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Home My WebLink About11-9321GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2057422 FIA CARD SERVICES, N.A. F/K/A BANK OF AMERICA 1825 E. BUCKEYE RD. PHOENIX, AZ 85034 Vs. KENNETH H PLEDGER 275 PINE VALLEY ROAD MC KNIGHTSTOWN PA 17343 and F&M Trust 3 East First Street Boiling Springs PA 17007 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-9321 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against KENNETH H PLEDGER defendant(s)and (2) against FPM Trust (3) AMOUNT DUE INTEREST from December 19, 2011 COSTS Prothonotary fee Sheriff fee (4) Less: Payments on Account TOTAL S s a9.Cbe, 44 1 0200.55 r '29- 00 " a. So 11 05 - Po A.TTY 4a.as 6ueCo .so U- garnishee(s) $9,778.95 $.00 ( $.00) c? C~ rnw :ZrrI 3:W -<> (7? G 2? tr. CA. N _ _ ? FREDERIC I. W=BERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff C K? /t' 4 33y -.4. / L i Z75 /7a WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-9321 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIA CARD SERVICES, N.A. Vk/a BANK OF AMERICA, Plaintiff (s) From KENNETH H. PLEDGER, 275 Pine Valley Road, McKnightstown, PA 17343 (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: F&M TRUST, 3 East First Street, Boiling Springs, PA 17007 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 $9,778.95 L.L. $.50 Interest from 12/19/11 Atty's Comm % Atty Paid $261.05 Plaintiff Paid Due Prothy $2.25 Other Costs Date: 5/14/12 (Seal) REQUESTING PARTY: Name : FREDERIC I. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, PC 1001 E. HECTOR STREET, STE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 DaXD uell, r onotary By: Deputy Supreme Court ID No. 41360 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 1,012 MAY 18 Pil I : 12 CUMBERLAND COUNIT PEN'#SYLVANIA FIA Card Services, N.A. f/k/a Bank of America Case Number vs. Kenneth H Pledger 2011-9321 SHERIFF'S RETURN OF SERVICE 05/17/2012 02:32 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 17, 2012 at 1432 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kenneth H. Pledger, in the hands, possession, or control of the within named garnishee, F&M Trust Company, 214A Westminster Drive, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Terry Glass, Security Officer 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 May 18, 2012 to Kenneth H. Pledger, 275 Pine Valley Road, McKnightstown, PA 17343. SO ANSWERS, May 18, 2012 RON R ANDERSON, SHERIFF Noah Cline, Depuut' y C, CGU Su.11 , She, tt. I E-F }cJ ( ,.,,. GORDON[ & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 FIA CARD SERVICES, N.A. F/K/A BANK OF AMERICA 1825 E. BUCKEYE RD. PHOENI=X, AZ 85034 Vs. KENNETH H PLEDGER 275 PINE VALLEY ROAD MC ?,.N-=GHTSTOWN PA 17343 and F&M Trust 3 East= First Street Boiling Springs PA 17007 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-9321 P(n?Qi S INTERROGATORIES IN ATTACHMENT TO: F&M Trust - GARNISHEE 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 subsequent time did you owe the defendant(s 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 dP-f?,?d?IV?-}' ?'1Gt$ defendant for any reason? des, t?ie pv?l aheCKi N9 mc(o wY4 woo f -4m 'TwYs+. 2. At the ti ma t,ou were certrer'1 --)Y at aniT su.bseq?tent. 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(s) had an interest? N 0. 5. At any time before or after you were served did the defendant(s) 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 therefore'? NO. '111.8 past ?tPoSi+-1v-}-he A«Ovyrt 04?1S Mai 1912012. 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 his(her, their) direction or otherwise discharge any claim of the defendant(s) against you? N d• 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time, did the def-endant(s) 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 reason for the exemption, the amount. of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis.N0, bUt -41e !!?{? ?YIdAYl+ W41SA1. N 8-t-i? e DI V G? I I b I I I O F 4+1 G 300 Yid' U-t`D V t X-e O N. If you are a bank or other financial instit,?tion, the time you were served or any subsequent: time did the defendant(s) nave funds on deposit in an account in which the funds on deposit., not including any otherwise exempt funds, did not exceed the amount of MA 11,201Z 211Lj the general monetary exemption under 42 Pa.C.S. 48123? J If. , identify each account .??0• MA Q,2o IZ+ -1 Sb - 0 0 ( ?o ?+) I D H H, `1 Z 9 . How much is the value of any property in our (XfMpON 300 • 00 possession belonging to the defendant (s) ? ?y1--?,?Z G? S ?F 1yy•1Z hold Ma 211-201Z. M A-) ZI o va , -LUI ??_- - y FREDERIC _.WEITNBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff DATED: 2057422 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 I `U9°IBERL.ANO CQtlPITI,` PENNSYLVANIA FIA CARD SERVICES, N.A. F/K/A BANK OF AMERICA VS. KENNETH H PLEDGER and F&M Trust Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-9321 PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant's bank account with F&M Trust, as Garnishee in the above entitled matter. Poll GORDON & WEINBERG, P.C. BY: FREDERIC I. W INB G, ESQUIRE JOEL M. FLINK, UIRE Attorney for Plaintiff QV?4 `q'SC'? a? 12-4L Q7?593