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Home My WebLink About12-6520Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERti' ASSOCIATES LLC c/o Blati:, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. JOHN RUBY 432 FACTORY ST CARLISLE PA 17013 Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA !, CIVIL ACTION n r `3 ~ No. - - -. ~~_~ ,- NOTICE TO DEFEND You have been sued) in court. If you wish to defend against the claims set forth in the following pages, you mu:~t 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 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.. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 e ~~ '<...®~ U~~ ~S ~~~ ' ~ ~ !' I~l~- ~ g s ~~ 2780820 p PPTCPADI (~ (~-- a 0 p~ ~~`' AVISO Le han demandado a usted en la torte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte Bias de plazo al partir de la fecha de la demanda y la notification. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la torte tomara medidas y puede continuar la demanda en contra suva sin previo aviso 0 notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas la.s provisioner de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAY'A EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTFN BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Blatt, Flasenmiller, Leibsker & Moare, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, HasenmillE~r, Leibsker & Maore, LLC Plaintiff, vs. JOHN RUBY 432 FACTORY ST CARLISLE PA 17013 Defendant(s). IN THE COURT C)F COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. COMPLAINT Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC, claims as follows: 1. The Defendant(s), JOHN RUBY , is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with GE CAPITAL RETAIL BANK, (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. Tne Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $3415.48. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2780820 PPTCDBCI WHEREFORE, the Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, prays for judgment in its favor and against Defendant(s), JOHN RUE3Y in the amount of $3415.48, plus costs. Respectfully submitted, PORTFOLIO RECOVERY ASSOCIATES LLC ~; ~~ One o its At rneys Morris Scot Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 (800) 850-1079 Dated: October 16, 2012 Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. JOHN RUBY 432 FACTORY ST CARLISLE PA 17013 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Morris ;>cott/Syretta Martin, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. 1 hereby certify that the Defendant is at least '18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information., knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.,A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: October 16, 2012 ~,,~ , By: ---- IV(orris ott Syrett Martin 2780820 PPTJCAM I I IIIIIII IIIIII IIII VIII III IIIIII VIII VIII VIII VIII VIII VIII IIII VIII IIII VERIFICATION the undersigned attorney for the Plaintiff, hereby verify i:hat the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is present y located outside of this jurisdiction, and that in order to file the vuithin document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. / .~ f PPTXVE.RI Exhibit "A" PPTXEX.AI ~7 ~~~20 VERIFICATION LTo be used by a r~erson associated with the present creditor) I, Evita Rodriguez ,hereby verify that: 1. I am employed by Portfolio Recovery Associates, LLC as Custodian of Records and am authorized to make this Verification on behalf of Portfolio Recovery Associates, LLC. Portfolio Recovery Associates, LLC is the successor in interest to GE CAPITAL RETAIL BANK/LOWE3. 2. I reviewed the following [ ](a) computerized documents; [ J(b) hard copy documents; and [xJ (c) other (specify)Account Records relating to Account number: ending in 5341. The foregoing Account of G$ CAPITAL RETAIL BANK/LOW83 was opened on 1/16/2008 in the name of JOHN RUBY. The accounts/documents that I reviewed were produced by GS CAPITAL RETAIL BANK/COWES. 3. Based on my review of the foregoing documents, there is due and payable the principal sum of $3,415.48. This sum includes the following (check all that are appropriate): [xj interest; [xJ late fees; [ collection fees; and [xJ any other additional fees permitted under the terms of the agreement with the debtor named in paragraph 2 above and GS CAPITAL RETAIL BANK/LOWE3. This sum does not include the following (check all that are appropriate): [ J interest; [, ]late fees; [xJ collection fees; and ( ]any other additional fees permitted under the terms of the agreement with the debtor named in paragraph 2 above and GS CAPITAL RETAIL BANK/COWES. 4. Based on my review of the foregoing documents, there are no payments that have not been credited. 5. The facts set forth in this Verification are true and correct to the best of my knowledge, information and belief. This Verification is made subject to the penalties for making an unsworn falsification to authorities in violation of 18 Pa. C.S. §4904. DATE ~~ Ev~aR°d'ipuez ,CUSTODIAN F~~ ~ r. ~~ Blatt, Hasenmiller, Leibsker & Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-5641-1567 Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC PORTFOLIO RECOVERI' ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. JOHN RUBY 432 FACTORY ST CARLISLE PA 17013 Defendant(s). IN THE COURT OF COMMON PLEAS PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC. P~~pers may bE~ served at the address set forth below: Blatt, Hasenmiller, LeibskE~r & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Telephone Number: 1-215-564-1567 Dated: October 16, 2012 BLATT, HASENMILLER, LEIBSKER & MOORE, LL.C ,. ,, ~~~' BY~ -- orris ott Attorney Syrett Martin Attorney 2780820 PPTXF'EAI I IIIIIIII IIII III IIIIII VIII VIII VIII VIII VIII VIII IIIIII III IIII SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Andersan Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor .;~~~~~' v ~? . , , L~~IZ~dt~b' --~ ~~ ~0~ ~'7 Portfolio Recovery Associates, LLC vs. Case Number John A. Ruby 2012-6520 SHERIFF'S RETURN OF SERVICE 10/25!2012 11:24 AM -Deputy Robert Bitner, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be KATHRINE SMILEY-FRIEND, who accepted as "Adult Person in Charge" for John A. Ruby at 432 Factory Street, Carlisle Borough, Carlisle.. F'A 17013. RO ERT BITNER, DEPUTY SHERIFF COST: $34.00 November 01, 2012 SO ANSWERS, RON - R ANDERSON, SHERIFF Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION Vs. No. 12-6520-CIVIL a r JOHN RUBY G7 r 432 FACTORY ST rn ' CARLISLE PA 17013 c 7 ~; Defendant(s). -< cn ` �O 4 Cyr —4 PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT cD FOR FAILURE TO PLEAD `= ' TO THE PROTHONOTARY: Kindly ENTER a Judgment by Default For Failure to Plead in favor of the plaintiff and against the Defendant JOHN RUBY in this matter in the amount of $2653.23 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 11/20/2012 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, BLATT, HASENMILLER, LEIBSKER & MOORE - C Dated: July 2, 2013 By: M• is Scott Syretta Martin 2780820 M 2 1 4112 , PPTJPFJI a (� I1111111111111111111111 III 11111111111111111111111111I111111111111111 1111111 Ps 8 ttaq Notiw a• rnad& PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PA vs. JOHN RUBY CIVIL ACTION 432 FACTORY ST No. CARLISLE PA 17013 Defendant(s). No. 12-6520-CIVIL TO: JOHN RUBY NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. PROTHONO,RY eftis orp 'J4' Dated: 7WAS By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker& Moore, LLC Morris Scott Attorney I.D. #83587 Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 2780820 PPTNDJNI III 11111 111111 1111 11 111 111 111111 11111 11111 11111 11111 11111 11111 1 111 11111 101 Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS 1835 Market Street, Suite 501 Philadelphia, PA 19103 CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. No. 12-6520-CIVIL JOHN RUBY 432 FACTORY ST CARLISLE PA 17013 Defendant(s). AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Cumberland: I, Morris Scott/Syretta Martin, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorized to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant(s) is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. See Defendant(s) Military Status Report pursuant to 50 U.S.C. App. Section 521, 525 which was obtained from the Department of Defense Manpower Data Center (https://www.dmdc.osd.mil/appj/scra/). I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILLER, LEIBSKER & MO. , L►C Dated: July 2, 2013 By: _ cott Syretta Martin 2780820 PPTJCAMI (06/28/2013) 1111111 11111 111111 I I I I I I 111111 11111 11111 11111 11111 11111 11111 11111 1 1 13 PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, IN THE COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY, PA JOHN RUBY CIVIL ACTION 432 FACTORY ST CARLISLE PA 17013 No. 12-6520-CIVIL Defendant(s). TO: JOHN RUBY Date of Notice: November 20,2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER.IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Sear By: Morris Scott Syretta Martin 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2780820 PPTNLRSI 111111111111111 111111 1111111111 111111111111111 111111111111 1 1 1111 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS Plaintiff, vs. CUMBERLAND COUNTY, PA JOHN RUBY CIVIL ACTION 432 FACTORY ST CARLISLE PA 17013 Defendant(s). No. 12-6520-CIVIL AND . <.:- y- MEMBERS 1ST FCU ``� 5000 LOUISE DRIVE . C1 MECHANICSBURG, PA 17055 = cp Garnishee _ -��° - - PRAECIPE FOR WRIT OF EXECUTION ? . � — :r? TO THE PROTHONOTARY: Kindly ISSUE a WRIT OF EXECUTION in the above matter, directed to the Sheriff of Cumberland County: (1) directed to the sheriff of Cumberland County; (2) against JOHN RUBY defendant[s]; and - . (3) against MEMBERS 1ST FCU garnishee[s]; rn ri`� .,- (4) and enter this writ in the judgment index :=�= (a) against JOHN RUBY Defendant r. r: (5) Amount due $ ,(4- g3 t""-'`° Interest from $ 5 9 -g0 mac-. ...1. rte_, ca 07-05-13 — Costs to be added $ c_y 9 Q,1,AAUN11� n Morris Scott #83587 3y. 66 eier Syretta Martin #309370 U /( Ir Attorney for Plaintiff / SO r� , -3-77g. ,2S-7717) -a--Ob .A10a,Psi-ni (al 44, Sa L.C.- 2780820 c �a�ej r PPTGPWEI o _ zi.7._ el4 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-6520 Civil COUNTY OF CUMBERLAND) CIVIL ACTION–LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES,LLC C/O BLATT,HASENMILLER, LEIBSKER& MOORE, LLC Plaintiff(s) From JOHN RUBY,432 FACTORY STREET,CARLISLE, PA 17013 (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: MEMBERS 1ST FCU,5000 LOUISE DRIVE,MECHANICSBURG,PA 17055 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$2,653.23 Plaintiff Paid$ Interest FROM 7-5-13-$59.90 Attorney's Comm. % Law Library$.50 Attorney Paid$183.25 Due Prothonotary$2.25 Other Costs$ Date: 11/18/13 /� —_- _ David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : MORRIS SCOTT,ESQUIRE BLATT,HASENMILLER,LEIBSKER& MOORE,LLC Address: 1835 MARKET STREET,SUITE 501 PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-1567 Supreme Court ID No. 83587 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS c/o Blatt, Hasenmiller, Leibsker & Moore, LLC CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION vs. No. 12-6520-CIVIL JOHN RUBY 432 FACTORY ST CARLISLE PA 17013 Defendant(s). r_fs , MEMBERS 1ST FCU CO', N? 5000 LOUISE DRIVE -- .- -„ MECHANICSBURG, PA 17055 r�r1 Garnishee U 1 i'SV\JU s Interrogatories to Garnishee To MEMBERS 1ST FCU, Garnishee: You are required to file Answers to the following Interrogatories within 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 subsequent time did you owe the defendant any money or were you liable to the defendant on any? 0 2. At the time you were served or any subsequent time thereafter, was there in your possession, custody, control or in 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? 4e,s, 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(s) or in which the defendant held or claimed any interest? 1.D C7 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 any interest? IVY 2780820 PPTGBKCI 1 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? I V b 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 defendant's direction or otherwise discharge any claim of the defendant(s) against you? k\ 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 amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. Q 8. 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 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 Sec.8123? If so, identify each account. Vim' izi- 9. How much is the value of any property in your possession belonging to the defendant(s)? 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. Morris Sco-t , Attorney No. 83587 Syretta Martin, Attorney No. 309370 Verification I, 4-\\AO. } �C�� the undersigned representative of MEMBERS 1ST FCU, hereby verify that the answer to interrogatories are true and correct to the best of my knowledge, information, and belief based upon information I have. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. OUL__ C) r Y Cr) SHERIFF'S OFFICE OF CUMBERLAND COUNTY-"az rnul re, .7.,- Ronny R Anderson „ ; Sheriff arty �t `rt° e ;' Jody S Smith 4,4 'r Chief Deputy W Stewart v _ ` Solicitor r� �� ;. F;.1Fr _ Portfolio Recovery Associates, LLC vs. Case Number John A. Ruby 2012-6520 SHERIFF'S RETURN OF SERVICE 11/27/2013 09:33 AM - Brian Grzyboski, 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Jan Finkle- Member Service Representative , 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 December 2 2013 to John Ruby at 432 Factory Street, Carlisle, PA 17013. . � • f/-3f BRIAN GRZY: ,D7 UTY SO ANSWERS, December 02, 2013 RONNY ANDERSON, SHERIFF f `, osc. 'c Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 ff)k4 PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS c/o Blatt, Hasenmiller, Leibsker & Moore, LLC CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION w vs. ti No. 12-6520-CIVIL JOHN RUBYQ !:t 432 FACTORY STS Cl) CARLISLE PA 17013 N� . Defendant(s). � � -- C o MEMBERS 1ST FCU 2C? �.. 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 Garnishee Interr gatories to Garnishee To MEMBERS 1 ST FCU, Garnishee: You are required to file Answers to the following Interrogatories within 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 subsequent time did you owe the defendant any money or were you liable to the defendant on any? ��(J' 2. At the time you were served or any subsequent time thereafter, was there in your possession, custody, control or in 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? 4e—S' 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(s) or in which the defendant held or claimed any interest? Q o 4. At the time you were served or at any subsequent time did you hold as fiduciary any property I in which the defendant(s) had any interest? jai U 2780820 PPTGBKCI 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? 1 C) 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 defendant's direction or otherwise discharge any claim of the defendant(s) against you? A 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 amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. (jam` Q 8. 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 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 Sec.8123? If so, identify each account. P,, C) 9. How much is the value of any property in your possession belonging to the defendant(s)? 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. � 4h ?Jt D �! n L � Morris eSce, Attorne)vy No. 83587 Syretta Martin, Attorney No. 309370 Verification the undersigned representative of MEMBERS 1STFCU, hereby verify that the answer to interrogatories are true and correct to the best of my knowledge, information, and belief based upon information I have. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. CU, Av.WV_ N A e 44- Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS c/o Blatt, Hasenmiller, Leibsker & Moore, LLC CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION VS. No. 12-6520-CIVIL «...- JOHN RUBY W 432 FACTORY ST am'? "'I CARLISLE PA 17013 {11 r" Defendant(s). cc MEMBERS 1ST FCU " 5000 LOUISE DRIVE 1' C.: I>) MECHANICSBURG, PA 17055 --- Garnishee -nsll ,.S 4 Interrogatories to Garnishee To MEMBERS 1ST FCU, Garnishee: You are required to file Answers to the following Interrogatories within 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 subsequent time did you owe the defendant any money or were you liable to the defendant on any? 2. At the time you were served or any subsequent time thereafter, was there in your possession, custody, control or in 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? — C;,.. 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(s) or in which the defendant held or claimed any interest? IV 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 any interest? 2780820 0-c) PPTGBKCI w✓.c 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? C7 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 defendant's direction or otherwise discharge any claim of the defendant(s) against you? fs4 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 amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. \ O 8. 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 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 Sec.8123? If so, identify each account. 3oO 9. How much is the value of any property in your possession belonging to the defendant(s)? I 0(00. (o ff 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. Morris Scot , Attorney No. 83587 Syretta Martin, Attorney No. 309370 {•-.d 4 i Verification I, N CCUA the undersigned representative of MEMBERS 1ST FCU, hereby verify that the answer to interrogatories are true and correct to the best of my knowledge, information, and belief based upon information I have. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. acji_Q__________ qsa Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC IN THE COURT OF COMMON PLEAS Plaintiff, vs. CUMBERLAND COUNTY, PA JOHN RUBY 432 FACTORY ST CIVIL ACTION CARLISLE PA 17013 Defendant(s). No. 12-6520-CIVIL AND 77: members 1st C*) 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 Garnishee k r .. ,- PRAECIPE TO DISSOLVE ATTACHMENT c-) Z.O := To the Prothonotary: Kindly mark the Writ of Execution against members 1st as DISSOLVED, and the attachment as DISSOLVED. Respectfully submitted, Morris Sco Syretta Martin a 2780820 G I 99 PPTXWPDI Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF THE $HERJFF THE r RO HONC 1: tr' SUN 16 PM 2: 35 CUMBERLAND COUN! `Y PENNSYLVANIA Portfolio Recovery Associates, LLC vs. John A. Ruby Case Number 2012-6520 SHERIFF'S RETURN OF SERVICE 11/27/2013 09:33 AM - Brian Grzyboski, 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Jan Finkle - Member Service Representative , 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 December 2, 2013 to John Ruby at 432 Factory Street, Carlisle, PA 17013. 06/13/2014 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. SHERIFF COST: $88.76 SO ANSWERS, June 13, 2014 (c) CountySuite Sheriff, Teleosoft. Inc. RONWR ANDERSON, SHERIFF 9(777