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Home My WebLink About11-4315 PRAECIPE FOR WRIT OF EXECUTION—(MONEY JUDGMENT)RULES PA.R.C.P. 3252,31.1.1 (a) MIDLAND FUNDING LLC In the Court of Conunon Pleas of Plaintiff CUMBERLAND County,Pennsylvania t'"j Civil Division vs. M rn NANCY BUCHER _ 309 RENO AVE NO: 11-4315 CIVIL CD NEW CUMBERLAND PA 17070-1875 sa �, Defendant C ' C-,) �> _..,_ VS. PRAECIPE FOR WRIT OF EXECUTIOiZ-ND , ATTACHMENT SOVEREIGN BANK 168 SOUTH 32ND ST CAMP HILL,PA 17011 Garnishee (MONEY JUDGMENT) To the Prothonotary:TO SATISFY THE JUDGMENT,ISSUE WRIT OF EXECUTON IN THE ABOVE MATTER (1) Directed to the Sheriff of CUMBERLAND County,Pennsylvania; (2) Against:NANCY BUCHER (3) And against:SOVEREIGN BANK 168 SOUTH 32ND ST CAMP HILL,PA 17011 (4) and index this writ(a)against Defendant(s)(b)against SOVEREIGN BANK 168 SOUTH 32ND ST CAMP HILL,PA 17011 Garnishee(s), as a lis pendens against the real property of the defendant(s)in the name of the Garnishee(s),any and all accounts of the defendant(s),in the possession of Garnishee,including but not limited to savings account balances; checking account balances;Certificates of Deposit; Money Market Accounts; contents of Safety Deposit Boxes.Defendant's SSN(s): ***-**-3847; (5) Judgment Amount $2,087.81 Interest $159.88 Payments $ Clerks Fee $ Sheriff $ Poundage $ Total $ Date:June 13,2013 \�A �� a Michae Ratchford, E uire CJ_` �p+�- ` Edwin A.Abrahamsen Associates,P.C. lJ`u (1-� CYO` Attorney for Plaintif p� mratchford @eaad com cj(, 12# a y(4)o WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-4315 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due MIDLAND FUNDING LLC Plaintiff(s) From NANCY BUCHER,309 RENO AVENUE,NEW CUMBERLAND,PA 17070-1875 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: SOVEREIGN BANK, 168 SOUTH 32ND STREET,CAMP HILL,PA 17011,ANY AND ALL ACCOUNTS OF THE DEFENDANT(S),IN THE POSSESSION OF GARNISHEE,INCLUDING BUT NOT LIMITED TO SAVINGS ACCOUNT BALANCES; CHECKING ACCOUNT BALANCES; CERTIFICATES OF DEPOSIT; MONEY MARKET ACCOUNTS; CONTENTS OF SAFETY DEPOSIT BOXES. 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; (2) 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$2,087.81 Plaintiff Paid$ Interest$159.88 Attorney's Comm. % Law Library$.50 Attorney Paid$56.25 Due Prothonotary$2.25 Other Costs$ Date: AUGUST 14,2013 David D.Buell,Prothonotary (seal) B : Deputy REQUESTING PARTY: Name : MICHAEL F.RATCHFORD,ESQUIRE Address: EDWIN A.ABRAHAMSEN&ASSOCIATES,P.C. 120 N.KEYSER AVENUE SCRANTON,PA 18504 Attorney for:PLAINTIFF Telephone: 570-558-5510 Supreme Court ID No. 85285 MIDLAND FUNDING LLC In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvania Civil Division Vs. NANCY BUCHER 309 RENO AVE NO: 11-4315 CIVIL NEW CUMBERLAND PA 17070-1875 v "`-- Defendant �� %j Fri VS. �C-) z CD SOVEREIGN BANK : •- 168 SOUTH 32ND ST CAMP HILL,PA 17011 Garnishee Praecipe for Entry of Appearance Kindly enter my appearance on behalf of MIDLAND FUNDING LLC in the above-captioned matter. Date:June 13, 2013 SII e: Pri Name: Michael s ire Address: 120 North Ke s Avenue Scranton PA 8504 Telephone No: 570 8-5510 Ext. 120 Supreme Court ID N : 86285 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i� AF FIL Sheriff f � TA ___�n OIAnNOTAR\/JodyS Smith �R�� W�� N�: �� Chief Deputy �°,+ �v" u.~, .~' — _ ' Richard VVStewart CUMBERLAND COUNTY Solicitor OFF ICE w`mmmREnIrP PENNSYLVANIA Midland Funding, LLC vs. Case Number Nancy Bucher | 2011-4315 | SHERIFF'S RETURN OF SERVICE 08/20/2013 1l:31AM-William Cline, duly sworn according to law, attached os herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 West High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Julie Myers, 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 todefendant was mailed on August 23 281 Reno Avenue, New Cumberland, PA17O78. /Z/z� z jr-- 4MKIAM CLINE-, DEPUTY SO ANSWERS, August 23. 2O18 Rbl\11`4�'R ANDERSON, SHERIFF MIDLAND FUNDING LLC In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania Civil Division vs. NANCY BUCHER Cl) ry cw 309 RENO AVE NO: 11-4315 CIVIL _cz _ -r NEW CUMBERLAND PA 17070-1875 Defendants YS M==;;o v rsl-- � WG vs. INTERROGATORIES IN ATTACHMENCd �p • AC7 � SOVEREIGN BANK 168 SOUTH 32ND ST C r*%) C:), CAMP HILL,PA 17011 ry J r Garnishee RE: Execution of Judgment against your depositor NANCY BUCHER SSN# ***-**-3847 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: 1) At the time you were served or at any subseqent time, did the Defendant possess any bank accounts,joint or individual,that were in your custody or control?Please specify joint or individual account. Please list the legal title of any such account(s) and the primary account holder and if known whether joint account is entireties property. YES 2) At the time you were served or at any subsequent time,what was the balance and account number of the bank accounts(s) identified in Interrogatory#1? SEE ATTACHED 3) At the time you were served or at any subsequent time,please list the average daily balance in the past five(5)months for each such account identified in your answer to Interrogatories number one(1) and two(2)above. SEE ATTACHED 4) At the time you were served or at any subsequent time, did the bank account(s)that the Defendant possessed contain fund derived solely from social security funds and/or disability funds? YES 5) At any time before or after you were served, did the Defendant(s)transfer or deliver any property or money to you or to any person or place pursuant to your direction or consent, and if so, what was the consideration therefore? NO � r E� 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 Depositor's direction or otherwise discharge any claim of the Depositor against you? NO 7) At the time you were served or any subsequent time, did you have, share,or utilize any safe-deposit boxes,pledges, documents of title, securities,notes, coupons, receivable, license, or collateral in which there was an interest claimed by Defendant(s)? NO 8) At the time you were served or at any subsequent time did the Defendant(s)account contain funds deposited electronically on a recurring basis and which are identified as being exempt from execution, levy or attachment. If so, state the reason for the exemption,the amount being withheld and the entity electronically depositing those funds on a recurring basis. YES, SEE ATTACHED 9) At the time you were served or at any subsequent time did the defendant 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. Section 8123? If so, identify each account. NO 10) Identify every other account(not previously noted)titled in the name of the Defendant(s) in which you believe the Defendant(s)have an interest in whole of part, whether or not styled as a payroll account, individual retirement account,tax account, lottery account,partnership account,joint or tenants by entirety account, insurance account,trust or escrow account, attorney's account, or otherwise. N/A 11) To the extent that you're above answers depend in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same).Our answers rely on the seareh of an Electtonic Customer Information Data Base. Edwin A. rah nse & ssoci sy,C By Michael P.Ratcl or d,Esquire 120 North Key r.Avenue Scranton, P 18504 (570) 558- 510 Ext. 101 ANSWERS TO INTERROGATORIES Account# 7676588065 Balance: $25.04 It has been determined that this account is exempt from attachment under the Code of Federal Regulations Title 31, Part 212. Account Holder: NANCY A BUCHER 309 RENO AVE NEW CUMBERLND, PA 17070-1875 Account # 0774304042 Balance: $0.00 Account Holder: NANCY A BUCHER 309 RENO AVE NEW CUMBERLND, PA 17070-1875 Account# 0771025971 Balance: $0.'00 Account Holder.- NANCY A BUCHER KIMBERLY A. BUCHER 309 RENO AVE NEW CUMBERLND, PA 17070-1875 VERIFICATION 1, John S. Games; C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment 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. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank By: _ John S. Gomes C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA ' IN RE: MIDLAND FUNDING LLC vs. NANCY A BUCHER CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Associates, P.C. 120 N. Keyser Avenue Scranton, PA 18504 Service by certified mail addressed as follows: NANCY A BUCHER 309 RENO AVE NEW CUMBERLND, PA 17070-1875 A Gomes . ead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 September 3, 2013 MIDLAND FUNDING LLC In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania Civil Division vs. NANCY BUCHER 309 RENO AVE NO: 11-4315 CIVIL, NEW CUMBERLAND PA 17070-1875 c -- Defendant Praecipe to Dissolve the Attachment agoi= ZZ ---i rn CO f/3 =-r' Garnishee fir,i � rx••,- vs. r -<> C SOVEREIGN BANK 168 SOUTH 32ND ST =C) { CD CAMP HILL, PA 17011 , +`� Garnishee C>a To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank ou, ichael F. Rat for , Esquire Edwin A. Abr amsen&Associates, P.C. Lawyer ID # 6285 C� a w SHERIFF'S OFFICE OF CUMBERLAND COUNTY iy R Anderson ariff C u be 4 �( I H'- Jody S Smith � Chief Deputy ; Mil MAR -4 PM 2: 2 9 Richard W Stewart Solicitor C,Pf CP=^Pn l % dUMBERLAND CUUNTY PENNSYLVANIA Midland Funding, LLC Case Number vs. 2011-4315 Nancy Bucher SHERIFF'S RETURN OF SERVICE 08/20/2013 11:31 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, Sovereign Bank, 17 West High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Julie Myers, 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 August 23, 2013 to Nancy Bucher at 309 Reno Avenue, New Cumberland, PA 17070. 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: $89.19 SO ANSWERS,"X": March 03, 2014 RON�R ANDERSON, SHERIFF p - a 4.o 93'297 ,&` 30..4$ / u ;juts OSO. lnc_