HomeMy WebLinkAbout12-2455FILED-Cq F-i E
WELTMAN. WEINBERG & REIS CO.. L.P. }'?E PRO jNONO TA
Attorney for Plaintiff(s) C?1Z APR
BY: William T. Molczan, Esquire 20 11-9 ??;
38
I.D. No.47437 !'U;48EftLH
436 Seventh Avenue, Suite 1400 FJENMSYLV COUNTY '
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 8966254
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ALLY FINANCIAL INC
F/K/A GMAC INC
Plaintiff
VS. Civil Action No. a'y 55 C?Vt
JUSTIN A HENNEGHAN
Defendant(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
pages, you must 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 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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
C' lG !/ /G y7y3/(P?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ALLY FINANCIAL INC
F/K/A GMAC IN C
Plaintiff
vs.
JUSTIN A HENNEGHAN
Defendant
No. 12-2455- CIVIL
PRAECIPE FOR DEFAULT JUDGMENT
cn r-- rv
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt, Esquire
PA I.D.#42524
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#8966254
Judgment Amount $ 11,213.57
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ALLY FINANCIAL INC
F/K/A GMAC IN C
Plaintiff
VS.
JUSTIN A HENNEGHAN
Defendant
Civil Action No. 12-2455- CIVIL
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter Judgment against the Defendant, JUSTIN A HENNEGHAN above named, in the default of an Answer,
in the amount of $11,213.57 computed as follows:
Amount claimed in Complaint $11,21.3.57
Interest from date of judgment
at the legal interest rate of 6.0% per annum
Attorneys' Fees $0.00
TOTAL $11,213.57
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.
Plaintiffs address is: m
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7 Avenue, Pittsburgh, PA 15219 Q* a77?a4
And that the last known address of the Defendant is: 134 WEST PENN STREET, CARLISLE, PA 17013
k)D,h k6i1ec -
By:
James C. W rodt, Esquire
PA I.D.#425
Weltman, nberg & Reis Co., L.P.A.
1400 Kop a Bldg.
436 Sev venue
Pittsbur A 15219
(412) 13471955
#8 66254
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ALLY FINANCIAL INC
F/K/A GMAC INC
Plaintiff
JUSTIN A HENNEGHAN
Defendant
CASE#: 12-2455 CIVIL
1MPORTANT NOTICE
TO:
Justin A Henneghan
134 W Penn St
Carlisle, Pa 17013
Date of Notice:
W WR#:8966254
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO
TO OR TELEPHONE THE FOLLOWING 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, WEINB.ERG & REIS CO., L.P.A.
By:
Matthew D. Urban, Esquire
P.A.I.D.# 90963
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
WWR #8966254
IN THE COMMON PLEAS COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ALLY FINANCIAL INC
F/K/A GMAC INC
Plaintiff
VS.
JUSTIN A HENNEGHAN
Defendant
Civil Action No. 12-2455 CIVIL
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 Defendant,
JUSTIN A HENNEGHAN is not in the 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:
JUSTIN A HENNEGHAN
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. §4904 relating to unsworn falsification to authorities.
Department of Defense Manpower Data Center
40 Sawls Report
P'u t to Service memben Civil Relief Act
Last Name: HENNEGHAN First Name: JUSTIN A
Active Duty Status As Of: Jun-14-2012
Results as of : Jun-142012 11:33:34
SCRA 2.2.1
Active Duty SW Deb Active Duty End Dste Status .Service Component
On Adfw• Duly On AcIMa Duly StMw Data
NA NA No NA
This response reflects the Individuals' active duty status based on the Active Duty status Date
Left Active Duty Within 367 Deys of Ace" Duty Sigan Deis
Actor Duty stsrt Dar Active Duty End Date status service component
NA NA No NA
This response rellects where the Individual left active duty abuts within 367 days preceding the Active Duty Status Date
The Member or HWHer Unit Was No#W of a Future Call,-Up to Active Duty on Active Duty Status Date
Order Notification Start Dab Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the individual or hWher unit has received early notlflcation to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, 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.
Yhm?, A 40?m_
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 at 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.miVfaq/pis/PCOgSLDR.html. 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).
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: KCVKR571K2
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ALLY FINANCIAL INC
F/K/A GMAC IN C
Plaintiff
VS. Civil Action No. 12-2455- CIVIL
JUSTIN A HENNEGHAN
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Ju ,gment was entered against you
on to
(xx) Assumpsit Judgment in the amount
of $11,213.57 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
Award
Prothonotary
By:
PROTHONOTARY (OR DEPU Y)
JUSTIN A HENNEGHAN
134 WEST PENN STREET
CARLISLE, PA 17013
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219
1-888-434-0085
COMPLAINT
Plaintiff is a corporation having offices in 2911 Lake Vista Dr, Lewisville, TX 75067.
2. Defendant is an adult individual residing at 134 W. Penn Street, Carlisle, PA 17013.
3. On or about August 22, 2006, Defendant duly executed a Retail Installment Contract
(hereinafter the "Contract") in favor of Sutliff Chevrolet Co., a true and correct copy of said Contract is
attached hereto, marked as Exhibit "1" and made a part hereof.
4. Pursuant to said Contract, Defendant took possession of the vehicle more particularly
identified in the Contract as a New 2006 Chevrolet Malibu.
5. Pursuant to the terms and conditions provided by the Contract, the Contract was assigned
from Sutliff Chevrolet Co. to Plaintiff.
6. Plaintiff avers that Defendant is in default of the Contract by having not made payment to
Plaintiff as promised, thereby rendering the entire balance immediately due and payable.
7. Plaintiff avers that a balance of $11,213.57 is due from Defendant as of February 23, 2012.
8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or
refused to pay the principal balance, or any part thereof to Plaintiff.
WHEREFORE, Plaintiff demands judgment against Defendant, Justin A. Henneghan, individually,
in the amount of $11,213.57 with continuing interest thereon at the statutory rate of 6.00% per annum
from the date of judgment, and costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
SHALL BE USED FOR THAT PURPOSE.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
William T. Mol zan, Esq ' e
I.D. No.47437
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 8966254
RETAIL INSTALMENT sALE CONTRACT
GMAC FLEXIBLE FINANCE PLAN ^A/A r
Dever Mwetar Canraw Nunaar (326.9/0A C
Wyar 0W Cpsuyw)-PYrs end NOW (almadw daaey and ap code)
1STIN A HEIME6HAN
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IG ET CO. Ism
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IRLISL N PA 17013 NARRISNURB, PA 17105
m reaAw did ft4U ' Many), may buy aw wNoda dM= =Wove sob am cued! a , M w*= rove b bur M wNab m ce
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EXHIBIT
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see book for other Imperlwm.grwrdy,
FEDERAL TPRnM4WLBXM160RCA)SWEt tumsaklaw, Yau coq bq ft I I , drtlpa
ANNUAL FNWICE Am" ToW d Pay a Tort caw Prlee m arvice on der6la. Mwe (an book) from
P1010MAOE
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RATE
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t a pert wNh tlW SeNar The Soft mtq eeE?ta EYS?/6? e1pRt
to waive of 6* FkMace-charvo.
Ilotites to 0W.
Do not sign con n blink. You am entitled to an exactimpy of the contract you sign. Keep
N to If a?rw D&22/2006 C,d,ye,a,RwN Cote
You ag?N the serfs of this contract. You confirm that bd m
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IFF CHEVROLET AGENT
Two saw Tow
ZION FR-PA 3FM (f) (Fw w m tlw awe a FN,wykw ) (1 a a) Nobee: on Dew aerie
Copy VM 2004 Gw w l Moms Aecspleme Caryoessn M ttgnw FMa owl
fxeO1NAL
OTHER VI PORTANT AGREEMENTS
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- 1- NOR OOUTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHWH
THE DEEITOR COULD ASSERT AGAWST THE SELLER OF GOODS OR 01IMM OSTARM PURSUANT
HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED
AMOUNTS PAID BY THE DEBTOR HEREUNDER.
. • - ;•J ,. ?.. • • ??b,? Jul
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is
(NAME)
P,2aII() Cob,rl?f MU '5CA'l? 0A*'
Qlaintiff herein, that
(TITLE) (COMPANY)
he/she is duly authorized to make this verification, and that the facts set forth in the foregoing
Complaint are true and correct to the best of his/her knowledge, information and belief.
av4*
(SIGNATURE)
WWR No. 08882377
Settles, Albert
Acct No. 752194373
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
4,.??a„
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
F,'LED -OFFICE
,try THE PROTHONOTAR"I
2012 MAY -1 AM 8: 17
CUM&ERLAND COUNTY
PENNSYLVANIA
Ally Financial, Inc.
vs. Case Number
.
Justin Alan Henneghan 2012-2455
SHERIFF'S RETURN OF SERVICE
04/23/2012 07:50 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on April
23, 2012 at 1950 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Justin Alan Henneghan, by making known unto Brittney Henneghan, Sister of Defendani
at 134 W. Penn Street, 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.
SHERIFF COST: $34.00
April 26, 2012
ST HEN BENDER, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ALLY FINANCIAL INC
F/K/A GMAC INC
Plaintiff
vs.
JUSTIN A HENNEGHAN
Defendant(s)
CITIZENS BANK
SUSQUEHANNA BANK
PNC BANK,
Garnishee(s)
No, 12-2455 CIVIL
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James P. Valecko, Esquire
PA I.D. #79596
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Avenue, Suite 2500
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 8966254
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ALLY FINANCIAL INC
F/K/A GMAC INC
Plaintiff
vs.
Civil Action No. 12-2455 CIVIL
JUSTIN A HENNEGHAN, 134 W. Pem SF, Cr1iste PA 11013
Defendant(s)
CITIZENS BANK- 1005 N. East '3+, aar-lisie, PA 1'7013
SUSQUEHANNA BANK- IID VIA nu+ Berliem Rd , 0.-a-rhSle PA 1'7013
PNC BANK- 10.5 Noble. Blvd, earlisla PA 170(3
Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
C)
rn
ZZJ
c.r)
z
< C)
2> c)
—4
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against JUSTIN A HENNEGHAN , Defendant
3. against CITIZENS BANK, SUSQUEHANNA BANK, PNC BANK, Garnishee
4. Judgment Amount $11,213.57
Less Payments/credits received $0.00
Interest
Costs
SUBTOTAL: $11,213.57
Costs (to be added by Prothonotary):
$ $0.00
4 9,9.002 PE5 Pi -Tri
34.00 NSF
ib 3 • a5 "
llo • 5o N
IBa.r15 P° PcIT't
.Dteet,
50 LL
a ira
0 so 477
&Ic‘u-o-d
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James • .1, ecko, Esquire
PA I.D. #76.96
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Avenue, Suite 2500
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 8966254
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
ALLY FINANCIAL INC
f/k/a GMAC INC.
Vs.
JUSTIN A HENNEGHAN
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 12-2455 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND. COUNTY:
To satisfy the judgment, interest and costs against JUSTIN A. HENNEGHAN, 134 W. Penn St, 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
CITIZENS BANK, 665 N. East Street, Carlisle, PA 17013
SUSQUEHANNA BANK , 1196 Walnut Bottom Rd, Carlisle, PA
PNC BANK, 105 Noble Blvd, Carlisle, PA 17013
GARNISHEE(S), as garnishee, (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.
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
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 $11,213.57
Interest
Attorney's Comm. %
Attorney Paid $182.75
Date F• 0/20114
'•'•
•
• . •
REQUESTING FAIkf'Y
Plaintiff Paid
Law Library $.50
Due Prothonotary $2.25
Other'Costs
David D. Buell, Prothonotary
Name : JAMES P. VALECKO, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO, LPA
436 7TH AVENUE, SUITE 2500
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No.
MAJOR EXEMPTIONS UNDER PENNSYLVANIA
AND FEDERAL LAW
I. $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
I HE PROTNONO AF Y
2014 NOV -4 AH IO: 45
CUMBERLAND COUNTY
0. PENNSYLVANIA
ra
v ot
C QF THE $H,G,FIFF
Ally Financial, Inc.
vs.
Justin Alan Henneghan
Case Number
2012-2455
SHERIFF'S RETURN OF SERVICE
10/29/2014 09:01 AM - William Cline, 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, Citizen's Bank, 665 North East Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to Rebecca Winter, Banker, personally three copies of
interrogatories together with three true and attested copies of the Writ of Exec ion d made the contents
there of known to her.
LIAM CLINE, DEPUTY
SO ANSWERS,
October 31, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Toleosoft, Inc.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson !I*r "-Or 1Cy_
Sheriff C THE PRDTHCNO T x'
t ;
i
Jody S Smith` $ '!b
Chief Deputy ; T 2014 NOV —4 AN 10: 45
Richard W Stewart = CUMBERLAND COUNTY
Solicitor car,ricEOF",B"ER"T PENNSYLVANIA
Ally Financial, Inc.
vs.
Justin Alan Henneghan
Case Number
2012-2455
SHERIFF'S RETURN OF SERVICE
10/29/2014 12:22 PM - William Cline, 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013,
Cumberland County, by handing to Carla Crozier, Sales, personally three copies of interrogatories together
with three true and attested copies of the Writ of Execution and made the cprrt res there of known to her.
L AM CLINE, DEPUTY
SO ANSWERS,
October 31, 2014 RONNR ANDERSON, SHERIFF
is CountySuito Sheriff, Teleasoft, Inc.
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
0001, o; c."0,,, y "• ;- E' t O l HONG
OFFICE OF THE $kER!
2 1 L NOV --14 AM 1014
CUMf�tNNS LEVAN A T it
P
Ally Financial, Inc.
vs.
Justin Alan Henneghan
Case Number
2012-2455
SHERIFF'S RETURN OF SERVICE
10/29/2014 12:47 PM - William Cline, 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, Susquehanna Bank, 1196 Walnut Bottom Road, South Middleton
Township, Carlisle, PA 17013, Cumberland County, by handing to Sally Weller, Operations Supervisor,
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 Ju,: in A. Henneghan at
134 W Penn Street, Carlisle, PA 17013.
WILLIAM CLINE DEPUTY
SO ANSWERS,
October 31, 2014 RN ' R ANDERSON, SHERIFF
(c) CounlySuilo Sherif', Teieosoft, inc.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ALLY FINANCIAL INC
F/K/A GMAC INC
Plaintiff
vs.
JUSTIN A HENNEGHAN
Defendant(s)
CITIZENS BANK
SUSQUEHANNA BANK
PNC BANK
Garnishee(s)
Civil Action No. 12-2455 CIVIL
TO: CITIZENS BANK, 665 NORTH EAST ST, CARLISLE, PA 17013
SUSQUEHANNA BANK, 1196 WALNUT BOTTON RD, CARLISLE, PA 17013
PNC BANK105 NOBLE BLVDCARLISLE, PA 17013
RE: JUSTIN A HENNEGHAN , 134 W PENN ST, CARLISLE, PA 17013
Suggested Reference No.: XXX -XX -5922
XXX -XX -
IMPORTANT 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.
WWR No. 8966254
ANSWERS TO 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)?
No.
la. 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.
N/A
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.
No.
3. At the time you were served or at any subsequent time did you hold legal title to any
property of any nature owned solely or part by the defendant 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 had an interest?
No.
5. At any time before or after you were served, did the defendant transfer or delivery any
property to you or to any person or place pursuant to your directions or consent and if so
what was the consideration thereof?
No.
6. At any time after you were served did you pay, transfer, or deliver any money or property
to the defendant to any person or place pursuant to his direction or otherwise discharge
any claim of the defendant against you?
No.
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.
No.
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 Pa.C.S. § 8123? If so, identify each account.
No.
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
N/A
10. If the answer to Interrogatory 1 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/A
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?.
N/A
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt
funds on deposit in the account.
N/A
VERIFICATION
I, William H. Finlay, verify that the facts set forth in these Garnishee's Answers to
Interrogatories are true and correct to the best of my knowledge, information, and belief. This
statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. §
4904) related to unsworn falsification to authorities.
Dated: November 3, 2014
William H. Finlay,
Associate Counsel
Susquehanna Bank
26 North Cedar Street
Lititz, Pa 17543
(717) 625-6554
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
ALLY FINANCIAL, INC
Plaintiff(s),
vs.
JUSTIN A HENNEGHAN
Defendant(s),
and
Citizens Bank of Pennsylvania,
Garnishee.
CIVIL DIVISION
12-2455
ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK
The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of
the Plaintiff(s):
(NUMBERS 1 to 12) At the time of service of above -captioned Writ of Execution and to the
present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories:
The Garnishee, Citizens Bank of Pennsylvania, states that it maintains no record of any
deposit account in the name of the defendant, JUSTIN A HENNEGHAN, accordingly, no
funds are being held subject to this Writ of Execution.
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY)
Before me, the undersigned authority, a Notary Public in and for said
Commonwealth and County, personally appeared Heather Zito who being duly sworn
according to the law deposes and says that she is the Operations Clerk, Operations Services,
and that the statements set forth in foregoing Answers to Interrogatories are true and correct
to the best of her knowledge, information, and belief.
Sworn and subscribed before
me this
13 day of
/JO ,2014.
Heather Zito
COMMONWEALTH OF PENNSYLVANIA
Nancy Loy, Notary Public
MY Commission Explres Sept. 22, 2016
City of Pittsburgh, Allegheny County
Notanal Seal
MER, PEKISYLYANIWASSOCIATION OF NOTARIES
Certificate of Service
I, Heather Zito, hereby certify that a true and correct copy of the Answers to
Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage
prepaid, this 13 day of NOVEMBER, 2014.
JAMES P VALECKO, ESQ
WELTMAN, WEINBERG & REIS CO,
LPA
436 7TH AVE
PITTSBURGH, PA 15219
Heather Zito
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
ALLY FINANCIAL, INC,
Plaintiff(s),
VS.
JUSTIN A HENNEGHAN,
Defendant(s),
vs.
Citizens Bank of Pennsylvania,
Garnishee.
CIVIL DIVISION
12-2455
Answers to Interrogatories
Code: 200 Execution
Filed on Behalf of Garnishee,
Citizens Bank of Pennsylvania
Counsel of Record for
this Party:
Nicholas Deenis, Esquire
PA I.D. No. 62378
Stradley, Ronan, Stevens & Young
2005 Market Street, Suite 2600
Philadelphia PA 19103
(215) 564-8672
(215) 564-8120 fax
ndeenis@stradley.com
www.stradley.com
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: William T Molczan, Esquire
I.D. No. 47437
436 Seventh Avenue, Suite 2500
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 8966254
ALLY FINANCIAL, INC
F/K/A GMAC INC.
Attorney for Plaintiff(s)
Cumberland County
Court of Common Pleas
vs.
JUSTIN A HENNEGHAN
NO. 12-2455 CIVIL
and
CITIZENS BANK, SUSQUEHANNA BANK, PNC BANK
Garnishee(s)
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly mark the above matter discontinued and ended as to Garnishee(s), CITIZENS BANK,
SUSQUEHANNA BANK, PNC BANK, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
William T Molcz
Esquire
Attorney for Plaintiff
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wt P361403cr
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