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HomeMy WebLinkAbout11-6712 PRAECIPE FOR WRIT OF EXECUTION—(MONEY JUDGMENT)RULES PA.R.C.P.3252,3111(a) DISCOVER BANK -� In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania "tTt 1 t Civil Division vs. CD RYC.KITTA M SHORT 37'c') C- 10 15 KENT DR. NO: CP-11-6712 MECHANICSBURG PA 17050-7608 ' Defendant - VS. PRAECIPE FOR WRIT OF EXECUTION AND ATTACHMENT MEMBERS 1 ST FCU 6280 CARLISLE PIKE MECHANICSBURG,PA 17050 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:RYCKITTA M SHORT (3) And against:MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG,PA 17050 (4) and index this writ(a)against Defendant(s)(b)against MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG,PA 17050 Gamishee(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): ***-**-4229; (5) Judgment Amount $7.846.64 Interest $785.52 Payments $ Clerks Fee $ Sheriff $ Poundage $ Total $ Date:April 24,2013 ichael F.Ratchford, Esquire Edwin A.Abrahamsen&Ass ciates,P.C. �� d Attorney for Plaintiff 1—ble /, mratchford @eaa-law.com ail 3S Wry �� WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-6712 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due DISCOVER BANK Plaintiff(s) From RYCKITTA M. SHORT, 101.5 KENT DRIVE,MECHANICSBURG,PA 1.7050-7608 (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: MEMBERS 1sT FCU,6280 CARLISLE PIKE,MECHANICSBURG,PA 17050 and to notify the garnishee(s)that: (a) an attachment has been issued; (b)the gamishee(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$7,846.64 Plaintiff Paid$ Interest$785.52 Attorney's Comm. % Law Library$.50 Attorney Paid$56.25 Due Prothonotary$2.25 Other Costs$ Date: JUNE 14,2013 David D. Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name : MICHAEL F.RATCHFORD,ESQUIRE Address: EDWIN A.ABRAHAMSEN&ASSOCIATES,P.C. 120 NORTH KEYSER AVENUE SCRANTON,PA 18504 Attorney for:PLAINTIFF Telephone: 570-558-5510 Supreme Court ID No. 86285 - 1 DISCOVER BANK = In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania Civil.Division vs. RYCKITTA M SHORT 1015 KENT DR NO: CP-11-6712 MECHANICSBURG PA 17050-7608 Defendant w VS. W/ C :1 MEMBERS 1ST FCU 6280.CARLISLE PIKE p n MECHANICSBURG,PA 17050 V�D —' Garnishee p Praecipe for Entry of Appearance Kindly enter my appearance on behalf of DISCOVER BANK in the above-captioned matter. Date:Apri124,2013 SignatuO, �ch Print N 4Kevser Es ire Addres e Scranton PA 185 0 Telephone No: 570 558-55 0 Ext. 120 Supreme Court ID No: 862J5 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 3 w Sheriff rnm C— Jody S Smith cn r— N Chief Deputy 6 Richard W Stewart Solicitor C#Fr C CF Tr�e �4rRfF= '- _ _ C-7 CD , Discover Bank Case Number vs Ryckitta M Short 2411-6712 SHERIFF'S RETURN OF SERVICE 0612112013 10:19 AM-Jamie DiMartle, Deputy Sheriff,who being duly sworn according to law, states that on June 21, 2013 at 1019 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant,to wit: Ryckitta M. Short, in the hands, possession, or control of the within named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania, by handing to Laurie Shultz, 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 June 25, 2013 to Ryckitta M. Short, 1015 Kent Drive, Mechanicsburg, PA 17050. A.A JA = DIMARTLE, DEPUTY SO ANSWERS, June 25,2013 RON R ANDERSON, SHERIFF {c}CountySulto Sheriff,Teleosoft.Inc, C) ' -- DISCO',ri SANK : .4; w • In the Court of Common Pleas of -0-'"+ r :1-1.:---' Plaintiff : CUMBERLAND County,Pennsylvania m r"' r•- . : Civil Division e 1 :'-1' vs. ,-..... •RYCKITTA M SHORT � C.) ; 101.5 KENT DR : NO: CP-11-6712 — MECHANICSBURG PA 17050-7608 -- Defendant : 11.54)&„s. vs. : INTERROGATORIES IN ATTACHMENT MEMBERS ISTFCU 6280 CARLISLE PIKE • MECIIANICSBURG,PA 17050 : Garnishee : • RE: Execution of Judgment against your depositor RYCKITTA M SHORT SSN# ***-**-4229 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: l) 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. i,(S 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? t l a° V. I C L11[1e S 0© e w° 1 l. 1382-00 - SovIs pr i -1-D1 -11Q$5 Co-(Yticb Vt, . rotpI- H4o _� chvc v6-3 0.11 -S�M S !Apo_ r (i -J 411,4- 414 4.teoi 3) At the time you were served or at any subsequent time, please list the average daily C . jP-3g balance in the past five(5)months for each such account identified in your answer to Interrogatories number one(1) and two(2)above. SAAA W. CW(WUtt I 317,6- e- Savinss 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? „ 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? NA) A ♦ . 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? RA) 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)? RO • 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. r1d 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. riA9 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// 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. ' :ah. , sen : As i ciat, '' firf IFIP By // Mich.el F. Ratchfo d, 'squire 120 North Keyse,Avenue Scranton,PA 1:504 (570) 558-55 0 Ext. 101 � ) 0--1(n6- - Sivinc� �'� �Y' n � M�,rc� kb ae�u t ��. �- m s3 8201 -- Savihs6s .(�� (�-q- 1, SZ I .siv I'�. II Rtual- (ivy,� OaCh ilts., qjç Ni(ittuk t s M I• ri o altioNs (PA() (Q 1 I (p:lt lD .56 0 ,0 tn1i y,ra Ch1111-i(46 r61;i:P 730 ,'ap )1i4o.a2 s bon- -3@ick 2 Ri9(144;0-k, M &'i1(atEctiT 0 .11 tL1 1 0i1 oxvi- S W ttqq.43) \\ q Il-ko.tp- i I9p22 .Ig DISCOVER BANK In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania Civil Division vs. RYCKITTA M SHORT 1015 KENT DR NO: CP-11-6712 MECHANICSBURG PA 17050-7608 Defendant Praecipe to Dissolve the Attachment against VS. Garnishee MEMBERS 1 ST FCU 6280 CARLISLE PIKE MECHANICSBURG, PA 17050 Garnishee To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. (Z c;zn Thank you, cry�" _ rr: � 0 F— 7 CZ N) C- Michael F. R 5chfd, s quire Edwin A. A rahamsen &Associates,P.C. Lawyer I # 86285 C� loo a1_.I Ii O . ,.. 2173166 f THE: f I l IEO O ,, 7.e13DEC 16 PM 12: C7 GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE CUMBERLAND CO NTY Identification No. : 41360 PENNSYLVANIA JOEL M. FLINK, ESQUIRE ggg Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 EEE DISCOVER BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY EEE MMM vs . DOCKET NO. : CP-11-6712 ERE EEE RYCKITTA M SHORT ggg mmm ENTRY OF APPEARANCE gME maE TO THE PROTHONOTARY: MME MMG Kindly enter my appearance on behalf of the plaintiff in the above-captioned matter. ggg GORDON & WEINBERG, P.C. gag BY: FREDERIC . WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P012 CERTIFICATION OF SERVICE I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Substitution of Attorney and Entry of Appearance Pursuant to Pa.R.C. P. 1028 (c) (1) , via First Class Mail, postage pre-paid, to all other parties or their counsel of record. z_ rm FREDERIC L WEINBERG ESQUIRE Dated: 4(4, SHERIFF'S OFFICE OF CUMBERLAND COUNTY ny R Anderson h ieriff ,a a 04 rrlubr1. Jody S Smith ? IE v1 ;`'i ;- -8 f\ I 9: c Chief Deputy i P f ... Richard W Stewart ,i 3Ek. -J°r " ' i Solicitor ' Discover Bank vs. Case Number Ryckitta M Short 2011-6712 SHERIFF'S RETURN OF SERVICE 06/21/2013 10:19 AM -Jamie DiMartle, Deputy Sheriff, who being duly sworn according to law, states that on June 21, 2013 at 1019 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Ryckitta M. Short, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania, by handing to Laurie Shultz, 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 June 25, 2013 to Ryckitta M. Short, 1015 Kent Drive, Mechanicsburg, PA 17050. 01/07/2014 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, January 07, 2014 RONNY R ANDERSON, SHERIFF 0?• not/ a ,SD �P°1' 3e2o