The URL can be used to link to this page

Home My WebLink About11-6237 3,141.2.• plc CAPITAL ONE BANK(USA),N.A. : In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania : Civil Division vs. • vs% KAITLIN M GOODHART • "c1c53 c-c-k 111 MEDIA RD : NO: 11-6237 r-- AC- CARLISLE PA 17013-1547 (-) • c-' Defendant : -7-, vs. : METRO BANK 3201 TRINDLE RD • CAMP HELL, PA 17011 • Garnishee : • Praecipe for Entry of Appearance Kindly enter my appearance on behalf of CAPITAL ONE BANK (USA), N.A. in the above- captioned matter. Date:May 30, 2014 Signatur-• Print ine: Mic el F. Ratchford r s uire Addr ss: 120 North Ke ser Avenu- Scranton PA 18504 Telephone No: (570) 558-5510 E t. 120 Supreme Court ID No: 86285 PRAECIPE FOR WRIT OF EXECUTION—(MONEY JUDGMENT)RULES PA.R.C.P.3252,3111 (a) CAPITAL ONE BANK(USA),N.A. In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania vs. Civil Division ' KAITLIN M GOODHART 111 MEDIA RD -_73 .a= CARLISLE PA 17013-1547 NO: 11-6237 ' 4s- Defendant vs. METRO BANK 3201 TRINDLE RD PRAECIPE FOR WRIT OF EXECUTIOI'�;&D p CAMP HILL,PA 17011 ATTACHMENT - ' Garnishee (MONEY JUDGMENT) To the Prothonotary:TO SATISFY THE JUDGMENT,ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER (1) Directed to the Sheriff of CUMBERLAND County,Pennsylvania; (2) Against:KAITLIN M GOODHART (3) And against:METRO BANK 3201 TRINDLE RD CAMP HILL,PA 17011 (4) and index:this writ(a)against Defendant(s)(b)against METRO BANK 3201 TRINDLE RD 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): ***-**-9184; (5) Judgment Amount $1.741.35 Interest $293.61 Payments $ Clerks Fee $ Sheriff $ Poundage $ Total $ e:May 30,2014 Sr Michael F. atchford, Esqui W Edwin A.Abrahamsen&A ociates.P.C. �1 A ',��P /Attorney for Plaintiff � mratchford@eaa-law.co l a.as� IL �57,� OF CU { F i THE COURT OF COMMON PLEAS a a o z CUMBERLAND COUNTY PA " a DAVID D.BUELL,PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 17 a (717)240-6195 www.ccpa.net CAPITAL ONE BANK(USA)N.A. Vs. NO 11-6237 Civil Term CIVIL ACTION—LAW KAITLIN M.GOODHART WRIT OF EXECUTION (Pa R.C.P.3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against KAITLIN M. GOODHART, 111 MEDIA ROAD, CARLISLE,PA 17013 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 METRO BANKGARNISHEE(S), as garnishee, 3201 TRINDLE ROAD, 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. (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 and are 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 multiple accounts are attached,a total of$300 in all accounts shall not be subject to levy and attachment as 1 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 $1,741.35 Plaintiff Paid Interest$293.61 Law Library $.50 Attorney's Comm. - % Due Prothonotary $2.25 Attorney Paid $56.25 Other Costs Date: 6/23/14 -14A� David D. Buell,Prothonotary 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 EX 101 Supreme Court ID No. 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 (; o--9 Cie BERLA;',!0 V PE 'NSYLVAIdlA Capital One Bank (USA) N.A. vs. Kaitlin M Goodhart Case Number 2011-6237 SHERIFF'S RETURN OF SERVICE 06/27/2014 04:42 PM - Noah 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, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Joseph R. Schroeder, Customer Service Representative, 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 him. The writ of execution and notice to defendant was mailed on June 30, 2014 to Kaitlen M. Goodhart at 111 Media Road, Carlisle, PA 17013. June 30, 2014 ;ountySuite Sheriff: Teleosoft. Inc. !OA/H CLINE, D UTY SO ANSWERS, RSON, SHERIFF N'F-R 5:DER r '.APITAL ONE BANK (USA), N.A. vs. KAITLIN M GOODHART 1 1 1 MEDIA RD CARLISLE PA 17013-1 547 vs. METRO BANK 3201 TRINDLE RD CAMP HILL, PA 17011 : hl the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania Civil Division Defendant : Garnishee : NO: 11-6237 INTERROGATORIES IN ATTACHMENT co RE: Execution of Judgment against your depositor KAITLIN M GOODHART SSN # ***-**-9184 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. Defendant had a balance of —$51.69 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? 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. $90.04 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? n/a 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 • w 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. 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. 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. 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). Edwin A. raha nsen B Michael F. Ratchford Esquire 120 North Keyser A enue Scranton, PA 1850 (570) 558-5510 E,t. 101 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 Specialist 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.