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
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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.
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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.
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NOAH CLINE, DEPUTY
SHERIFF COST: $43.;)0
November 01, 2012_
SO ANSWERS,
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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
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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
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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)
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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
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$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
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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:
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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
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