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HomeMy WebLinkAbout12-2970 WELTMAN, WEINBERG & REIS CO., L.P.A. Attorney for Plaintiff(s) -"' BY: James C. Warmbrodt, Esquire - I.D. No.42524 436 Seventh Avenue, Suite 1400 - = Pittsburgh, PA 15219 Phone: 412.434.7955 ?._ Fax: 412.434.7959 File # 9467276 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIZENS BANK, OF PENNSYLVANIA Plaintiff vs. Civil Action No. /a - a97D 0;'" BROOKE R RHODES 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 U Ci) 103. PQ ATN G'# lasbyl7(? At a 751-06 COMPLAINT Plaintiff is a corporation with offices at 480 Jefferson Blvd, Warwick, R1 02886 2. Defendant is an adult individual residing at 623 Hilltop Dr, New Cumberland, PA 17070. On or about November 14, 2007, Defendant applied for and was granted a revolving line of credit, a true and correct copy of the Application for the Line of Credit and the terms and conditions of which were agreed upon by the parties, is attached hereto, marked as Exhibit "1", and made a part hereof. 4. Defendant made use of such credit and currently has a balance due and owing to Plaintiff, as of December 8, 2011, in the amount of $20,282.79. A true and correct copy of Plaintiffs account details is attached hereto, marked as Exhibit "2", and made a part hereof. Defendant defaulted under the terms of the parties' agreement by failing to make the required payments to Plaintiff when due. 6. By the terms of the parties' agreement, more specifically the "acceleration clause" therein, Defendant's default made the entire balance of the loan immediately due and payable to Plaintiff. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's reasonable attorneys' fees incurred in enforcing said Agreement. 8. Plaintiff avers that such attorneys' fees amount to $125.00. 9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges, or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Brooke R Rhodes, individually in the amount of $20,282.79 with continuing finance charges thereon at the statutory rate of 6.00% per annum from the date of Judgment, plus attorneys' fees of $125.00, and costs THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELI'MAN. WEINBERC & RNIS. C'O., L.P.A. James C. armbrodt. Esquire I.D. No.4 24 436 Seve t Avenue, Suite 1400 Pittsbur PA 15219 Phone: .434.7955 Fax: 41 A' )4.7959 File # 467276 note SECONDARY MORTGAGE LOAN Borrower(s) HOME EQUITY LINE OF CREDIT AGRF.FMENT aROOK$ R RHODES i xn kr: Citizens Bank of Pennsylvania 735 Market Street Philadelphia, PA 19103 Date of Agrccuicrx: 11/14/2007_ This HOME EQUITY LINE OF CREDIT AGREEMENT ("Agreement") contains the terms which govern your line of credit (the "Credit Line" or the "Credit Line Account") issued through Citizens Bank of Pennsylvania as identified above and hereafter referred to as "Citizens Bank". The Agreement sets. forth the terms under which Citizens Bank extends credit advances against your Credit Line Account" t:ach person who signs this Agreement will be bound by its terms and conditions and will be responsible for paying 1111 an,nuntS Owed. In this Agreement, the words "Borrower," "you," "your," and "Applicant" mean each and every person who signs this Agreement, including all Borrowers named above. The words "we," "us," "bur." and "Lender" mean Citizens Rank as identified above. You agree to the following terms and conditions: 1. Promise to Pay. You promise to pay Citizens Batik the total of all credit advances made by us tinder the terms of this Agreement, any other charges, and FINANCE CHARGES clue, together with all costs and expenses for which you are responsible under this Agreement or under the "Mortgage" which secures Agreement, You will pay your Credit Line according to the payment terms set forth below. 2. Terra. "L he term of your Credit Line will begin as of the date of the Agreement ("Opening Date") and will continue until termination of youk Credit Line Account. All indebtedness under this Agreement, if not already paid pursuant to the payment provisions below, will be due and payable upon termination. fhe "Draw Period" of your Credit Agreement will begin on a date, after the Opening Date., when the. Agreement is accepted by the Commonwealth of Pennsylvania following the expiration of the right to canc6, the perfection of the Mortgage, and the meeting of all of our other conditious and will continue for a period of ten (to) years, subject to the terms and conditions of this Agreement. You may ublain credit advances during the "Draw Period" not to exceed, at any time, the credit limit ofyour line of credit. which is S 20,000.00 and more fully described in paragraph 5, "Credit Limit". After the Draw Period ends, the Repayment Period will begin; and you will no longer be able to obtain credit advances. Fhe length of the Repayment Period is Fifteen (15) Years, The end of the Fifteen (15) Years is known as the "lvlaturity Date". You agree that, at our discretion, we may renew or extend the period during which you may obtain credit advances or inuke payments. 3. Payments. a) Draw Period You can obtain advances ofcredit for ten (10 years (the "Draw Period"). You have chosen the payment option checked below. The option checked below is haled on the option that was indicated on your home equity application. If no option was indicated on your application, the loan wiii default to Option One (interest Only), ® Option One: Monthly interest•only payments -tinder this option, your payments will be due monthly and will equal the finance charges that accrued on the outstanding principal balance during the preceding billing period, plus imurancc premiums (if any), all other charges and any amount past due. The Minimum Payment will not reduce the principal that is outstanding on your Credit Line Account. This option will result in greater expcnsee over the life of the Credit Line Accoui it. O Option "1'wo: 2% of the balance . Under this option, your payments will be due monthly and will equal 21,-? of the New Total Balance (which includes the principal balance and outstanding finance charges as of the end of the billing period plus insurance premiums [if any], and all other charges), plus late fees and any amount past due. The Minimum Payment will equal $20.00 or the outstanding balance on your Credit Line Account, whichcver is less, b) Changing Your Draw Period Payment Option You may change your Draw Pennd Payment Option from Option 1 to Option 2, or from Option 2 to Option 1, You must ask us in writing at least 15 days beforo the start of the billing cyele in w.'tich you want to change your Draw Period Payment Option. Na1Ge'PourPPP P Rev 01107 F Page 2 We do not have to let you change your Draw Period Payment Option if: (i) any of your pavment_s under this agreement are past due at the time you make your request, (ii) your account balance is higher than your credit line at the time when you ask us to change your [haw Period Payment Option, or (iii) we, in our sole discretion, believe that your account is not in good standing. cj Repayment Perind AJter the draw period ends, you will no longer be able to btaiu credit advances and must pt iv the ourstanding balance over J j years (the "repayment period'). During the repayment period, payments will he due monthly. Your minimun monthly payment will equal 1/1 Roth of the nainncc that was outstanding at the end of the draw period plus the finance charges that have accrued on the remaining balance, plus any amount past due and all other charges or 520.00; whichever is greater. d) Payments All payments must be made by a check, money order, or other instrument in U S_ dollars and must be received by us at the rernittanee address shown on your periodic billing statement. Payments received at that address on any business day will be credited to your Credit Line as of the date received. Payments may also be made at any of our branch offices. You may also make payments by authorizing, us to debit your Citizens Bank checking account each month in the amount of the Minimum Payment. Payments sent by mail must be mailed early enough to insure receipt by us on the Payment Due Date. 4. Application of Payments, finless otherwise agreed or required by applicable law, during, the Draw Period, payments and tither credits will tie applied in the following order: to the oldcsl unpaid billings first, and then sequentially to any other unpaid billings from the oldest to the most current. Payments in excess of billed amounts will be credited to your account. During the Repayment Period, your payments will be applied n the following order, assuming that it is made by the Payment Due Date: (a) The interest purtion of the unpaid Minimum Payment; and (b) any additional amount paid that exceeds interest due will next be applied to the principal portion of the unpaid IvImimurn Payment. If you make a payment greater than the Minimum Payment, but less than the Total Due shown on your periodic statement you will still be required to make the Minimum Payments in the months that follow. We will refund to you any credit balance upon request if there is a credit balance on the date we receive the refund request. 5. Credit Limit. Ihts Agreement covers a revolving line of credit for S _ 20,000-00 which will be your "Credit. Limit" under t'nis Agreement. This is the maximum credit that is to be extended to you. If the Credit Limit is exceeded, you will be in default of a material obligation tinder this Agreement and the provisions of paragraph 7, "Limitations on Use of Checks" will apply. You may borrow against the Credit Line, repay any portion of the amount borrowed, and re-borrow up to the amount of the Credit Limit. You agree not to attempt, request, or obtain a credit advance that will make your Credit Line Account balance exceed your Credit Limit. Your Credit Limit will not be incrcused should you overdraw your Credit Line Account. If you exceed your Credit Limit, you agree to repay immediately the amount by which your Credit Line Account exceeds your Credit Limit, even if we have not yet billed you. b. How to Use the Credit Line. You may obtain credit advances under your Credit Line by writing a preprinted "check" that we will supply to you. Credit Line checks are specially designated checks which can he completed just like any other check. Each check written and negotiated will create a check advance from us to you. Checks drawn on the Account on forms other than those forms supplied by us or that purpose will not be honored. Cach check you write will be paid with a check advance from your Account unless you are in default under this Agreement, as described in paragraph 23, "Termination and Acceleration", or in those circumstances described in paragraph 7, "Limitations on Use of' Checks," Your use of a check will be reflected on your periodic statement as a check advance. Credit Line checks will not be certified by us and you agree that we may retain the actual checks written by you, and need not return the original checks to you. We may also provide additional ways of using your Account from tune to time. I( there is more than one person authorized to use this Credit Line Account, each of you agree tint to give us conflicting instructions, such as one of'you telling us not to give check advances to the other. Any such instructions will not he followed by us. However, any one of you cony cancel your Credit Line under paragraph 30, "(..ancellation by You". 7. Limitations on Use of Checks. We reserve the right not to honor Credit Line checks in the following circumstances: (a) Your Credit Limit has been, or would be, exceeded by paying the check. (b) Your check is post-dated. If a post-dated check is paid and as a result any other check is returned or not paid, we are not responsible, subject to any applicable law. (c) Your checks have been reported lost or stolen. (d)Your check is not signed by an "Authorized Signer" as defined below. (c)Your Credit Line has been terminated Or suspended as provided in this Agreement or could be tf we paid the check. (1) You are to violation of anv other transaction requirement or would be if we paid the check. Page 3 if we pay anv check under these circumstances, you must repay us, subject to applicable laws, for the amount of the check, The check itself will be evidence of your debt to us together with this Agreement, Out liability, if any, for wrongful dishonor of a check is limited to your actual damages. Dishonor for any reason as provided in this Agreement is not wrongful dishonor. 8. Authorized Signers. The words "Authorized Signer" on checks as used in this Agreement mean and include each person who (a) signs the application forthis Credit Line, and (b) signs this Agreement. 9. Stop Payments. we do not honor stop payment orders for checks drawn against your Credil Line Account. You therefore should not use your Credit Line Account if you anticipate the need In stop payment. You agree that we will have no liability to you or to any other party because we do not honor stop payment orders, 10. Lost Checks. f f you lose your check, or someone is using them without your permission, you agree to notifv us immediately. The fastest way w notify us is by calling us at (800) 922-9999. You also can notify us at Citizens Bank, Consumer Loan Servicing, 1 Citizens Drive, Riverside, RI 02915. 11. Charges to Your Credit Line, we may charge your Credit Line to pay other fees and costs that you are obligated to pay under this Agreement; under the Mortgage or under any other document related to your Credit Line. In addition, we may charge your Credit Line for funds required for continuing; insurance coverage as described in the paragraph 13, "Insurance" or as described in the Mortgage. We may also, at our option, charge your Credit Line to pay any costs or expenses to protect or perfect our security interest in your dwelling. These costs or expenses include, without limitation, payments to cure defaults under any existing liens on your dwelling. If you do not pay your property taxes, we may charge your Credit Line and pay the delinquent taxes. Any amount so charged to your Credit Line will be a credit advance and will decrease the funds available, if any, under the Credit Line. However, we have no obligation to provide any of the credit advances referred to in this paragraph 12• Collateral. This Agreement is secured by it Mortgage dated _ _11/14/2 DOT, us on property located in _ CUKBERLAt(Dounty, State or Commonwealth of ?pp, (the "Property"), We have the right, but are not required to take such action as is necessary to protect our Security Interest described to this paragraph. fury amounts we may pay in exercising our right to protect our Security Interest must be paid by you on demand, and will bear interest at the Annual Percentage Rate then applicable to your account. IMPORTANT NOTICE AROUT YOUR. REAL PROPERTY COLLATERAL: if the deed to the property you are pledging as security for this loan includes more than one parcel of land, the mortgage you are requesting wilt be secured by ALL parcels described in your deed. If your deed contains more than one parcel of land and you do not wart to pledge all of them as security for your loan you should ?'ontac', your legal representative. 13. Insurance. Vou must obtain insurance on the property securing this Agreement through any conhpany of your choice that is reasonably satisfactory to us for the lesser of the replacement cost of the huddings or appurtenances on the Property or the amount of the Credit Line plus any priority liens, You nn.isf name Cidtens Hank as mortgagee on all required insurance policies. The insurance you maintain must provide for Ten ( 10) days notice of ctmcellation to us. If the Property is luciii in it designated Food Zone, you must also maintain flood insurance on the Property. Subjcet to applicable law, if you fail to obtain or maintain insurance as required herein or in the Mortgage, we may purchase insurance to protect our own intcrrst, add dic premium to your balance, pursue any other remedies available to us, or do any one or none of these filings. In the event the Porrower fails to obtain and maintain any insurance on the Property required by the tender, the Borrower understands and agrees that the Lender may, at its option (unless required to do so ny applicable law), obtain and maintain the required insurance and pay the premium(s) for such insurance, and either: (i) add the cost of the insurance to the unpaid principal balance owed under the Agreement (in which case the Borrower agrees to repay the cost of the insurance in accordance with the .epayinunt tciims of the Agrecincnt), of (ii) bill the Boirower separately (in which case the Borrower agrees to pay the bill immediately). I"he Borrower agrees to pay interest on any Stich amounts at the interest rate provided in the Agreement until such amounts are repaid in full. The Borrower understands ind acknowledges that anv insurance obtained and maintained by the Lender may (i) only protect the interests of the Lender and any other creditor with a prior mortgage on the Property, and (it) be more expensive than insurance obtained and maintained by the Borrower. 1-1. Right of Setoff. We have the right under the law to transfer funds held in any deposit account that any person who signs this Agreement has with us or an affiliated bank, to pay or reduce your obligations i f you arr_ in default under this Ageement or we terminate or accelerate your Credit Line Account. You lzrnnt to its a contractual possessory security interest in, and hereby assign, convey, deliver, pledge, and transfer to its all right, title and interest in and to, your accounts with us (whether checking, savings, of some other account.). including without limitation all accounts held jointly with someone else and all accounts you may open in the funire, excluding however all IRA, Keogh, and Irus'. accounts. You authorize us, to the extent permitted by applicable law, to charge or set off all sums owinY ondc,r Ous Agreement against any and all such accounts. Parip 4 15. Periodic Statements. We will send you a periodic statement for all check advances made under this Agreement dunng the Draw Period and for all monthly payments due during the Repayment Period, The statement will show, among other things, payments and credits, check advances, FINANCE CHARGES, insurance, and other charges, your Previous Total Balance, and your New Total Balance. Your statement also will identify the Minunum Payincrit you must make for that billing period and the Payment Due Date. All periodic statements shall conclusively be considered to be correct and accepted by you unless we are notified in writing of any alleged errors within 60 days after receipt. 16. FINANCE CHARGES. You will pay a FINANCE CHARGE on the outstanding amount of the principal balance under your Credit Line, once each billing cycle during the Draw Period and the Repayment Period. The FINANCE CHARGE will begin to accrue on the date advances are posted to your Credit Line Account. Thcre is no "grace period" which would allow you to avoid a FINANCE, CHARCE on your Credit Line advances. FINANCE CHARGES do not accrue on any undisbursed proceeds. 17. Method Used to Determine the Balance on Which the FINANCE CHARGE Will Be Computed. We figure the FINANCE CHARGE on your account by applying the daily periodic rate to the average daily balance of your Credit Line Account and then multiply by the number of days in the billing cycle. To get the average daily balance. we take the total beginning balance of your Credit Line Account each day and add new advances and subtract the principal portion of any payments and credits. The beginning balance for the period is the New Principal Balance amount from your previous statement. To determine the principal portion of a payment, subtract any unpaid FINANCE CHARGES then insurance premiums (if any) and membership fees and other charges (if applicable). This gives us the daily principal balance each day. Then we add up all the daily principal balances fur the billing cycle and divide the total by the number of days in the billing cycle (the number of days since your last statement). This gives us the average daily halanre The average daily balance does not include finance charges. insurance premiums, membership `ecs or other charges. 18. How You May Compute the Finance Charges On Ynur Line of Credit Account. When the average daily'')alance has been computed, you multiply the average daily balance by the daily periodic rate which is arrived at by dividing the Annual Percentage Rate by the number of days in the year, The result is multiplied by the number of days in the billing cycle. This figure is the FINANCE CHARGE assessed for the billing cycle, 19. Periodic Rate and Corresponding ANNUAL PERCENTAGE RATE. We will determine the Periodic Rate and the corresponding ANNUAL PERCENTAGE RATE as follows. We start with an independent index, (the "Index"), which is The Wall Street Journal Prime Rate, published daily in the hsting of "Money Rates." We will use the Index value published on the last husiness clay of each month for any ANNUAL PERCENTAGE, RATE adjustment. If the Index is no longer available, we will choose a new Index and margin. The new index will have art historical movement similar to the original Index and margin, and the new index and margin will result in an Annual Percentage Kate that is suhslaniially similar to the rate in effect at the time the original index becomes unavailable T}ic Index is not necessarily the lowest rate charged by us on our loans To determine the Periodic Rate that will apply to your Credit Line Account, we add a margin to the value of the index, then divide the value by the number of days in a year (daily). To obtain the ANNUAL PERCENTAGE RATE, we multiply the Per-odic Rate by the number of days in a year (daily). This result is the ANNUAL. PERCENTAGE RATE. The ANNUAL. PERCENTAGE RATE includes only interest and no other cods. the Periodic Rate and the corresponding ANNUAL PERCENTAGE RATE on your Credit Line will mcrense or decrease as the Index increases or decreases from time to time. Any increase in the Periodic. Rate will take the form of higher payment amounts. Adjustments to the Periodic Rate and the corresponding ANNUAL PERCENTAGE RATE resulting from changes in the Index will take effect on the first day of the next billing cycle. The maximum ANNUAL PERCENTAGE RATE during the Draw Period o:1 your Credit Line will be 21,000% . The maximum ANNUAL PERCENTAGE RATE during the Repayment Period of your Credit Line will be 18.000% or the maximum rate allowed by applicable lava. In no event will the ANNUAL PERCENTAGE RATE be less than 2.500% during the life. of your Credit Line As of the date this Agreement was printed, the Index is 7.75 ",o per annum Rased on that index value, we estimate feat the initial Periodic Ratc and the corresponding ANNUAL PERCENTAGE RATE on your Credit Line for the first billing cycle will he as stated below: The initial Periodic Rate and corresponding ANNUAL PERCENTAGE RATE actually in effect during the first hilhng cycle, which will he diseinsed on your first periodic statement, may differ from these estimates if the Index Changes hetwccn the date this .Agreement was printed and the date you sign this Agreement. Margin Added ANNUAL Daily Periodic to Index PERCENTAGE RATE Rate 0.510 7.24000% 0.01984$ Page 5 20. Conversion Option. You can exercise the option to convert to a fixed rate only at the end of the Draw Period. Your ANNUAL PERCENTAGE RATE may increase if you exercise This option to convei t to a fixed rate, 'ltc fixed rate will be determined as follows. The ANNUAL PERCENTAGE RATE will he fixed during the entire Repayment Period and will be equal to 2 §% added to the Index which is in effect on the date that the final Draw Period payment is due, but will not be more than 15.00%. In the event the Prime Rate is published as a range of rates, then the lowest rate published shall be the Index. If The Wall Street Journal ceases publication of the Prime Rate we may select a substantially similar Index which we will use to determine the ANNUAL PERCENTAGE RATE for the Repayment Period. In no event shall the Finance Charge exceed that allowable under ony applicable law, if it is determined that the Finance Charge would, except for this provision, exceed the maximum rate allowable, all excess payments shall he considcred to be payments on the principal balance due hereunder and shall he applied nccoritnely 21, Annual Fee, lhcre is no Annual Fee for the life of the credit line account. 22 (a). Late Charges. Depending on the state or commonwealth identified above, your late fee will be calculated as follows: Your payment will be late if it ;s not received by its within 15 days of the "Payment Due Date" shown on your periodic statement. If your payment is late, we may charge you 5.000% of the payment or $20.00, whichever is less. 22 (b), PREPAYMENT, If you pay off'the entire balance and close your line of credit account before the due date, you will not have to pay a fee. 23. Termination and .Acceleration. The entire unpaid balance of your Credit Line Account. including anpaid fees and Finance Charges, shall at our option become irnmedialely due and payable and we can tcrminate your Credit Line Account by sending you notice, if any of the foilowing occur. (a) You have at any time in connection with this Credit Line Account, including your application for same, committed fraud or have made, or make at anytime, any material misrepresentation. For purposes of this provision, fraud and material misrepresentation shall mean knowingly making any false financial or other, statement with the intent that it be relied upon by us and/or intentionolly failing to disclose information in connection with the Credit Line Account; (b) Failure to make any payment under this Agreement; (c) Your action or inaction adversely affects the collateral for the Credit Line Account or our rights in the collatera;. "flits can include, for example, failure to maintain required insurance, waste or destructive use of the Property, failure to pay taxes, failure to maintain adequate insuranec for the Security, death of all persons liable nn the Credit Line Account or the death of any of the Borrowers if the collateral is adversely affected by such death, transfer of title or sale of the Property, the Property is taken through eminent domain, creation of a senior lien on he Property without our permission, foreclosure by the holder of a prior lien or the use of the dwelling for prohibited put-poses. 24. Suspension or Reduction, In addition to any other rights we may have, (neither notice nor your agreement is rct f,iued), we can suspend additional extensions of credit or reduce your Credit Limit during any Period in which any of the following are in effect (a) The value of the Property declines significantly below the Property's appraised value for purposes of this Credit Line Account, This includes, for example, a decline such that the initial difference between the credit limit and the available equity is reduced by fifty percent and may include a smaller decline depending on the individual circurns;ances_ (h) We rcaconably believe that you will be unable to fulfill your payment obligations under your Credit l inc Account duc to a material chunge in your financial oireumstances; Pagp 5 (c) You are in default under any material obligations of this Credit Line Account. We consider all of your obligations to be material. Categories of material obligations include the events described above under paragraph 23, "Termination and Acceleration", obligations to pay fees and charges, obligations and limitations on the receipt of credit advances, obligations concerning maintenance or use of the Property, obligations to pay and perform the terms of any other deed of foist, mortgage or Iease of the Property, obligations to notify us and to provide documents or information to us (such as updated financial information), obligations to comply with applicable laws (such as zoning restrictions), and obligations of any comaker. No default will occur until we mail or deliver a notice of default to you, 50 you can restore your nght to credit advances: (d) linvernment achon prevents us from imposing the ANNUAL PERCENTAGE RATE provided for under this Agreement, or impairs our security interest such that the value of the property is less than 120 percent of the credit line; c) We have been notified by govemmental authority that continued advances may constitute an unsafe and unsound business practice. We may charge your account for appraisal and Credit Report fees we incur in investigating whether any condition ,teminting us to suspend your oredit pr ivileges of reduce your credit limit continues to exist; (f) The maximum Annual Percentage Rate is reached. If your Credit Line is suspended or terminated, you must immediately destroy all Credit Line checks and any other access devices. Any use of checks or other access devices following suspension ur lei initiation may be considered fraudulent. You will also remain liable for any further use of such checks or other Credit Line access devices not returned to us. 25. Change in Terms. We may make changes to the terms of this Agreement if you agree to the change in writing at that time, if the change will unequivocally benefit you throughout the remainder of your Credit Line .Account, or if the change is insifmificant (such as changes relating to our data processinp, systems). 26. Collection Costs. If you fail to abide by any terms of this Agreement, and if we arc permitted to do so by apphcable law, we may hire or pay someone else to help collect your Credit Line Accotutt. You will pay all reasonable collections costs, including reasonable attorney's fees incurred by us in the cnl)echon of nmonnts due under this Agreement to the extent not prohibited by applicable law This includes, subject to any limits under applicable law, our legal expenses whether or not there is a lawsuit and legal expenses for bankruptcy proceedings (including efforts to modify or vacate any automatic stay of injunction), appeals, and any anticipated post-judgment collection services. 27. Delay in Enforcement. Failure at any time by us to exercise any of our rights hereunder shall not constitute a waiver of our right to exercise the same at a later time. 28. Default. You will be in default under this Agreement if any of the following occurs, each of which constinnes a breach of a material obligation of yours tinder this Agreement: (a) You fail to make any payment when dueor to pay any charge or fee when due- (b) Your action or failure to act adversely affects our secunty for your Credit Line Account or a right we have in the security (an attempt by any other creditor to take money or other property of yours that is in our possession is an example of a failure to act that would adversclti affect our security or security interest); (c) A court deternvnes that you are bankmpt or insolvent; or (d) You gave nr give ns false or materially misleading information in connominn with any extention ofcredit to you under your Credit Line Account. 29. Results of Default. If you are in default, we may lower your Credit Limit, we may refuse to make any further advances under this Agreement, we may refuse to pay any outstanding checks that would require us to make an additional credit advance to you, we may foreclose on the real property described in the Mortgage securing your Credit Line Account, we may take whatever other action is permitted under the Mortgage, and we may exercise any and all of our rights with respect to any other property securing your Credit line Account. We also may demand that you pay the full amount you nwe on your Credit Line Account immediately. You agree to pay any costs we incur in collecting what you owe following your default to flit extent not prohibited by applicable law if we have to sue you to collect what you owe, you agree to pay our legal fees, inclurtnig court costs to the extent not prohibited by applicable law. In addition to our other rights and remedies under this agreement and the Mortgage, we reserve the right to honor the check, or other device used to obtain an advance without permanently raising your credit limit. If we honor the check or other devxe, the amount that is more than your credit limit will be due and payable immediately. 3111. Cancellation by You. If you cancel your right to credit advances under this Agreement, you must notify us in writing and destroy all Credit. Line checks and any other Credit Line Account access devices. Despite cancellation, your obligations under this Agreement will remain in frill farce and effect until von have paid us all amounts due under this Agreement, Page V 31. Prepayment. You may make additional payments or may pay back more than the Minimum Payment Due at anv time without penalty, subject to Seetion 22 (b), except we will be entitled to receive all accrued FINANCE CHARGES. and other charges, if any. Payments in excess of your Minimum Payment will not relieve you of your obligation to continue to make your Minimum Payments. Instead, they will reduce the principal balance owed on the Credit Line. If you mark a check, money order, or other instntment sent in payment with "Paid in Full" or with similar language, we may accept the payment, and you will remain obligated to pay any further amount owed to us under this Agreement. 32. Notices. All notices will be sent to your address as shower in this Agreement unless you notify us in writing of any change in your address or name within thirty (30) days of the change. On joint accounts, notices sent to one will be considered notice sent to all. 33. Information About You, You authorize us to get financial information about you from third parties, including, btu not hiniled to, a c t edit bureau, your employer, or another financial institution. You also authorize -,is to disclose information about your creditworthiness and this Account to n credit bureau, our affiliates and subsidiaries, and to others, unless expressly prohibited by applicable law. We may require a new appraisal of the property which secures your Credit Line at any time, including an internal u;.spection, at our sole option and expense, except as provided for in paragraph 24, "Suspension or Reduction" 34. Documentation, You agree to execute or re-execute anv document that we request in order to correct any error or omission in the original Agreement, security instrument, or other Credit Line Account related documents, including, but not limited to, Confirmatory or Corrective security instruments. 35. Transfer or Assignment. Without prior notice or approval from you, we reserve the right to sell or transfer your Credit Line Account to another lender, entity, or person, and to assign our rights under the Mortgage. Your rights under this Agreement belong to you only and may not be transferred or assigned. Your oblieotions, however, are binding on your heirs and legal representativct 36. NEGATIVE: INFORMATION: We may report information about your account to credit bureaus. Late paymenk, missed payments, or other defaults on your account may be reflected in your credit report. 37. Tax Deductibility. You understand 'that Lender makes no representation or warranty whatsoever concerning the tax consequences of this Credit Line Account, including the deductibility of interest, and that you should consult with your own tax advisor for guidance on this subject. You also agree that Lender shall not be liable in any manner whatsoever should the interest paid on the Credit Line Account not be deductible 38. Governing Law. This Agreement is yoverned by federal law, and to the extent not preempted, by the laws of :he Commonwealth of Pennsylvania To the extent that federal law preempts state law, this Agreement is governed by federal law. If any provision of this Agreement conflicts with any existing or future law, it shall be deemed modified to the extent necessary to comply with such law and the validity r,f the remaining terms shall not he affected. 39. Interpretation. The names given to paragraphs or sections in this Agreement arc for reference puiposes only. They arc not to be used to interpret or define the provision of this Agreement. You agree That this Agreement. together with the Mortgage, is the best evidence of your egieetncnt with Us. If a court finds that any provision of this Agreement is not valid or should not be enforced, that fact by itself will not mean that the rest of this Agreemenl will not be valid orenforeed. Therefore, a court may enforce the rest of the provisions of this Agreemew. even if a provision of this Agreement maybe found to be Invalid or unenforceable. If we go to court for any reason, we can use a copy, filmed or electronic, of any periodic statement.. this Agreement, the Mortgage, or any other document to prove what you owe us or that a transaction has taken place. The copy, microfilm, microliche, or optical image will have the same validity as the original. You agree that, except to the extent you can show there is a billing error, your -tiost current periodic statement is the best evidence of your obligation to pay, 40. .Acknowledgment. You understand and agree to the terms and conditions in this Agreement. By signing this Agreement, you acknowledge that you have read this Agreement. You also acknowledge receipt of a copy of this Agreement, including the Fair Credit Billing Notice and the early Home Equity Line of'Credit application disclosure, in addition to the handbook entitled "When Your [Ionic Is On the Line: What You Should Know About Home Equity Lines of Credit," and disclosures/notices provided under applicable state law: given with the application before signing the Mortgage and before using your Credil t,uie Account I f thcrc is more than one Borrower, each is jointly and severally liable on this Agreement. This means we can require any one of you to pay all amounts due under this Agreement, including credit advances made to any of you. Each Borrower authorizes any other Borrower, on his or her signatui a alone, to cancel the (,'redit Line, to request and receive credit advances, and to do all other things necessary to carry out the tennis of this Agreement. We can release any of you from responsibility under this A&Tcement, and the otfier Rcmowei:s will remain responsible. Page B You, the undersigned. certify that you have insured the property as identified in Section 12, entitled "Coilateial". against loss by fire in an amount sufficient to cover (ilia lien and all superior liens, and that the policy includes extended coverage and has a standard mortgagee clause making; loss payable to Cif17"s as its interest may appear. You agree it is your responsibility to keep the premises, as identified in Section 12, entitled "Collateral", insured in an amount at least equal to the replacement cost of any buildings on the property; until this Agreement is paid in full You understurid that you muy purchase any required insurance through any duly licensed insurance agent and insurance company that is reasonablyaeceptable to us. You are not required to deal with any of our affiliates when choosing an insurance agent or insurance company. Your choice of a particular insurance agent or insurance company will not affect our credit decision, so long as the insurance providcc adequate coverage with an insurer that meets our reasonable requirements. All documents related to insurance for this loan should he mailed to the following address Citizens Bank, Consumer Finance Operations 1 Citizens Drive Riverside, RI 02915 (R00170R-(i6R0 ? Authorization of Payments to Third Parties 5 20, 000 .00 Credit Limit Amount paid to others on my behalf 3 6,034.34 Paid to HOMCOMING FINANCIAL S Paid to 6 Paid in 5 Paid to 5 Paid to Paid to S Paid to S Paid to S Paid to i paid to 5 Paid to 3 Paid to Paid to 5 Paid to Paid to a Paid to w 0.00 Amount received froin borrower S 0.00 Total fees to he paid by borrower 5 13, 965.66 Undisbursed Funds You understand that no loan proceeds will be disbursed until any notice of the right to cancel time period specified has expired. You authonzed disbursements to lien creditors and to Citizens Bank loan or line accounts listed above and acknowledge receipt of a filled in copy of this itemization of amount financed. You aie to make disbursements to the non-lien creditors listed above. to order to secure our lien position Citizens Bank !s nuthorized to add to the principal balance, or access deposit accounts to cover any shortage In the event a pay-off sent to another creditor is insufficient, Citizens Bank is authorized to add to the principal balance, or access your deposit account funds held by us to cover such shortage in order to complete your transaction and secure our lien position. You will receive notification in the event an additional amount is needed. This amount should not exceed $1.000.00; further remedies may apply if a irrcatcr amount is needed. Tbis may result in a higher final payment due. Page 9 You acknowledge that any payoff amounts referenced in the of Authorization of Payments to Third Parties section of this Agreement were estimates based on the balances listed on your credit bureau report(s), or obtained from the lien creditors on your behalf. You acknowledge that you received and read, as applicable, the Home Equity disclosure statements provided to you during the application process, which include Important Terms, When Your flame is On the Line, Serviring Disclosure Statement, Cood Faith Estimate, Right to Receive a Copy of an Appraisal, 04i ens Pledge Regarding the Responsible Use and Protection of Ctwonier [tformation. i,i there is more than one signer below, it is my/our intention That this account be a joint account. You acknowledge that with your application, you provided your consent to us to check your employment and credit historN, with anv source and to answer questions about your credit experience with us. READ THIS AGREEMENT BEFORE YOU SIGN. DO NOT SIGN THIS AGREEMENT IF IT CONTAINS BLANK SPACES. TEIE AGREEMENT IS SECURED BY A SECONDARY MORTGAGE ON YOUR REAL PROPERTY. This Agreement 1.8 dated 11/14/2007. THIS AGRFEM ENT 1S SIGNED UNDER SEAL. BORROWER: FWAME R RHO]Ms _.- X F.ffcetive Disbursement Dare: 11/19/2p07 Page 10 BILLING ERROR RIGHTS YOUR BILLING RIGHTS KEEP THIS NOTICE FOR FUTURE USE This notice contains important information about your rights and our responsibilities tinder the I?air Credit Billing Act Notify us in case of errors or questions about your hill. If you think your bill is wrong, or if you need more information about a transaction on your bill, write us on a separate sheet at the address checked at the beginning of this Agreement or at the address listed on the back of your bill. Write to us as soon as possible. We must hear from you no later than sixty (60) days after we sent you the first bill on which the error or problern appeared. You can telephone us, but doing so wit i not preserve your rights. In vour letter. Rive us the following information: Your name and account numher, I'hc dollar urnottnt of the suspected error. Describe the error and explain, i?f you can, why you believe there is an error. if you need more inforrnafion, descnbc the item you are not sure about. If you have authorized us to pay your bill automatically from your savings or checking account, you can stop the payment on any amount you think is wrong. To stop the payment, your letter must reach us three (?) business days before the automatic Payment is scheduled to occur. Your rights and our responsibilities after we receive your written notice. We must acknow)cdge your letter within thirty (30) days, unless we have corrected the crrtn- by then. Within ninety (901 days, we must either correct the error or explain why we believe the bill was correct. After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent. We can continue to bill you for the amount you question, including finance charges, and we can apply nny unpaid amount against your Credit Limit. You do not have to pay any questioned amount while we arc investigating, but you are still obligated to pay the parts of your bill that are not in question. It we find that we made a mistake on your bill, you will not have to pay any finance charges related to any questinned amount. If we didn't make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, we will send yo•.i a ;tatemcni of the amount you owe and the date on which it is due. if you fail to pay the amount that we think you owe, we may report you as delinquent. Flowever, if our explanation does not satisfy you and you write to us within ten (10) days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your bill. And, we must tell you the :tamc of anyone we reported you to. We must tell anyone we report you to that the matter has been settled betwecr us when it fmnlly is. If we don't follow these rules, we can't collect the first $50 of the questioned amount, even if your bill was CorTCCL (d (d a U ri ?i N lf, H W U'. M, CO 10 W W F+ E~ I W S" z. C W t 3 W W w U ull U C (" a1 v, N F4 p co W r? ? a N C C:, ? C H cc C :? R a L.n r- W m C m 4 W N ti ,71 a 4 U U ?? H lD U] 1-1 •?, ?'' W N :a p t` O H Fl, '.D C !` t5+ r4 W H v i< N W U, 4-4 U v ik v G C 4-( (ti o ?l ?A >1 x C + rd m L F ? Ti 11 1i - - -a: vc[; r.? U C]4 0 U U O H r- r1 H H H H C r1 H H C O O C G^ N O dT N lf) L n , -? C C H c7 H H H H O O C, C) 7 !`C% Hmw H N 11 4 O H H C7 a H C C; ?4 ?; 1 1-1 1J a % C U U S-I C) (d 44 4 0 1] 4-] v H +] f, r, p a-) (0 4J ?4 U) O C) U u O 0 (d 1] r, ?4 H iJ v v J C; U7 td U U W r, tU E-i F? 1-1 'J ? IT- H ? v v S •-i C; c 4 •ri H-] i] -w 1 1 F- m Tj 1 1 I-I 4u U'11 I?--'? U U) ? (~ to X W ? rO (? s p ! N C S" ai U7 0 0 (i v (d (d ?J QJ N 0 D; I- I fl? Fly U C.J ? ,Z i-7 0 h-J p ? 1-1 ?i Ul • ri rd (d (d 0 0 n -0CD 0OCCD aaa S_' O O O O O C O C H C; , C) C a a C a C O a C? Tj C) > r? r U KC [? 0 f= 4 H S t7' d% S•? p 41 Ga O ri 1-1 , -1 co C CO N O 61 O m -V CJ rd 0 0 0 lD O a 0 t- 1 ? I O C O m a 6? O N C fd C?1 m m H m 00 L; G, •?I rn rn m N W O rn rn o H H N U) 1 U 1A U) U, CJ C.) E •ri 4-4 0 U, ,n4, 1 S, 04 r ^?4? 0 U 0 C s? (d 11 W i C J IJ H r- I M t4-4 Fl, fl? 4-J t (1) Tj H Tj W 0 4-j v v 1 ?4 (d (d ?4 rC :4 1 U7 QJ CJ ,? • r-I Q) CJ U S as ?+ O U O C?4 C O?4 (d U 1-1 m U U U U E (a4 co m N H H CN . r{ H H N co N H Ql (] p VERIFICATION 'Fhe undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, tha he he is AJGt > (NAME) r c u j ' YJ 0i ' "1 '547) of J?65 i they:) /ufi , plaintiff (TITLE) (COMPANY) herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief 4)), L X (SIGNATURE) _ WWR# 9467276 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Fl EO-OFF"Wi: Sheriff THE PRtl7`NOtdO ?'A, Jody S Smith Chief Deputy ;r 2012 MAY 22 AM q: a? Richard W Stewart Solicitor °MCE OF CUMBERLAND COUNTY :PENNSYLVANIA Citizens Bank of Pennsylvania Case Number vs. 2012-2970 Broke R. Rhodes SHERIFF'S RETURN OF SERVICE 05/15/2012 08:03 PM - Shawn Gutshall, Deputy Sheriff, who being duly swom according to law, states that on May 15 2012 at 2003 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Brooke R. Rhodes, by making known unto herself personally, at 623 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. GUTS UTY SHERIFF COST: $45.00 May 18, 2012 SO ANSWERS, RONRIV R ANDERSON, SHERIFF (c) CcuntySuite Sheriff, Teleosoft, Inc. r1LEZ GFFICE Vim= rH PR TNONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION 20!2 JUL 3 PM 2: 38 CITIZENS BANK OF PENNSYLVANIA CUMBERLAND COIiNTY PENNS LVANIA Plaintiff vs. Civil Action No. 12-2970 CIVIL TERM BROOKE R RHODES Defendant PRAECIPE FOR DEFAULT JUDGMENT I TO THE PROTHONOTARY: I Kindly enter Judgment against the Defendant, Brooke R Rhodes above named, in the default of an Answer, i the amount of $20,407.79 computed as follows: Amount claimed in Complaint $20,282.79 Less Payments/Adjustments Made -$0.00 Attorneys' fees $125.00 i TOTAL $20,407.79 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance ??ith PA R.C.P. 237.1 on the dates indicated on the Notices. I WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Esquir PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#9467276 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 623 HILLTOP DR, NEW CUMBERLAND, PA 17070 ?Il?• I r? `1?} 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIZENS BANK OF PENNSYLVANIA Plaintiff BROOKE R RHODES Defendant CASE#: I2-2970 CIVIL TERM IMPORTANT NOTICE TO: Brooke .R Rhodes 623 Hilltop Dr New Cumberland, Pa 17070 Date of Notice: t 1, _ W WR#:9467276 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 O THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE OUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYE t, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU ITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By. P William T. Molczan, Es ire P.A.I.D.# 47437 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 AT A W W R #9467276 IN THE COMMON PLEAS COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIZENS BANK OF PENNSYLVANIA Plaintiff vs. Civil Action No. 12-2970 CIVIL NON-MILITARY AFFIDAVIT BROOKE R RHODES Defendant The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter anal states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance vv?th the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. 1 Affiant further states that based upon investigation it is the affiant's belief that the Defend nt, Brooke R Rhodes is not in the military service. Affiant further states that this belief is supported by the attached certificate from the 0 Manpower Data Center (DMDC), which states that the DMDC does not possess any infor indicating that the below individual is in the military service: BROOKE R RHODES 623 HILLTOP DR NEW CUMBERLAND, PA 17070 Affiant further states that the averments contained herein are true and correct to the Affiant's knowledge, information and belief and that these averments are made subject to the r of 18 Pa C.S.A. §4904 relating to unsworn falsification to authorities. Affiant ense ation 't of Ities Department of Defense Manpower Data Center 40 status Report Pursuant to Serv cemembers Civil Relief Act Last Name: RHODES First Name: BROOKE R Active Duty Status As Of: Jul-05-2012 Results as of : Jul-052012 12:51:55 SCRA 2.2.1 Active Duty Start Date Active Duty End Date Status Service Component On Active Duty On Active Duty Status Date NA 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 Active Duty Start Date Active Duty End Date Status Service Component NA 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 His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notiflcetion End Date Status Service Component NA 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 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, NGAA, Public Heal , and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 01 ..+ err s Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIZENS BANK OF PENNSYLVANIA Plaintiff vs. Civil Action No. 12-2970 CIVIL TERM BROOKE R RHODES Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or J gm t was entered against you on (xx) Assumpsit Judgment in the amount of $20,407.79 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operal license and/or registration will be suspended by the Department Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By Y (OR DEPUTY) BROOKE R RHODES PROTHO 623 HILLTOP DR NEW CUMBERLAND, PA 17070 Plaintiff's 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION CITIZENS BANK OF PENNSYLVANIA Plaintiff VS. Civil Action No. 12-2970 CIVIL TERM BROOKE R RHODES i �a 3 t(i Ne W '�` ' PO Defendant(s) - w NEW CUMBERLAND FCU J g4s Law A0 Q x� -0 z n ACNB BANK 37y� �(� �A �W / -<F M �c3 Garnishee(s) 1($� ' �o .� T PRAECIPE FOR WRIT OF EXECUTION =:C3 ac3 TO THE PROTHONOTARY: cn _ Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against BROOKE R RHODES ,Defendant 3. against NEW CUMBERLAND FCU, ACNB BANK, , Garnishee 4. Judgment Amount $ $20,407.79 Less Payments/credits received $ $0.00 Interest $ $1,372.07 Costs $ SUBTOTAL: $ $21,779.86 Costs(to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO.,L.P.A. By: William T. Molczan,Esquire PA I.D. #47437 WELTMAN, WEINBERG REIS CO., L.P.A. •g a 1400 Koppers Building c 436 Seventh Avenue u� .6b Pittsburgh,PA 15219 -75 (412)434-7955 It a17 J a•� SOLL 2 9 C��O WR o. 9467276 J O �f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIZENS BANK OF PENNSYLVANIA Plaintiff No. 12-2970 CIVIL TERM vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) BROOKE R RHODES Defendant(s) NEW CUMBERLAND FCU ACNB BANK Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG& REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR No. 9467276 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-2970 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIZENS BANK OF PENNSYLVANIA Plaintiff(s) From BROOKE R.RHODES,623 HILLTOP DRIVE,NEW CUMBERLAND,PA 17070 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: NEW CUMBERLAND FCU,345 LEWISBERRY ROAD,NEW CUMBERLAND,PA 17070 ACNB BANK,37 CARLISLE ROAD,NEWVILLE,PA 17241 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, (2) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$20,407.79 Plaintiff Paid$ Interest$1,372.07 Attorney's Comm. % Law Library$.50 Attorney Paid$194.25 Due Prothonotary$2.25 Other Costs$ Date: SEPTEMBER 18,2013 David D.Buell,Prothonotary Deputy REQUESTING PARTY: Name : WILLIAM T.MOLCZAN,ESQUIRE Address: WELTMAN,WEINBERG &REIS CO. L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH,PA 15219 Attorney for: PLAINTIFF Telephone: 412-424-7955 Supreme Court ID No. 47437 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i 3,11ir Jody S Smith Chief Deputy Richard W Stewart [k ' M ���� i 23{ 1 P LUU;;(-91` Solicitor PENNSYLVANIA Citizens Bank of Pennsylvania vs. Case Number Brooke R. Rhodes 2012-2970 SHERIFF'S RETURN OF SERVICE 09/20/2013 11:30 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, New Cumberland Federal Credit Union, 6692 Carlisle Pike, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, by handing to Briana Howsare, Branch Manager, 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 September 23, 2013 to Brooke R. Rhodes at 623 Hilltop Drive, New Cumberland, PA 17070. /r/c,i' .— AILLIAM CLINE, DEPUTY SO ANSWERS, September 23, 2013 RONNY R ANDERSON, SHERIFF ou4N u C -rit: rc SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff t ,y o'at..3TlrI C¢f t :. 1 Jody S Smith Chief Deputy HO SEP 23 PM 3: 31 Richard W Stewart CUMBERLAND ,�., Solicitor �� - PENNSYLVANIA Citizens Bank of Pennsylvania vs. Case Number Brooke R. Rhodes 2012-2970 SHERIFF'S RETURN OF SERVICE 09/20/2013 10:50 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, ACNB Bank, 37 Carlisle Road, West Pennsboro Township, Newville, PA 17241, Cumberland County, by handing to Shannon Finkey, Teller, personally three copies of interrogatories together with three true and attested copies of the Writ of Executio and made the contents there of known to him/her. / ctz LIAM CLINE, DEPUTY SO ANSWERS, 6 ;;;;: 4"f September 23, 2013 RONNY ANDERSON, SHERIFF cunt u_e'C . osc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW CITIZENS BANK OF PENNSYLVANIA, No. 12-2970 CIVIL TERM Plaintiff, V. Attachment Execution Proceedings BROOKE R. RHODES, Defendant, c and rnCO ' rri ACNB Bank, can'— �' C:) Garnishee. PROOF OF NOTICE TO DEFENDANT ° Z5 COMMONWEALTH OF PENNSYLVANIA, COUNTY OF ADAMS. - On this,the d5147 day of September, 2013, before me, a Notary Public, in and for said Commonwealth and County,the undersigned officer,personally appeared Richard E. Thrasher, Esquire, attorney for ACNB Bank, the Garnishee in the above entitled attachment execution proceedings, who having been by me duly sworn, according to law, on his oath, does depose and say that on September 25, 2013, he forwarded to the Defendant, Brooke R. Rhodes, a copy of the writ issued in said proceedings on September 20, 2013, and a copy of ACNB Bank's Answer to Interrogatories, by mailing the same certified mail deposited at the post office in Gettysburg, Adams County, Pennsylvania, addressed to the Defendant at the following address: 623 Hilltop Drive,New Cumberland, PA 17070. Attached to this Proof of Notice is the certified mail receipt showing the aforesaid mailing of the items hereinbefore mentioned. /e P z4D Richard E. Thrasher, Esquire Sworn to and subscribed before me this day of September,2013. Notary Public ' My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Ledie k Grimes,Notary Public Gettysburg Born,Adam County MY Commission Expires Oct 23,2015 MEMBER,PENNSYWANIA ASSOCIATION OF NOTARIES G U.S. Postal Service,. CERTIFIED MAILT. RECEIPT Er (Domestic Mail I I Insurance Coverage Provided) rU Ln 0 I '` Ir Postage $ f a. u7 Certified Fee O Imo( o ° a E3. Return Receipt Fee Sip C3 (Endorsement Required) Aare C3 Restricted Delivery Fee A C3 (Endorsement Required) Total Postage&Fees Sent To n' grdok¢ stree� - - ----------------- ----------------------------------------------- � Apt No.; orDnV�- ---------------------------- City State,Z%P+4 Nes Cuinbu land PA ono PS Form 3800,August 2006 See Reverse for instructions IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW CITIZENS BANK OF PENNSYLVANIA, : No. 12-2970 CIVIL TERM Plaintiff, : vs. , �„ c:: BROOKE R. RHODES, : rrg o °i=.` Defendant, : -k=r 1 rte- 6 vs. ' ACNB BANK, > Garnishee. : -< CERTIFICATE OF SERVICE AND NOW,this .44111 day of September, 2013, I, Richard E. Thrasher, Esquire, of Puhl, Eastman&Thrasher, attorney for Garnishee,ACNB Bank,hereby certify that I have this date served Garnishee's Answers to Interrogatories, by mailing the original and one true copy first class mail,postage prepaid, to William T. Molczan, Esquire, at the address shown below: Wellman, Weinberg& Reis, L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 PUHL, EASTMAN 0 RASHER By: E Richard E. Thrasher, Esquire Attorney ID#22904 Attorney for Garnishee 220 Baltimore Street Gettysburg, PA 17325 (717) 334-2159 F !L. :.1(- ..I+4F1t i-'iw,(-1ur O :At\ 2.;.;e OCT c I PAP 3: 4 Q CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIZENS BANK OF PENNSYLVANIA Plaintiff No. 12-2970 CIVIL TERM vs. PRAECIPE FOR JUDGMENT AGAINST GARNISHEE BROOKE R RHODES Defendant NEW CUMBERLAND FCU Garnishee FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T Molczan Esquire PA I.D.#47437 Weltman, Weinberg& Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#09467276 CtO SO Pei Cali/ C 113 latt- b N o c,o 1V ,1e d IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIZENS BANK OF PENNSYLVANIA Plaintiff vs. Civil Action No. 12-2970 CIVIL TERM BROOKE R RHODES Defendant NEW CUMBERLAND FCU Garnishee PRAECIIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee,NEW CUMBERLAND FCU , in the amount of$610.36, which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG &REIS CO., L.P.A. By: (i✓►IN' ✓ William T Molczan Esq e PA I.D.#47437 Weltman, Weinberg& Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#09467276 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg&Reis Co., L.P.A., 1400 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: PO BOX 658,NEW CUMBERLAND, PA 17070 New Cumberland Federal Credit Union Your Community Credit Union P.O. Box 658,New Cumberland,PA 17070-0658 Phone: (717)774-7706. 1-800-716-2328 •Fax: (717)774-7996•Web: www.ncfcuonline.org September 23, 2013 Weltman, Weinbert& Reis, Co., 1400 Koppers Building 436 Seventh Ave. Pittsburgh, PA 15219 To Whom It May Concern: The enclosed completed interrogatories are for our member Brooke Rhodes as of date and time of service, 9/20/13, 11:26am. Xx445 Brooke is primary owner on account,—S1 shares= $5.31. Balance is exact amount and includes S1 minimum balance requirement of$5.00. Last deposit was 7/28/09. Account is Dormant. Xx 446 Brooke is joint owner on account with Alyssa Rhodes, - S1 shares = $431.73. Balance is exact amount and includes S1 minimum balance requirement of$5.00. Last deposit was 12/6/10. Account is Dormant. Xx411 Brooke is primary owner on account, - S1 shares = $608.32. Balance is exact amount and includes 51 minimum balance requirement of$5.00 and $125.00 NCFCU garnishment fee. Last deposit was 12/6/10. Account is Dormant. If you need additional assistance, please feel free to contact me at 717-774-4633, ext 215, Monday through Friday 8:00AM —4:00PM. Deanna Walter of ec ionp lDe f. ��� %'CJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIZENS BANK OF PENNSYLVANIA Plaintiff vs. Civil Action No. 12-2970 CIVIL TERM BROOKE R RHODES Defendant(s) INTERROGATORIES IN ATTACHMENT immimmir ACNB BANK Garnishee(s) FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR No. 9467276 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIZENS BANK OF PENNSYLVANIA Plaintiff vs. Civil Action No. 12-2970 CIVIL TERM BROOKE R RHODES Defendant(s) NEW CUMBERLAND FCU ACNB BANK Garnishee(s) TO: NEW CUMBERLAND FCU, 345 LEWISBERRY RD,NEW CUMBERLAND, PA 17070 ACNB BANK, 37 CARLISLE RD,NEWVILLE, PA 17241 RE: BROOKE R RHODES , 623 HILLTOP DR,NEW CUMBERLAND, PA 17070 Suggested Reference No.: XXX-XX-8480 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. 9467276 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 fo any reason (inclu•'ng funds pn deposit for checking or savings accounts and certificates of deposit)? va_ 61i 1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. XXx5 ..r'i - b ,, 73 & or/ 4:1/ 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. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? A/O 4. At the time you were served or at any sub equent time did you hold as fiduciary any prope in which the defendant had an interest? - j�3 L� ezzY/V6 fae, e Xx4X _t . i)o XX� = w2.4 ow/ Q, lo/ 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? ,l/O 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. WWR No. 9467276 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds,did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. 9. If the answer to Interrogator} 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. 9�3t)%� //,. 4,v 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. g/aW `'.5 //' °7/_ If/, 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? .4Yv 12. If the response to Interrogatory 11 is in the affirmative,state the amount of non-exempt funds on deposit in the account. N//41 • WELTMAN, WEINBERG& REIS CO., L.P.A. By: 6,26/ William T. Molczan, Esqu' e PA I.D. #47437 WELTMAN, WEINBERG& REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR No. 9467276 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 ,�, 2,I /7z 424 /1'r (Name) ile61-71 //' of A/Ck , garnishee herein, (Title) (Company) that he/she is duly authorized to make this verification, and that the facts sert.th in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. aavia_,/adh,z, (SIGNATURE) WWR No. 9467276 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIZENS BANK OF PENNSYLVANIA Plaintiff vs. Civil Action No. 12-2970 CIVIL TERM BROOKE R RHODES Defendant NEW CUMBERLAND FCU Garnishee NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff ( )Defendant (xx)Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of$610.36 plus costs. ( ) Trespass Judgment in the amount of$ 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 ( ) Default ( ) Verdict ( ) Arbitration Award Prothonotary .0% *" mil, $ By: • PROTHONOTARY(OR DEPUTY) New Cumberland Fcu Po Box 658 New Cumberland, Pa 17070 WELTMAN,WEINBERG & REIS CO.,L.P.A. BY: Ashley L. Sweeney, Esquire Attorney for PI I.D.No. 313667 Pil 436 Seventh Avenue, Suite 1400 CI-IMBERLAND COUNTY Pittsburgh, PA 15219 PENNSYLVANIA Phone:412.434.7955 Fax: 412.434.7959 File# 9467276 CITIZENS BANK OF PENNSYLVANIA Cumberland County Court of Common Pleas VS. BROOKE R RHODES NO, 12-2970 CIVIL TERM and ADAMS COUNTY NATIONAL BANK Gamishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s),ADAMS COUNTY NATIONAL BANK, only. WELTMAN, WEINBERG&REIS CO., L.P.A. By Aley Ve#ey, Esquire�7 Attorney for Plaintiff C� WELTMAN,WEINBERG& REIS CO.,L.P.A. BY: Ashley L. Sweeney,Esquire Attorney for Plaintiff(s) I.D.No.313667 � '(lY j #� ; 436 Seventh Avenue, Suite 1400 Pittsburgh,PA 15219 CUMBERLAND COUNTY Phone: 412.434.7955 PE.NNs YLVANIA Fax: 412.434.7959 File# 9467276 CITIZENS BANK OF PENNSYLVANIA Cumberland County Court of Common Pleas vs. BROOKE R RHODES NO. 12-2970 CIVIL TERM and NEW CUMBERLAND FCU Garnishee(s) PRAECIPE TO SATISFY ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter satisfied as to Garnishee(s),NEW CUMBERLAND FCU, only. WELTMAN,WEINBERG&REIS CO., L.P.A. By ey wee ey, Esquire Attorn for P intiff d *APe Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OF -1: F. QF $,'FF,R!FF [1 APR [1# PI 2: rtE D p , PE t.r °SYL` i "`NIA Citizens Bank of Pennsylvania vs. Brooke R. Rhodes Case Number 2012 -2970 SHERIFF'S RETURN OF SERVICE 09/20/2013 10:50 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, ACNB Bank, 37 Carlisle Road, West Pennsboro Township, Newville, PA 17241, Cumberland County, by handing to Shannon Finkey, Teller, 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 him /her. 09/20/2013 11:30 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, New Cumberland Federal Credit Union, 6692 Carlisle Pike, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, by handing to Briana Howsare, Branch Manager, 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 September 23, 2013 to Brooke R. Rhodes at 623 Hilltop Drive, New Cumberland, PA 17070. • 04/14/2014 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. However, plaintiffs attorney was able to collect $ 610.36 from garnishee New Cumberland FCU. SHERIFF COST: $166.30 SO ANSWERS, April 14, 2014 RONNY R ANDERSON, SHERIFF (ci Cour tySu!,e Sherif . ie!eosoft, no. 30 I/SY