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Home My WebLink About11-9215 COURT OF COMMON PLEAS OF CUMBERLAND COUNTVf P FILED-OFFICE COMMONWEALTH FINANCIAL 2012 JAN 18 PM 1: 35 SYSTEMS, INC. CUMBERLAND COUNTY Plaintiff No. 2011-09215 PENNSYLVANIA vs. CIVIL ACTION WILLIAM WILLIAMS, Defendant CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO Pa.R.C.P. No. 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, I, Alan R. Mege, Esquire, hereby certify that: 1. Notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed to Plaintiff at least twenty days prior to the date the subpoena is sought to be served; 2. A true and correct copy of the notice of intent, including the proposed subpoena, are attached hereto; 3. No objection to the subpoena has been received; and 4. The subpoena that will be served is identical to the subpoena which was attached to the notice of intent to serve subpoena. By: ?1=omey . Mege, Esquire for Plaintiff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff : No. 2011-09215 V5. CIVIL ACTION WILLIAM WILLIAMS, Defendant NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO Pa.R.C.P. No. 4009.21 Plaintiff intends to serve a subpoena identical to the one that is attached to the notice. You have twenty (20) days from the date listed below in which to file of record and serve the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: December 21. 2011 Mege, Esq., Attorney f laintiff (COPY . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Commonwealth Financial Systems, Inc. Plaintiff vs. William Williams Defendant File No. 2011-09215 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Pennsylvania State Police (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Please provide any and all information with regards to direct deposit for Defendant. Also please provide any and all banking information with regard to Defendant. at 1538 Commerce Ave., Carlisle, PA 17013 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Alan P Mege, Esquire ADDRESS: Po Box 1426, Bethlehem, PA 18016 TELEPHONE: 610-954-5393 SUPREME COURT ID # 81288 ATTORNEY FOR: Plaintiff Date: tom` •J it Seal of the Court BY THE CO 1 Prothonotary, Civil Division Deputy ECOPY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. 2011-09215 Plaintiff No . VS =M 7V ,_. . CIVIL ACTION = WILLIAM WILLIAMS, `° > - Defendant c a p r\> co ?:. CERTIFICATE PREREOUISITE TO SERVICE OF A SUBPOENA PURSUANT Tb Pa.R.C.P. No. 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, I, Alan R. Mege, Esquire, hereby certify that: 1. Notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed to Plaintiff at least twenty days prior to the date the subpoena is sought to be served; 2. A true and correct copy of the notice of intent, including the proposed subpoena, are attached hereto; 3. No objection to the subpoena has been received; and 4. The subpoena that will be served is identical to the subpoena which was attached to the notice of intent to serve subpoena. By: R. Mege, squire Attorney for Plaint' P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff No. 2011-09215 vs. CIVIL ACTION WILLIAM WILLIAMS, Defendant NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO Pa.R.C.P. No. 4009.21 Plaintiff intends to serve a subpoena identical to the one that is attached to the notice. You have twenty (20) days from the date listed below in which to file of record and serve the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: February 9, 2012 an R. Mege, Esq., 75Y,6 Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Commonwealth Financial Systems, Inc. Plaintiff File NO.201 1-092 1 5 vs. William Williams Defendant SUBPOENA TO PRODUCE DOCUMENTS OR TIDINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Pennsylvania State Police (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Please provide any and all information with regards to direct deposit for Defendant who has a social security number ending in XXX-64-9564. Also please provide any and all bank information with regard to Defendant. at Law Offices of Alan R. Mege, Esq., PO Box 1426, Bethlehem, PA 18016 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the topics or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Nom: Alan R. Mege, Esquire ADDRESS: POBOa 1426, Bethlehem, PA 18016 TELEPHONE: 610A54•5393 SUPREME COURT ID # slags ATTORNEY FOR: Pin-will BY THE COURT: Prothonotary, Civil Division tofthe Court Deputy COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff No. 2011-09215,' r M vs. cn sv CIVIL ACTION WILLIAM WILLIAMS, z Q -- Defendant y y rv CERTIFICATE PREREOUISITE TO SERVICE OF A SUBPOENA PURSUANT' TO Pa.R.C.P. No. 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, I, Alan R. Mege, Esquire, hereby certify that: 1. Notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed to Defendant at least twenty days prior to the date the subpoena is sought to be served; 2. A true and correct copy of the notice of intent, including the proposed subpoena, are attached hereto; 3. No objection to the subpoena has been received; and 4. The subpoena that will be served is identical to the subpoena which was attached to the notice of intent to serve subpoena. By: _ an R. Mege, Esquir Attorney for Plai f P.O. Box 1426 ' Bethlehem, PA 18016-1426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff No. 2011-09215 vs. WILLIAM WILLIAMS, Defendant CIVIL ACTION NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO Pa.R.C.P. No. 4009.21 Plaintiff intends to serve a subpoena identical to the one that is attached to the notice. You have twenty (20) days from the date listed below in which to file of record and serve the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: February 9, 2012 an R. Mege, Esq., 75Y46r Plaintiff . I- - - ` COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Commonwealth Financial Systems, Inc. Plaintiff VS. William Williams Defendant File No. 2011-09215 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Commissioner's of Pennsylvania State Police and/or Custodian of Records (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: bank information with regard to Defendant. Please provide any and all information with regards to direct deposit for Defendant who has a social security number ending in XXX-64-9564. Also please provide any and all at Law Offices of Alan R. Mege, PO Box 1426, Bethlehem, PA 18016 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON NAME: Alan R. Mege, Esquire ADDRESS: Po Box 1426, Bethlehem, PA 18016 TELEPHONE: 610-954-5393 SUPREME COURT ID # 31299 _ ATTORNEY FOR: Plaintiff _ BY THE COURT: ;?, ' fJ Prothonotary, Civil Division Date:- Sa S' al o he Court Deputy e17 -1 0% 4..J it .f'f I ?IA Commonwealth Financial Systems, Inc. Case No. 2011-09215 Amount Due $2,047.88 Interest from 12/12/11 @6% V. William Williams V. Woodforest National Bank Atty's Fee** Costs to be added Garnishee PRAECIPE FOR WRIT OF EXECUTION To the Clerk of Courts: Issue a writ of execution in the above matter, (1) direct the Sheriff of CUMBERLAND county; (2) against William Williams , defendant(s) and upon the (Name of Defendant(s)) following described property of the defendant(s) All tangjible personal property of the defendant located at 2395 Dewey Ln. Enola, PA 17025 (Supply four copies of lengthy personalty list) (if real property supply six copies of the description) (3) against Woodforest National Bank , gamishee(s) for the following property: any and all accounts. sayings checking, certificate of deposit or otherwise, including safe deposit boxes. I-oOated at 60 Noble Blvd., Carlisle, PA 17013 (4) and enter this writ in the judgment index (a) against defendant(s) and (b) against , as gamishee(s) as a lis pendens against real property of the defendant in name of garnishee as follows: (Specifically described property) w Date: 4/23/12 Signature: Print Name: R. M Addr Box 1426, Bethlehem, P K19016-1426 Attorney for: Plaintiff Telephone: (610_) 954-53, Supreme Court ID No: 812SS **Where judgment has been entered under Rule 2951(a), attorneys' fees maybe included if they are authorized in the instrument and there has been a record appearance of counsel at any stage of the proceedings. Pa.RC.P.3251 LAMA ?a9. oord Q J9.ooMF t 50 a t! a $a.?5 J?ue ?. S o d,& C?? /S?°? ?Sgo4 .96) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-9215 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff (s) From WILLIAM WILLIAMS, 2395 DEWEY LANE, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL TANIGBLE PERSONAL PROPERTY OF THE DEFENDANT LOCATED AT 2395 DEWEY LANE, ENOLA, PA 17025 . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: WOODFOREST NATIONAL BANK, 60 NOBLE BLVD., CARLISLE, PA 17013 - ANY AND ALL ACCOUNTS, SAVINGS, CHECKING, CERTIFICATE OF DEPOSIT OR OTHERWISE, INCLUDING SAFE 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$2,047.88 Interest 12/12/11 @ 6% ($40.96) Arty's Comm % Atty Paid $60.50 Plaintiff Paid Date: APRIL 30, 2012 (Seal) L.L. $.50 Due Prothy $2.25 Other Costs -1/ lam. J David D. Buell, Prothonotary DREQUESTING PARTY: Name ALAN R. MEGE, ESQUIRE Address: LAW OFFICES OF ALAN R. MEGE P.O. BOX 1426 BETHLEHEM, PA 18016-1426 Attorney for: PLAINTIFF Telephone: 610-954-5393 Supreme Court ID No. 81288 SHERIFF'S OFFICE OF CUMBERLAND COUNTY A Ronny R Anderson Sheriff??11? Jody S Smith Chief Deputy P Richard W Stewart Solicitor Commonwealth Financial Systems, Inc. Case Number vs. 2011-9215 William Williams SHERIFF'S RETURN OF SERVICE 05/15/2012 11:11 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 15, 2012 at 1111 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: William Williams, in the hands, possession, or control of the within named garnishee, Woodforest National Bank, 60 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Kevin Duffy, Retail 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 him. 05/16/2012 Sheriff Ronny R. Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: William Williams. The Sheriff therefore returns the within requested Writ of Execution as "Not Served" at 2395 Dewey Lane, Enola, PA 17025. Defendant was present at the property; however, there was no items in the residence; the house was completely empty. The defendant stated that he was moving out of state on 05-17-12 and refused to provide the deputy with a forwarding address. Copy of writ of execution mailed to defendant at 2395 Dewey Lane, Enola, PA 17025 on 05-18-12. 05/18/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ of execution is returned Nulla Bona. SHERIFF COST: $113.88 May 18, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF you, a;lte Sn f Fe,,ao-,'t. !ns WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-9215 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff (s) From WILLIAM WILLIAMS, 2395 DEWEY LANE, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL TANIGBLE PERSONAL PROPERTY OF THE DEFENDANT LOCATED AT 2395 DEWEY LANE, ENOLA, PA 17025 . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: WOODFOREST NATIONAL BANK, 60 NOBLE BLVD., CARLISLE, PA 17013 - ANY AND ALL ACCOUNTS, SAVINGS, CHECKING, CERTIFICATE OF DEPOSIT OR OTHERWISE, INCLUDING SAFE 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$2,047.88 L.L.$.50 Interest 12/12/11 @ 6% ($40.96) Atty's Comm % Due Prothy $2.25 Atty Paid $60.50 Other Costs Plaintiff Paid Date: APRIL 30, 2012 David D. Buell, Prothonotary (Seal) BY Deputy REQUESTING PARTY: Name ALAN R. MEGE, ESQUIRE Address: LAW OFFICES OF ALAN R. MEGE P.O. BOX 1426 BETHLEHEM, PA 18016-1426 Attorney for: PLAINTIFF Telephone: 610-954-5393 Supreme Court ID No. 81288 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the al of said C urt at Carlisle, Pa. _ This day of ` " -'-- 2019 f Prot notary COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff vs. WILLIAM WILLIAMS, Defendant No. 2011-09215 _ r CIVIL ACTION 7-7 2r- C CJ C:)C. WOODFORESi NATIONAL BANK, I?? ?•? GARNISHEE " INTERROGATORIES TO THE ABOVE NAMED GARNISHEE TO: Woodforest National Bank, 60 Noble Blvd., Carlisle, PA 17013 interrogatories within twenty (20) days You are required to file an answer to the following i in judgment against yon. after service upon you. Failure to do so may result the fendant, At the time you were served or at any subsequent at 2395 Dewey Ln.?Enola, PA117025 and a William Williams who currently rest or were you liable to him on social security number ending in XXX-64-9561 any money money any negotiable or other written instrument, or did he claim that you owed him any or were liable to him for any reason? ?? II? #6, a'(10' /u 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? quo 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 the Defendant held or claimed any interest? Iv 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? IM 5. At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person, entity or place pursuant to your direction or consent and if so, what was the consideration therefor? 4A 6. At any time after you were served, did you pay, transfer or deliver any money or property to the Defendant or any other person, entity or place pursuant to his direction or otherwise discharge any claim of the Defendant against you? NA 7. 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? If so, identify each account and state the amount of funds in each account, the reason for the exemption, the amount being withheld under each exemption, and the entity electronically depositing those funds on a recurring basis. /UD 8. If you are a bank or other financial institution, at the time you were served or at any psubsequent 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. /V O 9. At any time before or after you were served, did Defendant, either solely or in part, have any account (savings, checking, certificate of deposit, money market, deposits, safe deposit box, and any other debt and/or property) with your office? /VD 10. If your answer to interrogatory #9 is in the affirmative, state: k The account number of each account; /U B. The amount of money in each account. IV )# R. sq. rAttorney for Plain ' f P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 VERIFICATION hereby state that I am authorized to answer the Garnishment Interrogatories in this case. I further verify that the facts contained in the foregoing attached answers to Interrogatories are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating th unworn falsifications to authorities. ?IAY 17 2012 Date: By: Title: k5-1, I Cf?? _ Phov-e.I& Woodforest National Bank-Legal Dept )Bryan Abraham Jessica Black 832-375-2898 - Phone Cedrick Frazier a*375-3471- F8x 25231 Grogan's Mill Rd, Suite 100 The Woodlands, TX 77380 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Commonwealth Financial Systems, Inc. vs. William Williams O'N%1l -.[ tAI P I I t''£Fl,t SHERIFF'S RETURN OF SERVICE 7? N!115Y''..' A Iii Case Number 2011-9215 05/15/2012 11:11 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 15, 2012 at 1111 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: William Williams, in the hands, possession, or control of the within named garnishee, Woodforest National Bank, 60 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Kevin Duffy, Retail 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 him. SO ANSWERS, May 15, 2012 RON R ANDERSON, SHERIFF Noah Cline, Deputy