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Home My WebLink About11-4588 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, vs. ISAAC UDOTONG, Defendant. COMPLAINT IN CIVIL ACTION Filed on behalf of Plaintiff , PNC Bank, National Association c-) G ?W -?- -i '/cQ Code: - YJ?J ?tvi z,, ?v r r.? wow 3 Counsel of Record for this Party: io 0 Donna M. Donaher, Esquire ca Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 A? ??a oc? ? d a, 124 0S 9"7(a l IN THE COURT OF COMMON PLEAS OF -CUMBERLAND COUNTY, PENNSYLVANIA Civil Division PNC BANK, NATIONAL ASSOCIATION, Plaintiff, vs. ISAAC UDOTONG, No. ? ( - LI S$9 C1 n Defendant. 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 the 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 1-800-990-9108 N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Division PNC BANK, NATIONAL ASSOCIATION, ) Plaintiff, ) vs. ) No. ISAAC UDOTONG, ) Defendant. ) COMPLAINT IN CIVIL ACTION AND NOW, comes the Plaintiff, PNC BANK, NATIONAL ASSOCIATION, by and through its counsel, Tucker Arensberg, P.C. and files this Complaint stating as follows: 1. Plaintiff is PNC Bank, National Association, a national banking association and a citizen of Pennsylvania with its main office at Fifth Avenue and Wood Street, Pittsburgh, Allegheny County, Pennsylvania 15222. 2. Defendant, Isaac Udotong is an individual with a residence address of 1202 Summit Way, Mechanicsburg, PA 17050. 3. On or about August 5, 2008, Plaintiff and Defendant entered into a Direct Installment Note ("Note") whereby Plaintiff did lend the sum $130,123.68, and Defendant promised to pay to Plaintiff the amount due under the terms and conditions of the Note. A true and correct copy of the Note is attached hereto, incorporated herein, and labeled Exhibit "A". 4. Under the terms and conditions of the Note, Defendant promised to pay to Plaintiff the sum of $697.72 per month commencing September of 2008. 5. On or about January of 2010, and at certain times thereafter continuing until the present, Defendant has failed to make monthly payments in the correct sum and when due under the terms and conditions of the Note. 6. By reason of Defendant's failure to make a monthly payment when due, there is a default under the terms and conditions of the Note and the entire balance of the Note is now due and payable. 7. Commencing on or about February of 2010, and continuing to the present, Plaintiff has made numerous requests and demands to Defendant for payment of the money due under the Note, but Defendant has failed/refused to remit payment of monies due to Plaintiff. 8. The amount due to Plaintiff under the terms and conditions of the Note is $139,079.45. 9. Pursuant to the terms of the Note, Defendant is liable to PNC Bank for reasonable attorneys fees. Attorneys fees due and owing total $1,500.00. WHEREFORE, Plaintiff requests this Honorable Court to enter a judgment in favor of Plaintiff and against Defendant, in the amount of $140,579.45, plus costs and interest. Respectfully submitted, TUCKER ARENSBERG, P.C. By. ?Donna M. Donaher, Esquire 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 Attorney for Plaintiff BA N K_F I N :406944-1 999999-999999 age 2 of 5) Direst Installment Borrower: ISAAC UWTONG Pop1of3 Loan Disclosure and Note Lender: pNC Banc, National Association aAas makd •®• a ow esm&ralet. IN.NACS f 13130163 UOP QPNCBANK Deis: 08/06/2008 % Afntwnt Finattoed The attoaw of rik Total of Pa TM amost *a Borrower M AGE T?otapw the paided t* N i m paid after ? ? Tswpvew s The as a lr wB test t ] Borra go um in behalf. ts as ll 'a e a ochedded. ye trio 4990 ;121,055.52 $130.123.68 $251,179.20 e Seearity: lsera it ptinp a swrity lowest b deposits or AeM by tenser sod: [Nero. 9 Goads a wwm belno pechaed Red Estate. to addlft collateral (Am Was Swomm s pbrdpd fedsa oo oft t d was to tower a"aka awn ft Nan. map???y W M IQ EM Rim Fees* 40.00 tea Cww ? Not Appieolda. ® if a paymm ie so salt W" is days of kt dess 49L Bsnssrar way be chm9w do peter of SMJ00 or 10% of de low rioter of the wmdm oat me psM M ha NBonowapaysoNarw 8aerowa ia] m?y wrrl sot fetes a pr a?My Ragebedotp"kB@kne«(a]NotAtmpiwebb 0TheAhsd NapMepe Rsq doer not tab fate w4ow my rogiitd deposk bdmL Asm odd- N 1W lose it sewed by a dwwlftap, =am pt" two tawse to raaaisda of the Ise a YRtMido Rats: ® Not Appikaat. UU We Im coeds a wnklb now feawe. Oialomtas about ft wrio6fe rea Worst have bass p rMW to test taft N Berroswrt asrti?sdm M eb twome k pymmt on is ffkmtdsaad for say Mato, its Aulnouie Paime w PM Dkcaws of ppamm ppalllt?ttit wB ww om ad nap am do am is I , - Asp I in blot me as comm the mma of go payaws to insert. for sssepfe, if yew loss wom for 110,800.00 at un b kW tale of 13112%, tepoyable is 48 wamm animates of 1270.78, sad the Dimmtt tetnaI - Ow 12 tlo parytaao armsaw wow bwxas to s for the rmrirda of that tam M Wt leer. fflo payment smms 8rsonr ham W sisal a purdntt tkt6t Iswmw.) ? N Berewa sswa a M s1p06 far der EwNlpoo Iswtik 0btowu M IM ipanM rw4 the iMpeq rap m Wk bin wM blasss to • sap ezletsaad by *A69 the Mgmmt use swool M dh No by B51i. Any b um m N do role will taus sir mum of tb payments; to letters. For vast has some IN {10,800,80 at so Will btleaa tale of f1.5%. 11 111 M 48 wtoN* pstsssws of $261.23. and tie k= ft Discount tundaaed shat 12 psym m eht p*rM amenwow bases s iS22 67 to dw raweMder of IN tent of fie Nos. RM -,-ms et e- wtseams seenwer has mat show to rowboat CM& ewwwwaa lot pr eaarset haramle fa awy asddoad brbaaadaa abort rmpayhset dMmk my sadmed wwrmmt h fur loners tle eckeWled dap er/ prsppewew teheNt awl penebiaa. Credit Insurance Is Not Regtdnd. Bonower My Cancel Credit Insurance at Any raw Without Penalty. Geld Ufa merino tad CNdt Mobi'ty la wsete aw of **W to pooh weft owl win not be pNtlhd alas Bonewer Ap us blow ad epees to pay We a1 61 om1 tarps!. Irurrma soy M pwdraN an Or Ma of oar or two screamers. Get IYaebifsy Inswa a wry be prcbued a alto ore Bwww. N ebubwd dnoopit tmdr the cast at We iwturs ce 1a tie erWW amt of the aedt is staid bebw. A peetka of de cost may be retained by or pan to de teda.'Barewa' who b heated may out be a Ce Wta. Its ' Mn of Amount I'monted Anoint Fwwxad 4 see settlement Statement III Anteuat One diree8r to Hamster R1 Amount paid on B emorses eccowt Amwpt reteMwd by tsidar for S, see settlement statement 44 Avert paid to otters an Borrowers t. to pwbOc otBdats See Settlement Statement for raadkMSwma s to See Settlement Statement S IQ to 8 b Ra b1 to a 1111 to 8 to 8 ftvW Fiamme Chop a Nsedtadm41 ANWAN few by Berrowa of do the t Ian Is node: i) 8 So@ Settlement Statement 121 $ s h wort Smile CNdt life Mmsave wMrh costs F SipnMUe of PeNat to be iroaad to Single CNdt lila neurone 1 rant Single Credit Disd&y Insurance wMch oats F Sipost" of Perm to be bared fee Sbels C"k Oisadsty tes rsec; We wort Joint Crefr lib inawance which costs t i. 2. Sipwawa of Passer lobe horsed br Jolat Cmedt Ub ko wserw Bermowa does tot m)esba err k rot sipble her erodh ins+rarmcm Nodes to Bo swoft The mtsimrt ammt of caarap wb'ab bsww bretwerM era ceshe bat pelt b der a Iffic a or pasty, ss apadcabb. IF YOU HAVE SIGNED. ABOVE. STATING THAT YOU WANT CREDIT MM ML THIS ODES NOT SUARANTEE YOU HAVE CMOIT INSIMAM. CREDIT INSURANCE MUST BE 8MEO USM A SEPARATE FORM. IF YOU CHOOSE TO ERECT MAIANCE COVEBABE A SEPARATE APPLICATION WILL BE FBOMOED TO YOU. Dkow Loan Note k clm. Tim ohs is fa Belly 7 Meer ty NYeem . .. mwtaadasnn and nbaenlwa. N d M era risk der M MiB a TAe nmrNert eta to der s M ? Defy wasu fats,,,,,,, 7 ... .... 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(\!? Umlelrrd EXHIBIT n 3? ? 8 ? m m A' V Y ?} icy a $$?r ILE 3 ill IL $ ?. ?Fj C) A F .p s is i '? A ?Rw ft I ?W? F$ jr* Sa ?$ ® lit 9 or it; ri I& iax Intl Ir mill. Z. t Vil l fluort x 3g fit E lit Its RG i grt $ . ? o _; I s ? e IL IL t y? : CJs ,l g R s}, sus W it $ $ ?? s - ffi A IL 0 IL I . mgr mrs V : .. sc . IL C s $ it Ffarto all 0 g$g n qtly it jig a jig m li £ - ?i S. if I am- t 'L 1WHI WO N ,b mV A? A 9 ?rC:i a or 4.8 ?' 88 AH a+ !L A$3 s• 3t a$ S[ a s+?s+ !? afia ff« gigs TsFfifi _ a W N s g ¦ A3lA =s :_ aeR=aeg= :>ssac r]_ ?1` RfA S [ '? U111 i u Jul If u R i : s• f w Ira Z' it I R t I it d r. ?. t _ $ s L a g IL? : ' 3 19 t -T x a $ !. R 8 it Its a it t rFf till fir I -- .1 F1 ! $tt =$ 1. 1r I $ a 2 o [IL?$ r. a F' Sri s?t? :'cRD ar$ ?d d O OR 9 Lo 2 co N ffg,24.11- sk, 8 Eli M r446 CL r tU1 S l ?N 3 'Rs tI 1 rcr till ? W 11.11 t IN Rent 4 Itlit Twee- 2l?w 21 ai s "` t "Aga 2L- d.. i i III t$ 3- 09. s?- O lit lit H t [file M. C :: aa''r t;$ ?at t s, s aIF g ? =fir ?u.?? x ?? r F. s? P_ I a ?° ill P ?n a ? . 1 10 •rn i j N1 t .? fi?rr;;y I_ EI sM x e o e e g El y_ _1 1 g 3 sI I? [lit -? :A4ta rjL$ 3 l ;.•[ 1 1 Q L!r Its: It H sg s ? K_ ?i d m CAD W as Z 90 o? ?n VERIFICATION The undersigned, Donna Kindred, hereby verifies the statements of fact contained in the attached Complaint in Civil Action to be true and correct according to her personal knowledge, information and belief, and further pledges that this verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Date: J! ?? By: 1?? ?,.1.?.? Donna Kindred, Loan Officer SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 8'ty of turrrl,? r ?fG _ P p r? yr3 i HC, w i5. Jody S Smith Chief Deputy Richard W Stewart Solicitor "UMBBLANU UN i , ICE I' NSYI_VANI A PNC Bank, NA vs. Case Number Isaac Udotong 2011-4588 SHERIFF'S RETURN OF SERVICE 06/02/2011 07:11 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on June 2, 2011 at 1911 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Isaac Udotong, by making known unto Msima Muani, Step Daughter of Defendant at 1202 Summit Way, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. Ci RONALD HOOVER, EPUTY SHERIFF COST: $38.00 June 03, 2011 SO ANSWERS, 4RONR4NDERSON, SHERIFF "LED-OFFICE i THE PROTHONOTAR 1 2012 AUG -7 AM 10= 52 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, vs. ISAAC UDOTONG, Defendant. NO. 11-4588 PRAECIPE FOR CONSENT JUDGMENT Filed on behalf of Plaintiff, PNC Bank, National Association Code: Counsel of Record for This Party: Donna M. Donaher, Esquire Pa. I . D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 Q ull?.?U? Q g4So ? ?B`f88 Vv)o c.? \nuw IN THE COURT OF COMMON PLEAS OF -CUMBERLAND COUNTY, PENNSYLVANIA Civil Division PNC BANK, NATIONAL ASSOCIATION, ) Plaintiff, ) vs. No. 11-4588 ISAAC UDOTONG, Defendant PRAECIPE FOR CONSENT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against the Defendant, Isaac Udotong, upon Consent of parties, the amount of $140,579.45, plus costs of suit. Consented to: aac TUCKER ARENSBERG, P.C. By Donna M. Donaher, Esquire in BANK FIN:410671-1 000011-151502 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ;-~' '``~ Sheriff -~ ~a Jody S Smith ~ `~ ~''~; ; ° r-- Chief Deputy ~ - ~ r' N ~ 4 ~-• ~ Richard WStewart - `-''~' Solicitor _,.. >, - `~- C~ - ~ ' ~ t ~~ - ~ ~"~ ;'.3 ~t~ PNC Bank, National Association Case Number vs. Isaac Udotong 2011-4588 SHERIFF'S RETURN OF SERVICE 11/28/2012 02:18 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on November 28, 2012 at 1418 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Isaac Udotong, in the hands, possession, or control of the within named garnishee, Wells Fargo Bank, 604 E High Street, Carlisle, Cumberland County, Pennsylvania, by handing to Kait Filipelli, Personal Banker, 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 November 29, 2012 to Isaac S. Udotong at 4113 Linglestown Road, Harrisburg, PA 17112 (attorney provided envelope). ------. YAN BURGETT, DEPUTY SO ANSWERS, November 29, 2012 `'--_ RON R ANDERSON, SHERIFF s i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION NO. 11-4588 Plaintiff, PRAECIPE FOR WRIT OF EXECUTION Filed on behalf of Plaintiff, PNC Bank, National Association vs. ISSAC UDOTONG, Defendant, CODE: WELLS FARGO BANK, Garnishee. Counsel of Record for This Party: Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 IN THE COURT OF COMMONS PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PNC BANK, NATIONAL ASSOCIATION ) CASE NO. 11-4588 Plaintiff, ) vs. c®r ISSAC UDO�NAG,� ) �� 409 6 L �q ) Fr 14bq PA 17/0-/000 Defendant. o WELLS FARGO BANK_. ) � ��= Garnishee. ) PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against , Issac Udotong, Defendant; O (3) and against N/A, Garnishee; �aa.oD Pp Al" (4) and index this writ 38,00 0-13F 9a.00 (a) against N/A, Defendants; ON.o o " 110•50 (b) and against N/A, Garnishee; 4.50 " (5) Amount due $138,481.39 °130' "P8 ASP Total $138,481.39 Donna M. Donaher, Esquire Attorney for PNC Bank, Nationale Association TUCKER ARENSBERG, P.C. 1500 One PPG Place C#3(o oU Pittsburgh, PA 15222 Q, aAa7a8 LOM- e t. NOTE Under paragraph (1) when the writ is directed to the sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph (3) above should be completed only if a name garnishee is to be included in the writ. Paragraph (4) (a) should be completed only if indexing of the execution in the county of issuance, is desired as authorized by Rule 3104(a). Where the writ issues to another county indexing is required as of course in that county by the Prothonotary. See Rule 3104(b). Paragraph 4 (b) should be completed only if real property in the name of a garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). Certification as to waiver of exemption may be included in the Praecipe. Specific directions to the sheriff as to property to be levied upon may be included in the Praecipe or by separate direction at the option to Plaintiff. Bank Fin:453982-1000011-151502 - 2 - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2011-4588 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK,NATIONAL ASSOCIATION, Plaintiff(s) From ISSAC UDOTONG,4075 Lingelstown Rd,Harrisburg,PA 17112-1020 (l) 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: WELLS FARGO BANK,604 E.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, (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$138,481.39 Plaintiff Paid$ Interest Attorney's Comm. % Law Library$ Attorney Paid$230.50 Due Prothonotary$2.25 Other Costs$ Date: 5/20/13 avid D. Buell, rothonotary By: Deputy REQUESTING PARTY: Name :DONNA M.DONAHER,ESQUIRE Address: TUCKER ARENSBERG,PC. 1500 ONE PPC PLACE PITTSBURGH,PA 15222 Attorney for: PLAINTIFF Telephone: 412-566-1212 Supreme Court ID No. 53165 SIRLIN LESSER& BENSON,P.C. By: don C. Sirlin,Esquire Identification No.: 17498 123 South Broad Street,Suite 2100 Philadelphia,PA 19109 (215)864-9700 Attorney for Garnishee PNC BANK,NATIONAL ASSOCIATION : COURT OF COMMON PLEAS COUNTY OF CUMBERLAND VS. n ISSAC UDOTONG : NO. 11-4588 _.. T"m c and WELLS FARGO BANK.GARNLSHFE ENTRY OF APPEARANCE TO THE PROTHONOTARY: - Kindly enter my appearance on behalf Wells Fargo Bank, Garnishee in the above- captioned matter. SON '. IN -- Art, ey r Garnishee � Date: ro`G'1 SIRLIN LESSER& BENSON,P.C. By: Jon C. Sirlin,Esquire i r r-r 1"R 0 T# 0 t Identification No.: 17498 z 123 South Broad Street, Suite 2100 2013 JUN 17 PM 2: 4 0 Philadelphia,PA 19109 (215)864-9700 �' MOERLANO COUNT ' Attorney for Garnishee PENNSYLVANIA PNC BANK,NATIONAL ASSOCIATION COURT OF COMMON PLEAS COUNTY OF CUMBERLAND VS. ISSAC UDOTONG : NO. 11-4588 and WELLS FARGO BANK, GARNISHEE ANSWERS TO INTERROGATORIES IN ATTACHMENT TO: PNC BANK,NATIONAL ASSOCIATION,Plaintiff 1. No. 2. No,Defendant has no accounts with Wells Fargo Bank. 1 - 6. No. 7. (Q) 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? (A) No. 8, (Q) 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 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. § 8123? (A) No. JON A rney fo Garnishee Dated: -'T Wells Fargo Bank,N.A. Liens,Levies& Garnishments 101 N. Independence Mall East MAC Code#Y1372-113 Philadelphia,PA 19106 VERIFICATION Phyllis Brummett,being duly sworn according to law, deposes and says that she is the Legal Order Processing Associate of Wells Fargo Bank, NA Garnishee herein, and verifies that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to sworn falsification to authorities. Phyllis rummett Legal Order Processing Associate Date: �P C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, NO. 11-4588 vs. PRAECIPE TO DISCONTINUE AS TO GARNISHEE,WELLS FARGO BANK ISAAC UDOTONG, Defendant, Filed on behalf of PNC BANK, National Association, Plaintiff WELLS FARGO BANK, Code: Garnishee. Counsel for PNC Bank, National Association: �w Donna M. Donaher, Esquire -- Pa. I.D. #53165 rn CD C. TUCKER ARENSBERG, P.C. i1 Firm#287 ter- ry 1500 One PPG Place Pittsburgh, PA 15222 rCc) -0 (412) 566-1212 7'r 1394S?°11°fr a gto-)&ei9� Qt0,92 elfY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff, NO. 11-4588 vs. ISAAC UDOTONG, Defendant, WELLS FARGO BANK, Garnishee. PRAECIPE TO DISCONTINUE AS TO GARNISHEE,WELLS FARGO BANK TO: Cumberland County Prothonotary: Kindly mark the above-referenced matter as discontinued as to the Garnishee,Wells Fargos Bank. Respectfully submitted, T - ARENSBERG, P.C. A A Donna M. Donaher, Esquire Attorney for PNC Bank, National Association TUCKER ARENSBERG, P.C. 1500 One PPG Place Pittsburgh, PA 15222 Sworn to and subscribed before me this 1I5.1" day of Jof,,c , 2013. Notary Public COMMONWEALTH OF PENNSYLVANIA BANK_FIN:456997-1 000011-151502 Notarial Seal Matthew G.Friedberg,Notary Public City of Pittsburgh,Allegheny County M Commission Expires June 7,2015 TF9N OF NOTARIES SHERIFF'S OFFICE OF CUMBERLAND COUFNTY � Ronny RAnderson ca Sheriff Mrn -0 Jody S Smith ' *'` c�1�r— s CD Chief Deputy ti --C ' "k "'A ' �. :.jr- , Richard W Stewart --s Solicitor PNC Bank, National Association Case Number vs. Isaac Udotong 2011-4588 SHERIFF'S RETURN OF SERVICE 05/30/2013 10:40 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, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Kristen Darhower,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 May 30, 2013 to Isaac Udotong at 4075 Linglestown Road, Harrisburg,PA 17112-1020. SHERIFF COST: $86.03 SO ANSWERS, June 27, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuite SherW,Teleosoft,Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson y __i�r t Sheriff y tr ui ,:.zrarthet, Jody S Smith I� Chief Deputy Richard W Stewart {� �;{j ; ,�� ; Solicitor t., � �� PENNSYLVANIA PNC Bank, National Association Case Number vs. Isaac Udotong 2011-4588 SHERIFF'S RETURN OF SERVICE 05/30/2013 10:40 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, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Kristen Darhower, 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 May 30, 2013 to Isaac Udotong at 4075 Linglestown Road, Harrisburg,PA 17112-1020. 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: $87.75 SO ANSWERS, December 03, 2013 RONNN ANDERSON, SHERIFF a . a7i . 9oy7 WRIT OF EXECUTION and/or ATTACHMENT r � • COMMONWEALTH OF PENNSYLVANIA) NO 2011-4588 Civil COUNTY OF CUMBERLAND) _ r $ CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PNC BANK,NATIONAL ASSOCIATION, Plaintiff(s) From ISSAC UDOTONG,4075 Lingelstown Rd,Harrisburg,PA 17112-1020 (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: WELLS FARGO BANK,604 E.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; (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$138,481.39 Plaintiff Paid$ Interest Attorney's Comm. % Law Library$ Attorney Paid$230.50 Due Prothonotary$2.25 Other Costs$ 1 � • 1 � avid D. Buell, rothonotary By: Deputy REQUESTING PARTY: Name : DONNA M. DONAHER,ESQUIRE Address: TUCKER ARENSBERG,PC. TRUE COPY FROM RECORD 1500 ONE PPC PLACE In Testimony whereof,I here unto set my hand c'' end the seal of said Court at Carlisle,Pa. PITTSBURGH,PA 15222 D1 of �"( 2013 Attorney for: PLAINTIFF I - at_ P Prothonotary Telephone: 412-566-1212 Supreme Court ID No. 53165 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson "' Sheriff u Jody S Smith §n Chief Deputy # 3 UEc 5 PM 2. Richard W Stewart !. utia� Solicitor y. y. - >y NLD C t L,'ti PE" YLVA NIA PNC Bank, National Association vs. Case Number Isaac Udotong 2011-4588 SHERIFF'S RETURN OF SERVICE 11/28/2012 02:18 PM - Ryan Burgett, Deputy Sheriff,who being duly sworn according to law, states that on November 28, 2012 at 1418 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Isaac Udotong, in the hands, possession, or control of the within named garnishee, Wells Fargo Bank, 604 E High Street, Carlisle, Cumberland County, Pennsylvania, by handing to Kait Filipelli, Personal Banker, 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 November 29, 2012 to Isaac S. Udotong at 4113 Linglestown Road, Harrisburg, PA 17112 (attorney provided envelope). 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: $116.63 SO ANSWERS, December 03, 2013 RONR ANDERSON, SHERIFF s'V 1—Lp61. Cif 9''/f Ati' 2 9901/7 curt, u C _:e.if; 1 t 6scf• WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA).. s NO 11-4588 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due PNC BANK,NATIONAL ASSOCIATION Plaintiff(s) From ISSAC UDOTONG, 1202 SUMMIT WAY,MECHANICSBURG,PA 17050 (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: WELLS FARGO BANK,604 E. 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$139,979.45 L.L. $.50 Interest Atty's Comm % Due Prothy $2.25 Atty Paid $178.00 Other Costs Plaintiff Paid iim ' rlild— L,S1,1 David P Buell, Prothonotary (Seal) By: !�► 4_ \�. ,: IL_ Deputy ' 4 REQUESTING PARTY: Name : DONNA M.DONAHER,ESQUIRE - Address: TUCKER ARENSBERG,P.C. FIRM 3287 1500 ONE PPG PLACE PITTSBURGH,PA 15222 Attorney for: PLAINTIFF Telephone: 412-566-1212 Supreme Court ID No. 53165 TRUE COPY FRO mM RECORD ,)here unto set Y In Testimony whereof hand and the seal of said Gour►at Carlisle, �^ This_°Q`—day of��Prothonota} (4,0„0.11 ID-c:•: \C"P "Cl