Loading...
HomeMy WebLinkAbout12-51932132281 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WE7IN32RG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19,128 484/351-0500 BARCLAYS BANK DELAWARE 125 S. West Street Wilmington, DE 19801 Vs. RICHARD D GILBERT 420 STONEHEDGE LN MECHANICSBURG PA 17055-7002 COURT OF COMMON PLEAS rr CUMBERLAND COUNTY -?? rri ° S' <CD Ja- SJ9 2> C') DOCKET NO ' -Cc:) CD-,j . NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGEMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 Qru? 0 q6 ) c3•7SPd 0) L-A- 5 S pA a? I .11 . . COMPLAINT IN CIVIL-ACTION 1. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 2. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 3. The defendant (s) received and accepted goods and merchandise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. A true and correct copy of the statements or Affidavit of Account, if available, is attached hereto, made part hereof and marked as Exhibit "A". 4. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of 8/7/12 in the amount of $6,584.97. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 6. Defendant's last payment on account was made on 11/28/2010. WHEREFORE, plaintiff claims of the defendant(s) the sum of $6,584.97 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. EINBERG, ESQUIRE JOEL M. L K, ESQUIRE Attorney for Plaintiff P01A 2132281 BARCLAYS BANK DELAWARE RICHARD D GILBERT 5140218899992976 VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements. lk" Q, V ?M-u NAME EXHIBIT "A" 2132281 BARCLAYS BANK DELAWARE RICHARD D GILBERT 5140218899992976 State of Delaware County of New Castle ] VVynAT7TT I, ?M?j '' M?? , being duly served sworn according to law, depose and say that: 1. I am the authorized representative of the Plaintiff herein and I have custody and control of the files relating to this account; 2. Plaintiff's files are maintained in the usual and ordinary course of business; 3. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 4. There is now due and owing from defendant to plaintiff, the amount of $6,584.97 less credits in the amount of $.00 totaling $6,584.97 as of June 13, 2012. 5. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The 4ibove facts are true and correct to the best of my knowledge, information and belief. Sworn to and Subscribed before, me this ?,iay of L1wyyiI _ , 20 Public P120 Mlc-w LA=J AFF ANT: ? SN 009 see ti.. c®• ?iIG3?.?1t f 2132281 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 O 2814 HAV 15 PH3:/ PEN S YL ANIA ' --BARCLAYS BANK DELAWARE 125 S. West Street Wilmington, DE 19801 vs. RICHARD D GILBERT =207 MULBERRY DR. #B MECHANICSBURG PA 17050-7916 and =Metro Bank =3201 Trindle Rd. Camp Hill, PA 17011 GARNISHEE TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-5193 PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against RICHARD D GILBERT defendant(s)and (2) against Metro Bank garnishee(s) (3) Amount Due Interest from October 9, 2012 Costs Prothonotary fee Sheriff fee (4) Less: Payments on Account 6;)TOTAL (Yal011()„. OU c� 4 -Dv, a N. so kk Li 1 FREDERIC I. WEINB $6,610.04 $.00 JOEL M. FLINK, E 0.../0+0Veittorney for Pla n iff Wk -(4 -/C -sT-StL14 $.00 /IL EdQUIRE THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net BARCLAYS BANK DELAWARE Vs. RICHARD D. GILBERT WRIT OF EXECUTION (Pa R.C.P. 3252) NO 12-5193 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against RICHARD D. GILBERT, 207 MULBERRY DRIVE, #B, MECHANICSBURG, PA 17050 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of METRO BANKGARNISHEE(S), as garnishee, 3201 TRINDLE ROAD, CAMP HILL, PA 17011 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $6,610.04 Interest FROM OCTOBER 9, 2012 Attorney's Comm. % Attorney Paid $187.25 Date: 5/16/14 (Scat) Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs -2c La David D. Buell, Prothonotary REQUESTING PARTY: Name : JOEL M. FUNK, ESQUIRE Address: GORDON & WEINBERG, P.C. 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41200 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson 7;i t_D-O TICS Sheriff OF THE PROTHONOTARY ifr4urr F,r�1 Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE QF THE SHERIFF 2014 4)29 AM 9:27 CUMBERLAND COUNTY PENNSYLVANIA Barclays Bank Delaware vs. Richard D. Gilbert Case Number 2012-5193 SHERIFF'S RETURN OF SERVICE 05/23/2014 11:06 AM - Tim Black, 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, Metro Bank, 20 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Taryn Walters, Store 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 May 29, 2014 to Richard D. Gilbert, 207 Mulberry Drive, # B, Mechanicsburg, PA 17050-7916. May 28, 2014 (c) ;ountySuito Sheriff, Toleosoft, Inc. TIM B ACK, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 q° � 1i 1: BARCLAYS BANK DELAWARE COURT OF COMMON PLEA! , ' i, 'iC J vCI r 125 S . West Street CUMBERLAND COUNTY PLa , S „ Wilmington, DE 19801 `'l vs . DOCKET NO. : 12-5193 RICHARD D GILBERT 207 MULBERRY DR. #B MECHANICSBURG PA 17050-7916 and Metro Bank 3201 Trindle Rd. Camp Hill, PA 17011 GARNISHEE Aikswt,(1 '/(,) INTERROGATORIES IN ATTACHMENT TO: Metro Bank - GARNISHEE You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so my result in judgment against you. 1 . At the time you were served or at any subsequent time did you owe the defendant (s) any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? Defendant has account with a balance of $977.66. Defendant did not receive $300 exemtion. 2 . At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant . no 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest . no 4 . At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant (s) had an interest? no 5. At any time before or after you were served did the defendant (s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefore? no 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant (s) or to any person or place pursuant to his (her, their) direction or otherwise discharge any claim of the defendant (s) against you? no 7 . If you are a bank or other financial institution, at the time you were served or at any subsequent time, did the defendant (s) have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis . no 8 . If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant (s) have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S . §8123? If so, identify each account. no 9. How much is the value of any property in your possession belonging to the defendant (s) ? see answer to question 1 n a FREDERIC I .,*EINBERG, ESQUIRE JOEL M. FLAK, ESQUIRE Attorney fo/ Plaintiff DATED: ��,r 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 Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ArgIli A • RE) 2132281 GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 BARCLAYS BANK DELAWARE COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs . DOCKET NO. : 12-5193 RICHARD D GILBERT and Metro Bank Garnishee NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT UPON ADMISSIONS HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL FREDERIC I. WEINBERG, ESQUIRE AT 484/351-0500 2132281 GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 BARCLAYS BANK DELAWARE COURT OF COMMON PLEAS 125 S. West Street CUMBERLAND COUNTY Wilmington, DE 19801 VS . DOCKET NO. 12-5193 C RICHARD D GILBERT _ and Metro Bank E' Garnishee � 7 r � .r-7 PRAECIPE FOR JUDGMENT UPON ADMISSION Y ` TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff, BARCLAYS BANK DELAWARE and against the Garnishee, Metro Bank, in the amount of $677 . 66, admitted in the Answer to Interrogatories to be in the Garnishee ' s possession, together with interest and costs which is not more than the amount of the judgment of the Plaintiff against the Defendant together with post judgment costs and post judgment interest which is $6, 789. 04 . Date: GORDON & WEINBERG, P.C. BY: FREDER C I . WE NBERG, ESQUIRE ,,,,> JOEL M. , ESQUIRE 150 f p a' ' 7 Attorney for Plaintiff 00a85°7q &307W3 NACe mai led CORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE , Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 BARCLAYS BANK DELAWARE COURT OF COMMON PLEAS 125 S . West Street CUMBERLAND COUNTY Wilmington, DE 19801 vs. DOCKET NO. 12-5193 RICHARD D GILBERT 207 MULBERRY DR. #B MECHANICSBURG PA 17050-7916 and Metro Bank 3201 Trindle Rd. Camp Hill, PA 17011 GARNISHEE INTERROGATORIES IN ATTACHMENT TO: Metro Bank - GARNISHEE You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so my result in- judgment against you. 1 . At the time you were served or at any subsequent time did you owe the defendant (s) any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant f o r any reason? Defendant has account with a balance of $977.66. Defendant did not receive $300 exemtion. 2 . At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. no 3 . At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest. no 4 . At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant (s) had an interest? no 5. At any time before or after you were served did the defendant (s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the �-- consideration therefore? no �6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant (s) or to any person or place pursuant to his (her, their) direction or /c otherwise discharge any claim of the defendant (s) against you? no 7 . If you are a bank or other financial institution, at the time you were served or at any subsequent time, did the defendant (s) have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis . no 8 . , If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant (s) have . funds on deposit in an account in which the funds on deposit.. not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C. S. §8123? If so, identify each account. no 9'. How much is the value of any property in your possession belonging to the defendant (s) ? see answer to question 1 FREDERIC I . �.IN�ERG, ESQUIRE JOEL M. FLIiIJK, ESQUIRE Attorney fo/ Plaintiff DATED: tk 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 Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set,forth in the foregoing Answers to interrogatories are true and correct to the best of his/her knowledge, information and belief. (SI AT RE) 2132281 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 OF' 011 Q T �.r I r� PeNNSYLVANIA BARCLAYS BANK DELAWARE vs. RICHARD D GILBERT and Metro Bank Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-5193 ORDER TO SATISFY JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly mark the judgment entered against garnishee Metro Bank in the above -captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: P013 FREDERIC I. BERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff �f .89.s7 j)1 w fid, ejal 6?9v 2.{008la3 2132281 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 BANK DELAWARE vs. RICHARD .D GILBERT r •L'_L.) THE PPOTHOt�,IO1r4,,, JUL 18 PM 12: CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 12-5193 ORDER TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the judgment entered October 9, 2012 in the above -captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: P005 FREDERIC I. WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 709. s-0 -?,1,941y cel .2soz3 �30.el Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY •.'r:l'i 1 Z rr J• C`:'J13E LAHLl;;'.,t PENNSYLVANIA Barclays Bank Delaware vs. Case Number Richard D. Gilbert 2012-5193 SHERIFF'S RETURN OF SERVICE 05/23/2014 11:06 AM - Tim Black, 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, Metro Bank, 20 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Taryn Walters, Store 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 May 29, 2014 to Richard D. Gilbert, 207 Mulberry Drive, # B, Mechanicsburg, PA 17050-7916. 01/08/2015 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, plainitiffs attorney did file a praecipe for judgment upon admission against Garnishee, Metro Bank, in the amount of $ 677.66. SHERIFF COST: $101.06 SO ANSWERS, January 08, 2015 (c) CeuntySuro Sheri tt, Teleosott, Inc. RONNY R ANDERSON, SHERIFF l THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net BARCLAYS BANK DELAWARE Vs. RICHARD D. GILBERT WRIT OF EXECUTION (Pa R.C.P. 3252) NO 12-5193 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against RICHARD D. GILBERT, 207 MULBERRY DRIVE, #B, MECHANICSBURG, PA 17050 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of METRO BANKGARNISHEE(S), as garnishee, 3201 TRINDLE ROAD, CAMP HILL, PA 17011 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $6,610.04 Interest FROM OCTOBER 9, 2012 Attorney's Comm. % Attorney Paid $187.25 Date: 5/16/14 (Seal) REQUESTING PARTY: Name : JOEL M. FLINK, ESQUIRE Address: GORDON & WEINBERG, P.C. 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41200 Plaintiff Paid Law Library $30 Due Prothonotary $2.25 Other Costs .41,v-4c��� David D. Buell, Prothonotary TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the s al of said Court at Carlisle, Pa. This IV day of ___, 20 Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law Q 2