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HomeMy WebLinkAbout11-6240IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff ) NO. V. ) LISA A GIRTON ) Defendant(s) ) NOTICE OF ORDER DECREE OR JUDGMENT TO: ( )Plaintiff ( X )Defendant ( )Garnishee ( )Additional Defendant You are hereby n tified that the following Order, Decree, or Judgment has been entered against you on LI ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( X) Judgment of ( ) Confession ( ) Verdict ( ) Court Order ( ) Default ( ) Non-suit ( ) Non-Pros ( ) Arbitration Award ( ) Judgment in the amount of $ 3-7 I.3?,'plus costs. ( X) District Justice Transcript of Judgment in the amount of $4,371.38, plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Prothonotary By_ C - y If you have questions concerning the above, please Contact: Name of Attorney: GREGG MORRIS, Esquire 213 East Main St Carnegie PA 15106 (412)-429-7675 PA 130 Ntc Jg ft DJ Jg P&I File No. 11-4520 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-6240 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TARGET NATIONAL BANK, Plaintiff (s) From LISA A. GIRTON, 72 Old Barn Ln, Newville, PA 17241-8709 (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: MEMBERS FIRST CREDIT UNION, 401 East King Street, Shippensburg, PA 17257 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 $4,371.38 L.L.$.50 Interest from 8/8/11 @ 6.00% per annum -- $83.95 Atty's Comm % Due Prothy $2.00 Atty Paid $54.25 Other Costs: Plaintiff Paid Date: 12/19/11 David D. Buell, Prothonotary (Seal) n .@y: G . Deputy REQUESTING PARTY: Name GREGG L. MORRIS, ESQUIRE Address: PATENAUDE & FELIX, APC 213 E MAIN STREET CARNEGIE, PA 15106 Attorney for: PLAINTIFF Telephone: 412-429-7675 Supreme Court ID No. 69006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff ) NO. 11-6240 V. LISA A GIRTON 72 Old Barn Ln Newville Pa 17241-8709 Defendant(s) MEMBERS FIRST CREDIT UNION 401 East King Street Shippensburg Pa 17257 Garnishee PRAECIPE FOR WRIT OF EXECUTION Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA 134 Prcp Writ of Exe P&F File No. 11-4520 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 11-6240 V. LISA A GIRTON 72 Old Barn Ln Newville Pa 17241-8709 Defendant(s) MEMBERS FIRST CREDIT UNION 401 East King Street Shippensburg Pa 17257 Garnishee PRAECIPE FOR WRIT OF EXECUTION To The Prothonotary: Issue writ of execution in the above matter, rn Ca ;M M z r. -c Ih. v rn C-) lD -a N c-a --s u ;,J' :-11 CD L(1) directed to the Sheriff of Cumberland County; (2) against, LISA A GIRTON Defendant(s); (3) against, MEMBERS FIRST CREDIT UNION, Garnishee; (4) and index this writ (a) against, Defendant(s) LISA A GIRTON, Defendant(s); and (b) against MEMBERS FIRST CREDIT UNION, Garnishee; as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows: (5) Amount due $4,371.38 Interest from August 08, 2011 At 6.00 % per annum $83.95 Court Cost $0.00 Less: Payment $0.00 act 50 PD AI N Total $4,455.33 aj•o15 C15F a5 Pa Arry -*,I -0o DL--- C6 4 -so u, PA_134 Prcp Writ of Exe P&F File No. 11-4520 0415710 ?,fat, gy67 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor b CF- Tt1E p OT14,h A i,. ? 201 1 DEC 29 AM 8: 33 C1118ERLANU COUNT PENNSYLVANIA Target National Bank vs. Case Number Lisa Girton 2011-6240 SHERIFF'S RETURN OF SERVICE 12/28/2011 10:11 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, 1166 WALNUT BOTTOM RD, SOUTH Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Marisol Barber, 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 December 29, 2011 at 72 Old Barn Lane, Newville, PA 17241. December 28, 2011 SO ANSWERS, M RON R &NDERSON, SHERIFF am Cline, Deputy ? ;:gun iit...,^ca ?t ? t.soft_ Inc- FILED-OFFICE OF THE PROTHONOTARY RECEIVED 2011 DEC 30 QM 11: 49 DEC 8 9 2011 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 11-6240 V. LISA A GIRTON 72 Old Barn Ln Newville Pa 17241-8709 Defendant(s) MEMBERS FIRST CREDIT UNION 401 East King Street Shippensburg Pa 17257 Garnishee *-WIS INTERROGATORIES IN ATTACHMENT EXECUTION Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA-139 [nterogs Anch Exe P&F File No. 11-4520 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff ) NO. 11-6240 V. ) LISA A GIRTON ) 72 Old Barn Ln Newville Pa 17241-8709 ) Defendant(s) ) MEMBERS FIRST CREDIT UNION ) 401 East King Street Shippensburg Pa 17257 ) Garnishee ) OFFICES OF PATENAUDE & FELIX You are hereby notified to BY: GREGG MORRIS, ESQUIRE plead to the enclosed 213 East Main St Interrogatories within 20 Carnegie PA 15106 days from the date of 858-244-7675 hereof or a default judgment may be entered against you. Gregg Morris, Esquire Attorney for Plaintiff You are required to answer the following interrogatories about Defendant(s) whose address is 22 OLD BARN LN, NEWVILLE PA 17241-8709. You must file with the Court answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default judgment being entered against you. A copy of said answers must be served on the undersigned. If your answer to any of the following interrogatories is affirmative, specify the amount, value and/or nature of the subject property. PA-139 Interogs Auch Exe P&F File No. 11-4520 1. 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 them any money or were you liable to them for any reason? If yes, please specify as set forth herein. DO 2. At the time you were served, or at any subsequent time, was there in your possession, custody or control, or in joint possession, custody or control of yourself or others, any property of any nature owned solely or in party by the Defendant(s)? If yes, please list and describe the property. 3. At the time you were served, or at any subsequent time, did you hold legal title to any property or any nature owned solely or in part by the Defendant(s)? If yes please list and describe the property. 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 an interest? If yes, please list and describe the property. PA-139 Interogs Attch Exe P&F File No. 11-4520 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 directions or consent? If yes, what was the consideration therefore? no b. 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 their direction, or otherwise discharge any claim of the Defendant(s) against you. no 7. 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 electroncially 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? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. no PA-139 Interogs Attch Exe P&F File No. 11-4520 8. If you are a bank or other financial insitution, 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? If so, indentify each account. 41L (WA-ZU Date: December 07, 2011 PA-139 Interogs Attch Exe Respectfully submitted: Patenaude & Felix, A.P.C. Gregg L. Morris, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 P&F File No. 11-4520 A MEMBERS 1St FEDERAL CREDrr UNION December 28, 2011 Lisa A. Girton 81 South High Street Newville, PA 17241-1405 Review Dates (60 Days): October 30, 2011 - December 28, 2011 Total Writ of Execution: $4,512.08 Cumberland County Docket Number: 11-6240 File # 11-4520 Account Number: XXX095-0000 Name on Account: Lisa A. Girton Savings: $5.00 -5.00 (Membership Fee) $0.00 Payroll: None Account Number: XXX095-0011 Name on Account: Lisa A. Girton Checking: Payroll: None Account Number: XXX158-0000 Name on Account: $0.00 Derrick A. Girton Lisa A. Girton (Joint) Savings: $5.00 -5.00 (Membership Fee) $0.00 Payroll: None $300.00 Statutory Exemption was not taken out. G( ( *(j Tania S. Young Deposit Operations Analyst Rev: 06/11 5000 Louise Drive" - P.O. Box 40 - Mechanicsburg, Pennsylvania 17055 - (800) 283-2328 - www.memberslst.org T 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 Ta n i a S. Young (Name) Deposit Operations AnalystofMembers 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNA E) TU IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. LISA A GIRTON Defendants(s) MEMBERS FIRST CREDIT UNION Garnishee NO. 11-6240 -1 rnrn t. 9T1r -J __4 I ? ? za +? -rs I 'a t? CD _ I -- 4 ' . PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_193 Prcp Disc with Prjdc Garnishee only P&F File No. 11-4520 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 11-6240 V. LISA A GIRTON Defendant(s) PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY TO: Prothonotary Please settle and discontinue the matter captioned above without prejudice as to Garnishee only. Thank you. Respectfully sub ttted: Patenaude lix, A.P.C. Date: January 06, 2012 GixA' Morris, Esc 4 E ain eet Car , A 15106 (41 429-7675 Sworn to and ubscribed before me this NOTARIAL SEAL day of , 20 MELINDA S PERRY Notary Public CARNEGIE BORO.,ALLEGHENY COUNTY My Commission Expires Jun 2, 2015 M4 I otary Public $9.50 PD A77`/ ?f 57?fKly/?`15109 a&9794 PA_193 Prcp Disc with Pddc Garnishee only P&F File No. 11-4520 { I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK, hereby certify that a true and correct of the foregoing document was served this date by US First Class Mail, postage prepaid upon the following: MEMBERS FIRST CREDIT UNION 401 EAST KING STREET SHIPPENSBURG PA 17257 ?^1 Date: January 06, 2012 Esquire X13 E. Mai t Carnegie, 15-A 15106 (412) 429-7675 PA_193 Prcp Disc with Prjdc Garnishee only P&F File No. 11-4520 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,derson , Smith Deputy ,chard W Stewart Solicitor a. 1J - Orr Target National Bank vs. Case Number Lisa Girton 2011-6240 SHERIFF'S RETURN OF SERVICE 12/28/2011 10:11 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, 1166 WALNUT BOTTOM RD, SOUTH Middleton Township, Carlisle, PA 17015, Cumberland County, by handinj ' to Marisol Barber, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the content: there of known to her. The writ of execution and notice to defendant was mailed on December 29, 2011 at 72 Old Barn Lane, Newville, PA 17241. 06/05/2012 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: $88.58 SO ANSWERS, June 05, 2012 RON R ANDERSON, SHERIFF .? -CO Pd.(p, e4 ? /mss v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff ) NO. 11-6240 V. ) LISA A GIRTON ) 81 S High St Newville Pa 17241 ) Defendant(s) MEMBERS FIRST CREDIT UNION ) M �- - 401 East King Street Shippensburg Pa 17257 Garnishee ) rn —tin PRAECIPE FOR WRIT OF EXECUTION =o To The Prothonotary: ,z Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against, LISA A GIRTON Defendant(s); (3) against, MEMBERS FIRST CREDIT UNION, Garnishee; (4) and index this writ (a) against, Defendant(s) LISA A GIRTON, Defendant(s); and (b) against MEMBERS FIRST CREDIT UNION, Garnishee; as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows: (5) Amount due $4,371.38 Interest from August 08, 2011 At 6.00 %per annum $371.53 Court Cost $0.00 Less: Payment $575.00 d� /l/ Total $4,10791 P COSTS a�- n� � MF A o or Plaintiff �y. ov Ck# �s»� PA_1 34 Prcp Writ of Exe P&F File No. 11-4520 Lo# Q6113� �� o� � v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff ) NO. 11-6240 V. ) LISA A GIRTON ) 81 S High St Newville Pa 17241 ) Defendant(s) ) MEMBERS FIRST CREDIT UNION ) 401 East King Street Shippensburg Pa 17257 ) Garnishee ) PRAECIPE FOR WRIT OF EXECUTION Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude &Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA-134 Prcp Writ of Exe P&F File No. 11-4520 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-6240 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TARGET NATIONAL BANK Plaintiff(s) From LISA A. GIRTON,81 S.HIGH STREET,NEWVILLE,PA 17241 (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 GARNISHEES)as follows: MEMBERS FIRST CREDIT UNION,401 EAST KING STREET,SHIPPENSBURG,PA 17257 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$3,796.38 Plaintiff Paid$ Interest FROM AUGUST 8,2011 AT 6.00% PER ANNUM-$371.53 Attorney's Comm. % Law Library$ Attorney Paid$1.78.33 Due Prothonotary$2.25 Other Costs$ Date: 4/26/13 David D.Buell,Prothonotary Deputy REQUESTING PARTY: Name : GREGG L. MORRIS,ESQUIRE Address:PATENAUDE&FELIX,A.P.C. 213 E.MAIN STREET CARNEGIE,PA 15106 Attorney for: PLAINTIFF Telephone: 412-429-7675 Supreme Court ID No. 69006 OF THE PROTHONOTWx:,. 2013 MAY -3 .PH 12: 31 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA ' TARGET NATIONAL BANK Plaintiff ) V. ) NO. 11-6240 LISA A GIRTON ) 81 S High St Newville Pa 17241 ) Defendant(s) ) MEMBERS FIRST CREDIT UNION ) 401 East King Street Shippensburg Pa 17257 ) Garnishee ) INTERROGATORIE IN ATTACHMENT EXECUTION Filed on behalf of TARGET NATIONAL BANK Counsel of Record for This party; Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 i PA—139 Interogs Attch Exe P&F File No. 11-4520 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff ) V ) NO. 11-6240 LISA A GIRTON ) 81 S High St Newville Pa 17241 ) Defendant(s) ) MEMBERS FIRST CREDIT UNION ) 401 East King Street Shippensburg Pa 17257 ) Garnishee ) OFFICES OF PATENAUDE & FELIX BY: GREGG MORRIS, ESQUIRE You are hereby notified to 213 East Main St plead to the enclosed Carnegie PA 15106 Interrogatories within 20 858-244-7675 days from the ee of here f or a d ju ment ay be entered M g Morris, Esquire orney for Plaintiff INTERROGATORIES 1N ATTACHMEN XECUTION You are required to answer the following interrogatories about Defendant(s)whose address is 72 OLD BARN LN NEWVILLE PA 17241-8709. You must file with the Court answers to the following interrogatories within twenty(20) days after service upon you. Failure to do so may result in a default judgment being entered against you. A copy of said answers must be served on the undersigned. If your answer to any of the following interrogatories is affirmative,specify the amount, value and/or nature of the subject property. PA_139 Interogs Attch Exe P&F File No. 11-4520 t 1. 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 them any money or were you liable to them for any reason? If yes, please specify as set forth herein. It 01,19 P U 2. At the time you were served, or at any subsequent time, was there in your possession, custody or control, or in joint possession, custody or control of yourself or others, any property of any nature owned solely or in party by the Defendant(s)? If yes, please list and describe the property. D 3. At the time you were served, or at any subsequent time, did you hold legal title to any property or any nature owned solely or in part by the Defendant(s)? If yes please list and describe the property. Q D 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 an interest? If yes, please list and describe the property. ,,`-i) PA_139 Interogs Atteh Exe P&F File No. 11-4520 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 directions or consent? If yes, what was the consideration therefore? U 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 their direction, or otherwise discharge any claim of the Defendant(s) against you. t\) 0 7. 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 electroncially 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? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. PA-139 Interogs Attch Exe P&F File No. 11-4520 8. If you are a bank or other financial insitution, 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? If so, indentify each account. Respectfully subm' ed: Patenau & x, A.P.C. Date: April 19, 2013 Morris, Esquire 1 Main Street C egie, PA 15106 (412) 429-7675 PA_139 Interogs Attch Exe P&F File No. 11-4520 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff ) NO. 11-6240 V. LISA A GIRTON ) -<> CO ---4�C),' Defendants(s) ) @ 'c W MEMBERS FIRST CREDIT UNION `< Garnishee ) PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix,A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 a PA-193 Prep Disc with Podc Garnishee only P&F File No.11-4520 OF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff ) NO. 11-6240 V. ) LISA A GIRTON ) Defendant(s) ) PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY TO: Prothonotary Please settle and discontinue the matter captioned above without prejudice as to Garnishee only. Thank you. Respectful sub tted: Patenaud & ix, A.P.C. Date: May 22, 2013 Gre =et uire 21 Mai arnegie, PA 15106 (412) 429-7675 �Uayan d subscribed before me this ch` ` NOTARIAL SEAL of m , 20 MELINDA S PERRY Notary Public CAPNEGIE BORO.,ALLEGHENY COUNTY Commission Expires Jun 2,2015 Notary Public PA-193 Prcp Disc with Pddc Garnishee only P&F File No.11-4520 I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK , hereby certify that a true and correct of the foregoing document was served this date by US First Class Mail,postage prepaid upon the following: MEMBERS FIRST CREDIT UNION 401 EAST KING STREET SHIPPENSBURG PA 17257 Date: May 22, 2013 A19 L. Morris, Esquire Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA-193 Prcp Disc with Prjdc Garnishee only P&F File No.11-4520 SHERIFF'S OFFICE OF CUMBERLAND COUNTY .onny R Anderson FILED-OFFICE Sheriff ` THE PROTHOHO I Rf Jody S Smith Chief Deputy 2913 NOV -6 AM 10' 4 Richard W Stewart CUMBERLAND COUNTY Solicitor op r ,;F. s ERIr= PENNSYLVANIA Target National Bank Case Number vs. Lisa Girton 2011-6240 SHERIFF'S RETURN OF SERVICE 05/01/2013 02:07 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Jan Finkle, Member 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 her. The writ of execution and notice to defendant was mailed on May 1, 2013 to Lisa A. Girton at 81 S High Street, Newville, PA 17241. 11/04/2013 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: $89.15 SO ANSWERS, November 04, 2013 RONI4 R ANDERSON, SHERIFF f,f , Cc' 07 Om' ,29.? t�,i C:cwhrSu?e 6t; r:.i.To osc• '..c • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff ) ) NO. 11-6240 v. ) ) LISA A GIRTON ) 81 S High St Newville Pa 17241 ) Defendant(s) ) MEMBERS FIRST CREDIT UNION ) 401 East King Street Shippensburg Pa 17257 ) 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, LISA A GIRTON Defendant(s); (3) against, MEMBERS FIRST CREDIT UNION, Garnishee; (4) and index this writ (a) against, Defendant(s) LISA A GIRTON, Defendant(s); and (b) against MEMBERS FIRST CREDIT UNION, Garnishee; as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows: (5) Amount due $4,220.38 Interest from August 08, 2011 At 6.00 % per annum $720.82 Court Cost $0.00 g Payment �� S'e3 Less: y $1,575.00 Total $3,366.1 plus costs t)4kk. 1413JA1 Atte 41 . t, Ra . nv tr `� I • +S�lt " LIJ, 561( CZ) „ a4 7R/6P PA 134 P&F File No.11-452 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK ) Plaintiff ) ) NO. 11-6240 v. ) LISA A GIRTON ) 81 S High St Newville Pa 17241 ) ) Defendant(s) ) MEMBERS FIRST CREDIT UNION ) ) 401 East King Street Shippensburg Pa 17257 ) Garnishee PRAECIPE FOR WRIT OF EXECUTION Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_134 Prcp Writ of Exe P&F File No.11-4520 01!—__ c U (------ '. Mat. THE COURT OF COMMON PLEAS -4.174?-- `'�� CUMBERLAND COUNTY PA " \°,, { DAVID D. BUELL,PROTHONOTARY aw ,� ': wh' One Courthouse Square• Suite 100 • Carlisle,PA • 17013 N-. --i-ii-ti---- (717)240-6195 www.ccpa.net TARGET NATIONAL BANK Vs. NO 11-6240 Civil Term CIVIL ACTION—LAW LISA A.GIRTON WRIT OF EXECUTION (Pa R.C.P.3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against LISA A.GIRTON,81 S.HIGH STREET,NEWVILLE, PA 17241 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 MEMBERS FIRST CREDIT UNIONGARNISHEE(S), as garnishee, 401 EAST KING STREET, SHIPPENSBURG,PA 17257(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 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 1 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 $2,645.38 Plaintiff Paid Interest FROM AUGUST 8,2011 AT 6.00% PER ANNUM-$720.82 Law Library Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $371.23 Other Costs Date: 6/20/14 _ . _ _I - David D. Buell,Prothonotary - - Deputy REQUESTING PARTY: Name : GREGG L. MORRIS,ESQUIRE Address: PATENAUDE& FELIX,A.P.C. 213 E.MAIN STREET CARNEGIE,PA 15106 Attorney for: PLAINTIFF Telephone: 412-429-7675 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 THE PrRDTHQ O �:�:t. ���,o1 `t�nzrr,,�s 2U1 JUN 30 M910: 50 ; ,•.. CUMBERLAND COUNTY ornm4FTHEStiSRIFF PENNSYLVANIA Target National Bank vs. Lisa Girton Case Number 2011-6240 SHERIFF'S RETURN OF SERVICE 06/26/2014 09:32 AM - Christopher Sharpe, 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, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Nicole Martin, Assistnt Branch 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 June 27, 2014 to Lisa a. Girton at 81 S High Street, Newville, PA 17241. CHRISTA HER SHARPE, DEPUTY SO ANSWERS, June 27, 2014 RONR ANDERSON, SHERIFF (c) CountySuito Shontf, Teleosofi. Inc. rli i ivd THE PROTHOf Mit JUL -22 2 : P.� ^ 2 FP I �. CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff v. LISA A GIRTON 81 S High St Newville Pa 17241 Defendant(s) MEMBERS FIRST CREDIT UNION 401 East King Street Shippensburg Pa 17257 Garnishee PA_139 Interogs Attch Exe NO. 11-6240 INTERROGATORIES IN ATTACHMENT EXECUTION Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for ThisTarty: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 P&F File No. 11-4520 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff v. LISA A GIRTON 81 S High St Newville Pa 17241 Defendant(s) MEMBERS FIRST CREDIT UNION 401 East King Street Shippensburg Pa 17257 Garnishee OFFICES OF PATENAUDE & FELIX BY: GREGG MORRIS, ESQUIRE 213 East Main St Carnegie PA 15106 858-244-7675 NO. 11-6240 You are hereby notified to plead to the enclosed Interrogatories within 20 days from the date 1 hereof or a defay1t judg ent ma entered ag inst you/ G gg Morris, Esquire t'torney for Plaintiff INTERROGATORIES IN ATTACHMENT EXECUTION You are required to answer the following interrogatories about Defendant(s) whose address is 72 OLD BARN LN , NEWVILLE PA 17241-8709. You must file with the Court answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default judgment being entered against you. A copy of said answers must be served on the undersigned. If your answer to any of the following interrogatories is affirmative, specify the amount, value and/or nature of the subject property. PA_139 Interogs Attch Exe P&F File No. 11-4520 1. 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 them any money or were you liable to them for any reason? If yes, please specify as set forth herein. N 0 2. At the time you were served, or at any subsequent time, was there in your possession, custody or control, or in joint possession, custody or control of yourself or others, any property of any nature owned solely or in party by the Defendant(s)? If yes, please list and describe the property. Pvccu,ro- \C 3. At the time you were served, or at any subsequent time, did you hold legal title to any property or any nature owned solely or in part by the Defendant(s)? If yes please list and describe the property. IQ -6 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 an interest? If yes, please list and describe the property. 0) PA_139 Interogs Attch Exe P&F File No. 11-4520 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 directions or consent? If yes, what was the consideration therefore? \\)O 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 their 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 at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electroncially 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? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. PA_139 l nterogs Attch Exe P8c F File No. 11-4520 8. If you are a bank or other financial insitution, 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? If so, indentify each account. Date: June 12, 2014 . Morris, Esquire . Main Street negie, PA 15106 412) 429-7675 PA_139 lnterogs Attch Exe P& F File No. 11-4520 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. LISA A GIRTON Defendants(s) MEMBERS FIRST CREDIT UNION Garnishee NO. 11-6240 C7 n� c__: C c�1 `I-1 -1:7 3 .t- --i PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_193 Prcp Disc with Prjdc Garnishee only P&F File No. 11-4520 oid 14 5°1)4 e),(4 7y3/4/d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK v. LISA A GIRTON Plaintiff Defendant(s) NO. 11-6240 PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY TO: Prothonotary Please settle and discontinue the matter captioned above without prejudice as to Garnishee only. Thank you. Date: July 10, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Alexandra E. Till, Notary Public Carnegie Boro, Allegheny County My Commission Expires May 19, 2018 MEMBER, PENNSYLVA IA ASSOCIATION OF NOTARIES Sworn to and subscribed before me this (0 day of Uv l y , 201 t . Notary Public Respectfully submitte Patenau• /& Feli. • .P.C. ��g • is, Esquire 213 _ Street , PA 15106 (41►) 9-7675 PA_193 Prcp Disc with Prjdc Garnishee only P&F File No. 11-4520 I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK , hereby certify that a true and correct of the foregoing document was served this date by US First Class Mail, postage prepaid upon the following: MEMBERS FIRST CREDIT UNION 401 EAST KING STREET SHIPPENSBURG PA 17257 Date: July 10, 2014 squire .P.C. 43 E.reet Carnegie, PA 15106 14,12) 429-7675 PA_193 Prcp Disc with Prjdc Garnishee only P&F File No. 11-4520