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HomeMy WebLinkAbout04-6420PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) PA Supreme Court Rule of Civil Procedure 3101 to 3149 Commonwealth Financial Systems, Inc. In the Court of Common Pleas of Cumberland Plaintiff County, Pennsylvania, Civil Division Vs. JANET A ADAMS 315 HEMLOCK RD MECHANICSBURG, PA 17055 vs Citizens Bank 255 Cumberland Pkwy Mechanicsburg, PA Defendant(s) Nob K 4 PRAECIPIE FOR WRIT OF EXECUTION AND ATTACHMENT (MONEY JUDGMENT) Garnishee To the Prothonotaryr TO SATISFY THE JUDGMENT, ISSUE WRIT OF EXECUTON IN THE ABOVE MATTER (1) Directed to; the Sheriff of Cumberland County, Pennsylvania; (2) Against NET A ADAMS, 315 HEMLOCK RD. MECHANICSBURG, PA 17055 Defendant(s) (3) And against Citizens Bank 255 Cumberland Pkwy Mechanicsburg, PA (4) and index this writ (a) against; Garnishee(s); Defendant(s) (b) against Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s), 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): 184-52-0811; (5) Judgment Amount $?Q Interest Q ! Clerks Fee Sheriff Poundage Total l^ Dated 1?- ia-a;- JU Patricia A. Cobb, Esq. Attorney for Plaintiff G T U? v 5L, .? ? J.., (.a !u G> WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N004-6420 Civil CIVIL ACTION - LAW TO T14E SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COMMONWEALTH FINANCIAL SYSTEMS INC Plaintiff (s) From JANET A ADAMS 315 HEMLOCK ROAD, MECHANICSBURG, PA. 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) Ylou are also directed to attach the property of the defendant(s) not levied upon in the possession of CPIjIZENS BANK 255 CUMBERLAND PKWY, MECHANICSBURG, PA i GARNISHEE(S) as follows: ANY AND ALL ACCOUNTS OF THE DEFENDANT IN THE POSSESSION OF GARNISHEE, INCLUDING BUT NOT LIMITED TO SAVINGS ACCOUNT BALANCES; CHECKING ACCgUNT BALANCES; CERTIFICATES OF DEPOSIT; MONEY MARKET ACCOUNTS; CON' ENTS OF SAFETY DEPOSIT BOXES. DEFENDANTS SSN 184-52-0811 and to otify 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 any?ne 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 $ 5,118.43 L.L.$ 0.50 Interest $ 69.03 Atty's Comm % Due Prothy $1.00 Atty Paid $ 37,25 Plaintiff Paid Date: AUGUST 2, 2005 Other Costs '*7 (Seal) By: Deputy REQUESTING PARTY: Name PATRICIA A COBB ESQUIRE Address: 120 N KEYSER AVENUE SCRANTON, PA 18504 Attorney for: PLAINTIFF Telephone: (570) 347-1115 EXT 202 Supreme Court ID No. 39688 In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Division Commonwealth Financial Systems, Inc. 120 N. Keyser ;Avenue Scranton, PA 118504 Plaintiff File No: 04-6420 Vs. Janet A. Adams : 315 Hemlock Ind. : Mechanicsburg, PA 17055 Defendant (s) Vs. Citizens Bank 255 Cumberland Pkwy Mechanicsburg, PA Garnishee (s) Praecipe for Entry of Appearance Kindly enter my appearance on behalf of Commonwealth Financial Systems, Inc. in the above- captioned matt$r. Date: TA-Og?;- Signature: LU?A' C&u' Print Name: 6(&.o4 'M- 0)06- Address: 120 N. Keyser Avenue Scranton, PA 18504 Telephone No: (570) 347-1115 ext. 202 Supreme Court ID No: 39688 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N004-6420 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COMMONWEALTH FINANCIAL SYSTEMS INC Plaint#ff (s) From ; JANET A ADAMS 315 HEMLOCK ROAD, MECHANICSBURG, PA. 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) Yjou are also directed to attach the property of the defendant(s) not levied upon in the possession of CItIZENS BANK 255 CUMBERLAND PKWY, MECHANICSBURG, PA GARNISHEE(S) as follows: ANY AND ALL ACCOUNTS OF THE DEFENDANT IN THE POSSESSION OF GARNISHEE, INCLUDING BUT NOT LIMITED TO SAVINGS ACCOUNT BALANCES; CHECKING ACCOUNT BALANCES; CERTIFICATES OF DEPOSIT; MONEY MARKET ACCOUNTS; COMMENTS OF SAFETY DEPOSIT BOXES. DEFENDANTS SSN 184-52-0811 and to notify the gamishee(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) 14 property of the defendant(s) not levied upon an subject to attachment is found in the possession of any I ne 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 $ 5,118.43 L.L.$ 0.50 Interest $ 69.03 Atty's;Comm % Due Prothy $1.00 Atty P4id $ 37,25 Plaintiff Paid Date: AUGUST 2, 2005 (Seal) REQUESTING PARTY: Name !YATRICIA A COBB ESQUIRE Address: 120 N KEYSER AVENUE SCRANTON, PA 18504 Attorney for: PLAINTIFF Telephone: (570) 347-1115 EXT 202 Supreme Court ID No. 39688 Other Costs Prothonota By: Deputy R. Thomas Kline, Sheriff, who being duly sworn ;acc i, g to law, states this Writ is returned ABANDONED, no action taken in six'rrimnths. Sheriff's Costs: _ Adce Costs: 150.00 Sheriff's Costs 90.50 Docketing 18.00 59.50 Poundage 1.60 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 5/12/06 Mileage 10.40 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL. 90.50 Sworn and Subscribed to before me ers; this day R. Thomas Kline, Shefiff 2w6-A.D. By Prothonotary i SHFRT7•^`S RETURN - GARNISHEE CASE NO: 2004-06420 p COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND COMMONWEALTH FINANCIAL SYSTEMS MS VS ADAMS JANET A And now BRIIAN BARRICK Cumberland Sheriff or Deputy Sheriff of County of Pennsylvania, who bein to law g duly sworn according at 0014_48 Hours, on the 24th day of August as herein commanded ' 2-005, attached all goods, chattels, ri hts moneys of the g , debts, credits within named DEFENDANT and ADAMS JANET; A hands, possession in the , or control of the within named CITIZENS BASK 255 Garnishee CUMBERLAND PKWY MECHANICS,B PA 17055 Cumberland county, Pennsylvania, by handing to FAY PHARO-F K (ASST MANAGER) personally three copies of ' interogatories together with _ and attested co 3 true pies of the within WRIT OF EXECUTION the contents there of known to Her and made Sheriff's Costs: Docketing So answers: Service •0C Affidavit .00 Surcharge .00 Thomas .00 Sheriff Klin . 00 of Cumbers .00 08/25/2005 Sworn and subscribed to before me this dajy of BY A.D.' P othonot r R y ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION COMMONWEALTH FINANCIAL SYSTEMS, INC Plaintiff(s ), VS. JANET A. ADAMS Defendant(s), VS. CITIZENS BANK OF PA, Garnishee. Docket No. 04-6420 Answers to Interrogatories Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of PA Counsel of Record for this Party: Nicholas Deenis, Esquire PA I.D. NO. 62378 Stradley, Ronon, Stevens & Young LLP 2600 One Commerce Square Philadelphia, PA 19103 (215) 564-8142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION COMMONWEALTH FINANCIAL SYSTEMS, INC Plaintiff(s) vs. JANET A. ADAMS Defendant(s) and CITIZENS BANK OF PA, Garnishee. No. 04-6420 ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of PA responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1 to 9) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of PA, provides the following Answers to Interrogatories: The Parnishee, Citizens Bank of PA, states that it maintains a checking account in the name of tho' Defendant, Janet A. Adams, held jointly by the entireties and therefore not subject to attachment. f.. - c un a U Commonwealth Financial Systems, Inc. In the Court of Common Pleas of 120 North Keyser Avenue Cumberland County Pennsylvania, Civil Scranton, PA 18504 Division Plaintiff Vs. No: 04-6420 Janet A. Adams 315 Hemlock Rd. Mechanicsburg, PA 17055 Praecipe to Dissolve the Attachment Defendant Vs. Citizfns Bank 255 Cumberland Pkwy Mechanicsburg, PA Garnishee To the Prothonotary of Cumberland County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment. Thank you, atrieia A. Cobb, Esquire Lawyer ID # 39688 Com*nwealth of Pennsylvania Lackawanna County --- Sworn and subscribed before me on this uhay of 20!?? <50? Public EOOFF OTARIAL SEAL ENNIFER LOEH Notary Public ON. LACKAWANNACOUNTY ssion Expires Mar 2, 2009 ? nV (_ L f? ?p ? c- S ? ? ?. _ ?1 k. J ?? _ ? '? ? I ?~ ??? ? ? T '. 1 ??ey y La7 ?- _ ?Fv V •• ' i `"? • ? .AJ •?