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Home My WebLink About11-8687 X r: CAPITAL ONE BANK(USA),N.A. In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvania Civil Division VS. LINDA L PHELAN 735 S HANOVER ST NO: 11-8687-CIVIL TERM CARLISLE PA 17013-4106 Defendant , a rrir q vs. METRO BANK c1 -- 3201 TRINDLE RD CAMP HILL,PA 17011 "'C- C Garnishee Praecipe for Entry of Appearance Kindly enter my appearance on behalf of CAPITAL ONE BANK(USA),N.A. in the above- captioned matter. Date:October 21,2013 Sign a Print ame: ichael F. atchford TEsaguire Address: 120 North K ser Avenue Scranton A 18504 Telephone No: C570 558-5510 Ext. 120 Supreme Court ID No: 86285 PRAECIPE FOR WRIT OF EXECUTION—(MONEY JUDGMENT)RULES PA.R.C.P.3252,3111 (a) CAPITAL ONE BANK(USA),N.A. In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania vs. Civil Division LINDA L PHELAN ` 735 S HANOVER ST CARLISLE PA 17013-4106 NO: 11-8687-CIVIL TERM Defendant X vs. 0�T11 METRO BANK s"- 3201 TRINDLE RD PRAECIPE FOR WRIT OF EXECUTION - , CAMP HILL,PA 17011 ATTACHMENT ° r' Garnishee v (MONEY JUDGMENT) To the Prothonotary:TO SATISFY THE JUDGMENT,ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER (1) Directed to the Sheriff of CUMBERLAND County,Pennsylvania; (2) Against:LINDA L PHELAN (3) And against:METRO BANK 3201 TRINDLE RD CAMP HILL,PA 17011 (4) and index this writ(a)against Defendant(s)(b)against METRO BANK 3201 TRINDLE RD CAMP HILL,PA 17011 Garnishee(s), as a lis pendens against the real property of the defendant(s)in the name of the Gamishee(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): ***-**-6153; (5) Judgment Amount $5,877.57 Interest $680.13 Payments $1250.00 Clerks Fee $ Sheriff $ Poundage $ Total $ DDate:October 21,2013 Aichaeltchford, Esquire Edwin A.Abrahamsen&Ass ciates,P.C. Attorney for Plaintiff mratchford @eaa-law.com 56 C WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-8687 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK(USA)N.A. Plaintiff(s) From LINDA L. PHELAN,735 S.HANOVER STREET,CARLISLE,PA 17013 (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,3201 TRINDLE ROAD,CAMP HILL,PA 17011,ANY AND ALL ACCOUNTS OF THE DEFENDANT(S),IN THE POSSESSION OF GARNISHEE,INCLUDING BUT NOT LIMITED TO SAVINGS ACCOUNT BALANCES; CHECKING ACCOUNT BALANCES; CERTIFICATES OF DEPOSIT; MONEY MARKET ACCOUNTS; CONTENTS OF SAFETY DEPOSIT BOXES. 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$5,877.57 Plaintiff Paid$ Interest Attorney's Comm. % Law Library$.50 Attorney Paid$56.25 Due Prothonotary$2.25 Other Costs$ Date: 11/6/2013 David D. Buell, Prothonotary 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 EXT. 120 Supreme Court ID No. 86285 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff +' 'H E P R 0 f H0IN if"1°, n nt 111rib"P, Jody S Smith 201:3 NOV ZO AM 11; 7 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor OFFICE FTK# SRS-RIrr PENNSYLVANIA Capital One Bank vs. Case Number Linda Phelan 2011-8687 SHERIFF'S RETURN OF SERVICE 11/18/2013 09:31 AM- Brian Grzyboski, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Maria T. 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 November ,, 2013 to Linda Phelan at 735 S Hanover Street, Carlisle, PA 17013. BRIAN GRZY S K7 Q&UTY SO ANSWERS, November 19, 2013 RbNO R ANDERSON, SHERIFF (c)CountySuiie Sheriff,Teleosoft,Inc. CAPITAL ONE BANK(USA),N.A. In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania Civil Division vs. LINDA L PHELAN 735 S HANOVER ST NO: 11-8687-CIVIL TERM r z CARLISLE PA 17013-4106 Defendant vs. INTERROGATORIES IN ATTACHMENT"- sue D METRO BANK E --0 L7, 3201 TRINDLE RD CAMP HILL,PA 17011 � Garnishee RE: Execution of Judgment against your depositor LINDA L PHELAN SSN# ***-**-6153 You are required to file answers to the following interrogatories within twenty(20)days after service upon you. Failure to do so may result in judgment against you: 1) At the time you were served or at any subseqent time, did the Defendant possess any bank accounts,joint or individual,that were in your custody or control?Please specify joint or individual account.Please list the legal title of any such account(s) and the primary account holder and if known whether joint account is entireties property. Defendant has less than $300 exemption 2) At the time you were served or at any subsequent time, what was the balance and account number of the bank accounts(s) identified in Interrogatory#1? 3) At the time you were served or at any subsequent time, please list the average daily balance in the past five(5)months for each such account identified in your answer to Interrogatories number one(1)and two(2)above. 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? 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? 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)? 8) At the time you were served or at any subsequent time did the Defendant(s)account contain funds deposited electronically on a recurring basis and which are identified as being exempt from execution, levy or attachment. If so, state the reason for the exemption.,the amount being withheld and the entity electronically depositing those funds on a recurring basis. 9) At the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. Section 8123?If so,identify each account. 10) Identify every other account(not previously noted)titled in the naive of the Defendant(s) in which you believe the Defendant(s)have an interest in whole of part, whether or not styled as a payroll account, individual retirement account,tax account, lottery account, partnership account,joint or tenants by entirety account, insurance account,trust or escrow account,attorney's account,or otherwise. 11) To the extent that you're above answers depend in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). Edwin Abraham en Associate . G Michael F. tchfor4tsquire 120 North Jkeyser Avenue Scranton/PA 18504 (570) 558-5510 Ext. 101 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ( I GY TURE CAPITAL ONE BANK(USA),N.A. In the Court of Common Pleas of Plaintiff : CUMBERLAND County,Pennsylvania Civil Division vs. LINDA L PHELAN 735 S HANOVER ST : NO: 11-8687-CIVIL TERM CARLISLE PA 17013-4106 Defendant : Praecipe to Dissolve the Attachment against vs. Garnishee 3201 METRO ORLE RD CAMP HILL,PA 17011 • ,, it Garnishee . J • • -4 -� -< To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank you, J./ Mich, F. Ratchfc d, Esquire Edwin A. Abraha sen&Associates, P.C. Lawyer ID # 862:5 49.50 PQ c-rrY 331/34 0x0 419 7. LiTt!g'L _. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE', (F TNa $kMFiMF:P Z KU t 11LNUI`. It CUMtiBERLA ao CCUNF�, PENNSYLVANIA Capital One Bank vs. Linda Phelan Case Number 2011-8687 SHERIFF'S RETURN OF SERVICE 11/18/2013 09:31 AM - Brian Grzyboski, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Maria T. 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 November 19, 2013 to Linda Phelan at 735 S Hanover Street, Carlisle, PA 17013. 06/13/2014 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: $89.26 SO ANSWERS, June 13, 2014 RONN ' R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teeleosoft, Inc.