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Home My WebLink About11-8869SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor It V0 - tll Er- Target National Bank vs. April Sherwood Case Number 2011-8869 SHERIFF'S RETURN OF SERVICE 06/01/2012 10:23 AM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 1, 2012 at 1021 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: April Sherwood, in the hands, possession, or control of the within named garnishee, Wells Fargo Bank NA, 604 E High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Kait Filipelli, Personal Banker, 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 4, 2012 to April Sherwood at 3013 Lisburn Road, Mechanicsburg, PA 17055. SO ANSWERS,, June 04, 2012 RON R ANDERSON, SHERIFF Michelle Gutshall, Deputy f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. ?C r? t+=m APRIL A SHERWOOD 3013 Lisburn Rd Mechanicsburg Pa 17055-4825 Defendant(s) WELLS FARGO 6416 Carlisle Pike Mechanicsburg Pa 17050 Garnishee NO. 11-8869-CV PRAECIPE FOR WRIT OF E ~ EXECUTION ?- - Filed on behalf of. TARGET NATIONAL BANK e C) SdM Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_ 134 Prep Writ of Exe P&F File No. 11-30648 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff ) NO. 11-8869-CV V. ) APRIL A SHERWOOD ) 3013 Lisburn Rd Mechanicsburg Pa 17055-4825 ) Defendant(s) ) WELLS FARGO ) 6416 Carlisle Pike Mechanicsburg Pa 17050 ) Garnishee ) PRAECIPE FOR WRIT OF EXECUTION To The Prothonotary: Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against, APRIL A SHERWOOD Defendant(s); (3) against, WELLS FARGO, Garnishee; (4) and index this writ (a) against, Defendant(s) APRIL A SHERWOOD, Defendant(s); and (b) against WELLS FARGO, Garnishee; as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows: (5) Amount due $7,385.45 Interest from November 28, 2011 At 6.00 % per annum Court Cost Less: Payment Total &,y 4ZQ.ao t?cL 7.21r- 4?asf a. s8.w% .2. Z S- ?' 9.sc.> 4.L,- PA_134 Prcp Writ of Exe $204.54 crCta4 S'89?? oo?3 ?? a7s'9rp P&F File No. 11-30648 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-8869 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TARGET NATIONAL BANK, Plaintiff (s) From APRIL A. SHERWOOD, 3013 LISBURN RD, MECHANICSBURG, PA 17055-4825 (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 WELLS FARGO, 6416 CARLISLE PIKE, MECHANICSBURG, PA 17050 GARNISHEE(S) as follows: 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 $7,385.45 L.L. S.50 Interest FROM 11/28/11 AT 6.00% PER ANNUM - $204.54 Atty's Comm % Due Prothy $2.25 Atty Paid $58.75 Other Costs Plaintiff Paid Date: MAY 30, 2012 (Sea!) REQUS'. IiVCa PARTY: Name : GREGG L. MORRIS, ESQUIRE Address. PATERAUDE & FELIX, A.P.C. 213 E. MAIN STREET CARNE.GIE, PA 15106 Attorney for: PLAINTIFF Telephone: 412-429-7675 Supreme Court ID No. 69006 David D. Buell, Prothonotary Deputy SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee TARGET NATIONAL BANK vs. APRIL A SHERWOOD and PH; I: ENNISYLVAMA COURT OF COMMON PLEAS COUNTY OF CUMBERLAND NO. 11-8869-CV WELLS FARGO BANK N.A. GARNISHEE ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf Wells Fargo Bank, N.A., Garnishee in the above-captioned matter. Date: ?-?``?` SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee TARGET NATIONAL BANK COMMON PLEAS : COURT OF : COUNTY OF CUMBERLAND VS. APRIL A SHERWOOD and : NO. 11-8869-CV WELLS FARGO BANK N.A., GARNISHEE ANSWERS TO INTERROGATORIES IN ATTACHMENT TO: TARGET NATIONAL BANK, Plaintiff 1. No. 2. Account titled April Sherwood(8602) with a zero balance, an account titled April Sherwood(9290) with a balance of $204.27, and an account titled April Sherwood(5235) with a zero balance. The total sum of $204.27 has been restricted pursuant to this Writ. Pursuant to the terms and conditions of the deposit agreement between the bank and the depositor, the bank claims a priority lien in, and a right of set-off against the account consisting of $100.00 Legal Processing Charge, leaving a balance for execution purposes of $104.27. In addition, pursuant to 42 Pa.C.S.A. Section 2503, a garnishee's attorney fee in the minimum amount of $335.00 is authorized and will be deducted from the attached funds. 3. - 6. No. 7. (Q) If you are a bank or other financial 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? ?e i r?4 1 , Q l; 0 •` ? r???`(I ur;l (A) No. 8. (Q) If you are a bank or other financial 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? (A) In addition to any amounts disclosed above, if any, as of the date of the execution of the Verification to these Answer an account titled April Sherwood (9290) contained the sum of $300.00, which is not being held because Garnishee believes that it is exempt pursuant to Section 8123 of the Judicial Code, 42 Pa.C.S. Secti Dated: (v \5--\ r Legal Order Processing P. O. Box 7600 11'' Floor -Y1372-113 Philadelphia, PA 19106 VERIFICATION Lisa Burke, being duly sworn according to law, deposes and says that she is the Writ of,'Execution Administrator of Wells Fargo Bank, Garnishee herein, and verifies that the statements made I the forgoing Answers to Interrogatories are true Arid correct to the best of knowledge. Said Garnishee understands that false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to sworn falsification to authorities. is e Manager Dated: UW 12 ? M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff V. APRIL A SHERWOOD Defendants(s) WELLS FARGO Garnishee NO. 11-8869-CV 4... l 4 =-n -+ -? C? PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY Filed on behalf of: TARGET NATIONAL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 . (412) 429-7675 PA_193A Prcp Disc with Prjdc Gamishee Atty P&F File No. 11-30648 av? ,, q. sb-? 0, Co W31o3 la'1?1113 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARGET NATIONAL BANK Plaintiff NO. 11-8869-CV V. APRIL A SHERWOOD Defendant(s) TO: Prothonotary Please settle and discontinue the matter captioned above without prejudice as to Garnishee only. Thank you. Respectfully subZt'?.C. Patenaude &Yet- Date: June 18, 2012 Sworn to and subscribed before me this day of 20Y2. ($v? P0 Notary Public PA_193A Prcp Disc with Ndc Garnishee Atty Gregg L rris quire 213 E. i reet Cam , PA 15106 (41 9-7675 NOTARIAL SEAL MELINDA S PERRY Notary Public CARNEGIE BORO.,ALLEGHENY COUNTY My Commission Expires Jun 2, 2015 P&F File No. 11-30648 I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK, hereby certify that a true and correct of the foregoing document was served this date by US First Class Mail, postage prepaid upon the following: JON SIRLIN 123 S BROAD STREET SUITE 2100 PHILADELPHIA PA 19109 APRIL A SHERWOOD 3013 LISBURN RD MECHANICSBURG PA 17055-4825 Date: June 18, 2012 Gr L. o Fis, Esquire rrnaameegie, ude & Felix, A.P.C. Main Street PA 15106 (412) 429-7675 PA-193A Prcp Disc with Prjdc Gamishee Atty P&F File No. 11-30648 SIRLIN GALLOGLY & LESSER, P.C By: Jon C. Sirlin, Esquire, I.D. No.: 17498 - " 123 South Broad Street, Suite 2100 - - -?'L4 t 1 S T ARy Philadelphia, PA 19109 (215) 864-9700 2012 JUG. - 2 PM 2:31 Attorney for Garnishee TARGET NATIONAL BANK °. UMT`OF COMMON PLEAS COUNTY OF CUMBERLAND vs. APRIL A SHERWOOD and NO. 11-8869-CV WELLS FARGO BANK N.A.. GARNISHEE ATTORNEY I.D.#17498 BILL OF COSTS OF GARNISHEE, WELLS FARGO BANK, N.A. Garnishee, Wells Fargo Bank, N.A., hereby bills the following costs to the fund attached and will be satisfied therefrom, as authorized by 42 Pa.C.S.A. Section 2503: Garnishee's fee pursuant to 42 Pa. C.S.A Section 2503: Notary Charges: Entry of Appearance: Answers to Interrogatories: Order to Discontinue or Satisfy: Other: TOT. JON C. SIRI Attorney for Costs are hereby taxed in the amount of $ this PROTHONOTARY $104.27 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 day of 2012. BY: