HomeMy WebLinkAbout12-4649Atlantic Credit & Finance In the Court of Common Pleas of
c/o Edwin A. Abrahamsen & Assoc. CUMBERLAND County, Pennsylvania
120 North Keyser Ave. Civil Division
Scranton, PA 18504
Plaintiff
NO: O( `? UvVlll
P.C.
vs.
M
KAITLIN CHRISTOPHER PRAECIPE FOR ENTRY OF JUDGMEN'X r:;no t?-
365 Pleasant View Dr Lot 32?'" N
Etters PA 17319
Defendant rC C7.
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To the Prothonotary of CUMBERLAND County: x-+
I) Enter Judgment on the attached Certified copy of Judgment from a District Justice.
A) Date of Instrument: July 31, 2009
B) Amount of Judgment: $2,872.95
C) Interest From: July 31, 2009
2) Enter the judgment in favor or the original holder, or (unless expressly forbidden in
the instrument) in favor of the assignee or other transferee;
3) I hereby certify that the address of the plaintiff is:
Atlantic Credit & Finance
c/o Edwin A. Abrahamsen & Assoc.
120 North Keyser Ave.
Scranton, PA 18504
4) I hereby certify that the address of the defendant is:
KAITLIN CHRISTOPHER
365 Pleasant View Dr Lot 32
Etters PA 17319
F. Ratchford, Esquire yhorno for Plaintiff
Michael F. Ratchford, Es
Edwin A. Abrahamsen &
120 N. Keyser Ave
Scranton, PA 18504
570-558-5510 Ext. 101
Attorney ID 86285
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Atlantic Credit & Finance In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Civil Division
Plaintiff '
vs.
NO:
KAITLIN CHRISTOPHER
365 Pleasant View Dr Lot 32 NOTICE OF FILING JUDGMENT
Etters PA 17319
Defendant :
Notice is herby given that a money judgment in the above-captioned matter as be/en entered
against you in the amount of $ a 8 7 vL , q5 on 74 ;1 S /
By:
If you have any questions regarding this notice, please contact the filing party:
Edwin A. Abrahamsen & Associates
120 N. Keyser Avenue
Scranton, PA 18504
Telephone: (570)-558-5510
(Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236)
Atlantic Credit & Finance
c/o Edwin A. Abrahamsen & Assoc.
120 North Keyser Ave.
Scranton, PA 18504
Plaintiff
vs.
KAITLIN CHRISTOPHER
365 Pleasant View Dr Lot 32
Etters PA 17319
Defendant
State of Pennsylvania
County of CUMBERLAND SS:
NO:
AFFIDAVIT UNDER SOLDIERS AND SAILORS
RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED
Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the
above named defendant(s): K.AITLIN CHRISTOPHER is(are) not in the military service of the
United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as
amended;
That the defendant(s): K:AITLIN CHRISTOPHER is(are) older than eighteen years of age;
That the employment status of the defendant(s): KAITLIN CHRISTOPHER is(are) unknown.
Subscribed before me this-i'lday of :1
INAL-
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal Public
Dana L. Stillarty, tart
City of Scranton, Lackawanna County
My CominlWon Expires )uly 21, 2015
ION of p(yfARIES
'EMBER, PENNSYLVANIA ASS?AT
In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Civil Division
10MMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Notice of JudgmentlTranscript Civil
Case
Mag. Dist. No: MDJ-09-3-05
MDJ Name: Honorable Mark Martin
Address: 507 North York Street
Mechanicsburg, PA 17055
Telephone: 717-766-4575
Attorney Michael F. Ratchford, Esq.
120 N Keyser Ave
Scranton, PA 18504
Disposition Summary
MJ-09305-CV-0000221-2009
Judgment Summary
Participant
Atlantic Credit & Finance
Kaitlin Christopher
Plaintiff
Atlantic Credit & Finance Kaitlin Christopher
JoinVSeveral Liability Individual Liability
$0.00 $0.00
$0.00 $2,872.95
Atlantic Credit & Finance
V.
Kaitlin Christopher
Docket No: MJ-09305-CV-0000221-2009
Case Filed: 7/6/2009
Disposition Disposition Date
Default Judgment for Plaintiff 07/31/2009
Amount
$0.00
$2,872.95
Judgment Detail (*PostJudgment)
In the matter of Atlantic Credit & Finance vs. Kaitlin Christopher on 7/31/2009 the disposition is Default Judgment for Plaintiff and
judgment was awarded as follows:
Judament Component JointiSeyeral Liability Individual Liability Deposit Applied Amount
Civil Judgment $0.00 $2,776.45 $2,776.45
Costs $0.00 $96.50 $96.50
Grand Total: $2,872.95
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH
THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF
JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT
HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE
COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A
REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
Date Magisterial District Judge Mark Martin
certify that this is a true an correct copy o the record o the proceedings contamm t e JU ment.
r
Z- 112-
Date Magisterial District Judge Mark Martin
MDJS 315
Page 1 of 2
Printed: 02/06/2012 4:06:44PM
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'2012 J1 U I. 25 Ar- l l • 41 S
i LMBLERLAND COON I ',.
Department of Defense Manpower Data Center
Status Repoli
Pursuant to Servicemem is Civil Relief Act
Last Name: CHRISTOPHER First Name:
Active Duty Status As Of: Jul-13-2012
Results as of : Jul-13-2012 06:12:16
SCRA 2.2.2
Active Duty Start Date- Active Duty End Date Status service Corrponeni
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
Leff Active Duly Within 367 Days of Active Duty Sum Date
Active Duty Start Date Active Duty End Date. .. Status Service Cw ponent
NA NA No NA
This response refle<is where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or HsMar Unit Was Notified of a Future Celf-Up to Acfive Duty on Active Duty Status Date
Order Notification Stan Date Drder Notification 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, 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.
41
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
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: R02B51 Q91V
Atlantic Credit & Finance
Plaintiff In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
VS. Civil Division
KAITLIN CHRISTOPHER >
365 Pleasant View Dr Lot 32
Etters PA 17319 NO: 12-4649 CIVIL ri? ca P
Defendant : -C-) .,.-') --F
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VS. ?? `.. ._.j.^
INTERROGATORIES IN ATTACHMENT
ca -?
SOVERIGN BANK =, j C= C=
36 ROBIN HOOD DRIVE y*z
ETTERS, PA 17319 --i r"
Garnishee
RE: Execution of Judgment against your depositor KAITLIN CHRISTOPHER SSN # 036-58-0114
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:
1) At the time you were served or at any subsegent time, did the Defendant possess
any bank accounts, joint or individual, that were in your custody or control?
Please specify joint or individual account. Please list the legal title of any such
account(s) an dthe primary account holder and if known whether joint account is
entireties property.
YES - SEE ATTACHED
2) At the time you were served or at any subsequent time, what was the balance and
account number of the bank accounts(s) identified in Interrogatory #1?
SEE ATTACHED
3) At the time you were served or at any subsequent time, please list the average
daily balance in the past five (5) months for each such account identified in your
answer to Interrogatories number one (1) and two (2) above.
SEE ATTACHED
4) At the time you were served or at any subsequent time, did the bank account(s)
that the Defendant possessed contain fund derived solely from social security
funds and/or disability funds?
NO
5) At any time before or after you were served, did the Defendant(s) transfer or
deliver any property or money to you or to any person or place pursuant to your
direction or consent, and if so, what was the consideration therefore?
NO
f'
6) At any time after you were served, did you pay, transfer or deliver any money or
property to the Defendant(s) or to any person or place pursuant to the Depositor's
direction or otherwise discharge any claim of the Depositor against you?
NO
7) At the time you were served or any subsequent time, did you have, share, or
utilize any safe-deposit boxes, pledges, documents of title, securities, notes,
coupons, receivable, license, or collateral in which there was an interest claimed
by Defendant(s)?
NO
8) At the time you were served or at any subsequent time did the Defendant(s)account
contain funds deposited electronically on a recurring basis and which are identified
as being exempt from execution, levy or attachment. If so, state the reason for the
exemption, the amount being withheld and the entity electronically depositing
those funds on a recurring basis.
NO
9) 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. Section 8123? If so, identify each account.
SEE ATTACHED
10) Identify every other account (not previously noted) titled in the name of the
Defendant(s) in which you believe the Defendant(s) have an interest in whole of
part, whether or not styled as a payroll account, individual retirement account, tax
account, lottery account, partnership account, joint or tenants by entirety account,
insurance account, trust or escrow account, attorney's account, or otherwise.
SEE ATTACHED
11) To the extent that you're above answers depend in whole or part on documents,
account records, or other papers or electronic data, describe each in exact detail
(or attach a copy of the same). Our answers depend on the research
of an Electronic Customer Data Base.
Michael F. Rjdcy(ord, Esquire
120 North yser Avenue
Scranton, A 18504
(570) 551-5510
ANSWERS TO INTERROGATORIES
Account # 10027832889 Balance: $692.01
After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this
account is $392.01
Account Holder: Kaitlin L Di Maria
35 Sunset Blvd
Newport, RI 02840
Account # 39804764734 Balance: $494.17
Account Holder: Kaitlin L Di Maria
35 Sunset Blvd
Newport, RI 02840
Account # 1681794519 Balance: $0.00
Account Holder: Kaitlin L Di Maria
35 Sunset Blvd
Newport, RI 02840
Account # 0931077710 Balance: $0.00
Account Holder: Kaitlin L Di Maria
35 Sunset Blvd
Newport, RI 02840
ANSWERS TO INTERROGATORIES pq 2
In answer to Interrogatories No: #3 as follows:
Average Daily Balance for the Past five (5) months:
Account No. 10027832889 39804764734
September $184.50 $212.73
August $12.90 $223.21
July $0.00 $275.05
June $0.00 $118.19
May $10.00 $55.41
Account No. 1681794519 0931077710
September $0.00 $0.00
August $0.00 $0.00
July $0.00 $0.00
June $0.00 $-27.23
May $0.30 $5.08
VERIFICATION
I, Elizabeth Fontes-Nunes, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that
the information contained in the foregoing Answers to Interrogatories in Attachment are
true and correct to the best of my knowledge, information and belief. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094,
relating to unsworn falsification to authorities.
Sovereign Bank
By:
lizabeth Fontes-Nunes
C.O.P. Lead Specialist
THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
IN RE:
Altantic Credit & Finance
VS.
Kaitlin Christopher (Kaitlin L Di Maria)
CERTIFICATE OF SERVICE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner
indicated below:
Service by first class mail addressed as follows:
Michael F. Ratchford, Esquire
Edwin A. Abrahamsen & Associates, P.C.
120 N. Keyser Avenue
Scranton, PA 18504
Service by certified mail addressed as follows:
Kaitlin L Di Maria
35 Sunset Blvd
Newport, RI 02840
601?x-?
Eliza h Fontes-Nunes
C.O. . Lead Specialist
Sovereign Bank
MA1 M133-02-10
2 Morrisey Boulevard
Boston, MA 02125
October 10, 2012
Atlantic Credit & Finance
Plaintiff
vs.
KAITLIN CHRISTOPHER
365 Pleasant View Dr Lot 32
F.tters PA 17319
Defendant
vs.
SOVERIGN BANK
36 ROBIN 1I00D DK1VF,
ETTERS. PA 17319
Garnishee
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In the Court of Common Pleas of ro~ r.a ~' ~~
CUMBERLAND County, Pennsylva~ .~-+ ~t-~~
Civil Division ~~
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N O: 12-4649 C I V ll. ~~ ''~
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Praecipe to Enter Judgment against ~iarnishee
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Enter Judgment against Garnishee in the amount of $886.18.
This amount is less the $300.00 statutory exemption claim.
"Thank vou.
V1 ..~--`
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~_ I ~ __`
Michael F. Ratchford, Esquire
Edwin A. Abrahamson & Associates., P.C.
Lawyer ID # 86285
Sworn and subscribed before me on this ~ day of ~ ~ ' _~ _ __ _20
n _
Notary Pu
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Court Ordered Processing - MAl-MI33-02-10 - P. O. Box 841005 -Boston, MA 0:2284
October 10, 2012
The Court of Common Pleas of Cumberland County, Pennsylvania
Prothonotary's Office
1 Courthouse Square
Carlise. PA. 17013
RE: Altantic Credit & Finance
vs.
Kaitlin Christopher (Kaitlin L Di Maria)
No.: 12-4649
Dear Sir/Madam:
Enclosed are Sovereign Bank's Answers to Interrogatories in Attachment and an
original and one copy of a Certificate of Service. Please pile the originals in your office
and return the Time-stamped copy of the Certificate of Service in the enclosed return
envelope. By copy of this letter we are serving those parties listed on the Certificate of
Service with a set of Answers. We are also serving the Defendant with a copy of the
Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order, and Claim
for F_xemption.
Very truly yours,
r y-p ~~
Elizab Fontes-Nunes
C.O.P. Lead Specialist
Court Order Processing
Phone: 617-514-5189
Fax: 617-533-1931
Enclosures
pc: Michael F. Ratchford, E=squire (w/enclosures)
Kaitlin Christopher (Kaitlin L Di Maria) (w/enclosures, certified mail)
Atlantic Credit & Finance
v~.
KAlT1_LPJ CHRISTOPHER
365 Pleasant View Dr Lot 32
Ettcrs PA 17319
vs.
SOV ERIGN BANK
36 ROBIN HOOD DRIVE
ETTERS, PA 17~ 19
Plaintiff In the Court of Common Pleas of
CUMBERLAND County. Pennsylvania
Civil Division
Defendant
Garnishee
NO: 12-4649 CIVIL
INTERROGATORIES TN ATTACIiMEN"('
iZ3: Execution of Judgment against your depositor KAITLIN CHRISTOPI-fER SSN # 036-58-01 14
Xou 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:
At the time you were served or at any subsegent time, did the Defendant possess
any bank accounts, joint or individual, that were in your custody or control?
Please specify joint or individual account. Please list the legal title oi' any such
account(s) an dthe primary account holder and if known whether joint account is
entireties property.
YES - SEE ATTACHED
2) At the time you were served or at any subsequent time, what was the balance and
account number of the bank accounts(s) identified in liiterrogatory # l?
SEE ATTACHED
;) At the time you were served or at any subsequent time, please list. the average
daily balance in the past five (5) months for each such account identified in v_ our
answer to Interrogatories number one (1) and two (2) above.
SEE ATTACHED
4} At the time you were served or at any subsequent time, did the bank accowit(s)
that the Defendant possessed contain fund derived solely from social security
funds and/or disability fiords?
NO
S) At any time before or after you were served, did. the Defendant(s) transfer or
deliver any property or money to you or to any person or place pursuant to your
direction or consent, and. if so, what was the consideration therefore?
NO
b) At any time after you were served, did you pay, transfer or deliver an~% me?nev or
property to the Defendant(s) or to any person or place pursuant to the f~epositor's
direction or otherwise discharge any claim of the llepositor against You''
NO
7) At the time you were served or any subsequent time, did you have, share, or
utilize any safe-deposit boxes, pledges, documents of title, securities, notes..
coupons, receivable, license, or collateral in which there was an interest claimed
by Defendant(s)?
NO
S) At the time you were served or at any subsequent time did the Defendant(s)account
contain funds deposited electronically on a recurring basis and which are identified
as being exempt from execution, levy or attachment. If so, state the reason for the
exemption, the amount being withheld and the entity electronically depositu7g
those funds on a recurring basis.
NO
9) At the time you were served or at any subsequent time did the defendant have tilnds
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. Section 8123? If so, identify each account.
SEE ATTACHED
'. Oj Identify every other account (not previously noted) titled in the name of the
Defendant(s) in which you believe the Defendant(s) have an interest in whole of
part, whether or not styled as a payroll account, individual retirement account, tax
account, lottery account, partnership account, joint or tenants by entirety account,
insurance account, trust or escrow account, attorney's account, or otherwise.
SEE ATTACHED
11) To the extent that you're; above answers depend in whole or part on documents,
accowrt records, or other papers or electronic data; describe each in exact detail.
{or attach a copy of the same). Our answers depend on the r. esearch
of an Electronic Customer Data Base.
A.,Abral~mse,~r & Q~,s~~~':~
Michael F. R ch~'ord, 1/squire
120 North ysei= Avenue
Scranton, A 18504
(570) 55 ,-5510
ANSWERS TO INTERROGATORIES
Account # 10027832889 Balance: $E392.01
After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balar~re in this
account is $392.01
Account Holder: Kaitlin L Di Maria
35 Sunset Blvd
Newport, FZI 02840
Account # 39804764734 Balance: $494.17
Account Holder: Kaitlin L Di Maria
35 Sunset Blvd
Newport, fZI 02840
Account # 1681794519 Balance: $0.00
Account Holder: Kaitlin L Di Maria
35 Sunset Blvd
Newport, RI 02840
Account # 0931071710 Balance: $0.00
Account Holder: Kaitlin L Di Maria
35 Sunset. Blvd
Newport, RI 02840
ANSWERS TO INTERROGATORIES pq 2
In answer to Interrogatories No. #3 as follows:
Average Daily Balance for the Fast five (5) months:
Account No. 10027832889 39804764734
September $184.50 $212.73
August $12.90 $223.21
July $0.00 $275.05
June $0.00 $118.19
May $10.00 $55.41
Account No_ 1681794519 0931077710
September $0.00 $0.00
August $0.00 $0.00
July $0.00 $0.00
June $0.00 $-27.23
May $0.30 $5.08
VERIFICATION
1, Elizabeth Fontes-Nunes, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that
the information contained in the foregoing Answers to Interrogatories in Attachment are
true and correct to the best of my knowledge, information and belief. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094,
relating to unsworn falsification to authorities.
Sovereign Bank
BY: _ - _
lizabeth Fontes-Nunes
C.O.P. Lead Specialist
THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE:
Altantic Credit 8~ Finance
vs.
Kaitlin Christopher (Kaitlin L Di Maria)
CERTIf=IC,~TE OF aERVECE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner
indicated below:
Service by first class mail addressed as follows:
Michael F. Ratchford, Esquire
Edwin A. Abrahamsen & Associates, P.C.
120 N. Keyser Avenue
Scranton, PA 18504
Service by certified mail addressed as follows:
Kaitlin L Di Maria
35 Sunset Blvd
Newport, RI 02840
Eliza th Fontes-Nunes
C.O. .Lead Specialist
Sovereign Bank
MA1 MB3-02-10
2 Morrisey Boulevard
Boston, MA 02125
October 10, 2012
Atlantic Credit & 1~inance In the Court of Common Pleas of
1?0 North Keyser Ave. CUMBERLAND County, Pennsylvania
Scranton.. PA 18504 Civil Division
Plaintiff
vs.
RAITLIN CI~RISTOPHER
365 Pleasant View Dr Lot 32
Etters PA 17319
SOVL-RtGN BANK
36 ROBlN HQOD DR1VE
ETTERS, P,A 17319
NO: 12-4649 CIVI[
NOTICE OF FILING JUDGMENT
Defendant
Garnishee
Notice is herby given that a money judgment in the above-captioned matter has been entered
against you in the amount of $ g(o, lf3 _ _ on
H,
If you have any questions regarding this notice, please contact the filing party:
Edwin A. Abrahamsen &, Associates
120 North Keyser Avenue
Scranton, PA 18504
Telephone: (570)-558-5510
(Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236)
Atlantic Credit & Finance Inc.
Assignee from In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
vs.
KAITLIN CHRISTOPHER NO: 12-4649 CIVIL
365 Pleasant View Dr Lot 32
Etters PA 17319
Defendant Praecipe to Satisfy Judgment against Garnishee
& Associates, P.C.
Sworn and subscribed before me on this ~ day of ~®~Q_~ ~ 20~~
Notary Public
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SOVERIGN BANK ~ => r~r
36ROBIN HOOD DRIVE ~~ ~ nrt
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ETTERS, PA 17319 ,
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Garnishee ~..,. ~ ~M-~,.;
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To the Prothonotary of CUMBERLAND County Pennsylvania: - _ -
Please enter the above Praecipe to Satisfy Judgment against Garnishee.
Thank you,
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MEMBER, PENNSYLVANLI 0.'SSOQATION OF
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson „:!i ED- r
Sheriff of Cu Ia I F P R 0 T H 0 N Er t: t
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Jody S Smith
Chief Deputy 2013 APR "S PM 3' 54
Richard W Stewart
Solicitor MOFTHE RIFr CUMBERLAND COUNTY
PENNSYLVANIA
Atlantic Credit&Finance Inc.
Case Number
vs.
Kaitlin Christopher 2012-4649
SHERIFF'S RETURN OF SERVICE
09/28/2012 11:47 AM-William Cline, Deputy Sheriff,who being duly sworn according to law, states that on
September 28,2012 at 1145 hours, attached as herein commanded all goods, chattels, rights,debts,
credits,and monies of the within named defendant,to wit: Kaitlin Christopher in the hands, possession,
or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland
County, Pennsylvania, by handing to Julie Myers, Branch Operations 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 October 3, 2012 to Kaitlin Christopher at 365
Pleasant View Drive, Lot 32, Etters, PA 17319.
04/05/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $88.40 SO ANSWERS,
April 05,2013 RbNW R ANDERSON, SHERIFF
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;'c)Caunty5ude SmoriN.Teteosott,Inc.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 12-4649 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION--LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due ATLANTIC CREDIT&FINANCE, Plaintiff(s)
From KAITLIN CHRISTOPHER,365 PLEASANT VIEW DR.,LOT 32,ETTERS,PA 17319
(I)You are directed to levy upon the property of the defendant(s)and to sell
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEES)as follows:
SOVEREIGN BANK,36 ROBIN HOOD DRIVE,ETTERS,PA 17319,ANY AND ALL
ACCOUNTS OF THE DEFENDANT(S),IN THE POSSESSION OF GARNISHEE,INCLUDING
BUT NOT LIMITED TO SAVINGS ACCOUNT BALANCES;CHECKING ACCOUNT
BALANCES; CERTIFICATES OF DEPOSIT;MONEY MARKET ACCOUNTS;CONTENTS OF
SAFETY DEPOSIT BOXES. DEFENDANT'S SSN(S): 036-58-0114
and to notify the garnishee(s)that:(a)an attachment has been issued;(b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant
(s)or otherwise disposing thereof;
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $2,452.95 L.L.$.50
Interest $24.09
Atty's Comm % Due Prothy $2.25
Arty Paid $62.75 Other Costs
Plaintiff Paid
Date:SEPTEMBER 24,2012
Jri y
David D.Buell,Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name: MICHAEL F.RATCHFORD,ESQUIRE
Address: EDWIN A.ABRAHAMSEN&ASSOCIATES,PC
120 NORTH KEYSER AVENUE
SCRANTON,PA 18504
Attorney for: PLAINTIFF
Telephone: 570-558-5510 Ext.1101
Supreme Court ID No.86285 TMA COPY."M
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