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HomeMy WebLinkAbout12-0241SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy P? 11 -.`> FILEU-OFFICE Off' THE PROTHONOTARY 1012 FEB 17 Pty 12: 16 Richard W Stewart Solicitor p€€iC;? ;- rr? S?EHiF€ CUMBERLAND COUNTY PENNSYLVANIA Drexel University vs. Shawn M. Thompson Case Number 2012-241 SHERIFF'S RETURN OF SERVICE 02/13/2012 05:45 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February 13, 2012 at 1745 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Shawn M. Thompson, by making known unto Deanna Maple, Daughter of Defendant at 1233 Hunters Ridge Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $48.00 February 14, 2012 TIM IAQK, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF c; CcuntvSuite Snerff 7eiecsoft, (na A PROFESSIONAL CORPORATION BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031, FAX (215)972-5390 DREXEL UNIVERSITY V. SHAWN M. THOMPSON Plaintiff I hereby certify that I have served a co of this paper upon all other iss or their attorneys by: regular mail p certified maij Q othe By CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION c NO. 2012-0241 Defendant N) r~ PRAECIPE FOR DEFAULT JUDGMENT > rv TO THE PROTHONOTARY: `f Enter Judgment in favor of the Plaintiff, DREXEL UNIVERSITY, and against the Defendant, SHAWN M. THOMPSON, for failure to file an Answer in the above referenced action within twenty (20) days from the date of service of the Complaint, and assess Plaintiffs damages as follows: Amount of Claim $6,484.13 Interest from 11/O1/I 1 at 12% + 259.36 Attorney's Fees at 33 1/3% +2,247.83 Subtotal $8,991.32 Less: Payments received subsequent to filing of complaint - 100.00 TOTAL AMOUNT DUE $8,891.32 -Tj /y/q/3 I hereby certify that on the 6th day of March 2012, the attached copy of the Notice required by Pa. R.C.P. No. 237.1 was mailed to the above referenced Defendant. L. BERGER, Attorneys for Plaintiff 2 c`1Of`Clll?i & A Pwnwionec Co.RA21oN AA"!V& ae-fzeo- BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia., Pennsylvania 19103 (215)564-2031 F_A1X (215)972-5390 DREXEL UNIVERSITY Plaintiff v. SHAWN M. THOMPSON Defendant To: Shawn M. Thompson 123 3 Hunters Ridge Drive Mechanicsburg, PA 17050 Date of Notice: March 6, 2012 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2012-241 EMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS 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. PENNSYLVANIA BAR ASSOCIATION Pennsylvania Lawyer Referral Servioa 'TdLSERVlCF® Certificate Of ?Maila1 -his %artificate or Matling Provitles evidence mal mail has Door proseu?c., - - ?his iorm may be used for domestic a?d international mail From: ii 1 i To: \Y LV \ V . 1 • ?\vi'? ? ? ? 70 Ps Form 3817. April 2007 PSN i530-02-000-9065 ? .i To Pay fa ,.ter bs L. o UNI-r&o 0 Z3 F C C, N 1 e PostmarloiT Cq ? W ay 9 >QL L'lE ?a0z m o ? ? nn; '0 A PROFESSIONAL CORPORATION &SI BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215) 564-2031 FAX (215)972-5390 DREXEL UNIVERSITY CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. CIVIL DIVISION SHAWN M. THOMPSON NO. 2012-0241 Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss EDWARD L. BERGER, ESQUIRE, being duly sworn according to law, hereby deposes and says that I am the attorney for the Plaintiff in the above captioned action, and that the following Defendant is not in the Military Service of the United States of America or any State or Territory thereof, or its allies, and that the Defendant is not in any manner subject to the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended: Mr. Shawn M. Thompson 1233 Hunters Ridge Drive Mechanicsburg, PA 17050 SWORN TO AND SUBSCRIBED BEFORE ME THI3-->?Dr)CbAY OF rYarCh COI a . ARY PUBLI NOTARIAL StAL Public FALLON A. VANBLARCOM, Notary y hiladeiphia, PhAa. County . -9!t- ,,.sL e. Coo rdamhet 22.2015 EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff 4 A PROFESSIONAL. CORPORATION BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-203-1 FAX (215)972-5390 DREXEL UNIVERSITY CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. CIVIL DIVISION SHAWN M. THOMPSON Defendant NO. 2012-0241 ASSESSMENT OF DAMAGES AND NOW, to wit, this day of M a`k- , 2012, Judgment is entered in favor of the above referenced Plaintiff, and against SHAWN M. THOMPSON, the above referenced Defendant, for failure to file an Answer and Plaintiff s damages are assessed in the sum of $8,89132. Prothonotary OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS To: Mr. Shawn M. Thompson 1233 Hunters Ridge Drive Mechanicsburg, PA 17050 DREXEL UNIVERSITY CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. CIVIL DIVISION SHAWN M. THOMPSON NO. 2012-0241 Defendant Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. ? Judgment by Default Money Judgment ? Judgment in Replevin Judgment for Possession 'u Judgment on Award of Arbitrators ? Judgment on Verdict El Judgment on Court Findings If you have any questions concerning this notice, please call: ATTORNEY _ EDWARD L. BERGER Esquire (Insert Attorney's Name) at this telephone number: 215-564-2031 10.232 (Rev. 2100) 5 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 2012-241 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DREXEL UNIVERSITY Plaintiff (s) From SHAWN M. THOMPSON, 4225 ROTH LANE, APT. 108, MECHANICSBURG, PA 17050 (I )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: MEMBERS 1sT FEDERAL CREDIT UNION, 6280 CARLISLE PIKE, MECHANICSBURG, PA 17050 USAA FEDERAL SAVINGS BANK, 6706 CARLISLE PIKE, MECHANICSBURG, PA 17050 CHECKING ACCOUNTS, SAVINGS ACCOUNTS, MONIES ON DEPOSIT, SAFETY DEPOSIT BOXES, OR ANY OTHER PERSONALTY OR REALTY WHICH MAY BE IN THE POSSESSION OF THE GARNISHEE BELONGING TO THE DEFENDANT. 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$8,791.32 Interest 3/26/12 Atty's Comm % Atty Paid $199.75 Plaintiff Paid Date: July 24, 2012 (Seal) L.L. $.50 Due Prothy $2.25 Other Costs David D. Buell, Prothonotary "Qy: Deputy REQUESTING PARTY: Name : EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, P.C. 1760 MARKET STREET, SUITE 600 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-2031 Supreme Court ID No. 34116 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DREXEL UNIVERSITY V. SHAWN M. THOMPSON : y ? a5 ?Zc.? Lane. TO THE PROTHONOTARY OF THE SAID COURT: File No. 2012-0241 Amount Due 8,891.32 X Less Payment 100.00 rn? Interest 03/26/12 x Atty's Comm costs ° za c r- N 3m 3 co to The undersigned hereby certifies that the below does not arise out of a retail installment s, contract, or account based on a confession of judgment, but if it does, it is based on the appropria original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to 6 of 1974 as amended. PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the Defendant(s) F Uni ?eL? . l? O50 i\llec.h . PA ! 1 VSo PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following prop (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee belonging to the Defendant, SHAWN M. THOMPSON. and all other property of the Defendant(s) in the possession, custody or control of the said Garnishee(s). (Indicate) Index this writ against the Garnishee(s) as a lis pendens against real e of the Defendant(s) described in the attached exhibit. DATE: Signature: DA raq. ?a a L4 a• 00 I da. 7 S 1u. So g. 50 Print Name: Edward L. Berger, Esquire Address: Gordin & Berger P.C 1760 Market Street Suite 600 Philadelphia PA 19103 Attorney for: Plaintiff Telephone: 215-564-2031 Supreme Court ID No. 34116 d..".wi f-'r ?w.t. Co dc--) ?.k Notes: If real property, supply six copies of description including improvements and an original an copy of affidavit of ownership (Pa. R.C.P No. 3129). ?1 . If lengthy personalty list, supply four copies of list. ag (?? To index writ, file separate prae{cipe?with writ. ? Sp e ?A d-7-8311 Y ?? C4 Ss u SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ????s, at 4zr?r?tr,Er, Jody S Smith Chief Deputy Richard W Stewart C,F-ICL OF `E RIF+ Solicitor Drexel University Case Number'. vs. Shawn M. Thompson 2012-241 SHERIFF'S RETURN OF SERVICE 07/30/2012 '.1:11 AM - Elizabeth Muller, Deputy Sheriff, who being duly sworn according to law, states that on July 30, 2012 at 1111 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Shawn M. Thompson, in the hands, possession, or contl-ol of the within named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Jan Finkle, Member Service Representative, 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 July 31, 2012 to Shawn M. Thompson at 1233 Hunters Ridge Drive, Mechanicsburg, PA 17050. 07/31/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Garnishee to wit: USAA Federal Savings Bank, but was unable to locate tfie Garnishee in his bailiwick. The Sheriff therefore returns the within requested Writ of Execution as "Not'. Found" at 6706 Carlisle Pike, Mechanicsburg, PA 17055. NOTE: ADDRESS PROVIDED IS FOR A CVS DRUG STORE. THERE ARE NO BRANCHES OR LOCATIONS FOR USAA FEDERAL SAVINGS BANK IN PENNSYLVANIA (PER THEIR WEB SITE). SO ANSWERS, July 31, 2012 RONN RANDERSON , SHERIFF Eli abeth Mullef; Deputy Countysu t s Cnli. TeL1c.;oi1. 1-c A IONAL CORPORATION BY: EDWARD L. BERGER, ESQUIRE. Identification No. 34116 1-160 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 '215)564-2031 F_?X (215)9'2-5390 DREXEL UNIVERSITY V. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION SHAWN M. THOMPSON -and- Defendant USAA FEDERAL SAVINGS BANK Garnishee NO. 2012-0241 INTE"o AT/'1Sp(?r ES IN ATTACHMENT rn >C AUG I 2012 c G-') _ N CD ? ,. ?v TO: USAA Federal Savings Bank, 6706 Carlisle Pike, Mechanicsburg PA 17050 You are required to file answers to the followi ng interrogatories within twenty after service upon you. Failure to do so may result in a default jud ment being entered against 1. At the time you were served, or at any subsequent time, did you owe th Defendant(s) any money or were you liable to Defendant(s) on any negotiable or other written instrument, or did Defendant(s) claim that you owed Defendants an the him/her for any reason? No y money or were liable to 2. At the time you were served, or at any subsequent time, was the possession, custody, control, or in the joint possession, custody or control of more persons any in your y property of any nature owned solely or in Yourself and one or part by the Defendant(s)? lVa 3 At the time you were served, or at any subsequent time, did o any property Of any nature owned solely or in part by the Defendant(s) or in u, hold legal title to held or claimed any interest? Ald loch Defendant(s) 4. At the time you were served, or at any subsequent time, did ou any property in which the Defendant(s) had an interest? Y hold as fiduciary IW AUI 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 what was the consideration thereof`? No 6. At the 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 Defendant(s) direction of otherwise discharge any claim of the Defendant(s) against you? N 0 7. I f you are a bank or other financial institution, at the time you were served or a subsequent time did the Defendant (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 identify each account and state the reason for the exemption and the entity electronically depositing those funds on a recurring basis. MO 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which the fun on deposit, not including any otherwise exempt funds, did not exceed the amount of the genera exemption under 42 Pa. C.S. §8123? If so, identify each account. 0) 9. How much is the value of any property in your possession belonging to the Defendant(s)? P 0 10. In the space below, the Plaintiff may set forth additional appropriate interrogatories. Afgkv & Oeeye , .0 0 DWARD . BERGER, ESQUIRE Attorneys r Plaintiff 1 2012 r ~~~tii~l~~/ QCi ~~~ A PROP6SSN)NAL CORP~OpRA~~7~10N BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Stxeet • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 ~~f., ~ii~t_RVlNDi1VIM~~` 1Qt2 AUG t 7 PM 2.36 CtIM~E~~,~ND COUNTY P6~NSYLVANIA DREXEL UNIVERSITY CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEATS v. CIVIL DIVISION SHAWN M. THOMPSON Defendant -and- NO. 2012-241 USAA FEDERAL SAVINGS BANK Garnishee ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against Garnishee, USAA FEDERAL SAVINGS BANK, ~ discontinued, upon payment of your costs only. 8c ~e ~' ~' _-- EDWARD L. BERGER, Attorneys for Plaintiff ~,Sv~a i~a c~3 ~~~~ ~vr~~iv ~ ~e~~.e~ A PrtovssswNAL CoeMR~T1ox ~~~ BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 ~`~' ~~N~ PRa NOf~t?TA,~, 2011 AUG 17 PM 2.35 c~r1~~~La1~~ cQ1~r~rY p~N1~sY~.vAt~~ DREXEL UNIVERSITY CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. CIVIL DIVISION SHAWN M. THOMPSON Defendant -and- N0.2012-241 MEMBERS 1ST FEDERAL CREDIT UNION Garnishee ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against Garnishee, MEMBERS 1ST FEDERAL UNION, discontinued, upon payment of your costs only. EDWARD L. BERGS Attorneys for Plaintiff a!~ ~q.5o o~ -1µa s a~ ~ 5~~ :1 PROFESSIONAL CORPORATION - ,..~y . ,~ttrNyaey~ czt_~'a,~o ~ B~': I:D\x"~~RD L. BERGER, ESQL"IRE ~~~ ., f Identification No. 34116 ~~ °~. ~_ _~ ~~~ 1760 Market Street • Suite 600 Philadelphia, Pennsti~l~-ania 9.9103 ~:~=~~-= cti. _ (215;564-21)31 ~" cs° }-~~~ ('215)')'72-53)0 `-~' DREXEL UNNERSITY CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS ~. CIVIL DIVISION SHAWN 1~I. THOMPSON NO. 2012.-241 Civil Defendant CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.21 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.21. DREXEL UNIVERSITY, certifies that (1 j a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date orr which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (~) no objection to the subpoena has been received, and the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. (4) the subpoena which will be served is identical to the subpoena which i attached to the notice of intent to serve the subpoena. Date: _~lo' l /.L' ~~+~_~ EDWARD L, BERGER, ESQU[RE Attorney for Plaintiff Bruce N. Gordin A PROFESSIONAL CORPORATIO` r~~~~~' (1979-1990) 1?6C Market Street Suire 600 ~'~~~~~' ~-~~U Philadelphia, PA 19103 October 3 X012 zis/sue-zo3i Edward L. Berger* ~ " Fax z15/972.5390 Our File No. * .Also Membe- NJ Bar 89-b22-3811 Ms. Shawn M. Thompson 1233 Hunters Ridge Drive Mechanicsburg, PA 17050 RE: Drexel University v. Shawn M. Thompson Cumberland County No. 2012-241 Civil Dear Ms. Thompson: Pursuant to Rule 4009.21, enclosed please find our Notice of Intent to Serve a Subpoena to Produce Documents and Things upon AES/PHEAA. You have 20 days from the date of this Notice to file anal serve your objection in this matter; if no objection is made we will serve the subpoena. Please govern. yourself accordingly. Very truly yours, EDWARD L. BERGER ELB:ds Enclosure WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE ~~~ ~ ~~ A PROFESSIONAL CORPORA770N ~~~~ at.~°aui BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1?60 Market Street • Suite 600 Philadelphia, Pennsvh~~ania 19103 (21 ~) 564-2031 F ~ i21 S)9?2-5390 DRE;~L, UNNERSITY CUMBERLAND COUNTY Plaintiff COURT OF COMMOhT PLEAS ~'~ CIVIL DIVISION SI-LAVJN M. THOMPSUN NO. 2012-241 Civil. Defendant NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE, DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DREXEL UNIVERSITY ,intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. Date: 00/ /,L .~~ ~ ~~; ~ ~~~/~~~ EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff .~ DRE~I. L>~~IVERS'~ITY CU1vBERLAND COLNTY Plaintiff COURT OF COMMON PLEAS v. CNIL DIVISION SH:AWT1 M. THOMPSON NO. 2012-241 Civil Defendant OB.TECTION TO SUBPOENA PURSUA ~'T TO CIVIL RULE 4009.21 _ (Defendant) objects to the proposed subpoena attached to this Objection for the following reason(s): _~ Date: Defendant SHERIFF'S OFFICE OF CUMBERLAND COUNTY anny RAnderson FILED-OFFICE OF TffPR0THON0TPtR'1' Sheriff �t+�:u+n�rft•,t�itty Jody S Smith 2019 MAR 15 AM 9: 54 Chief Deputy Richard W Stewart : CUMBERLAND COUNTY Solicitor OFFICE Or TH9 SKERJr= ptANS YLVA N I A Drexel University vs. Case Number Shawn M.Thompson 2012-241 SHERIFF'S RETURN OF SERVICE 07/30/2012 11:11 AM-Elizabeth Muller, Deputy Sheriff,who being duly sworn according to law,states that on July 30, 2012 at 1111 hours,attached as herein commanded all goods, chattels, rights,debts,credits,and monies of the within named defendant,to wit: Shawn M.Thompson, in the hands, possession,or control of the within named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to,fan Finkle, Member Service Representative, personally three copies of interrogatories together with thlee 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 July 31, 12 to Shawn M.Thompson at 1233 Hunters Ridge Drive, Mechanicsburg, PA 17050. 07/31/2012 Ronny R.Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry for the within named Garnishee to wit: USAA Federal Savings Bank, but was unable to locate the Garnishee in his bailiwick.The Sheriff therefore returns the within requested Writ of Execution as"Not Found"at 6706 Carlisle Pike, Mechanicsburg, PA 17055. NOTE: ADDRESS PROVIDED IS FOR A CVS DRUG STORE. THERE ARE NO BRANCHES OR LOCATIONS FOR USAA FEDERAL SAVINGS BANK IN PENNSYLVANIA(PER THEIR WEB SITE). 03/14/2013 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. i SHERIFF COST: $133.28 SO ANSWERS, March 14, 2013 RON R ANDERSON, SHERIFF r i 1 ,ocs§§s� (c)CountySuite Sheriff,Teleosoit,Inc. veo" A PitormioNAL CoRpomnoN U1 BY: EDWARD L. BERGER,ESQUIRE 3'0C-) Identification No. 34116 =C:) 1760 Market Street • Suite 600 Philadelphia,Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 DREXEL UNIVERSITY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO. 2012-241 SHAWN M. THOMPSON Defendant CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.21 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.2 1, DREXEL UNIVERSITY, certifies that (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Art&w & MeVW.-, -0 Date: 31-tolli EDWARD L. BERGER, ESQUIRE Attorney for Plaintiff (./i��i����mac✓ v Bn=e N.Gordin A PROMSIONAL COVORATtON 1760 Mwket Street • Suite 600 (1979-1990) '& .al`,.?&Z' Philadelphia,PA 19103 215/564-2031 EAwwd L&ner* February 25,2013 Fax 215/972-5390 Our File No. •Ako Member NJ Bw 89-622-3811 Ms. Shawn M. Thompson 1233 Hunters Ridge Drive Mechanicsburg, PA 18050 RE: Drexel University.v. Shawn M. Thompson C.P. Cumberland County No. 2012-241-Civil Dear Ms. Thompson: Pursuant to Rule 4009.2 1,enclosed please find our Notice of Intent to Serve Subpoena to Produce Documents and Things upon YMCA. You have 20 days from the date of this Notice to file and serve your objection in this matter; if no objection is made we will serve the subpoena. Please govern yourself accordingly. Very truly yours, EDWARD L. BERGER ELB:ds Enclosure WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE A PROPUSKMAL COI@omlm BY. EDWARD L.BERGER,ESQUIRE Identification No. 34116 1760 Market Street- Suite 600 Philadelphia,Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 DREXEL UNIVERSITY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO. 2012-241 SHAWN M. THOMPSON Defendant NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DREXEL UNIVERSITY,intends to serve a subpoena identical to the one that is attached to this notice. You have twenty(20)days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made,the subpoena may be served. Date: /�� 04 EDW L. B!!�G JR,ESQUIRE Attorneys for Plain IT DREXEL UNIVERSITY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO. 2012-241 SHAWN M. THOMPSON Defendant. OBJECTION TO SUBPOENA PURSUANT TO CIVIL RULE 40"621 (Defendant) objects to the proposed subpoena attached to this Objection for the following reason(s): Date: Defendant