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HomeMy WebLinkAbout12-21582122816 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED.,.- GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE a Identification No.. 41200 r 1001 E. Hector Street, Ste 220 3-_ Conshohocken, PA 19428 484/351-0500 Unifund Corporation 10625 Techwoods Circle, Cincinnat-_ OH 45242 vs. LORI A TAYLOR 121 COVENTRY DR CARLISLE PA 17015 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : /,:2- p2(58 NOTICE `i i v i l TE?I"A1 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 JUDGEMENT 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 O (717) 249-3166 S + 103.'75 PO Airy 6'1(0589 et a -723 qq? COMPLAINT IN CIVIL-ACTION 1. Plaintiff, Unifund Corporation , is a debt buyer and successor in interest to the original creditor, CITIBANK SOUTH DAKOTA NA. 2. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the original creditor under the terms of which the original creditor agreed to extend to defendant(s)the use of original creditor's credit facilities. 3. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the original creditor for the use of said credit card. 4. The defendant (s) received and accepted goods and merchandise and/or accepted services or cash advances through the use of the credit card issued by the original creditor. A true and correct copy of the Statement of Account or Affidavit of Account, if available, is attached hereto as Exhibit "A". 5. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of March 7, 2012 in the amount of $3,791.90. 6. :Plaintiff has made demand upon the defendant(s)for payment of the balance due but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 7. Defendant's last payment on account was made on 5/20/2009. WHEREFORE, plaintiff claims of the defendant (s) the sum of $3,791.90 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC . W NBERG, ESQUIRE JOEL M. F , ESQUIRE Attorney for Plaintiff P01P.DB 2122816 U3997063 Unifund Corporation LORI A TAYLOR 5256502401462,361 VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements. NAME: EXHIBIT "A" LORI A TAYLOR 5256502401462861 2122816 Unifund Corporation AFFIDAVIT I ? being duly served sworn according to law, depose and say that: 1. I am an affiant for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I have personal knowledge of the facts and circumstances in connection with this case and base this affidavit on Plaintiff's records, as well as the account information provided to Plaintiff Unifund Corporation upon the purchase of debtor's account, which was issued by CITIBANK SOUTH DAKOTA NA. 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are scught as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $3,355.01 plus interest of $422.56 at the rate of 60 less credits in the amount of $.00 totaling $3,777.57 as of February 10, 2012. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. AFFIANT NAME: Sworn to and Subscribed before me th_s V- day of 2012 Notixi e; ' `f S >T3As L tt N ,. )F 0HIC A, June 18; 2012 C. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 0), 0 Jody S Smith Chief Deputy All I I F Richard W Stewart 11 t, w i,_{ Solicitor ' rt x 'Y t A w ` Unifund Corporation Case Number vs. Lori A. Taylor 2012-2158 SHERIFF'S RETURN OF SERVICE 04/11/2012 09:00 AM - Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on April 11, 2012 at 0900 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lori A. Taylor, by making known unto herself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. Deputies were advised, Lori A. Taylor's current address is 658 N. Hanover Street, Carlisle, Pennsylvani 17013. ' r r BRIAN BARRICK, DEPUTY SHERIFF COST: $34.00 April 12, 2012 SO ANSWERS, RON y R ANDERSON, SHERIFF 2122816 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.. 41360 25 Z JOEL M. FLINK, ESQUIRE Identification No.: 81894)--`M?3E'AND n OUI"T i 1001 E. Hector Street, Ste 220 FERNISYLV N'A Conshohocken, PA 19428 484/351.-0500 Unifund Corporation VS. LORI A TAYLOR TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-2158 CIVIL TERM Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $3,791.90 Less: Payments on Account ( $.00) Total: $3,791.90 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: Unifund Corporation and that the last known address of defendant, LORI A TAYLOR, 658 N. HANOVER STREET, CARLISLE PA 17013. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. o} ?I?•Jv Q CY_. ?IAW I? Ie u l ?- a-7 s? ? a .AND ,NOW, this ?s day of _, 2012 Judgment is entered in favor of the plaintiff( and against defendant s) by default for want. of an answer and dama s aTXsTt the f , $3,967.16 as per the above certificate Prothonotary GORDON & WEINBERG, P.C. BY: FREDERIC WE BERG, ESQUIRE JOEL M. F I , ESQUIRE Attorney for Plaintiff 2122816 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Unifund Corporation VS. LORI A TAYLOR 658 N. HANOVER STREET CARLISLE PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-2158 CIVIL TERM NOTICE Pursuant to Pa.R.Civ.P. 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. /XL Judgment by Default $3,355.01 Money Judgment $ Judgment on Award of Arbitrators$ Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CAL ATTORNEYS: FREDERIC I. WEINBERG OR J )L M. FLINK SQUIRES THIS TELEPHONE NUMBER: 484/351-0500 SID- S) tt? PROTHO Y GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2122816 Unifund Corporation LORI A TAYLOR TO/PARA VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-2158 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT LORI A TAYLOR 658 N. HANOVER STREET CARLISLE PA 17013 DATE OF NOTICE/FECHA DEL AVISO: May 2, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN 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 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: kl /^ ? FREDERIC f. W INBERG, ESQUIRE JOEL M. FUNK, ESQUIRE PLOD-2 J 2122816 GORDON & WEINBE;RG, P . C . BY: FREDERIC I. WEINBERG, ESQUIRE Identif,~cation No.: 41360 JOEL M. FhINK, ESQUIRE Ider.tif-cation No.: 41200 1001 E. Hector Street, Ste 220 Consnohccken, PA 19428 484/351-0500 ;, ,+ v L ~. ' ~ ~~ `,~i L5 }'t A ~. Unifund Corporation v:~ . LORI A 'IAYLOF; and Membf~rs 1st FCU Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 12-2158 CIVIL TERM PRAECIPE TO DISSOLVE ATTACFIMENT TO THE PROTHONOTARY: Kin~:ily dissolve the attachment of the defendant's b,:~nk account with Members 1st FCU, as Garnishee in the above entitled ,<<atter. GORDON & WEINE3ERG, P . C . /~ BY : v ~~ _ FREDERICK EINBERG, ESQUIRE JOEL M. ~'.hTNK, ESQUIRE Attorney for Plair:tiff POll ~~~~.~~ ~' ~~~ ~2g ~. SHERIFF'S OFFICE OF CUMBERLAND COUNTY ny R Anderson " heriff �,r4r f a araEatar %y t , Jody S Smith Chief Deputy y _ Richard W Stewart Solicitor �,i., a 1 Unifund Corporation I Case Number vs. Lori A.Taylor 2012-2158 i i SHERIFF'S RETURN OF SERVICE 10109/2012 11:08 AM-William Cline, Deputy Sheriff,who being duly sworn according to law, states that on October 9, 2012 at 1108 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant,to wit: Lori A. Taylor, in the hands, possession, or control of the within named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania, by handing to Merlinda Wilkins, 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 October 10, 2012 to Lori A.Taylor at 658 N Hanover Street, Carlisle, PA 17013. 06104/2013 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: $88.40 SO ANSWERS, June 04, 2013 R-ONW R ANDERSON, SHERIFF i3 y idi c She,-t"itlie-`)So The Lanni Offices of Frederic I. Weinberg & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2122816 Unifund Corporation - 10625 Techwoods Circle - Cincinnati OH 45242 vs. —LORI A TAYLOR 658 N. HANOVER STREET CARLISLE PA 17013 and Members 1st FCU — 401 East King St Shippensburg, PA 17257 GARNISHEE(S) TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-2158 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against LORI A TAYLOR (2) against Members 1st FCU defendant(s)and garnishee(s) (3) Amount Due Interest from May 25, 2012 Costs Prothonotary fee Sheriff fee (4) Less: Payments on Account TOTAL Baa .3° °' 01/40 41,9c033 ori c F 06(1 L a s (' 1C.4 IQFNU SI o, cS i �i 2*310),140?3 $3,791.90 $549.30 $240.00 FREDERIC I. WEIN;E.', ESQUIRE .ps'b JOEL M. FLINK, ESQUIRE C'v.Attorney for Plaintiff wc,4- d THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net UNIFUND CORPORATION Vs. NO 12-2158 Civil Term CIVIL ACTION — LAW LORI A. TAYLOR WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against LORI A. TAYLOR, 658 N. HANOVER STREET, CARLISLE, PA 17013 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of MEMBERS 1sT FCU GARNISHEE(S), as garnishee, 401 EAST KING STREET, SHIPPENSBURG, PA 17257 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $3,791.90 Interest FROM MAY 25, 2012 - $549.30 Attorney's Comm. Attorney Paid $310.15 Date: 10/24/14 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs 1,02.66 David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : FREDERIC I. WEINBERG, ESQUIRE Address: LAW OFFICES OF FREDERIC I. WEINBERG 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY oS 1 KE PRO T HDNO lAR'i OH [CZ 9F THS Ri�F IFF 20611 NOV -3 PM 3: 56 CUMBERLAND COUNTY PENNSYLVANIA Unifund Corporation vs. Lori A. Taylor Case Number 2012-2158 SHERIFF'S RETURN OF SERVICE 10/29/2014 04:21 PM - Jason Kinsler, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Paula T Breitenbach, Member Service Represesntive, 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 October 31, 2014 to Lori A. Taylor at 658 N Hanover Street, Carlisle, PA 17013. J ON KINSLER, DEPUTY SO ANSWERS, October 31, 2014 RNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Te!eosoft, Inc. The Law Offices of Frederic I. Weinberg & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 RECEIVED OCT 31 2014 Unifund Corporation 10625 Techwoods Circle Cincinnati OH 45242 vs. LORI A TAYLOR 658 N. HANOVER STREET CARLISLE PA 17013 and Members 1st FCU 401 East King St Shippensburg, PA 17257 GARNISHEE(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-2158 CIVIL TERM INTERROGATORIES IN ATTACHMENT TO: Members 1st FCU - GARNISHEE MC N N C) You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so my result in judgment against you. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? u`,..c) 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. d 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest. No 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had an interest? ‘)p 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefore? DATED: 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to his(her, their) direction or otherwise discharge any claim of the defendant(s) against you? 06 7. 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 funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on ` a recurring basis. ��'z��_��\�\�"��»~v~»�u�C) {�-�� �����r���+�^ �)��p�`.f� ,-~—` --~' 8 If you are a bank or other financial instituCioo, at the time you were served or any subsequent time did the defendant(s) 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.3. §8123? If so, identify each account. 9. How much is the value of any property in your possession belonging to the defendant(s)? FREDERIC BERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff The Law Offices of Frederic I. Weinberg & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 375 E. Elm Street, Suite 210 Conshohocken, PA 19428 484/351-0500 2122816 Unifund Corporation vs. LORI A TAYLOR and Members 1st FCU GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY cz ri .agt. DOCKET NO. : 12-2158 CIVIL TERM BILL OF COSTS Plaintiff herewith bills the following costs to the funds attached, as authorized by Title 42 Pa.C.S.A. § 1726: Complaint $103.75 Service $100.00 Judgment $16.50 Praecipe for Writ of Execution (2) $58.00 Service of Writ of Execution (2) $300.00 Sheriff's Poundage $75.83 Accrued interest $574.67 Costs Returned from Sheriff -($127.60) Total $1,101.15 FREDERIC BERG, ESQUIRE JOEL M. 1 IN ESQUIRE Attorney or Plaintiff Costs are hereby taxed in the amount of $ Day of , 2014. PROTHONOTARY this The Law Offices of Frederic I. Weinberg & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 375 E. Elm Street, Suite 210 Conshohocken, PA 19428 484/351-0500 2_ 1 L: COLE..!Ty IA 2122816 Unifund Corporation 10625 Techwoods Circle Cincinnati OH 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. : 12-2158 CIVIL TERM LORI A TAYLOR and Members 1st FCU Garnishee PRAECIPE FOR JUDGMENT UPON ADMISSION TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff, Unifund Corporation and against the Garnishee, Members 1st FCU, in the amount of $4,407.10, admitted in the Answer to Interrogatories to be in the Garnishee's possession, together with interest and costs which is not more than the amount of the judgment of the Plaintiff against the Defendant together with post judgment costs and post judgment interest which is $4,438.81. Date: l`f The Law Offices of Frederic I. Weinberg & Associates, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Attorney for Plaintiff 111) JOEL M. FLINK, ESQUIRE 441 ^ ��� lY (ijc1c J(Jt J (2 31t4 3S2 4110 11/10/2014 Frederic L. Weinberg, Esquire 1001 E. Hector Street, STE 220 Conshohocken, Pa 19428 S MEMBERS 1" FEDERAL CREDIT UNION RE: Writ of Execution for Lori A Taylor: Dear Sir: 21215s1(# A search of our records has revealed one account bearing the name Lori A Taylor with an address of 121 Conventry Dr Carlisle, Pa 17015. The account reflects an available balance of $4654.00. Pursuant to the writ, all funds in the aforementioned accounts above and beyond the monetary exemption provided by 42 P.S. Section 8123 and Pa. Rule of Civil Procedure 3111.1(3) in the amount of $300.00 have been frozen. Except for the exempt funds in the amount of $300.00 which are statutorily not subject to attachment, the accounts have been restricted from any further withdrawal transactions. Should,you have any questions or need any additional information, feel free to contact neat (800) 283-2328, ext. 6022. Sincerely,- ?ianna Skibiel Deposit Operations Analyst 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • wwwmemberslst.org The Law Offices of Frederic I. Weinberg & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 RECEIVEL, NOV 0 7 2014 Unifund Corporation 10625 Techwoods Circle Cincinnati. OH 45242 vs. LORI A TAYLOR 658 N. HANOVER STREET CARLISLE PA 17013 and Members 1st FCU 401 East King St Shippensburg, PA 17257 GARNISHEE (S) COURT OF COMMON PLEAS CUMBERLAND COUNTY RECEIVED OCT 31 2014 DOCKET NO. : 12-2158 CIVIL TERM INTERROGATORIES IN ATTACHMENT TO: Members 1st FCU - GARNISHEE c-) rico =r11 cr)r- -<> r—= <a) 3>c-) Zc) zc —3 r\,) You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so my result in judgment against you. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? uyt.175 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. r4C) 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had an interest? 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefore? DATED: 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to his(her, their) direction or otherwise discharge any claim of the defendant(s) against you? 06 7. 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 funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on , a recurring basis. erN (S/Nc),NAA,-‘ 3 cl.e.v)5; ek 4 1-2;66.m, \-A.1 tv.u.." 4 cx)% 00 r." Sotic4 S44'44' 8. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant(s) 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. WAANNA" e1/44-AN't 9. How much is the value of any property in your possession belonging to the defendant(s)? FREDERIC NBERG, ESQUIRE JOEL M. FL NK, ESQUIRE Attorney for Plaintiff 2122816 The Law Offices of Frederic I. Weinberg & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 375 E. Elm Street, Suite 210 Conshohocken, PA 19428 484/351-0500 Unifund Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. : 12-2158 CIVIL TERM LORI A TAYLOR and Members 1st FCU Garnishee NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT UPON ADMISSIONS HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL FREDERIC I. WEINBERG, ESQUIRE AT 484/351-0500 The Law Offices of Frederic I Weinberg & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 375 E. Elm Street, Suite 210 Conshohocken, PA 19428 484/351-0500 2122816 Unifund Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. : 12-2158 CIVIL TERM LORI A TAYLOR and Members 1st FCU Garnishee ORDER TO SATISFY JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly mark the judgment entered against garnishee Members 1st FCU in the above -captioned matter satisfied upon payment of your costs only. The Law Offices of Frederic I. Weinberg & Associates, P.C. BY: P013 t Frederic I inberg, Esquire Joel M. F ink, Esquire Attorney for Plaintiff LOb CAt_ii06015_561 The Law Offices of Frederic I Weinberg & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 375 E. Elm Street, Suite 210 Conshohocken, PA 19428 484/351-0500 Unifund Corporation vs. LORI A TAYLOR COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-2158 CIVIL TERM ORDER TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the judgment entered May 25, 2012 in the above - captioned matter satisfied upon payment of your costs only. The Law Offices of rederic I. Weinberg & Associat BY: P005 Frederic I neinberg, Esquire Joel M. Flink, Esquire Attorney for Plaintiff