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r 1L70-CiF ICE E ? 0TH0N9TAAY 19 P: i iU i s3 CUMBERLAND COUNTY ptEg 6YL.VANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. : CIVIL-LAW GLEN A. HOFFMAN, DOCKET NO. Q D a 7 ?"? Cl V! Defendant NOTICE TO DEFENDANT TO THE DEFENDANT: YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by_entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without 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 or property or other rights important to you. 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. G Nu+ • dos. 7S ? aA5 Ck-1E ll0?3 P? a?asi? Pennsylvania Lawyer Referral Service 100 South Street, PO Box 186 Harrisburg, PA 17108 800-692-7375 717-238-6807 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 RAYM D W. KESSLER, ESQUIRE Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. : CIVIL-LAW GLEN A. HOFFMAN, DOCKET NO. Defendant COMPLAINT The Plaintiff, Unifund Corporation, by and through its attorney Raymond W. Kessler, Esquire, hereby files this Complaint of which the following is a statement: The Plaintiff, Unifund Corporation is a Corporation doing business at 10625 Techwoods Circle, Cincinnati, Hamilton County, Ohio 45242. 2. The Defendant, Glen A. Hoffinan, is an adult individual residing at 18 West Springfield Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. Defendant obtained a MasterCard credit card on or about July 22, 2008, from Citibank (South Dakota) NA, (hereinafter "original creditor"), Account number 5256 5003 4002 3091. 4. Unifund Corporation has been assigned the account of the Defendant by Unifimd CCR Partners. Pursuant to Pa.R.C.P. No. 1019(i), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit A. 5. Unifund CCR Partners has been assigned the account of the Defendant by Pilot Receivables Management, LLC. Pursuant to Pa.R.C.P. No. 1019(i), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit B. 6. Pilot Receivables Management, LLC purchased the account of the Defendant from Citibank, N.A.. Pursuant to Pa.R.C.P. No. 1019(i), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit C. 7. Defendant used the extended credit leaving an unpaid balance of $2,902.60 with interest continuing to accrue at 6.00% per annum. 8. Defendant defaulted on the payments due and the last payment on this account was on or about February 5, 2010. 9. To date the balance on the charge-off balance $2,902.60 and post-charge off interest has accrued in the amount of $243.84 for a total remaining balance due of $3,146.44. COUNT 1 BREACH OF EXPRESS CONTRACT 10. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 11. In consideration of the extension of credit provided by original creditor through a credit card, Defendant agreed to pay for all charges for purchases, balance transfers, cash advances, fees and interest on his/her account. 12. The reasonable charges and expenses owing for the credit card purchases, cash advances, balance transfers, fees and interest is $3,146.44. 13. Defendant accepted the extension of credit and utilized the credit card without complaint, objection or dispute as to credit services provided, the prices charged for the same or the costs incurred. 14. Defendant is indebted to the Plaintiff in the amount of $3,146.44. Defendant has failed and refused to pay the aforesaid sum despite frequent demand to do so and the same is now due and owing. 15. Defendant's failure to pay is a breach of the express written agreement between the Defendant and original creditor. Pursuant to Pa.R.C.P. No. 1019(i), a copy of the written agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit D. WHEREFORE, Plaintiff, Unifund Corporation, demands judgment against the Defendant in the amount of $3,146.44 together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT II BREACH OF IMPLIED CONTRACT 16. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 17. It is averred, in the alternative, in the paragraphs set forth above, if an express contract between original creditor and Defendant did not exist, that a contract implied by fact or implied within the law exists. 18. At all times relevant hereto, Defendant was aware that the original creditor was extending credit services to Defendant and that the original creditor expected to be paid for the Defendant's use of this credit. 19. Defendant used the credit card to purchase items, and/or transfer balances, and/or obtain cash advances and he/she received the same to Defendant's benefit. 20. The total reasonable value of the Defendant's use of the credit extended by original creditor is $3,146.44. 21. In breach of the implied contract, Defendant has failed and refused to pay the outstanding sum for the credit card use and the same is now due and owing. 22. The Defendant has failed and refused to pay the aforementioned sum despite frequent demand to do so. 23. By virtue of Plaintiff s assignment of this account, Defendant is indebted to the Plaintiff in the amount of $3,146.44. WHEREFORE, Plaintiff, Unifund Corporation, demands judgment against Defendant in the amount of $3,146.44, together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. COUNT III QUANTUM MERIUT/UNJUST ENRICHMENT 24. The preceding paragraphs are incorporated herein by reference and made a part thereof as if fully set forth herein. 25. Original creditor provided the extension of credit as set forth above with the expectation of receiving payment for all use of this credit including, but not limited to, purchases, cash advances, balance transfers, fees and interest. 26. The credit extended by original creditor benefited Defendant. 27. The Defendant will be unjustly enriched if Defendant is allowed to retain the benefit resulting from Defendant's use of the credit card provided by original creditor without having to make reasonable payment for the value of the benefits received from the original creditor's provision of credit. 28. The original creditor was not a volunteer in providing the credit services set forth above and the Defendant understood that original creditor was entitled to compensation based upon Defendant's use of the credit card. 29. The reasonable value of the Defendant's use of the credit card including purchases, balances transfers, cash advances, fees and interest is $3,146.44. 30. Plaintiff is entitled to $3,146.44 from the Defendant and frequent demand for said sums has been made and the Defendant has failed and refused to pay the same. WHEREFORE, Plaintiff Unifund Corporation demands judgment against the Defendant in the amount of $3,146.44 together with interest, costs, attorney fees and such further and additional relief, as this Honorable Court deems just and equitable. Respectfully submitted, RayrnW. Kessler, Esquire Attorney for Plaintiff PA ID #309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 ASSIGNMENT THIS ASSIGNMENT is effective as of January 1, 2012 between UNIFUND CCR PARTNERS a New York partnership ("Assignor") and UNIFUND CORPORATION, an Ohio Corporation ("Assignee"). Unless otherwise defined herein, terms used herein shall have the meanings specified in the Servicing Agreement between Assignor and Assignee (the "Agreement"). Assignor, for value received and in connection with the Agreement, transfers and assigns to Assignee all of Assignor's rights in the Receivables, for collection purposes only, including conducting litigation in Assignee's name, for those Receivables which Assignor owns or may acquire from time to time. Assignor shall retain title and ownership of such Receivables. The assignment is without recourse to Assignor and without warranty of any kind (including, without limitation, warranties pertaining to title, validity, collectability, accuracy or sufficiency of information, and applicability of any statute of limitations), except as stated in the Agreement or herein. UNIF D CCR PARTNERS rudy Weiss- raig Vice Presiden UNIFUND CORPORATION By: Morg . S itl Vice Pr id nt o Q erations EXHIBIT ASSIGNMENT THIS ASSIGNMENT is effective as of January 1, 2012 between PILOT RECEIVABLES MANAGEMENT, LLC an Ohio limited liability company ("Assignor') and UNIFUND CCR PARTNERS, a New York Partnership ("Assignee"). Unless otherwise defined herein, terms used herein shall have the meanings specified in the Servicing Agreement between Assignor and Assignee (the "Agreement"). Assignor, for value received and in connection with the Agreement, transfers and assigns to Assignee all of Assignor's rights in the Receivables, for collection purposes only, including conducting litigation in Assignee's name, for those Receivables which Assignor owns or may acquire from time to time. Assignor shall retain title and ownership of such Receivables. The assignment is without recourse to Assignor and without warranty of any kind (including, without limitation, warranties pertaining to title, validity, collectability, accuracy or sufficiency of information, and applicability of any statute of limitations), except as stated in the Agreement or herein. PILOT RECEIVABLES MANAGEMENT, LLC By: ?fv'lsl Trudy Weiss Craig Vice Preside t UNIFUND CCR PARTNERS By:14 Mor J. Smit Vice e dent Operations EXHIBIT Contract ID: UN IMUIAB 112111 Document ID: 111.611UN1AS1SBBi Document ID: 111611UN1FX.ITBBI. Document ID: 111611 UN I PM 1 PBB 1 BILL OF SALE THIS BILL OF SALE, dated November 21, 2011, is by Citibank, N.A., a national banking association organized under the laws of the United States, located at 701 East 60th Street North, Sioux Falls, SD 57117 (the "Bank") to Pilot Receivables Management, LLC, organized under the laws of the state of Ohio, with its headquarters/principal place of business at 10625 Techwoods Circle, Cincinnati, OH 45242 ("Buyer"). For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated November 21, 2011, between Buyer and the Bank (the "Agreement"), the Bank does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, the Accounts described in Exhibit 1 and the final electronic file. Citibank, N.A. By: (Signature) Name: Patricia Hall Title: Financial Account Manager Pilot CBNA 112111 EXHIBIT CITIBANK CARD AG;EEM?NT T liS Agreemati! and folder comatn ;' g :nc :ard are ': jur Gitibark Ccm 49reei%nt. 7'1? cur .^vfrtaEnS f=nC01t2 air lint Ir'orrnation. u1^IudirG ?hl; annual 4CIre:i?G'jp r.f [? 1 t'? ?^o_nt (}? nJ `,iC7'.?'`.r?n?U lee. ntn'?'s r:ur; and cep tr?c folder and this Agreernent for '?cur rec: res. V T? a simp'iN h res" of'r+s ,`r-Bement `rr rr , >u. Ir,e o !owing tler,nit;ens :+r( apCiy n: +10101S you. jOJ/ . rid /,t1 .,, can the per.•or resronsille f?( trifs Agreement, to ,horn we (Ji C? 'ra b ling St3tern The 'a1Qrd " _yd M cis i}ma or more Cdr S v& O we '"-ve issued'mth your 3CroU?it nUniDer. T,,te etords we, us-, and oar (efean Citibank ($outli Dakota), U.A. The vxrds v117?317 f !, ('r?'i i'-Pan on.? Pr t7Gr2 ;neck, `riot ','/e Tcc, '! Gr3.'Pde to arcass Jour Citibank card account. This Agreement is bindio on you unIESS ycJ CancPl roar account *ith'n ?g rlays a?'.°r recelvir:g irFe ,ard and /ou 11aVe i1Cif ised of axd iorited use of your acccurit, Using Your Account and `four Credit Line: The card mutt be signed to be used. Your initial credit fine appears on the folder containing the care. A ccrtion of your credit line, called the cash advance limit, is available or cash advances. At our ..^iscreticn and at any lime, we may change your credit line or Iasi' advance limit. We will notify you if we do, either by mail or through a hiiling stafarnent sent eit`,er I:efore or after the charge takes effect. You may recuest a change to your credit fine or cash advance imit by contacting Customer Service by tslephone or rrlai'. The full anount of your credit line is available to buy or ease goods or services wrerevar the card is honored. Your cash advance limit is available for cash through any bank or automated teller machine that accspts the card or by using Citibank checks. The total amount charged cn your account, including purchases, balance transfers, cash advances, finance charges, fees, or other charges, must always remain belo-w your credit 'ine. ffowzver, if that total amount exceeds ;roue credit line you must sill p. y us. Additional Cards: You may request additional cards on your account for yourself or others and you may permit another person to have access to the card or account number- However, if you do, you must pay us tr all charges made by those persons, including charges for which you may not have intended to to responsible. You must notify us o revoke permission for any ,person you previously autrori?ed to use your account. if you tell us to revoke another person's use of your account, vie may close the account and issue a hew card or cards Vlit,! a different account number. You are responsible torte use of each card issued or your accourt according to the terms of this Agreement. Membership Fee: The folder contriving the card indicates whether your account is subject to a membership fee f it is, the fee is added to the purchase balance and is nor:- refundable unless you notify us to cancel your account within 30 days from the malting data of the billing statement on wt.irh the fee is billed. 6, . c. 1 f r. x { 1 ' Y ;R t 77 ZZ t= -7 C ? r r n ... J ' / LL. - - - - ' a? > J i f c 3 - _ z y r -+ w ; 3 J r? ?' .,? ?:. _ .3 :'1 ery _ ?. ' 'n "l C > -` v7 --{ ` •''? . ?- K ?+ t?D , _N 3 .`S - -- ".. - J.J j ? V J '? G`. Lam` ? ? -. ? ?-. 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I J v ' .y -? n' 'W = ? = N tD n c n y A r C 4 - "=^ LA CJ + ? ` j <ii a' v - ( al C? ro O .- cV .v ':.y ."'? ?'+ C c7 =? F? [b y -CJ's. O •?= CJ c^? ai ._. en ... S ^. '? '' 'CJ D 4 N N .•?. Gy 3 m o =L ; c'a c°7 G .J j.i G O d O C'.+'4 O '? O 7 (O CO CO V'+. m ,? _? 4 C:• C 1 ° !G _° O,,r Q = . = Ci C D O 3 Oi `+a Tf C C C1 = y 2i n . u = Q. ??i _: 3 O .-. x O C r ._ 7 =? T3 sn rO n r ? ro C (v ?1 = G .. = O r_' _. C 'C co • t ., Cam C R v C • f :If O u? .? - n CD . y _. .m. ` G> u, y• :n Cr CL , x = ra cm c7 M - 4 c; _ " cy CJ C^ Citibank Checks: G ,o4r :.ir (F :! 4v us.-, . c,rc! a I:, a ..e r r 'c .tat..: r r ; th.N a?curi i 3r lti ?? r,4tilwanc 1,n i uetth,. mc_nt D ill Cause the U-37 're G u'V,a.d your -, ,Jir f rid IA1 ..1rEt l1 ?C; t,llt'S%f !,rsC4` 'A:; ? - cafe acv t r;o r;F 'r m +;a .l /o t ??n d . .hKe rn st r, n Iie .,.i1 e9r 1 i!t is„1.d aj -i ust a '1 .u :or, ind t°! :'t'/ hi , '.(r r. CB `?+ ( CL ??tl ll .E' r" i r'- r , 3f le + yl L r v(i `Ic li. all t x :is ( t ce cd o r' t sn o y'ed 'G 's snit. ?,-is a -rnr r, r U1;1IrF..arc ly..em°^.1- +f1: wA n nt .ar ifr lily C t, b1--nl. CrAI i n `!I I we rFturn paid i;:t F_r+K aR3:'ri. Returned Citibank Check Fee: 9 a :o hp ' sq v, s`cline rc L car :t " r N- - C rtali ch , .. `ir :: e C. , r.qr... r ±IK crec' r 2f .;ar,.i,le. tr.n Gr c(.d I ne, If ! 1G &50, !f for t;id not cniqii, ith of r ua-,,:icns icydi rq th-. check, if •dc?Jlr acc ur` as becn r'c?ed. irr care has, e'%p,red Stop Payment FeA: We will :dd u S2.9 fe to `h' cash advance balance when }laynlr .t , a i; itan. cheL'`4 is stOp.ped at your req ,,it Vc may st^uj: paymer t on _ Aiba x CFeck by :lcL /ing us :1 :Ar t'i l; %;t P 0 'ox 65%10. Sicu:t IIaxota 57117 or by calling is zt :he to%ptlone number fisted on the Milne va''Rrrer.t. if you call, .voe riitlSt rhntirn the call in yYriurig within 14 days. A written stop payrnznt order will reln'111.ri #-ct `or six r;lonths unless r-.newec in r Ling. Once a :?harae is glade through the use of 'he card or account number awe c-innci "stop , yrnent" or. the rharr,W. if there is a dispute involving a charge on r :CCU+:nt. Pica!", roar `.C The "dC60A entitled 'Vat 10 Dc If 'nLre's Art F1'i' Lost or Stolen Cards, Account Numbers or Citibank Checks: 11 any rd account number or Citibank checx is lost or stolen of if you rink r t _ r? ne.:r +, 'r= ad ,: ?Il use t fern mthout your perm'sslt,n, ratify us ,t once by r c"Iliing ra tefephcre number shown on rh hi'ing statetnen: or he number 9t- n-.. ,allicl t^11 frae O; focal olrectory .Iz:slstancP. `#1 may require yoll to c? rte „_ 0141 i^ I ria;irr, in writing to indp us tin" out what happened. Don't use t re rant or rye Citibank checks attar we've bean notified. even if -,.hey are found or 'eturllad. You m3'y Ce liable, for uxauthcriied use of the card, but an, I for mole Ycnl wo t be'iatle far urrauthori'nd purchases or casn advances made than S50 . aster we've baen nottGd of the lass ar the theft: however, you must identify for es the charges on the billing statement that uere not made sy you, or sGI Leone authorized by you. and from which you rsceiyed rG benetit_ Defau it: i You default under this t~+jreemeni if you fail to ply itte minimum payment r' listed on eacli vilhrrt slaternent xhen rue, fail to make a payment to any Other un:ditar when due, file for bankruptcy, exceed your credit line Hithout Permission. pay by a ;check or similar instrument that is not',onored or lhat . we must return because it cannot be processed, pay by automatic debit that is retur.-A unpaid, or default art any other Citibank Card Agreement. If you Cai?Lir, ve may ,lose you(, account and dem anc imrediate payrnert of i tf e, 'uli bial::nc3. 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C ma c c9 C { .„ ca O t7 e ^ C :v .O ?• ??' _? ` „? ro C?`D ro CD iA LD ?_ '+ :) d 'J r!f ry _ C1s 7 D V, C O y td". G n - Z Co z ca C < 'C ` C =' O < a D o c, `6 U to zi T Cm 7 O fA N :C O v' r . ? t+ a C<A -1 T .-...`` C -3 .D ? 0 'T' :dD G ? -• O ' + cU ? y _ n N ?• 3 ro .r <i cY w •' ^ C " O. :?, O D ( 7 '< , om :.? . fi F' t Gv ¢ -' J ` t i .. _? 4h c T CU Q.C 00 CD O C n ?•? ---'? m J d n yn? co 0 5_' 5 -?:?= = , ow=co?K n cp a5 ? C = a ?. cl 'o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. : CIVIL-LAW GLEN A. HOFFMAN, DOCKET NO. Defendant AFFIDAVIT OF NON-MILITARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, and has not been in such service within thirty days hereof. Dated this T day of I41&rb? , 2012 Raym nd W. Kessler, Esquire Attorney For Plaintiff Attorney ID 309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 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 Mar-02-2012 06:24:14 < La 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 HOFFMAN GLEN A 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). 0117 1,4.11 0014 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://www.defenselink.mil/fag/vis/PC09SLDR.httnl. 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. 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:FM20VVIAVD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. CIVIL-LAW GLEN A. HOFFMAN, DOCKET NO. Defendant CERTIFICATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff: Unifund Corporation 10625 Techwoods Circle Cincinnati, OH 45242 Defendant: Glen A. Hoffman 18 West Springfield Road Boiling Springs, PA 17007 Respectfully submitted, Raymond '0_. Kessler, Esquire Attorney for Plaintiff PA ID #309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 4 low IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff CIVIL-LAW VS c `' ?.a --' C"i . M Fri L-4 r_ DOCKET NO. GLEN A. HOFFMAN , Defendant ti U t u? Q r ' zC o ? >C: E3 C3 ENTRY OF APPEARANCE ' Kindly enter my appearance on behalf of Unifund Corporation, Plaintiff, in the above captioned matter. Respectfully Submitted, -G RAYM ND W. KESSLER, ESQUIRE Attorney No. 309802 36 W Main St Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson _ Sheriff LQ`???1At, of ?itt;ibr?r.?j? , ???? ?•??1 f ? _ ? .. , Jody S Smith Chief Deputy WR 30 AM ! ! .' Richard W Stewart Solicitor Ni S Y I!y' A,!1 t` .'`. Unifund Corporation Case Number vs. 2012-1712 Glen A. Hoffman SHERIFF'S RETURN OF SERVICE 03/27/2012 08:08 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 27, 2012 at 2008 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Glen A. Hoffman, by making known unto Damian McKenzi, Step Son of Defendant at 18 W. Springville Road, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. RO E BITNER, DEPU SHERIFF COST: $34.00 March 28, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. CIVIL-LAW GLEN A. HOFFMAN, DOCKET NO. 2012-1712-CIVIL Defendant NOTICE OF ENTRY OF JUDGMENT ( ) Notice is hereby given that a in the above-captioned matter has been entered against you in the amount of $3,316.17 on ?0 , 20 I ( ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. • Prothonotary Civil Div. By: If you have any questions regarding this Notice, please contact the filing party: NAME: Remit Corporation ADDRESS: 36 West Main Street Bloomsburg, PA 17815 TELEPHONE NO: 570-387-1873 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: NAME: Glen A. Hoffman 18 West Springfield Road Boiling Springs, PA 17007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION - ?? Plaintiff ; VS. CIVIL-LAW C GLEN A. HOFFMAN, DOCKET NO. 2012-1712-CIVIL Defendant PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES FAILURE TO FILE ANSWER TO THE PROTHONOTARY: Kindly enter judgment against Defendant in the above captioned matter as follows: Real debt $ 3,146.44 Court Costs $ 137.75 Default Judgment $ 16.50 Interest from Mar. 19, 2012 $ 15.73 Total: $ 3,316.17 Kindly assess damages against Defendant in the sum of $3,316.17 plus continuing interest at the statutory rate of 6%. BY: Angela L. Mattis, Esquire Attorney for Plaintiff OuW4 $ I U. sopd CV- (+ 171 Sully op-? ath, Neu W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. GLEN A. HOFFMAN, Defendant : CIVIL-LAW DOCKET NO. 2012-1712-CIVIL TO: Glen A. Hoffman 18 West Springfield Road Boiling Springs, PA 17007 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. X Judgment by Default Money Judgment Judgment in Replevin Judgment of Possession Judgment on Award on Arbitration Judgment on Verdict Judgment on Court findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: ANGELA L. MATTIS, ESQUIRE AT THIS TELEPHONE NUMBER: 570-387-1873 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. GLEN A. HOFFMAN, Defendant CIVIL-LAW DOCKET NO. 2012-1712-CIVIL CERTIFICATION OF TEN (10) DAY NOTICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: I, ANGELA L. MATTIS, ESQUIRE, hereby swear and certify that a copy of the Ten (10) Day Notice was served on Defendant by regular mail on April 23, 2012. BY: Angela L. Mattis, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. GLEN A. HOFFMAN, Defendant CIVIL-LAW DOCKET NO. 2012-1712-CIVIL TO: Glen A. Hoffman DATE OF NOTICE: April 23, 2012 18 W. Springville Road Boiling Springs, PA 17007 IMPORTANT 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. Pennsylvania Lawyer Referral Service Cumberland County Bar Association 100 South Street, PO Box 186 2 Liberty Avenue Harrisburg, PA 17108 Carlisle, PA 17013 800-692-7375 717-249-3166 717- -6807 RE I N Angela L. Mattis, Esquire 570-387-1873 Mailed to: Glen A. Hoffman 18 W. Springville Road Boiling Springs, PA 17007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. : CIVIL-LAW GLEN A. HOFFMAN, DOCKET NO. 2012-1712-CIVIL Defendant AFFIDAVIT OF NON-MILITARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, not has been in such service within thirty days hereof. //?? +? Datkd &011 day of 2012 Angela L. Mattis, Esquire Attorney ID 309229 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 Department of Defense Manpower Data Center Status Roport Pursuant to Sez-vicemembers Civil Relief Act Last Name: hoffman First Name: glen Active Duty Status Date May-07-2012 Results as of : May-07-2012 12:11:42 SCRA 2.1 Active Duty End Date Status Service Component On Active Duty On Active Duty Status Date NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HWHer Unit Was Nottfled of a Future Calf-Up to Active Duty on Active Duty Status Date NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provtaea, me aoove is me ttdtuZI Ur the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. xit r4. ,L..a;?.- Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) 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 Servicemembers 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 only 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 was on active duty for the active duty status date, 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://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date 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., a SSN, First Name), you can submit your request again at this Web site and we will provide a new certificate for that query This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (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). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: S69055D81 G IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff VS. CIVIL-LAW GLEN A. HOFFMAN, DOCKET NO. 2012-1712-CIVIL Defendant CERTIFICATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff: Unifund Corporation 10625 Techwoods Circle Cincinnati, OH 45242 Defendant: Glen A. Hoffinan 18 West Springfield Road Boiling Springs, PA 17007 Respectfully submitted, Angela L. Mattis, Esquire Attorney for Plaintiff PA ID #309229 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Telephone: (570) 387-1873 Fax: (570) 387-6474 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 2012-1712 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CORPORATION Plaintiff (s) From GLEN A. HOFFMAN, 18 WEST SPRINGVIEW ROAD, BOILING SPRINGS, PA 17007 (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: WELLS FARGO BANK, 604 EAST HIGH STREET, 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$3,316.17 Interest FROM 5/10/12 - $43.61 Atty's Comm °% Arty Paid $185.75 Plaintiff Paid Date: AUGUST 3, 2012 (Seal) L.L. $$.50 Due Prothy $2.25 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : RAYMOND W. KESSLER, ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorney for: PLAINTIFF Telephone: 570-387-1873 Supreme Court ID No. 309802 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - iLE OFFICE COMMONWEALTH OF PENNSYLVANIA -HE PIt TNONOTAR 1 UNIFUND CORPORATION, 2012 AUG - PM Z: 37 Plaintiff UMBERL ND COUNTY PENNSYLVANIA vs. VA CIVIL-LAW Sxv • uiP,c? GLEN A. HOFFMAN, ?g Wof Il,,?.? r? t : DOCKET NO. 2012-1712-CIVIL 11 : Defendant -L-) vs. WELLS FARGO BANK, IP04 hS .q I Cor1?s1 t 1 Garnishee PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of Cumberland County, Pennsylvania (2) against Glen A. Hoffinan, defendant; and (3) Against Wells Fargo Bank, Garnishee; (4) and index this Writ in the judgment index and (a) against Glen A. Hoffinan, defendant(s), and (b) against Wells Fargo Bank, as garnishee, as a lis pendens against real property of the defendant in name of garnishee(s) as follows: N/A , (5) Amount Due: Interest from 05/10/2012 Credits Costs to be added: Clerks Fee: Sheriff: © Total: ff?? ? aG . oo ? a ?'1 Oull- tc u I ?.taz S p u ? $ 3,316.17 $ 43.61 $ 0.00 Dated this a;t, day ofAt? 04 , 2012 Raymond W. Kessler, PA ID #309802 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Phone: (570) 387-1873 Fax: (570) 387-6474 12- 9 0 k499 I ?_? t6 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~41~~~ta ut ~~~+nbe~j~~6 ~~ ~' , ~' .. '., ~.. 1FitV ~~~~ ~. .,. , ~:~~ ~~G ~ ~ ~ ~S~ 2 PE`Nt~5YL1f,~~!/ Unifund Corporation Case Number vs. Glen A. Hoffman 2012-1712 SHERIFF'S RETURN OF SERVICE 08/08/2012 10:57 AM -John Hanner, Deputy Sheriff, who being duly sworn according to law, states that on Augusl 2012 at 1057 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and mon of the within named defendant, to wit: Glen A. Hoffman, in the hands, possession, or control of the with named garnishee, Wells Fargo Bank, 604 E High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Lindsay Johnson, Lead Teller, personally three copies of interrogatories together 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 08-13-12 to Glen A. Hoffman at 18 W Springville Road, Boiling Springs, PA 17007. August 13, 2012 SO ANSWERS, • ~"`~„ RON R ANDERSON, SHERIFF ~o~r - J n Hanner, Deputy 8, with rc) CauntySGnte Sheng, 1"e;eosoft, Ino SIRLIN LESSER & BENSON, 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 IJIVIFUND CORPORATION :COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. 4") r~. GLEN A. HOFFMAN C : N0.2012-1712-CIVIL 'C7~ :v" '~` and ~ ~ a ~ r~ WELLS FARGO BANK N.A., rz GARNISHEE ° ~~ 3 ENTRY OF APPEARANCE ~. ~ ; , , ~~,,. °-i t+S TO THE PROTHONOTARY: ~'~ `"' Kindly enter my appearance on behalf Wells Fargo Bank, N.A., Garnishee in above-captioned matter. Date: ~~~ ~~ r ~::r -r ~. rte; .. _;~,-- SIRLIN LESSER & BENSON, 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 UNIFUND CORPORATION M. 1? k'ED-OFF ROHOnOTA n12 AUG 23 PH 2: 23 ('tl"iaERLAND COUNrY, PENNSYLVANIA COURT OF COMMON PLEAS COUNTY OF CUMBERLAND VS. GLEN A. HOFFMAN : NO. 2012-1712-CIVIL and WELLS FARGO BANK N.A., GARNISHEE ANSWERS TO INTERROGATORIES IN ATTACHMENT TO: UNIFUND CORPORATION, Plaintiff 1. No. 2. At the time of service of the Writ, Defendant maintained the following accounts and balances: Account titled in the name of Glen A. Hoffman, Juliana R. Hoffman (23 10) with a balance of $107.04, and an account titled Glen A. Hoffman, Juliana R. Hoffman (9689) with a balance of $4.01. The total sum of $111.05 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 $11.05. 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. Garnishee is unable to determine from its records whether Glen A. Hoffinan, Juliana R. Hoffinan (2310), and an account titled Glen A. Hoffman, Juliana R. Hoffman (9689) are entireties accounts or joint accounts. Garnishee incorporates herein by reference its New Matter as set forth below. 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? (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 Glen A. Hoffman, Juliana R. Hoffinan (2310) 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. Section 8123. NEW MATTER YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED NEW MATTER WITHIN' TWENTY (20) DAYS OF SERVICE THEREOF OR A DEFAULT JUDGMENT MAYBE ENTERED AGAINST YOU. 9. Garnishee incorporates by reference its Answers to Interrogatories one through eight above as though fully set forth herein. 10. As set forth above, the account titled Glen A. Hoffman, Juliana R. Hoffman (2310), and an account titled Glen A. Hoffman, Juliana R. Hoffman (9689) are titled to either tenants by the entireties or to joint tenants and as such may be exempt or immune from attachment. Garnishee is unable to determine from its records as to the appropriate designation of the accounts. If the parties to the instrument are husband and wife, then such assets are entireties assets and are not subject to execution pursuant to a judgment against either parry, but only pursuant to a judgment against both parties. If the assets are titled to joint tenants, the assets cannot be executed upon without competent proof by Plaintiff that the attached assets belong to the judgment debtor and without an appropriate Order of Court directing the Garnishee to permit execution against such assets by Plaintiff in whole or in art. Garnishee will stay further action pending a hearing and determination by the approp ' to Court. JON IN Atto ey Garnishee Date:- Legal Order Processing P. O. Box 76®® 11th 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 and 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. Li?sa?th e Manager gated: g'11'1 r ) SIRLIN LESSER & BENSON, P.C. By: Jon C. Siren, Esquire, I.D. No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (21~ 864-9700 Attorney for Garnishee UNIFUND CORPORATION :COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. ~ ~ ~ '~' N GLEN A. HOFFMAN : N0.2012-1712-CIVIL y ~ and ~ z ~. ~o WELLS FARGO BANK N.A., GARNISHEE :ATTORNEY I.D.#17498 ~~ s ~~ w BILL OF COSTS OF GARNISHEE, WELLS FARGO BANK,. N.A. ~ w Garnishee, We11s Fargo Bank, N.A., hereby bills the following costs to the fund attach 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: Costs are hereby taxed in the amount of $ 11.05 0.00 0.00 0.00 0.00 201 BY: SHERIFF'S OFFICE OF CUMBERLAND COUNJY ,nny R Anderson FILE-OFFICE { aneriff v ua cr ` PROTHONOT y Jody S Smith .r"�,2013 MAR IS AN Chief Deputy ; Richard W Stewart ` P CUMBERLAND COUNTY I Solicitor OTF46 OF T%r;SKRIFF PENNSYLVANIA Unifund Corporation vs. Case Number Glen A. Hoffman 2012-1712 SHERIFF'S RETURN OF SERVICE 08/0812012 10:57 AM-John Hanner, Deputy Sheriff,who being duly sworn according to law, states that on August 8, 2012 at 1057 hours,attached as herein commanded all goods,chattels, rights,debts, credits,and monies of the within named defendant,to wit. Glen A. Hoffman,in thq hands,possession, or control of the within named garnishee, Wells Fargo Bank,604 E High Street, CaV Isle, Cumberland County, Pennsylvania 17013, by handing to Lindsay Johnson, Lead Teller,personalfy 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 08-13-12 to&n A. Hoffman at 18 W Springville Road, Boiling Springs, PA 17007. 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. f SHERIFF COST: $88.40 SO ANSWERS, March 14, 2013 RONNY R ANDERSON, SHERIFF tc)CountySuite Sheriff,Teleosofl Inc, ij