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A iorns?y for Plaintiff(s)
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BY: William T'. 1`Jclczan, Esquire -<> - - ?
I.D.No.47437
436 Seventh Avenue, Suite 1400 - '
Pittsburgh, P.2 15-219
Phone: 412.4-34.7955
Fax: 412.4'• 4.7959
File # 7? 78025
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
RBS CITIZENS, N..':.
%lain';iff
vs. Civil Action No. 1.Z - qq 0,;, 1 lerk,
L..,NNIE! F FORS!,U:N0
LAURA. L FORSLUND
Defendarib's)
COMPLAINT AND NOTICE TO DEFEND
YOU HAVE. BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following ppges, you rri.st take action within twenty (20) days after this complaint and notice are served,
by entering a written appearance personally or by an attorney and filing in writing with the court your
defenses or object ons to the claims set forth against you. You are warned that if you fail to do so the
case may proceed kAthout you and a judgment may be entered against you by the court without further
notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff.
You may lose money o: property or other rights important to you.
YOU SHOU;_D TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU' W;TH AFORMATION ABOUT HIRING A LAWYER.
YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU V';"Ti a !AFOFiIViAT1,0N ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERS(',N;', AT A REDI.;CED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
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/03.'75 04 ATTy
Gr7?' Io3 S1 /0(0
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COMPLAINT
Plaintiff is a corporation having offices in 480 Jefferson Blvd, Warwick, RI 02886.
Defe-dants are adult individuals residing at 5402 Oxford Drive, Apt C, Mechanicsburg,
PA 170".
3. On yr bout March 10, 2003, Defendants duly executed a Retail Installment Sale Contract
(,ereinafter -_tie "C(.ntract") in favor of Faulkner Mazda Subaru, a true and correct copy of said Contract is
attached hereto, market as Exhibit "I" and made a part hereof.
4. Pursuant to said Contract, Defendants took possession of the vehicle more particularly
identified in the Contract as a Used 2001 Mazda Tribute.
Pursuant o the terms and conditions provided by the Contract, the Contract was assigned
from Fcialkner Ma:;da Subaru to Plaintiff.
6. Plaintiff avers that Defendants are in default of the Contract by having not made payment
to Plaintiff -2s promised, thereby rendering the entire balance immediately due and payable.
7. Plaintiff avers that a balance of $19,875.08 is due from Defendants as of September 2,
2011.
o. Plaintiff avers that the Contract between the parties provides that Defendants will pay
F'•ainti,i s reasonablc «ttorneys' fees.
9. Plaintiff avers that such attorneys' fees amount to $125.00.
10. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or
refused to pa,., the principal balance, attorneys' fees, or any part thereof to Plaintiff.
WHEREFORE, Plaintiff demands judgment against Defendants, Daniel P Forslund and Laura L
Forslund, jointly and se-erally, in the amount of $19,875.08 with continuing interest thereon at the
statutory rate of 6.0G% per annum from the date of Judgment, plus attorneys' fees of $125.00 and costs.
THIS IS AN A-d'TEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
SHALL. 'BE USEi? FOR THAT PURPOSE.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
William T. Molezan, quire
I.D. No.47437
436 Seventh Avenu , Suite 1400
Pittsburgh. PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 7378025
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VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904
relating
to unsworn falsifications to authorities, tha lie she is ,1 la e, ,;' /
(NAME)
? faU 1 Ve n o6a tac oyl of K& 61ttze j?s , AJ , plaintiff
v (TITLE) (COMPANY)
herein, that he/she is duly authorized to make this verification, and that the facts set forth
in the foregoing Complaint in Civil Action are true and correct to the best of his/her
knowledge, information and belief.
(I ", Jaz
(SIGNATURE)
WWR# 7378025
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
RBS Citizens, NA
vs.
Daniel P Forslund (et al.)
oWlr?tr o{ 4at?roberfr? ? ? H°,:.
'V2 MAR -I PM 3: 42
LAW
RI-F
EN"5? L
Case Number
2012-944
SHERIFF'S RETURN OF SERVICE
02116/2012 09:04 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February
16, 2012 at 2104 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Daniel P. Forslund, by making known unto himself personally, at 5402C Oxford Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to
him personally the said true and correct copy of the same.
TIM KLACR, DEPUTY
02/16/2012 09:04 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February
16, 2012 at 2104 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Laura L. Forslund, by making known unto Daniel Forslund, Husband of Defendant at
5402C Oxford Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the
same time handing to him personally the said true and correct copy of the same.
TIM BLACK, DEPUTY
SHERIFF COST: $54.00
February 23, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
o; cau
a
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA tL 4 C? I`0 1 O TA R`'
CIVIL DIVISION
RBS CITIZENS, N.A.
L_1AND COUNTY
Plaintiff_ `.'zNISYLYAIA
VS. Civil Action No. 12-944 CIVIL TERM
DANIEL P FORSLUND
LAURA L FORSLUND
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONI'ARY:
Kindly enter Judgment against the Defendants DANIEL P FORSLUND , LAURA L
FORSLUND , above named, in the default of an Answer, in the amount of
$20000.08 computed as follows:
Amount claimed in Complaint $19875.08
Less payments / adjustments made $0.00
Attorney's fees $125.00
TOTAL $20000.08
I hereby certify that appropriate Notices of Default, as attached have
been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the
Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By :
William T. Mo czan 7437
07378025 C A Pit TIC
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219
And that the last known address of the Defendants are
DANIEL P FORSLUND
5402 OXFORD DRIVE APT C
MECHANICSBURG, PA 17055
LAURA L FORSLUND
5402 OXFORD DR APT C
MECHANICSBURG, PA 17055
C? IU?c15(Q?
12-*a73 y78
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
RIBS CITIZENS, N.A.
Plaintiff
Case No. 12-944 CIVIL TERM
vs.
DANIEL P FORSLUND
LAURA L FORSLUND
Defendant
IMPORTANT NOTICE
TO:
DANIEL P FORSLUND
5402 OXFORD DRIVE APT C
MECHANICSBURG, PA 1705
Date of 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 PAPER TO YOUR 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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA. 17013
(717) 249-3168
WELTMAN, WEINBERG & REIS CO., L.P,A.
By:
Matthew Urban
P.A.I. D.# 90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
(412) 338-7130
7378025 A PIT WTM
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
RBS CITIZENS, N.A.
Plaintiff
Case No. 12-944 CIVIL TERM
vs
DANIEL P FORSLUND
LAURA L FORSLUND
Defendant
IMPORTANT NOTICE
TO:
LAURA L FORSLUND
5402 OXFORD DR APT C
MECHANICSBURG, PA 17055
Date of 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 PAPER TO YOUR 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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA. 17013
(717) 249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
Matthew Urban
P.A.I.D.# 90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
(412) 338-7130
7378025 A PIT WTM
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
RBS CITIZENS, N.A.
Plaintiff.
vs. Civil Action No. 12-944 CIVIL TERM
DANIEL P FORSLUND
LAURA L FORSLUND
NON-MILITARY AFFIDAVIT
The undersigned is the duly authorized agent and/or attorney for the
Plaintiff in the within matter and states as follows:
Affiant states that the within Affidavit is made pursuant to and in
accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App.
521.
Affiant further states that based upon investigation it is the affiant's
belief that the Defendants , DANIEL P FORSLUND , LAURA L FORSLUND , are not
in military service.
Affiant further states that this belief is supported by the attached
certificate from the Defense Manpower Data Center (DMDC), which states that
the DMDC does not possess any information indicating that the below
individual is in the military service:
DANIEL P FORSLUND
5402 OXFORD DRIVE APT C
MECHANICSBURG, PA 17055
LAURA L FORSLUND
5402 OXFORD DR APT C
MECHANICSBURG, PA 17055
Affiant further states that the averments contained herein are true and
correct to the best of Affiant's knowledge, information and belief and that
these averments are made subject to the penalties of 18 Pa C.S.A. Section
4904 relating to unsworn falsification to authorities.
AFFIANT
Request for Military Status
Department of Defense Manpower Data Center
10 Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Apr-02-2012 10:07:47
Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
FORSLUND DANIEL P Based on the information you have furnished, the DMDC does not possess
any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
Ohl, lot 0144,
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http://ww,?v.defenselink.m.il/fag/pis/PC09SI..,DR.htm.l. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dmdc.osd.mil/appj/scra/popreport.do 4/2/2012
Request for Military Status Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:1 I6UL 1 l32HF
https://www.dmde.osd.mil/appj/scra/popreport.do 4/2/2012
Request for Military Status
Department of Defense Manpower Data Center
40 Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Apr-02-2012 09:56:14
<. Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
Based on the information you have furnished, the DMDC does not possess
FORSLUND LAURA L any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http://,.N,-wtiv.defenselin.k.m.il/fag/pis/PC09Sl..,DR.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dmdc.osd.mil/appj/scra/popreport.do 4/2/2012
Request for Military Status Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:5QAT83HOJA
https://www.dmdc.osd.mil/appj/scra/popreport.do 4/2/2012
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
RBS CITIZENS, N.A.
Plaintiff
VS. Civil Action No. 12-944 CIVIL TERM
DANIEL P FORSLUND
LAURA L FORSLUND
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the fo lowing order of Judgment
was entered against you on
(xx) Assumpsit Judgment in the amount of $20000.08 plus costs.
( ) Trespass Judgment in the amount of $ plus costs-
( ) If not satisfied within sixty (60) days, your motor vehicle
operator's license and/or registration will be suspended
by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration A 7d Prothonotary
By:
PROTHONOTARY DEPUTY
DANIEL P FORSLUND
5402 OXFORD DRIVE APT C
MECHANICSBURG, PA 17055
LAURA L FORSLUND
5402 OXFORD DR APT C
MECHANICSBURG, PA 17055
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 12-944 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due RBS CITIZENS, N.A. Plaintiff (s)
From DANIEL P. FORSLUND & LAURA L. FORSLUND, 5402 Oxford Drive, Apt. C,
Mechanicsburg, PA 17055
(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:
MEMBERS 1sT FCU, 1711 SPRING ROAD, CARLISLE, PA 17013
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$20,000.08
Interest $118.36
Atty's Comm %
Atty Paid $205.75
Plaintiff Paid
Date: JUNE 18, 2012
L.L. $.50
Due Prothy $2.25
Other Costs
David D. Buell, Prothon t
(Seal) By: •
Deputy
REQUESTING PARTY:
Name : MATTHEW D. URBAN, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 90963
i ?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
RBS CITIZENS, N.A.
Plaintiff
VS. Civil Action No. 12-944 CIVIL TERM
c
DANIEL P FORSLUND
t{ p;L ?'p,.cl ?' • C , fn ntk-- -PA ?
- R
1-705S
Y
w
J
LAURA L FORSLUND
Defendant(s)
A Vie
?
MEMBERS 1ST FCU 1 (71 1 coc
`11
Garnishee(s) •
PRAECIPE FOR WRIT OF EXECUTION C^? ` `;
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against DANIEL P FORSLUND LAURAL LAURA, Defendant
3. against MEMBERS 1 ST FCU,, , Garnishee
4. Judgment Amount $ $20,000.08
Less Payments/credits received
Interest
Costs
SUBTOTAL:
Costs (to be added by Prothonotary):
a
ate} sy,F
60
75
$ $0.00
$ $118.36
$ $20,118.44
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
?a• Sv ??
ck W553 195
WWR No. 7378025
wrl-i 4 ex
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
RBS CITIZENS, N.A.
Plaintiff
VS.
DANIEL P FORSLUND
LAURA L FORSLUND
Defendant(s)
MEMBERS 1 ST FCU
Garnishee(s)
No. 12-944 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 7378025
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
RBS CITIZENS, N.A.
Plaintiff
VS. Civil Action No. 12-944 CIVIL TERM
DANIEL P FORSLUND
LAURA L FORSLUND
Defendant(s)
C,
MEMBERS 1ST FCU
Garnishee(s) ,.
TO: MEMBERS 1 ST FCU, 1711 SPRING RD, CARLISLE, PA 17013
RE: DANIEL P FORSLUND, 5402 OXFORD DRIVE APT C, MECHANICSBURG, PA 17055
LAURA L FORSLUND, 5402 OXFORD DR APT C, MECHANICSBURG, PA 17055
Suggested Reference No.: XXX-XX-2327
XXX-XX-4433 ?nSW?S
IWORTANT NOTICES TO GARNISHEE!
A. 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.
B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of
Execution is issued.
C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes
into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the
resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the
time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited
and withdrawn during the intervening period.
am m
jUN 2 5 NQ
WWR No. 7378025
INTERROGATORIES IN ATTACHMENT
1. At the time you were served or at any subsequent time did you owe the defendant any money or
were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money
or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of
deposit)? ?4 o
1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof;
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe or owed to him; and the nature and amount of each of such liabilities. I-cr0
2. At the time you were served or at any subsequent time was there in your 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. tv ?
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 part by `the defendant or in which defendant held or claimed any interest?
ey
l 0
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? ? \ p
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 directions or consent and if so what was the consideration thereof?
.?A c)
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 his direction or otherwise discharge any claim of the defendant
against you? tAO
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 reason for the exemption,
the amount being withheld under each exemption and the amount of funds in each account, and the entity
electronically depositing those funds on a recurring basis. t"'k L)
WWR No. 7378025
8. 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? If
so, identify each account. . 0-0
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution. til
10. If the answer to Interrogatory I is in the affirmative, state the date the written instrument, checking
or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this
institution. N' N
11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account
which are not 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? I
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on
deposit in the account. 7.'L Ua d 1 vcx.?_ S ` M,JVV\Q_ NtL Ou---,
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 7378025
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff FIL -UMCE
Jody S Smith ? u?u of tTr;r,?pr??? C-r Tit ONN,' NARY
Chief Deputy Z 'UN 27 AN 8: X42
?x?9c
Richard W Stewart
Solicitor C 'CE -ERIFF CUM VL9 CITY
VANI A
RBS Citizens, NA
vs. Case Number
Daniel P Forslund (et al.) 2012-944
SHERIFF'S RETURN OF SERVICE
06/22/2012 10:19 AM - Noah Cline, Deputy Sheriff, who being duly swom according to law, states that on June 22,
2012 at 1019 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendants, to wit: Daniel P. Forslund, and Laura L. Forslund, in the hands,
possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring
Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Laurie Shultz, 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 June 25, 2012 to Daniel P. Forslund at 5402
Oxford Drive, Apartment C, Mechanicsburg, PA 17055 and to Laura L. Forslund at 5402 Oxford Drive,
Apartment C, Mechanicburg, PA 17055.
SO ANSWERS,
June 25, 2012 RON R ANDERSON, SHERIFF
:
Noah Cline, Deputy
(c) Cour??ySuite Sneritt. Ieleosoft. Inc.
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: William T. Molczan, Esquire
I.D. No.47437
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 7378025
RBS CITIZENS, N.A.
VS.
DANIEL P FORSLUND,
LAURA L FORSLUND,
and
M & T BANK
Garnishee(s)
Attorney for P1.
2412 ,, 13 P" 2:32
CUMBERLAND County
Court of Common Pleas
NO. 12-944 CIVIL TERM
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly mark the above matter discontinued and ended as to Garnishee(s), M & T BANK,,
only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
William T. Molczan, quire
Attorney for Plainti
amm '& .SOPaH1.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
.finny R Anderson ILFIC
Sheriff OFJOE PROTHONOTA'�
t Jody S Smith 201 MAR 15 AM 9:
Chief Deputy
Richard W Stewart CUMEERLA ND COUNTY
Solicitor OFFICE OF THE SRERIFt' t'E"0S i LVANIA
i
i
I
RBS Citizens, NA
vs. Case Number
Daniel P Forslund(et al.) 2012'944
SHERIFF'S RETURN OF SERVICE
06/22/2012 10:19 AM-Noah Cline, Deputy Sheriff,who being duly swam according to law,states that on June 22,
2012 at 1019 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendants,to wit: Daniel P. Forslund,and Laura L. Forslund, in the hands,
possession, or control of the within named garnishee, Memb,*s 1st Federal Credit Union, 1711 Spring
Road, Carlisle, Cumberland County, Pennsylvania 17013, by%anding to Laurie Shultz, 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 June 25,2012 to Daniel P. Forslund at 5402
Oxford Drive,Apartment C, Mechanicsburg, PA 17055 and to Laura L. Forslund at 5402 Oxford Drive,
Apartment C, Mechanicburg, PA 17055.
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.
SHERIFF COST: $98.13 SO ANSWERS,
March 14,2013 RONW R ANDERSON, SHERIFF
i
i
t
(c)C,ountySuite Sheriff,Teleosoft.Inc.