reporting agencies maintain separate credit histories on each individual upon request. The Ohio civil rights commission administers compliance with this law. California Residents: If you are married, you may apply for a separate account. New York Residents: A consumer credit report may be ordered in connection with the processing of an application, or subsequently with the update, renewal or extension of credit. Upon your request, you will be informed of whether or not a consumer credit report was ordered, and if it was, you will be given the name and address of the consumcr-reporting agency that fumished the report. Rhode Island and Vermont Residents: A consumer credit report may be ordered in connection with the https://onlineaccess.mycrcditcard.cc/WebApps/express?Action-'1"ac..jsp 8/27/2008 EXPRESS - Credit Card 'Perms and Conditions Page 2 of 2 processing of an application, or subsequently for purposes of review or collection of the account, increasing the credit line on the account, or other legitimate purposes associated with the account. Wisconsin Residents: No provision of any marital property agreement, unilateral statement under Section 766.59 of the Wisconsin statutes or court order under Section 766.70 adversely affects the interest of the creditor, World Financial Network National Bank, unless the Bank, prior to the time credit is granted is furnished a copy of the agreement, statement or decree or has actual knowledge of the adverse provision when the obligation to the Bank is incurred. i am applying to World Financial Network National Bank (WFNNB) for, and hereby request, an Express credit card account for personal, family or household use. I hereby authorize WFNNB to investigate my credit record. 'The information that I have supplied is true and correct. I acknowledge that I am a permanent resident of the United Stales. I agree that a credit report may be obtained for any lawful purpose, including in connection with the processing of an application, or subsequently with the update, renewal or extension of credit. Upon my request, I will be informed of whether or not a consumer credit report was ordered, and if it was, l will he given the name and address of the consumer-reporting agency that furnished the report. I agree to be bound by the terms of the Credit Card Agreement. I acknowledge that I will receive a Credit Card Agreement upon approval. I also acknowledge that there is no agreement between WFNNB and me until WFNNB approves my credit application and accepts the Credit Card Agreement at its office in Ohio and that the Credit Card Agreement is deemed to be made in Ohio. Cards are issued and credit is extended by WFNNB, Columbus, Ohio. PLEASE: NOTE: BY SUBMITTING THIS CREDIT APPLICATION, YOU ARE AGREEING TO THE FOLLOWING WITH RESPECT TO CERTAIN CONSUMER INFORMATION ABOUT YOU. You hereby authorize World Financial Network National Bank ("us" or "we") to furnish our decision to issue an account to you to Express, Inc_ You hereby authorize us to furnish, if your application is approved, information concerning your account to credit bureaus, other creditors and Express, Inc. Check your information before submitting. We cannot process any submission without a complete and accurate name, address, date of birth and social security number. By submitting this Application you are acknowledging having read and understood the IMPORTANT RATE, FEE AND OTHER COST INFORMATION and, if approved, agreeing to be bound by them. Hasa https://onlineweess.myereditcard-cc/WebApps/express?Action=Tac jsp 9/27/2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC assignee of EXPRESS / World Financial Network, Plaintiff NO. 2011-895Civi1 vs. CIVIL ACTION - LAW C3 (- r-> O C- -.F ANITA R MAYBERRY -V3 = --? ma) xp- -fit Defendant tom- -O rn PRAECIPE FOR DEFAULT JUDGMENT To the Prothonotary: ? o 4, Please enter Default Judgment in favor of Plaintiff and against Defendant(s), ANITA R MAYBERRY I&?il ure-to fj vl written response to Plaintiffs Complaint. --^? -,; C (X) Principal in Complaint $1732.90 Less payments received $0.00 Interest in Complaint $ -0- Attorneys' Fees $ -0- TOTAL $1732.90, plus court costs (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to Pa.R.C.P. 237, I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.R.C.P. 237. 1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. FULTON, FRIEONt +J, & QW.,LACE LLP FFG File # 260743 Signature: _ David R. Galloway #8 26 130B Gettysburg Pike Mechanicsburg, PA 17055 (866) 563-0809 Counsel for Plaintiff Attorneys in the Practice of Debt Collection m 4 y / a) !--)?k) ,yej?4# -X-7 9 36- PA PA_PRAEJD ?1'?o // lk ?'GI 4 FULT"ON FRIEDMAN & GULLACE LLP COLLECTIONS, CONSULTING & LITIGATION LICENSED IN ARIZONA. CALIFORNIA, DISTRICT OF COLUMBIA, MARYLAND, NEW YORK, PENNSYLVANIA. TENNESSEE &TEXAS NEW YORK 28 E. MAIN STREET, SUITE 500 ROCHESTER, NEW YORK 1 461 4 PENNSYLVANIA TELEPHONE 130B GETTYSBURG PIKE (800) 869-2331 MECHANICSBURG, PA PLEASE DIRECT ALL CALLS TO TOM MCCARTHY 17055 March 22, 2011 ANITA R MAYBERRY 586 ARIEL CT MECHANICSBURG PA 17055-5496 Re: ASSET ACCEPTANCE LLC assignee of EXPRESS / World Financial Network vs. ANITA R MAYBERRY Docket No. 2011-895Civi1 Dear Defendant: Enclosed herein please find a 10-Day notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Enclosure CC: Sincerely, FULTON, FRIEDMAN, & GULLACE LLP David R. Galloway #87326 130B Gettysburg Pike Mechanicsburg, PA 17055 (800) 869-2331 Counsel for Plaintiff Attorneys in the Practice of Debt Collection THIS IS AN ATTEMPT TO COLLECT A DEBT BY A DEBT COLLECTOR AND ANY INFORMATION WILL BE USED FOR THAT PURPOSE. FFG File # 260743 PAPA 10DAYNTC . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V ASSET ACCEPTANCE LLC assignee of EXPRESS / World Financial Network Plaintiff NO. 2011-895Civil CIVIL ACTION - LAW ANITA R MAYBERRY Defendant(s) To: ANITA R MAYBERRY 586 ARIEL CT MECHANICSBURG PA 17055-5496 DATE OF NOTICE.: 03/22/2011 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 32 S BEDFORD ST. CARLSILE, PA 17013 (717) 249-3166 FULTON, FRIEDMAN, & GULLACE LLP By: David R. Galloway #87326 130B Gettysburg Pike Mechanicsburg, PA 17055 (800) 869-2331 Counsel for Plaintiff Attorneys in the Practice of Debt Collection FFG File # 260743 PA/PA IODAYNT(' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC assignee of EXPRESS / World Financial Network Plaintiff V. ANITA R MAYBERRY Defendant(s) NO. 2011-895Civil CIVIL ACTION - LAW NOTICE OF JUDGMENT Notice is hereby given that a Judgment in the above-captioned matter has been entered against you as follows: Principal in Complaint Less payments received Interest in Complaint Attorneys' Fees TOTAL $1732.90 $0.00 $ -0- $ -0- $1732.90, plus court costs NOW, A/T 20 ( JUDG)PRNT IS ENTERS AS ABOVE. tart'/Clerk, ivil Division By: Deputy I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: ANITA R MAYBERRY 586 ARIEL CT MECHANICSBURG PA 17055-5496 FFG file #: 260743 1111111 Nil 11111111111111111111111111111111111111111111111 FULTON, LLP Signature: \,A L David R. Galloway #8732 130B Gettysburg Pike Mechanicsburg, PA 170 5 (866) 563-0809 Counsel for Plaintiff Attorneys in the Practice of Debt Collection PA/PA NTCOFJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC assignee of EXPRESS / World Financial Network v ANITA R MAYBERRY 586 ARIEL CT MECHANICSBURG PA 17055-5496 : ❑ Confessed Judgment : t I Other : Docket No. 2011-895Civil : Judgment Amount $1732.90 : Less Payments $(0.00) : Interest: : Total: Comrn: : Costs: PRAECIPE FOR ATTACHMENT" r,AIL, u i 1VIN TO THE PROTHONOTARY: $331.86 $2064.76: Atty's 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. a W Pine Ct, Mt HollgSprin�s PA I'tD((5 Issue writ of attachment in the above natter to the Sheriff of Cumberland aunty, for debt, interest and cons, directing attachment against PNC BANK , as Garnishee, for the following All accounts, including but not limited to, all savings, checkin deposit, notes receivables, collateral, pledges, documents of title, securi the defendant(s) in the possession, custody or control of Garnishee. Date FFG File # 260743 of the defendant(s): otter accounts, certificates of ox pons and all other property of Signature: %ar Print name: Michael B. Volk, Esq. Address: 6 Kacey Court, Suite 203 Mechanicsburg, PA 17055 Attorney for: ASSET ACCEPTANCE LLC Telephone: (866) 563-0809 Supreme Court ID No:#88553 111111111111111111111111111111111111111111111111111111 li i i 1111111 A.114003 CliqVTJeN113 !fid Z- 7!?r 'I 1St N q r{ o' PA_BANKPWRITC .*aq . 00 PD AT`/ 3°l. oo 'CBF 9a.Do " I�. o0 $ I ria .od— Pi Amt *a. a.5 cue v • 5o LI. eaaLi8a8 ?#3°195/ 1,011+10 \d 'd THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net ASSET ACCEPTANCE, LLC, assignee of EXPRESS/World Financial Network Vs. NO 2011-895 Civil Term CIVIL ACTION — LAW ANITA R. MAYBERRY WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against ANITA R. MAYBERRY, 586 Ariel Ct, Mechanicsburg, PA 17055-5496, Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of PNC BANK, 2 W Pine St, Mt. Holly Springs, PA 17065, GARNISHEE(S), as garnishee, All accounts, including but not limited to, all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and all other property of the defendant in the possession, custody or control of Garnishee. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis andare identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If 1 multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $1,732.90 Interest -- $331.86 Attorney's Comm. % Attorney Paid $172.00 Date: 7/2/14 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary REQUESTING PARTY: Name : MICHAEL B. VOLK, ESQUIRE Address: FULTON, FRIEDMAN & GULLACE, LLP 6 KACEY COURT, SUITE 203 MECHANICSBURG, PA 17055 Attorney for: PLAINTIFF Telephone: 866-563-0809 Supreme Court ID No. 88553 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE PRO -MONO ;'', Z1114111_ I M !O: CUMBERLAND COUNTY MICE OFTHF G'EF'iIFF PENNSYLVANIA tin �t Ctroito rf Asset Acceptance LLC vs. Anita R. Mayberry Case Number 2011-895 SHERIFF'S RETURN OF SERVICE 07/09/2014 10:00 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Susan Casale, Consultant, 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 11, 2014 to AnitR Mayberry at 586 Ariel x9 Court, Mechanicsburg, PA 17050-5496. 7 A LI E, DEPUTY SO ANSWERS, July 11, 2014 RONIN' R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoff, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSET ACCEPTANCE LLC assignee of EXPRESS / World Financial Network Plaintiff NO. 2011-895Civil v. ANITA R MAYBERRY Defendant(s) TO THE PROTHONOTARY: CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT Please discontinue the Writ of Execution filed against Garnishee PNC BANK in the referenced matter without prejudice. Michael B. Volk, Esq. #88553 Fulton, Friedman & Gullace, LLP Counsel for Plaintiff 6 Kacey Court, Suite 203 Mechanicsburg, PA 17055 (866) 563-0809 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office, first class mail, postage prepaid, addressed as follows: ANITA R MAYBERRY 586 ARIEL CT MECHANICSBURG PA 17055-5496 PNC BANK 2 WEST PINE STREET MT. HOLLY SPRINGS PA 17065 FFG file #: 260743 PA/PA_PRAEDISATT Michael B. Volk, Esq. Attorney ID #88553 1111111 IIIII VIII IIIII IIIII IIIII IIIII IIII 111111 1111111 IIII III IIII ()ow\ c$cl.-e Ot--4-01))0tgi 3bcc?07