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HomeMy WebLinkAbout12-6573)f , Andrew Sklar, Esquire (ID#65332) Lloyd S. Markind, Esquire (ID #52507) Jordan W. Felzer, Esquire (ID #38670) Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: FT110661 Attorneys for Plaintiff t:'l I? CC T 22 PH 3: 13 NBEFIAND COUNT)` NINS1'LVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY No. 06-5553 Plaintiff(s) I I Term I V. CIVIL ACTION MICHAEL E SR GARLAND 620 GUTSHALL ROAD ?v? V s BOILLING SPRINGS PA 17007 Defendant(s) I I I PRAECIPE TO ISSUE WRIT OF REVIVAL OF JUDGMENT To the Prothonotary: Issue writ of revival of judgment in the above-entitled cause and index it in the judgment index against: MICHAEL E SR GARLAND, Defendant(s) in the amount of 14332.38 with interest from October 18, 2007. Date: October 12; 2012 %3?.SO?A Q. lu Ci `7 1 Iv any 413 0 r 5a?s a?aa-7 0 rda ew Sklar, Esquire (ID #65332) S. Markind, Esquire (ID$52507) n W. Felzer, Esquire (ID #38670) Attorneys for Plaintiff 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Vs. CIVIL ACTION LAW MICHAEL S. SR. GARLAND 620 GUTSHALL ROAD BOILING SPRINGS, PA 17007 No 12-6573 CIVIL TERM WRIT OF REVIVAL TO: MICHAEL S. SR. GARLAND, You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to No. 06-5553 Civil Term The Plaintiff claims that the amount due and unpaid is $14,332.38 with interest from OCTOBER 18, 2007. You are required within twenty (20) days after service of this Writ to file an answer or otherwise, plead to this Writ. If you fail to do so, Judgment of revival will be entered. Costs $ 137.16 PD ATTY $ 2.25 DUE CO David D. Buell, Prothonotary Date October 22, 2012 (Seal) Deputy , ANDREW SKLAR, ESQUIRE - ATTORNEY #65332 Attorney for the Plaintiff SKLAR- MARKIND, 102 BROWNING LANE, BLDG B, STE 1, CHERRY HILL, NJ 08003 856-616-8710 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Ford Motor Credit Company vs. Michael E. Garland. Sr. ,,,, ~~ ~ ''~#~tTr~ ;4 ~'~~ '+7 Pia ,, ~. A~ t0= 07 i~'r"~'~SYi.Vq~l,~ ;, Case Number 2012-6573 SHERIFF'S RETURN OF SERVICE 10/26/2012 07:03 PM -Deputy Noah Cline, being duly sworn according to law, served the requested Writ of Revival by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Michael E. Garland, Sr. at 7 Louis Lane, East Pennsboro Township, Enola, PA 17025. .r ~ ..-- ,.~~:` ~ NOAH CLINE, DEPUTY SHERIFF COST: $43.;)0 November 01, 2012_ SO ANSWERS, ~f~( J 7 ~` RONNY R ANDERSON, SHERIFF Lloyd S. Markind, Esquire (ID#52507) Jordan W. Felzer, Esquire (ID#38670) SKLAR—MARKIND PILFS'CFFiCE 102 Browning Lane, Building B, Suite 1 OF THE PROTKOIqOTARY Cherry Hill, New Jersey 08003 2013 APR 8 (856) 616-8710 PM 3: �8 Attorney for Plaintiff(s) CUMBERLAND C ��. Our File Number: FT 110661 PENNSYLVA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW FORD MOTOR CREDIT COMPANY : No. 12-6573 Plaintiff TERM vs. CIVIL ACTION MICHAEL E GARLAND SR. Defendant PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the attachment as to garnishee, M&T Bank, in the above captioned action. Date: Andrew Sklar, Esquire (ID #65332) Lloyd S. Markind, Esquire (ID #52507) Jordan W. Felzer, Esquire (ID #38670) Attorneys for Plaintiff _ Sklar—Markind 102 Browning Lane, Bldg B, Suite 1 Cherry Hill, NJ 08003 (856) 616-8710 phone (856) 616-8716 fax 0,b4 Il3as "),, znvi SHERIFF'S OFFICE OF CUMBERLAND COUNTY HE mny RAnderson tf`� [ O- (rry' ipry sheriff �*"r of clurlb,c,.x�f Jody S Smith 7-00 SEP _5 Ply 2; 53 Chief Deputy Richard W Stewart ° CUMBERLAND COW a' Solicitor OFF CE OF THE SKRIF.= PENNSYLVANIA Ford Motor Credit Company Case Number vs. 2012-6573 Michael E. Garland, Sr. SHERIFF'S RETURN OF SERVICE 01/31/2013 10:25 AM-William Cline, Deputy Sheriff,who being duly sworn according to law, states that on January 31, 2013 at 1020 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Michael e. Garland Sr., in the hands, possession, or control of the within named garnishee, M &T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania, by handing to Joan Crowl,Teller, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on February 1, 2013 to Michael E. Garland Sr., at 7 Louis Lane, Enola, PA 17025-2125. 09/04/2013 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: $90.69 SO ANSWERS, September 04, 2013 RON R ANDERSON, SHERIFF <<,i CnunrySwte henti,?e:eosoft. nc. 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY 1335 S. Clearview Avenue Mesa, AZ, 85209 Plaintiff(s) v. MICHAEL E GARLAND SR. 7 LOUIS LN ENOLA PA 17025-2125 Defendant(s) v. M&TBANK 100 SOUTH SPRING GARDEN ST CARLISLE, PA 17013 Garnishee(s) No. 12-6573 CIVIL ACTION PRAECIPE FOR WRIT OF EXECUTIO1 (Money Judgment) rte rr r- n E CD 1> CD Q w 7j r T . CD CD * TO THE PROTHONATORY: (1) Issue writ of execution in the above matter, directed to the Sheriff of CUMBERLAND County, against MICHAEL E GARLAND SR. , defendant(s) (2) and against, M & T BANK, 100 SOUTH SPRING GARDEN ST, CARLISLE, PA 17013 garnishee. AMOUNT DUE INTEREST from: October 18, 2007 PLUS COSTS Dated: June 3, 2014 FILE NO.: FT110661 ayA $09.°° pd. a it .(q D C.6F� 3.OO "et cools u $14,332.38 $5,646.48 Lloyd arkind, Esquire (ID #52507) Attorneys for Plaintiff Markind Law Group, P.C. 102 Browning Lane, Building B, Suite 1 Cherry Hill, New Jersey 08003 (856) 616-8710 9.56(1 s 3/`ci a J ua y: sc: etitaoygyg# S61 318 tOd oF&Ts5.od 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 FORD MOTOR CREDIT COMPANY Vs. MICHAEL E. GARLAND SR. WRIT OF EXECUTION (Pa R.C.P. 3252) NO 12-6573 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against MICHAEL E. GARLAND, SR., 7 LOUIS LANE, ENOLA, PA 17025-2125 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 M&T BANKGARNISHEE(S), as garnishee, 100 SOUTH SPRING GARDEN STREET, CARLISLE, PA 17013 (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 $14,332.38 Plaintiff Paid Interest FROM OCTOBER 18, 2007 - $5,646.48 Law Library $.50 Attorney's Comm. % Due Prothonotary $1.300: Attorney Paid $338.35 Other Costs .2LLAlL Date: 6/16/14 t"cat) David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : LLOYD S. MARKIND, ESQUIRE Address: MARKIND LAW GROUP, P.C. 102 BROWNING LANE, BUILDING B, SUITE 1 CHERRY HILL, NJ 08003 Attorney for: PLAINTIFF Telephone: 856-616-8710 Supreme Court ID No. 52507 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW ] . $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 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY (F'FiCE OF THE SH....RIFF THE P CO ttc 2OtiiSSP -2 PM 3:56 rUMB NNSYLVAN A COUNTY PE Ford Motor Credit Company Case Number vs. Michael E. Garland, Sr. 2012-6573 SHERIFF'S RETURN OF SERVICE 08/28/2014 02:52 PM - Shawn Gutshall, 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, M & T Bank, 960 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Jessica L Reese, Relationship Banker, personally threecopies 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 August 29, 2014 to Michael E Garland, Sr. at 7 Louis Lane, Enola, PA 17025-2125. SO ANSWERS, EPUTY August 29, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleo TN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY : No. 12-6573 Plaintiff vs. MICHAEL E GARLAND SR. Defendant V. M&TBANK 100 SOUTH SPRING GARDEN ST CARLISLE, PA 17013 Garnishee(s) : CIVIL ACTION • 4kNai.S. INTERROGATORIES IN ATTACHMENT TO: M & T BANK , Garnishee: r —0 ".1C) tr,t, /67 1 fi P 0 '44 44Zy * 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 subsequent time did you owe the defendant(s) any money or were you liable to him (her/them) on any negotiable or other written instrument, or did he (she/they) claim that you owed him (her/them) any money or were liable to him (her/them) for any reason? 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 persons any property of any nature owned solely or in part by the defendant? 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which the defendant held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had any interest? 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 what was tk consideration thereof? 74S R ;QOM 6. At any time after you were served did you pay, transfer or deliver any money or property tot he / 00, defendant(s) or to any person or place pursuant to his (her/their) direction or otherwise discharge 'Q4.eiljs any claim of the defendant(s) against you? e } 1) 7. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption, the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. k)) 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 41 Pa.C.S § 8123? If so, identify each account. 9. How much is the value of any property in your possession belonging to the defendant(s)? Date: June 3, 2014 FILE NO.: FT110661 Lloyd S. Markind, Esquire (ID#52507) Markind Law Group, P.C. 102 Browning Lane, Building B, Suite 1 Cherry Hill, NJ 08003 (856) 616-8710 Disclosure You are hereby advised, pursuant to the Fair Debt Collection Practices Act, that this firm is deemed to be a debt collector attempting to collect a debt and any information obtained will be used for that purpose. Lloyd S. Markind, Esquire (ID #52507) Markind Law Group, P.C. 102 Browning Lane, Building B, Suite 1 Cherry Hill, New Jersey 08003 (856) 616-8710 Attorney for Plaintiff(s) Our File Number: FT110661 IN THE COURT OF COMMON PLEAS CIVIL FORD MOTOR CREDIT COMPANY Plaintiff vs. MICHAEL E GARLAND SR. Defendant vs. M&TBANK Garnishee(s) THE 'Off DEC 29 I'I'I 2:09 COLEYS FC=XSYLVANIA OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION - LAW : No. 12-6573 TERM : CIVIL ACTION PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the attachment as to garnishee, M&T Bank, in the above captioned action. /► Date: September 30, 2014 Lloyd S. Markind, Esquire (ID #52507) Attorneys for Plaintiff Markind Law Group, P.C. 102 Browning Lane, Bldg B, Suite 1 Cherry Hill, NJ 08003 (856) 616-8710 phone (856) 616-8716 fax api-‘6T5'fdal6a. �,(4qqa 3