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Home My WebLink About11-7764Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney LD #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, Vs. BRIAN L MAHER 1806 BRANDT AVE NEW CUMBERLND PA 17070 Defendant. c_ r T 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 this 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 g44 10 P4 2668912 PPTCPADI ?a ? S8'9o2 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA `q , _r_a -.a CIVIL ACTION ,,// No. -- ?C?) AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, vs. BRIAN L MAHER 1806 BRANDT AVE NEW CUMBERLND PA 17070 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: The Defendant(s), BRIAN L MAHER, is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with HSBC BANK NEVADA, N.A, (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $2286.52. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2668912 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), BRIAN L MAHER in the amount of $2286.52, plus costs. Respectfully subm PORTFOLIO RECO One of its Attorneys Daniel Santucci, Attorne No. 92800 Gregory R. Dye Attorney No. #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850-1079 Dated: September 29, 2011 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 PORTFOLIO RECOVERY ASSOCIATES LLC Gregory R. Dye, Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. BRIAN L MAHER 1806 BRANDT AVE NEW CUMBERLND PA 17070 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, H? & MOORE, Dated: September 29, 2011 By: Danie$-Sa*Gcci Gregory R. Dye 2668912 PPTJCAMI 111111111111111IN IN 1111IIIIIIIIII1111I1111111111111 LEIWKER VERIFICATION the undersigned attorney for the Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is presently located outside of this jurisdiction, and that in order to file the within document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to au- PPTXVERI Exhibit "A" PPTXEXAI )AC 1'j Id, AFFIDAVIT State of Virginia City of Norfolk ss. I, the undersigned, C Isflna Patterson Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 1. I am competent to testify to the matters contained herein. 2. I am an authorized employee of Portfolio Recovery Associates, LLC, ("Account Assignee') which is doing business at Riverside Commerce Center, 140 Corporate Boulevard, Norfolk, Virginia, and I am authorized to make the statements, representations and averments herein, and do so based upon a review of the business records of the Account Assignee and those records transferred to Account Assignee from HSBC BANK NEVADA, N.AJMETRIS ("Account Seller') which have become a part of and have integrated into Account Assignee's business records, in the ordinary course of business. 3. According to the business records, which are maintained in the ordinary course of business, the account, and all proceeds of the account are now owned by the Account Assignee, all of the Account Seller's interest in such account having been sold, assigned and transferred by the Account Seller on 1/24/2011. Further, the Account Assignee has been assigned all of the Account Seller's power and authority to do and perform all acts necessary for the settlement, satisfaction, compromise, collection or adjustment of said account, and the Account Seller has retained no further interest in said account or the proceeds thereof, for any purpose whatsoever. 4. According to the records transferred to the Account Assignee from Account Seller, and maintained in the ordinary course of business by the Account Assignee, there was due and payable from BRIAN L MAHER ("debtor and co- debtor') the Account Seller the sum of $2,286.52 with the respect of account number ending in 0018, as of 7131/2010 with there being no known un-credited payments, counterclaims or offsets against the said debt as of the date of the sale. 5. According to the records of said Account Assignee, after all known payments, counterclaims, and/or setoffs occurring subsequent to the date of sale, there is currently due and owing the sum of $2,286.52 as of the date of this affidavit. 6. Plaintiff believes that the defendant is not a minor or an incompetent individual, and declares that the Defendant is not on active military service of the United States. Po 'o Reco eryAs es, LC By Custodian of Records Subscribed and sworn to before me on SEP 1 3 2011 Notary Public Tanya Brown Commonwealth of Virginia Notary Public Ok Commission No. 7155840 My Commission ExNres 11/30/2011 s communrca ron rs m a e collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. # 92800 Gregory R. Dye Attorney I.D #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 610-902-0644 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC C/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. BRIAN L MAHER 1806 BRANDT AVE NEW CUMBERLND PA 17070 Defendant(s). IN THE COURT OF COMMON PLC P+. W r CUMBERLAND COUNTY, PA _r CIVIL ACTION - CZ, No. PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-610-902-0644 Dated: September 29, 2011 2668912 PPTXPEAI I IN 11111111 IN 111111111111111111111111111 By: Gregory R. Dye SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff„?? ?t ?tI+NGc?.n0 Jody S Smith ' PC, T 2 i PH 2: '-l Chief Deputy' f? t ts,:' Q ?131r p r s Richard W Stewart t7 ±-:?'rt?`I" `' OFFtcE OF THE 5r.ERIFF t ? ? ?I C ? 11 r a Solicitor Portfolio Recovery Associates, LLC Case Number vs. 2011-7764 Brian L. Maher SHERIFF'S RETURN OF SERVICE 10/21/2011 08:05 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on October 21, 2011 at 2005 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Brian L. Maher, by making known unto Anita Maher, Wife of Defendant at 1806 Brandt Avenue, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $45.00 October 24, 2011 TIM BLA , DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Shenft. Teleosoft, Inc Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 By: PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. BRIAN L MAHER 1806 BRANDT AVE NEW CUMBERLND PA 17070 Defendant(s). Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC ry1 `I] r ri IN THE COURT OF COMMON P CUMBERLAND COUNTY, PA ;moo CIVIL ACTION _ No. 11-7764 CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT BRIAN L MAHER in this matter in the amount of $2,286.52 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 2-23-12 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: March 5, 2012 2668912 PPTJPFJI 1111111111111111111111111111111111111111111111111111111111111 IN Respectfully s & MOORE, L / r V ?c_i' R SKE BLATT, HASE"ILAR, T Cry a 0* 4IG.'sbO a# r ck# &s2&6 12MLg7a1g3 i\ fn4-1r D Nlcxx 1-e 1. PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, Vs. BRIAN L MAHER 1806 BRANDT AVE NEW CUMBERLND PA 17070 Defendant(s). TO: BRIAN L MAHER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 11-7764 CIVIL NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. PROTHO TAR Dated: J 17 I By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. 492800 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 2668912 PPTNDJNI 111111111 IN 1111111111111111111111111111111111111111111111 IIII Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 PORTFOLIO RECOVERY ASSOCIATES LLC Gregory R. Dye, Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. BRIAN L MAHER 1806 BRANDT AVE NEW CUMBERLND PA 17070 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 11-7764 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: March 5, 2012 By: BLATT, HAS & MOORE, L Daniel Santuccil Gregory R. Dye R, LEIBSKER 2668912 PPTJCAM I 1111111111111 III 111111IIIII1111111111111111111111111111111ill IIII PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, vs. BRIAN L MAHER 1606 BRANDT AVE NEW CUMBERLND PA 17070 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 11-7764 CIVIL TO: BRIAN L MAHER Date of Notice: February 23, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC By: Daniel Santucci 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2668912 PPTNLRSI i llllllll IIIII II Iillll Iilil Ilill IIIII Iliil lilil 1i1li IIII 1!111 iili WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-7764 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff (s) From BRIAN L. MAHER, 1806 BRANDT AVENUE, NEW CUMBERLAND, PA 17070 (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: METRO BANK, 65 ASHLAND AVENUE, CARLISLE, PA 17013 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; (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$2,286.52 L.L. $.50 Interest FROM 3-7-12 - $21.89 Atty's Comm % Atty Paid $185.00 Plaintiff Paid Due Prothy $2.25 Other Costs Date: MAY 21, 2012 (Seal) David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name MORRIS SCOTT, ESQUIRE Address: BLATT, HASENMILLER, LEIBSKER & MOORE, LLC 1835 MARKET STREET, SUITE 501 PHLADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-1567 Supreme Court ID No. 83587 Blatt, Heo n WHer, Lolbeker & Moore, LLC Morris SOW Attars ey I.D. 685587 18811 Mist SbINK Seib 501 Ptdleclelola, PA 19103 215-5641967 Defendant(s). PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, VS. BRIAN L MAHER 1806 BRANDT AVE NEW CUMBERLND PA 17070 AND METRO BANK 65 ASHLAND AVE CARLISLE, PA 17013 Garnishee Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS ? _ c- , CUMBERLAND COUNTY, PA 3 ' CIVIL ACTION --< -r ?, > N CD r 2 No. 11-7764 CIVIL =r -+c7 ca-T'r . r o : r PRAECIPE FOR WIMT OF IMOTION TO THE PROTHONOTARY: Kindly ISSUE a wRIT OF EXECUTION in the above matter, directed to the Sheriff of Cumberland County: (1) against BRIAN L MAHER defendant[s] (2) against METRO BANK gamishee[s] REAL DEBT $ 2286.52 INTEREST $ Zl _ ?( From 03-07-12 COST PAID $ Prothonotary SHERIFF $ STATUTORY $ COSTS DUE $ S so?exr a, b0 all ('0. S0 1t a !;D It FS. 2668912 PPTGPWEI M 83587 Attorney for Plaintiff So C.c._ C. -7a97s 9ISS IQ ?4?! t)4 F u JssKa SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OF: ",-P , t? AY 29 kl `iBE R L A K 0 L; }E PENNSYL1(A1fli, Portfolio Recovery Associates, LLC vs. Brian L. Maher Case Number 2011-7764 SHERIFF'S RETURN OF SERVICE 05/25/2012 02:48 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May 25, 2012 at 1448 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Brian L. Maher, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Maria Theodoratos, Assistant Store 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 May 29, 2012 to Brian L. Maher at 1806 Brandt Avenue, New Cumberland, PA 17070. SO ANSWERS, May 29, 2012 RON R ANDERSON, SHERIFF uts all, Deputy (c? CCcin='yS.Ae Che+' Te h Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, vs. BRIAN L MAHER 1806 BRANDT AVE NEW CUMBERLND PA 17070 Defendant(s). METRO BANK 65 ASHLAND AVE CARLISLE, PA 17013 Garnishee Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIAT?$? LLC i ,{ ; Cj i I p', ; ; i" R Li D C0 U N 'F11'1SY LVANIA IN I HE UUUH I OF UUMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 11-7764 CIVIL Interrogatories to Garnishee To METRO BANK, Garnishee: You are required to file Answers to the following Interrogatories within 20 days after service upon you. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant? Joint Spousal 2. At the time you were served or any subsequent time thereafter, was there in your possession, custody, control or in joint possession, custody and control, any property of the defendant? 3. At the time you were served or any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant(s) or in which the defendant held or claimed any interest? 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 any interest? 2668912 PPTGBKCI 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 direction or consent and what was the consideration thereof? 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 defendant's direction or otherwise discharge any claim of the defendant(s) against you? If you are a bank or other financial institution, at the time you were served or 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? If so, identify each account and state the reason for the exemption and the entity electronically depositing those funds on a recurring basis. 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant(s) 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 exemption under 42 Pa.C.S Sec.8123? If so, identify each account. 9. How much is the value of any property in your possession belonging to the defendant(s)? 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. Morri Sc , orney No. 83587 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 hOher kn wledge, information and belief. Blatt, Hasenmiller, Lelbsker & Moore, LLC Morris Scott Attorney I.D. #183587 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. BRIAN L MAHER Defendant(s). METRO BANK Garnishee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA . J ..; CIVIL ACTION NO. 11-7764 CIVIL v?' rv 'tea,--; PRAECIPE TO DISSOLVE ATTACHMENT To the Prothonotary: Kindly mark the Writ of Execution against BRIAN L MAHER and METRO BANK as DISSOLVED, and the attachment as DISSOLVED. Respectfully submitted, - ? Z, n?? Morris c THIS MESSAGE IS FROM A DEBT COLLECTION FIRM. ANY INFORMATION OBTAINED FROM THIS COMMUNICATION MAY BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. *q.50 PQ Am/ CY rya707/73/l0 2668912 PPTXPDAI ? ? ?? ?. '? :jt?i -