HomeMy WebLinkAbout11-8411IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant.
Civil Action No. 11- sq )1 0zrui Mr=
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PRAECIPE TO FILE FOREIGNyz z
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JUDGMENT
FILED ON BEHALF OF
Plaintiff(s)
COUNSEL OF RECORD OF
THIS PARTY:
SHAWN P. MCCLURE, ESQUIRE
PA ID #205951
JENNIFER L. TIS, ESQUIRE
PA ID #203751
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
BERNSTEIN FILE NO. 04514-117
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY' S AUTO SALES, INC.,
Defendant.
Civil Action No.
PRAECIPE TO FILE FOREIGN JUDGMENT
TO THE PROTHONOTARY:
Please file the enclosed certified transcript of Judgment of Superior Court of California, County of
Orange in accordance with Section B of the Uniform Enforcement of Foreign Judgment Act (42 Pa. C.S.A.
§4306), and also mail notice of the filing of the Judgment to the Judgment-debtor at the address shown on
the attached verification.
Amount of Judgment computed as follows:
Principal Amount of Judgment
Interest at 10%
Prior Attorney Fees
$16,131.02
$ 2,526.93
$ 1,319.47
Total Judgment
Date / i
$19,977.42
BERNSTEIN LAW FIRM, P.C.
/?/
By:
Shawn P. McClure, Esquire
PA ID #205951
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
(412) 456-8100
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant.
Civil Action No.
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following Order or Judgment
was entered against you on !t
(xx) Assumpsit Judgment in the amount
of $19,977.42 plus costs.
() Trespass Judgment in the amount
of $ plus costs.
() If not satisfied within sixty (60) days, your motor
vehicle operator's license and/or registration will
be suspended by the Department of Transportation,
Bureau of Traffic Safety, Harrisburg, PA.
Spankey's Auto Sales, Inc.
701 East Locust Street (xx) Entry of Judgment of
Mechanicsburg, PA 17055 (x) Court Order
( ) Non-Pros
( ) Confession
( ) Default
( ) Verdict
( ) Arbitration Award
Prothonot
By:_
PR T7Rrr E UTY)
I SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE
JUS'rICE CENTER:
? Central - 700 Civic Center Dr. West, Santa Ana, CA 92701-4045
? Civil Complex Center- 751 W. Santa Ana Blvd., Santa Ana, CA 92701-4512
® Harbor-Laguna Hills Facility - 23141 Moulton Pkwy., Laguna Hills, CA 92653-1251
? Harbor-Newport Beach Facility - 4601 Jamboree Rd., Newport Beach, CA 92660-2595
? Lamoreaux - 341 The City Drive, Orange, CA 92868-3205
? North - 1275 N. Berkeley Ave., P. O. Box 5000, Fullerton, CA 92838-0500
? West - 8141 131h Street, Westminster, CA 92683-4593
PLAINTIFF/PETITIONER: Consumer Portfolio Services., Inc, a California Corporation
DEFENDANT/RESPONDENT: Spankey's Auto Sales, Inc., a Pennsylvania Corporation
EXEMPLIFICATION OF COURT RECORD CASE NUMBER:
30-2009-00280516
I, Alan Carlson, Executive Officer and Clerk of the Superior Court of California, Countv of Orange. which is a rmirt havinn
a seal, do certiry and attest that the attached document consisting of 2 page(s) is a true and correct copy of the original
record in this Court.
Date Filed:
10/22/10
Document:
Judgment
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Clerk of the Superior Court
Date: 04/20/11
TYPE OR PRINT NAME VTL
I, the undersigned, a judicial officer of the above-named court, certify that Alan Carlson, who is named above, is the Clerk
of the above-named court, having a seal, which is affixed above; that this person is the proper officer of the court
authorized by law to execute the same; that the Clerk's signature is genuine; and that the attestation is in due form
according to the laws of the State of California.
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Date: 04/20/11 COREY S. C AM«
JUDICIAL OFFTUM
L-1062 (Rev. March 30, 2009) EXEMPLIFICATION OF COURT RECORD Civil ode, §§ 1181, 1188, 1189
Evidence Code, §§ 1451, 1530, 1531
1
ATTORNEY OR PARTY WRHMT ATTORNEY (Name, ebb bwmadw and aollhsO: -.vv
FOR C06rrr USE ONLY
Michael T. Lavin, 199423
19500 Jamboree Rd.
Irvine, CA 92612
,/'' ppty?
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TELEPHONE NO.: 888-224-8881 FAX No. (OM W: 949-753-6897
E-MLAWRESS (qO-Q.- michaell(a-,)consumCfppl C ,0llo.com
ATTORNEY FOR(Al =X Consumer Portfolio Services, Inc.
SUPERIOR COURT OF CALIFORWA. COUIITY OF Orange OCT
22
STREETADoREss: 23141 Moulton Parkway
MAILING ADDRESS:
crrYAND27PCooe Laguna Hills, 92653 .Glsrlttoittfl?t;aNMt
BRANCH NAME: Harbor Justice Center -- Laguna Hills
PLAINTIFF: Consumer Portfolio-Services, Inc., a Ca i ornia CO711 ra
DEFENDANT: S anke 's Auto Sales, Inc., a Pennsylvania corporation
JUDGMENT CASE NUMBER:
By Clark (] By Default After Court Trial 30-2009-00280516
By Court (] On Stipulation Defendant Did Not
Appear at Trial
JUDGMENT
1. Q BY DEFAULT
a. Defendant was properly served with a copy of the summons and complaint
b. Defendant failed to answer the complaint or appear and defend the action within the time allowed bylaw.
c. Defendant's default was entered by the dark upon plaintiffs application.
d. 0 Clark's Judgment (Code Civ. Proc., § W5(a)). Defendant was sued only on a contract or judgment of a court of
this state for the recovery of money.
e. [Z] Count Judgment (Code Civ. Proc., § 585(b)). The court considered
(1) plaintiffs testimony and other evidence.
(2) plaintiffs written declaration (Code Civ. Proc., § 585(d)).
2. Q ON STIPULATION
a. Plaintiff and defendant agreed (stipulated) that a judgment be entered in this case. The court approved the stipulated
judgment and
b. M the signed written stipulation was filed in the case.
c. = the stipulation was stated in open court = the stipulation was stated on the record.
3. 0 AFTER COURT TRIAL. The jury was waived. The court considered the evidence,
a. The case was tried on (date and time):
before (name of judicial ofter):
b. Appearances by:
Plaintiff (name each): 0 Plaintiffs attorney (name each):
(1) (1)
(2)
Continued on Attachment 3b.
(2)
Defendant (name each):
(1)
(2)
Q Continued on Attachment 3b.
Defendant's attorney (name each):
(1)
(2)
c. Defendant did not appear at trial. Defendant was properly served with notice of trial.
d. A statement of decision (Code Civ. Proc., § 632) 0 was not = was requested.
Pape 1 of 2
Form APW0Wd 1W OPUa1al Use JUDGMENT
Juddsl Counts of Cdaomla Code Of CMI Procsdun, Of 386, 864.®
4UO-100 (New January 1. 2021
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30-2009400210316 corporadw
os AuW Sak Inca Pamaylvania
JUDO M W ti Mff R At{ FOLLOW BY: Q TM cow p TM CLEMC
4. Q Sftuhftd Ju ftmft AmignoM i• sift a coo?diq to b atlpir ft of the p"m
5. Psdloa. Jrw owd is
a. m for pi,InIR (wwofty: G E] fm aoaFOOmpiaNwart oww aaov:
Conscumv Portfolio Services, Inc., a California cOtGfq wvt- M-
and apalnat pl i k ow (r++r+w): and ap*W aoaa4a4ndant Oum *80):
Spa dwA Auto Saks, Inc., a Pemsylvania coWoLl `•.1 t #t
[j Canttnuad on A*Wff ant 5a. Q Confted on Atfadwwo 50.
b. Q for ft%ndo t (nano aach). d. Q for mmdefendant (nom each):
9. A?NOarrt.
s: Q otlnidant named h lam Be above must
par pldntalf on Ne complaint
(t) m ounapas S 16,131.02
(z) M Pr*WpnW $ 2,326.93
#*Am at the
wMal rule of 10 %
(3) M Atlon:ey rave $1,319.47
(4) O Comb $
(5) omw. (waRYJ :
(e) TOTAL. $19,977.42
c U f'Iar N w reaalw n #ft kwn ddendant
nmNd in thin 5b.
Q nwondw named inNam 5b b i mar
acsrs $
ED and dwnw bra ti
7. M 01w (*=No.
oar OCf 2 2010
ALAN CARLSOk3k`z?
Ds'Ct 2.2 2010 o Clerk, by
l aww
cMaM CEe MATE (bpfbrfag
I owfiry that NO is a true copy of ft original judrwt on No in the nowt.
DOW.
D"
Clark by , t7epu4,
rrwsas
JILMOMENT
) hKdby oo** bjo?NMrt of l d a;p;qiom
?utrr o?'o Y a bo and coned copy of ft oripkNl on me in IMit MA
ALAN CARL EXECUTIVE OFFICER ,wo CLERK of TM5
lti s suPEleoR CxtuRTOF CUM 6
f MM
a Q C? named M ftam 5c avow rnuat pay
acwaom nwd on the aosawnpaim
(1) M oanapee 3
(2) Q Pmpftmwt $
lyd~ at Me
wmual raw of %
(3) p Aft" ilea. S
(4) p cats S
(5) other ppadl?O.. i
(6) TOTAL ft
d. Q Cross?oornpMi,ant to na m rift flan
ave"oWdat rranwd In Nam 5d.
Q ?c Cme4nbndW -w in Morn lid
[1 anitalloera?Om $
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VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities, that the undersigned is the attorney for the Judgment Creditor, Consumer
Portfolio Services, Inc.; that the last known address of the Judgment Creditor is c/o Bernstein Law Firm,
P.C., Suite 2200 Gulf Tower, Pittsburgh, Pennsylvania 15219; and that the last known address of the
Judgment Debtor, Spankey's Auto Sales, Inc. is 701 East Locust Street, Mechanicsburg, PA 17055; that the
Foreign Judgment is valid, enforceable and unsatisfied, and that the facts set forth in the foregoing Praecipe
are true and correct to the best of the undersigned's knowledge information and belief.
Shawn P. McClure, Esquire
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant,
and
PNC BANK and CITIZENS BANK,
Garnishees.
Civil Action No. It - 841( 0"1,i1-&k
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PRAECIPE FOR WRIT OF EXECUTION
FILED ON BEHALF OF
Plaintiff(s)
COUNSEL OF RECORD OF
THIS PARTY:
SHAWN P. MCCLURE, ESQUIRE
PA ID #205951
JENNIFER L. TIS, ESQUIRE
PA ID #203751
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
BERNSTEIN FILE NO. 04514-117
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CbNSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant,
and
PNC BANK and CITIZENS BANK
Civil Action No. I( - 8411 Civil `fxpt
Garnishees.
PRAECIPE FOR WRIT OF EXECUTION p
To the Prothonotary:
t ?colr' '
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of Cumberland County: ?dve& k4 V
Seize
2. against Defendant: Spankey's Auto Sales, Inc.
701 East Locust Street, Mechanicsburg, PA 17055
3. against Garnishees: PNC Bank
2 E. Main Street, Mechanicsburg, PA 17055
Citizens Bank
2 W. Main Street, Mechanicsburg, PA 17055
4. JUDGMENT
Interest from 10/22/10 to 10/31/11 at 10% on $16,131.02: $11,977.42
Poundage $ 1,652.88
SUBTOTAL: $ 322.62
Costs (to be added by Prothonotary): $21,952.92
TOTAL $
Date: < <?
e
BERNSTEIN LAW FIRM, P.C.
By:
Shawn . McClure, Esquire
PA ID #205951
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
BERNSTEIN FILE NO. 04514-117
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4614-So PA ATrq
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-8411 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff (s)
From SPANKEY'S AUTO SALES, INC, 701 East Locust Street, Mechanicsburg, PA 17055
(1) You are directed to levy upon the property of the defendant (s)and to sell seize, levy advertise and
sell all property of Defendant .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
PNC BANK, 2 E. Main Street, Mechanicsburg, PA 17055
CITIZENS BANK, 2 W. Main Street, Mechancisburg, PA 17055
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 $19,977.42
L.L. $.50
Interest from 10/22/10 to 10/31/11 at 10% on $16,131.02 -- $1,652.88
Atty's Comm %
Arty Paid $56.00
Plaintiff Nasal
Date: 1117/11
(Seal)
REQUESTING PARTY:
Name SHAWN P. McCLURE, ESQUIRE
Address: BERNSTEIN LAW FIRM, PC
FIRM #718
SUTIE 2200 GULF TOWER
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-456-8100
Supreme Court ID No. c2O5951
Due Prothy $2.00
Other Costs:
Poundage - $322.62
David D. Buell, Prothonot
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAhjIA
CIVIL DIVISION c °
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CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff, Civil Action No. 11-8411 t -v o-n
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Vs. >
SPANKEY'S AUTO SALES, INC.,
Defendant,
and PRAECIPE TO SETTLE, DISCONTINUE AND
END AS TO GARNISHEE, CITIZENS BANK
PNC BANK and CITIZENS BANK, ONLY
Garnishees. FILED ON BEHALF OF
Plaintiff(s)
COUNSEL OF RECORD OF
THIS PARTY:
SHAWN P. MCCLURE, ESQUIRE
PA ID #205951
JENNIFER L. TIS, ESQUIRE
PA ID #203751
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
BERNSTEIN FILE NO. 04514-117
ab
438111
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant,
and
PNC BANK and CITIZENS BANK,
Garnishees.
Civil Action No.
PRAECIPE TO SETTLE. DISCONTINUE AND END
AS TO GARNISHEE. CITIZENS BANK ONLY
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Settle, Discontinue and End the above-captioned matter upon the records of the Court and mark the
costs paid as to Garnishee, Citizens Bank, only.
Commonwealth of Pennsylvania
County of Allegheny
Sworn to and subsc 'bed
before me this day
of Dec ber, 201
Notary Public
NOTARIAL SEAL
LINDA BOYLE
Notary Public
PITTSBURGH CITY. ALLEGHENY COUNTY
MY Commission Expires Oct 29 2015
438111
BERNSTEIN LAW FIRM, P.C.
Ik fi,-
By:
Shawn P. McClure, Esquire
PA ID #205951
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
(412) 456-8100
T -+
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant,
and
PNC BANK and CITIZENS BANK,
Garnishees.
Civil Action No.
CERTIFICATE OF SERVICE
I, Shawn P. McClure, Esquire, hereby certify that a true and correct copy of the foregoing
PRAECIPE TO SETTLE, DISCONTINUE AND END AS TO GARNISHEE, CITIZENS BANK ONLY
was served on the Defendant and Garnishees by First Class U.S. Mail, this ZO day of December, 2011,
addressed as follows:
Spankey's Auto Sales, Inc.
701 East Locust Street
Mechanicsburg, PA 17055
PNC Bank
2 E. Main Street
Mechanicsburg, PA 17055
Citizens Bank
c/o Nicholas Deenis, Esquire
Stradley, Ronon, Stevens & Young
Great Valley Corporate Center
30 Valley Stream Parkway
Malvern, PA 19355
Shawn . McClure, Esquire
438111
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CONSUMER PORTFOLIO SERVICES,
CIVIL ACTION - LAW C)
INC. NO.: 11-8411
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SPANKE V'S AUTO SALES, INC.
Defendant, ANSWERS TO INTERROGATORIES IN
ATTACHMENT
and
PNC BANK
Garnishee
ANSWERS TO INTERROGATORIES IN ATTACHMENT
AND NOW, PNC Bank, N.A. the Garnishee ("Bank"), files this response stating as follows:
1. No.
2. No.
3. No.
4. No.
5. No.
6. No.
7. No.
8. No.
WHEREFORE, PNC Bank, N.A. does not admit to owing a debt to or to holding property of the
judgment defendant.
Respectfully submitted,
PNC BANK, NATIONAL ASSOCIATION
??Pg. Wd
Lit/garnishee answers/Spankey's Auto Sales, Inc. 12092011
VERIFICATION
The undersigned hereby verifies that I am an authorized representative of
PNC Bank, N.A.; that the statements made in the foregoing Answers to
Interrogatories are true and correct to the best of my knowledge, information and
belief and that these statements are made subject to the penalties of 18Pa_ C.S.
s4904, relating to unworn falsification to authorities.
i
RE: Consumer Portfolio Services Inc vs Spankeys Auto Sales Inc
DOCKET NO.: 11-8411
Theresa A Dusch
Team Lead. Garnishment Processina
Position
DATE: December 29.2011
Lit-233946.1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant,
and
PNC BANK and CITIZENS BANK,
Civil Action No. 11-8411
PRAECIPE TO SETTLE, DISCONTINUE AND
END AS TO GARNISHEE, PNC BANK ONLY
Garnishees. FILED ON BEHALF OF
Plaintiff(s)
G
COUNSEL OF RECORD OF
THIS PARTY: z =
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SHAWN P. MCCLURE, ESQUIRE ,
PA ID #205951 z
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JENNIFER L. TIS, ESQUIRE
PA ID #203751
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
442030
BERNSTEIN FILE NO. 04514-117
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant,
and
PNC BANK and CITIZENS BANK,
Garnishees.
Civil Action No.
PRAECIPE TO SETTLE, DISCONTINUE AND END
AS TO GARNISHEE, PNC BANK ONLY
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Settle, Discontinue and End the above-captioned matter upon the records of the Court and mark the
costs paid as to Garnishee, PNC Bank, only.
Commonwealth of Pennsylvania
County of Allegheny
Sworn to and subscr'bed
before me this Vl? day
of Januar , 2012
Not Public
NOTARIAL SEAL
LINDA BOYLE
Notary Public
PITTSBURGH CITY. ALLEGHENY COUNTY
4 4 2 0 3 My Commis" Expires Oct 29, 2015
BERNS EIN LAW FIRM, P.C.
By: ?A_??
Shawn P. McClure, Esquire
PA ID #205951
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
(412) 456-8100
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PINNNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant,
and
PNC BANK and CITIZENS BANK,
Garnishees.
Civil Action No.
CERTIFICATE OF SERVICE
I, Shawn P. McClure, Esquire, hereby certify that a true and correct copy of the foregoing PRAECIPE TO
SETTLE, DISCONTINUE AND END AS TO GARNISHEE, PNC BANK ONLY was served on the Defendant and
K-
Garnishees by First Class U.S. Mail, this 9 day of January, 2012, addressed as follows:
Spankey's Auto Sales, Inc.
701 East Locust Street
Mechanicsburg, PA 17055
PNC Bank
c/o Joel B. Gold, Esquire
One PNC Plaza, 20t" Floor
249 fifth Avenue
Pittsburgh, PA 15222
Citizens Bank
c/o Nicholas Deenis, Esquire
Stradley, Ronon, Stevens & Young
Great Valley Corporate Center
30 Valley Stream Parkway
Malvern, PA 19355
Shawn P. McClure, Esquire
442030
Jan, 4, 2012 3.49PNl PNC SAN
Nu. 6802 P. 3
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CONSUMER PORTFOLIO SERVICES,
INC.
Plaintiff,
V&
SPANKEY' S AUTO SALES, INC.
Defendant,
and
PNC BANK
Garnishee
CIVIL ACTION - LAW
NO.: 11-8411
ANSWERS TO INTERROGATORIES IN
ATTACHMENT
Filed on behalf of PNC Bank, National Association
Joel B. Gold, Esquire
Sr. Counsel for PNC Be* National Association
Pa. I.D. #42090
PNC Bank National Association
Firm #862
One PNC Plaza, 2e Floor
249 Fifth Avenue
Pittsbux1h, Pennsylvania 15222-2707
(412) 762-280116763 (facsimile)
Jwn, c, 2012 3:150P'NI PNC EAN
No. 6802 4
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CONSUMER PORTFOLIO SERVICES,
INC,
Plaintiff,
VS.
SPANKEY'S AUTO SALES, INC.
Defendant,
and
PNC BAND
Garnishee
CIVIL ACTION - LAW
NO.; 11-8411
ANSWERS TO INTERROGATORIES IN
ATTACHMENT
AND NOW, PNC Bank, N.A. the Garnishee ("Bank"), files this response stating as follows.
1. No.
2. No.
3. No.
4. No.
5. No.
6. No.
7. No.
S. No.
Jan. . 2012 3,50 N1 PNC BAN< No, 6802 P. 5
WHEREFORE, PNC Bank. N.A. does not admit to owing a debt to or to holding property of the
judgment defendant.
Respectfully submitted,
PNC BANK, NATIONAL ASSOCIATION
d
I-Wgffn{shee ass vv0psaWs Auto Sales, Ina 12092011
Jan. 4. 2! 12 3, 50PN1
PNC P?R\<
No, 6802 P. b
3
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The undwsigned hwiby miles ther I am an authorized rep magadve of
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PNC Be* NA; that the A taaments made in the foregoing Answers to
Iderrogoatories = true and oozmct to the best of my knowledge, information and
belief and t@at these statements are made subject to the penalties of IM C.S. ?
94904, relating to uwwom Unification to mWwdties.
RE Consumer Portfolio Services Inc vs Spankeys Auto Sates lne
DOC'I ET NO.:11.8411
Lad-,
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DATE:. 29.2011
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff, Civil Action No. 11-8411
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant.
SUGGESTION OF BANKRUPTCY
FILED ON BEHALF OF
Plaintiff(s)
COUNSEL OF RECORD OF
THIS PARTY:
SHAWN P. MCCLURE, ESQUIRE
PA ID #205951
JENNIFER L. TIS, ESQUIRE
PA ID #203751
Bernstein Law Firm, P.C.
Firm #718
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
412-456-8100
BERNSTEIN FILE NO. 04514-117
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY'S AUTO SALES, INC.,
Defendant.
Civil Action No. 11-8411
SUGGESTION OF BANKRUPTCY
TO PROTHONOTARY:
AND NOW comes Plaintiff, by counsel, Bernstein Law Firm, P.C. to advise this Honorable Court
that the above named Defendant, Spankey's Auto Sales, Inc., has filed a Chapter 1 I Bankruptcy in the
United States Bankruptcy Court for the Middle District of Pennsylvania at Bankruptcy Case Number 08-
04267, and accordingly, all proceedings in this Court are stayed pursuant to 11 U.S.C. § 362.
BERNSTEIN LAW FIRM, P.C.
B 2
Y•
Shawn P. McClure, Esquire
PA ID #205951
Attorney for Plaintiff
Suite 2200 Gulf Tower
Pittsburgh, PA 15219
(412) 456-8100
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CONSUMER PORTFOLIO SERVICES, INC.,
Plaintiff,
Vs.
SPANKEY' S AUTO SALES, INC.,
Defendant.
Civil Action No. 11-8411
CERTIFICATE OF SERVICE
I, Shawn P. McClure, Esquire, hereby certify that a true and correct copy of the foregoing
SUGGESTION OF BANKRUPTCY was served on the Defendant by regular U. S. Mail, postage prepaid,
,
this ZL1 " day of February, 2012, addressed as follows:
Spankey's Auto Sales, Inc.
701 East Locust Street
Mechanicsburg, PA 17055
Shawn P. McClure, Esquire