Loading...
HomeMy WebLinkAbout11-8878SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 1I 1-D-OFFICA Sheriff r of ??'-H PR0TP.ONOT°? , ?u?(? Jody S Smith Chief Deputy L? 16 ?? ?Q' H Richard W Stewart CUMBERLAND COUNTY Solicitor OFI,CE -'E SwERIFF PENNSYLVANIA Pride Acquisitions, LLC vs. Case Number . Stacy R. Hart 2011-8878 SHERIFF'S RETURN OF SERVICE 12/05/2011 07:52 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on December 5, 2011 at 1952 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Stacy R. Hart, by making known unto Robert Hart, Husband of Defendant at 57 Woodmyre Lane, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. PKA,WNJI?OTS HALL, SHERIFF COST: $43.00 December 07, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, ieleosoft, Inc. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ----------------------------------X PRIDE ACQUISITIONS LLC, 100 HERRICKS RD, SUITE 200 MINEOLA, NEW YORK 11501 Plaintiff, -vs- STACY HART 57 WOODMYRE LN, ENOLA, PA 17025-1552 Defendant. Docket No.: 11-8878 Our File No.: 1019581 CIVIL ACTION - LAW71. 70 X :>c- C.4 cn ra PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter Judgment by Default in favor of the Plaintiff, PRIDE ACQUISITIONS LLC, and against the Defendant, STACY HART, for failure to Answer the Civil Action Complaint. The Complaint was served upon Defendant, STACY HART, on 12/05/2011. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. Copies are attached hereto. Assess Plaintiffs damages in the principal sum of $ 41,323.50, less credit for payment in the amount of $ 0.00 plus interest at the rate of 27.24% from 09/30/2009 to 03/07/2012 in the amount of $ 27,416.61, together with cost in the amount of $ 192.00, for a total of $ 68,932.11, with further interest on the judgment until paid in fu'l, in accordance with the player of the Complaint. Date: March 07, 2012 BAKER, ERS, BARSHAY, GROSSMAN, FASS, UHLST.QCK & NEUWIRTH, LLC By: F cis X. Grimes, Esq. PA creme Court ID: 62404 804 WEST AVENUE JENKINTOWN, PENNSYLVANIA 19046 Phone: (484) 690-3910 Toll Free: (877) 741-7370 Email: PAlitigationinfo@bakersanders.com Mailing Address: 100 Garden City Plaza, Suite 500 Garden City, New York 11530 Our File No.: 1019581 +16,6-0 p0 A-rW e? IB&O IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ------------------------------------------------------------------------X PRIDE ACQUISITIONS LLC, 100 HERRICKS RD, SUITE 200 MINEOLA, NEW YORK 11501 Docket No.: 11-8878 Plaintiff, -vs- STACY HART Our File No.: 1019581 57 WOODMYRE LN, CIVIL ACTION - LAW ENOLA, PA 17025-1552 Defendant. ------------------------------------------------------------------------X AFFIDAVIT OF NON-MILITARY SERVICE I, Francis X. Grimes, Esq., being duly sworn according to law, deposes and says: a. That the Defendant is not in the military services of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors Civil Relief Act of Congress of 1940 as amended. b. That the Defendant, STACY HART, is an adult individual and resides at 57 WOODMYRE LN, ENOLA, PA 17025 1552. c. Affiant has ascertained the foregoing information by personal investigation and makes this Affidavit in due authority; and he understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unsworn falsification on to authorities. Date: March 07, 2012 BAKE ANDERS, BARSHAY, GROSSMAN, B,S?',1lUHL NEUWIRTH, LLC Att mev r Plain iff By: Fra #s X. Grimes, Esq. PAS eme Court ID: 62404 Of C nsel 804 WEST AVENUE JENKINTOWN, PENNSYLVANIA 19046 Phone: (484) 690-3910 Toll Free: (877) 741-7370 Email: PAlitigationinfo@bakersanders.com Mailing Address: 100 Garden City Plaza, Suite 500 Garden City, New York 11530 Our File No.: 1019581 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ------------------------------------------------------------------------X PRIDE ACQUISITIONS LLC, 100 HERRICKS RD, SUITE 200 MINEOLA, NEW YORK 11501 Docket No.: 11-8878 -vs- STACY HART 57 WOODMYRE LN, ENOLA, PA 17025-1552 Plaintiff, Our File No.: 1019581 CIVIL ACTION - LAW Defendant. --------------X CERTIFICATION UNDER PA. R.C.P. 237.1 I, Francis X. Grimes, Esq., attorney for Plaintiff, PRIDE ACQUISITIONS LLC, certify that I sent a copy of the attached Notice on e oZ:?> , 201oZ by regular mail, to the Defendant(s) at the address at which the Defendant(s) was/were served with a copy of the Complaint by the Office of the Sheriff indicated by the court records. Date: March 07, 2012 BAKER, NDERS, BARSHAY, GROSSMAN, FASS, ZWJ!l CK & NEUWIRTH, LLC ? By: F cis X. Grimes, Esq. PA meme Court ID: 62404 804 WEST AVENUE JENKINTOWN, PENNSYLVANIA 19046 Phone: (484) 690-3910 Toll Free: (877) 741-7370 Email: PAlitigationinfo@bakersanders.com Mailing Address: Garden City, New York 11530 , -41 100 Garden City Plaza, Suite 500 Our File No.: 1019581 -- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ------------------------------------------------------------------------X PRIDE ACQUISITIONS LLC, 100 HERRICKS RD, SUITE 200 MINEOLA, NEW YORK 11501 Docket No.: 11-8878 Plaintiff, -vs- STACY HART 57 WOODMYRE LN, ENOLA, PA 17025-1552 Our File No.: 1019581 CIVIL ACTION - LAW Defendant. ---------------------------------X NAME AND ADDRESS CERTIFICATION I hereby request the Prothonotary to enter the within judgment against: STACY HART 57 WOODMYRE LN ENOLA, PA 17025-1552 Defendant(s) within named, the last named address of the Defendant(s) being as shown above, and I hereby certify that the precise address of the Plaintiff/Judgment Creditor is: PRIDE ACQUISITIONS LLC 100 HERRICKS RE), SUITE 200 MINEOLA, NEW YORK 11501 Date: March 07, 201.2 ZF S DE BAGROSSMAN, U C&RTH, LLC or aintiff I vi t-ounsei 804 WEST AVENUE JENKINTOWN, PENNSYLVANIA 19046 Phone: (484) 690-3910 Toll Free: (877) 741-7370 Email: PAlitigationinfo@bakersanders.com Mailing Address: 100 Garden City Plaza, Suite 500 Garden City, New York 11530 Our File No.: 1019581 EXHIBIT (10 days Notice) Baker, Sanders, Barshay, Grossman Fass, Muhlstvck & Neuwirth, LLC r Attorneys and Counselors at Law 804 WEST AVENUE JENKINTOWN, PENNSYLVANIA 19046 Tel: 484-690-3910 Toll Free: (877) 741-7370 Please direct all correspondence to our main office: 100 Garden City Plaza, Suite 500 Garden City, New York 11530 February 17, 2012 STACY HART 57 WOODMYRE LN, ENOLA, PA 17025 1552 RE: PRIDE ACQUISITIONS LLC v. STACY HART Docket No.: 11-8878 Our File No.: 1019581 Dear STACY HART: Enclosed herewith please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. nois X. Grim, Esq. Supreme Court ID: 62404 Counsel IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ------------------------------------------------------------------------X PRIDE ACQUISITIONS LLC, CASE NO.: 11-8878 Plaintiff, -vs- OUR FILE NO.: 1019581 STACY HART, Defendant. -------------------------- ---------------------------------------------X To: STACY HART 57 WOODMYRE LN ENOLA, PA 17025-1552 DATE OF NOTICE: February 17, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR 013JE:C-1-IONS -1.0 THE CLAIMS SET FORTH AGAINST YOU. UNI,ESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A :I DGMEN`T' MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTI4ER IMPORTANT RIGHTS. YOU SHOULD TAKE TINS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FOR'T'H BELOW. TH1S OFFICE CAN [PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 11; YOU CANNOT AFFORD TO HIRE A LAWYER, TINS 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. Cumberland Co. Bar Association 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (800) 990-9108 Sincerely, BAKER, ANDERS, BARSHAY, GROSSMAN, FASS,rU) L)I'OCK & NEUWIRTH, LLC By: F cis X. Grimes, Esq. PA preme Court 1D; 62404 Of counsel 804 WEST AVENUE JENKINTOWN, PENNSYLVANIA 19046 Phone: (484) 690-3910 Toll Free: (877) 741-7370 Email: PAlitigationinfo@bakersanders.cam Mailing Address: 100 Garden City Plaza, Suite 500 Garden City, New York 11530 Our File No.: 1019581 EXHIBIT (Affidavit of Service) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny Ft Anderson she?:!Y a" t0v sf Ct; gt?„xi_r?@ Fx?.? ? p rriE. Ssss'•±?iFc i :: z . . Jody 8 Smuts Chip'fDppllty RIChard W Stewart Sca'i;;*C.' 16 AN 1.f1• C PENNSYLVAN1A, Pride Arqu;s.tions, LL C. VS. Case Number . aiaoy R. Hart 201'1-8878 SHERIFF'S RETURN OF SERVICE 12.0 'ski 1 07:62 t -Shown W.-shall, € -*Lty Sheriff, who being dWy sworn aacx4 fittg to law, states that of) e 5, 2011 at "S52 hours, he tiered a true oopy of the within QmViaint and Notice, upon the within earned d endattt, to wtt, Stacy R. KW, by making knmvn unto Robert Hart. Husband of Defendant at 57 Wc odmyre Lane, Enola, Cumberland County, Pennsylvania 17025 its contents and at the sane time handing to hire personalty tt* said titre.. and ;?.)erect copy of the same. 'RV SHAt L .. SHERIFF COST: $43.03 €?e.cember,0+, 2? 1-i Sa ANSWERS, 0" '1 7 r RON ' R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ------------------------------------------------------------------------X PRIDE ACQUISITIONS LLC, 100 HERRICKS RD, SUITE 200 Docket No.: 11-8878 MINEOLA, NEW YORK 11501 Plaintiff, Our File No.: 1019581 -vs- STACY HART 57 WOODMYRE LN, ENOLA, PA 17025-1552 Defendant. CIVIL ACTION - LAW --------------X NOTICE OF FILING JUDGMENT To:STACY HART 57 WOODMYRE LN ENOLA, PA 17025-1552 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment by Default has been entered against you in the above-captioned matter in the amount of $ on and that enclosed herewith is a copy of all documents filed with the Prothonotary in support of said Judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Name: Francis X. Grimes, Esq. Address: BAKER, SANDERS,_BARSHAY, GROSSMAN, FASS, MUHLSTOCK & NEUWIRTH. LLC 804 WEST AVENUE JENKINTOWN, PENNSYLVANIA 19046 Telephone No.: (484) 690-3910-,(877) 741-7370 Prothonotary: By: ,u IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA PRIDE ACQUISITIONS LLC, Plaintiff vs. STACY HART, Defendant • : CIVIL -LAW : DOCKET NO. 2011 -08878 WITHDRAWAL OF APPEARANCE I, Francis X. Grimes, Esquire, hereby withdraw my appearance as counsel in the above stated matter. Date: By: ancis X. Grimes, Esq. PA ID# 62404 ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Pride Acquisitions LLC, Plaintiff, in the above - captioned matter. Date: By: Angela L. Mattis, Esquire PA ID 309229 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: 570 - 387 -1873 Fax: 570- 387 -6474 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA PRIDE ACQUISITIONS LLC, Plaintiff CIVIL ACTION — LAW VS. DOCKET NO. 2011-08878 STACY HART, Defendant PRAECIPE TO MARK JUDGMENT TO USE OF ASSIGNEE TO THE PROTHONOTARY: Please mark the Judgment entered in the above captioned case against the Defendant(s), STACY HART, to and for the use of UNIFUND CCR LLC, Assignee, as per the Assignments of Judgment, copies of which are attached hereto and made part hereof as Exhibits A and B.. DATED: 114 BY: Angela L. Mattis, Esquire PA ID# 309229 JUDGMENT MARKED TO USE OF ASSIGNEE AND NOW, to wit, this day of optiL , 2014, the Judgment entered in the above captioned case against the Defendant(s), STACY HART, is hereby marked to and for the use of UNIFUND CCR LLC. Prothonotary of Cumberland County am-1- Rd 04J/ Mtcy EXHIBIT B BILL OF SALE AND ASSIGNMENT OF ACCOUNTS Pride Acquisitions LLC, a Limited Liability Company organized under the laws of Delaware with an office at 100 Garden City Plaza, Suite SOOB, Garden City, NY 11530 ( "Seller ") hereby absolutely sells, transfers, assigns, sets -over and conveys to Pilot Receivables Management, LLC, a limited liability company organized under the laws of Ohio with an office at 10625 Techwoods Circle, Cincinnati, OH 45242, ("Buyer") without recourse and without representations or warranties, express or implied, of any type, kind or nature except as set forth in the Agreement (hereinafter defined): (a) all of Seller's right, title and interest in and to each of the Accounts identified in the Account schedule attached hereto as Exhibit A (the "Accounts "), and (b) all principal, interest or other proceeds of any kind with respect to the Accounts, but excluding any payments or other consideration received by or on behalf of Seller on or prior to July 31, 2013, with respect to the Accounts. This Bill of Sale is being executed and delivered pursuant to and in accordance with the terms and provisions of that certain Purchase and Sale Agreement made and entered into by and between Seller and Buyer dated August 29, 2013, (the "Agreement "). The Accounts are defined and described in the Agreement and are being conveyed hereby subject to the terms, conditions and provisions set forth in the Agreement. This Bill of Sale shall be governed by the laws of the State of New York without regard to the conflicts - of -laws rules thereof. DATED: 30 , Zd f 3 SELLER: Pride Acqu By: Name: Title: STATE OF New Care ) ) ss. COUNTY OF Hassey./ On this the day of Sepkwbrr, 2013, before me the undersigned officer, personally appeared Ere. QnN„wa vv , who acknowledged him/herself to be the Piesr`cQe✓14 of .Se)le r , a !_L C- corporation, signer and sealer of the foregoing instrument, and that he /she as such officer, deed as such being authorized so to do, acknowledged the execution of the same to be his/her free act and officer and the free act and deed of said corporation. IN WITNESS t REOF, I hereunto set my hand. Comm i,. loner of the Supe N Public or Court Albert Koleenikbv Nptiry ublic, State of NeW_York No. 31K06255811 QusIUktd.ln Nassau Coon*, ., Cotiinilssion Explres:Februery 13; 20.16: Page 23 of 33 EXHIBIT A ASSIGNMENT THIS ASSIGNMENT is effective as of August 29, 2013 between PILOT RECEIVABLES MANAGEMENT, LLC, an Ohio limited liability company ( "Assignor "), and UNIFUND CCR, LLC, an Ohio limited liability company ( "Assignee "). Unless otherwise defined herein, terms used herein shall have the meanings specified in the Servicing Agreement between Assignor and Assignee (the "Agreement "). Assignor, for value received and in connection with the Agreement, transfers and assigns to Assignee all of Assignor's rights in the Receivables, for collection purposes only, including conducting litigation in Assignee's name, for those Receivables which Assignor owns or may acquire from time to time. Assignor shall retain title and ownership of such Receivables. The assignment is without recourse to Assignor and without warranty of any kind (including, without limitation, warranties pertaining to title, validity, collectibility, accuracy or sufficiency of' information, and applicability of any statute of limitations), except as stated in the Agreement or herein. [PILOT RECEIVABLES MANAGEMENT, By: Morgan J. Smith Vice President of Operations [ UNIFUND CCR, LLC] By: Autumn Bloom Manager of Legal Operations C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIAC 20/4 `6 ir ` SY,v4/©a UNIFUND CCR LLC, Plaintiff vs. STACY HART, l Wlx:Awre- UL1‘9" Defendant vs. \a , w 11u as CIVIL -LAW : DOCKET NO. 11-8878 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, g50 kAfAyV k.Ga shee Cie k'A "� PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of Cumberland County, Pennsylvania (2) against Stacy Hart, defendant; and (3) Against Susquehanna Valley Federal Credit Union, Garnishee; (4) and index this Writ in the judgment index and (a) against Stacy Hart, defendant(s), and (b) against Susquehanna Valley Federal Credit Union, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: N/A (5) Amount Due: Interest from 04/05/2012 Credits Other Costs to be added: Clerks Fee: Sheriff: Total: 68,932.11 9,325.66 0.00 9.50 29.00 150.00 78,446127 is '1 day of , 2014 Angela L. Mattis, PA ID# 309229 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 ax (570) 387-6474 'aS 'S 2.sk:V asttp err E)4 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717)240-6195 www.ccpa.net UNIFUND CCR, LLC Vs. STACY HART WRIT OF EXECUTION (Pa R.C.P. 3252) NO 11-8878 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against STACY HART, 57 WOODMYRE LANE, ENOLA, PA 17025 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 SUSQUEHANNA VALLEY FEDERAL CREDIT UNIONGARNISHEE(S), as garnishee, 3850 HARTZDALE DRIVE, CAMP HILL, PA 17011 (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 $68,932.11 Interest FROM 4/5/2012 - $9,325.66 Attorney's Comm. % Attorney Paid $190.00 Date: 8/6/14 (Seal) REQUESTING PARTY: Name : ANGELA L. MATTIS, ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorney for: PLAINTIFF Telephone: 570-387-1873 Supreme Court ID No. 309229 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary 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 maybe provided by law 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY _ Ronny RAnderson FILE. -D -OFFICE Sheriff OF THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor zow of .mutt I,b 2814 AUG 14 A1111:45 CUMBERLAND COUNTY NSYLVANIA QFFICE OF THE SHERIFF Unifund CCR, LLC vs. Stacy R. Hart Case Number 2011-8878 SHERIFF'S RETURN OF SERVICE 08/12/2014 03:07 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, Susquehanna Bank, 1196 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Mary Ellen Ballew, Service Rep., 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 August 13, 2014 to Stacy Hart at 57 Woodmyre Lane, Enola, PA 17025. August 13, 2014 (c) CountySuite Sheriff, Teleosott, Inc. WI " IAM CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CCR LLC, vs. STACY HART, vs. Plaintiff Defendant SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, Garnishee : CIVIL -LAW : DOCKET NO. 11-8878 Cul cars -A, INTERROGATORIES TO GARNISHEE TO: Susquehanna Valley Federal Credit Union 3850 Hartzdale Drive Camp Hill, PA 17011 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. If you need additional information such as a social security number, contact the attorney listed at the end of this document. 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 on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? No. 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? No. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? No. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? No. 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration thereof? No. 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? No. 7. If you are a bank or other 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 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 amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. No. 8. If you are a bank or other institution, 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, identify each account. No. 9. If your answer to any of the above is in the affirmative, state the amount on deposit or owed or describe the property in detail and provide any other particulars of the transaction as may be relevant to this attachment. INA COMPLETED BY: Signature Title Interrogatories submitted to garnishee by: Angela L. Mattis, PA ID #309229 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 Name (print) VERIFICATION I, Catherine M. Bush, verify that the facts set forth in these Garnishee's Answers to Interrogatories are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. § 4904) related to unsworn falsification to authorities. Dated: August 18, 2014 _WL.e,u.C1-'6('`'1- Catherine M. Bush, Assistant Secretary and Legal Counsel Susquehanna Bank 26 North Cedar Street Lititz, Pa 17543 (717) 625-6273 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 1j `UFII;�f, COMMONWEALTH OF PENNSYLVANIA `7��� 4j/G G ��U/y�� UNIFUND CCR LLC, COf f U� ' �/ 3' 'C Plaintiff 13etoy -,A py' vs. : CIVIL -LAW � }'� d� NIA a�� STACY HART, : DOCKET NO. 11-8878 Defendant vs. SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, Garnishee PRAECIPE TO DISCONTINUE ATTACHMENT To the Prothonotary: Kindly discontinue the Writ of Execution against SUSQUEHANNA VALLEY FEDERAL CREDIT UNION. SUBMITTED BY: Ang a L. attis, PA ID #309229 Attorney for Plaintiff 36 West Main St. Bloomsburg, PA 17815 Tel. (570)387-1873 Fax (570)387-6474 0),(51 C'k-lt�'os� �tk 310--/S9