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HomeMy WebLinkAbout13-1293 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson L CIF THE O HO��i��t';`. Sheriff Jody S Smith �-` �� 2013 MAR 26 AM 9: 35 Chief Deputy . Richard w Stewart ��` PENNSYLVANIA CUMBERLAND CoUtz f �� C) Solicitor MCG OF THE SKRIFF Samuel Ainbinder vs. Case Number Linda R Scott-Reed 2013-1293 SHERIFF'S RETURN OF SERVICE 03/20/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Linda R Scott-Reed, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint&Notice as"Not Found"at 653 Devonshire Drive, Carlisle Borough, Carlisle, PA 17013. Per current tenants defendant was the previous tenant and moved out in July 2012. The_Carlisle Postmaster confirms that the defendant moved and left no forwarding address. SHERIFF COST: $39.00 SO ANSWERS, March 20, 2013 RONW R ANDERSON, SHERIFF (c)CountvSuite Sheritf,Tel=_osoit inc. Supreme C, `�`,nnsylvania Con F CU�i rt r County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the ling and service of pleadings or other papers as required by law or rules of court. Coummacement of Action: a ® Complaint Q Writ of Summons Q Petition ;. . Q Transfer from Another Jurisdiction © Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name: SAMUEL AINBINDER LINDA R.SCOTT-REED Dollar Amount Requested: ©within arbitration limits : . Are money damages requested? ©Yes Q No (check one) Qoutside arbitration limits Is this a Class Action Suit? Q Yes ® No Is tois an MDJAppear. Q Yes ® No 3 Name of Plaintiff/Appellant's Attorney: ,Jeffrey S.Wilson,Esquire'" Q Check here if you have no attorney(are a Self-Represe ked [Pro Sel Litigant) Niftre+ Piave am" "to# of +abt ct ffiq r Py . If a n -+am►e Eiad,rbeck t f^; you car in r TORT(do not include Mass Ton) CONTRACT(do not include judgments) CIVIL APPEALS Q Intentional Q Buyer Plaintiff Administrative Agencies Q Malicious Prosecution Q Debt Collection:Credit Card Q Board of Assessment 13 Motor Vehicle ®Debt Collection:Other Board of Elections [j Nuisance Loan of Money Dept.of Transportation ' Q Premises Liability Statutory Appeal:Other Q Product Liability(does not include mass tort) ©Employment Dispute: Slander/Libel/Defamation Discrimination Other: Q Employment Dispute:Other Q Zoning Board Q Other: Q Other: MASS TORT Q Asbestos Tobacco Toxic Tort-DES Q Toxic Tort-Implant © Toxic Waste REAL PROPERTY MISCELLANEOUS 13 Q Other: Ejectment Q Common Law/Statutory Arbitration j = Eminent Domain/Condemnation Q Declaratory Judgment Ml,„ Ground Rent Mandamus Q Landlordfrenant Dispute 8 Non-Domestic Relations O Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY Q Mortgage Foreclosure:Commercial Q Quo Warranto Q Dental Q Partition Replevin Q Legal Q Quiet Title Q Other: r Q Medical Q Other: „- Q Other Professional: 6y Updated 1/1/2011 JEFFREY S. WILSON, ESQUIRE ATTORNEY NO. 50503 POST OFFICE BOX 42321 PHILADELPHIA, PA 19101 ATTORNEY FOR PLAINTIFF 610-543-0434 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SAMUEL AINBINDER NO. 13-1293 Civil Terms , vs. -- -� =M � LINDA R. r.nr- C) PRAECIPE TO REINSTATEx'-- ` c TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter. -AtfomeolrPlaintiff Lv I ao �. c SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff rr r�� ( lC 'J� a Tt H�- Jody S Smith r Chief Deputy ;4�r 2013 MAY 1.3 Ate 10' 37 Richard W Stewart Solicitor OFF!C&OrT14�E SRER[Fr C&BERLAND COUNTY PENNSYLVANIA Samuel Ainbinder vs. Case Number Linda R Scott-Reed 2013-1293 SHERIFF'S RETURN OF SERVICE 05/03/2013 07:06 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint& Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Linda R Scott-Reed at 8 Pine Creek Drive, North Middleton, Carlisle, P 17013. TSHALL, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, May 06, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuito Sheriff,Teleosoft,Inc. JEFFREY S. WILSON,ESQUIRE +- :t" xi94D `t' R`x ATTY.NO. 50503 POST OFFICE BOX 42321 2013 AN 1 � ��� �� �� Attorney for Plaintiff PHILADELPHIA,PA 19010 , 610-543-0434 C1l� BERLPM COUNT PENNSYLVA141A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SAMUEL AINBINDER NO. 13-1293 Civil Term vs. LINDA R. SCOTT-REED PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Please enter Judgment against the Defendant(s): LINDA R. SCOTT-REED in accordance with Pennsylvania Rule of Civil Procedure No. 1037, Defendant(s) having (a) failed to Enter an Appearance, and (b) failed to file Responsive Pleadings within the time required. Assess Damages Follows: Real Debt $1,308.00 Interest 3/13-6/13 $ 19.62 Total $1,327.62 Plus Costs " 6 11 tt rney f laintiff DATE: 6/17 i3 I hereby Assess Damages as above and enter Zfo6gosts the sum of e Prothonotary co o Vat JEFFREY S.WILSON,ESQUIRE ATTY.NO. 50503 POST OFFICE BOX 42321 Attorney for Plaintiff PHILADELPHIA,PA 19101-2321 610-543-0434 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SAMUEL AINBINDER NO. 13-1293 Civil Term VS. LINDA R. SCOTT-REED CERTIFICATION OF WRITTEN NOTICE PURSUANT TO PA. R.C.P. 237.1 JEFFREY S. WILSON, Attorney for Plaintiff, does hereby certify that the attached written Notice of Intention to file Praecipe for Entry of Judgment was mailed by regular mail to the Defendant(s) and/or Defendant's attorney ten (10) days prior to the date of this filing. to ey for intiff DATE: June 14, 2013 JEFFREY S. WILSON, ESQUIRE ATTORNEY FOR: PLAINTIFF Attorney I.D. No. 50503 Post Office Box 42321 Philadelphia, PA 19101 610-543-0434 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SAMUEL AINBINDER NO. 13-1293 Civil Term vs. LINDA R. SCOTT-REED IMPORTANT MESSAGE TO: LINDA R. SCOTT-REED DATE OF NOTICE: May 24, 2013 8 Pine Creek Drive Carlisle, PA 17013 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 REFERENCE SERVICE Of CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 717-249-3166 Attorney for Plaintiff JEFFREY S. WILSON,ESQUIRE ATTY.NO. 50503 POST OFFICE BOX 42321 Attorney for Plaintiff PHILADELPHIA,PA 19101-2321 610-543-0434 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SAMUEL AINBINDER NO. 13-1293 Civil Term vs. : LINDA R. SCOTT-REED AFFIDAVIT OF UNDER SOLDIERS' AND SAILORS' CIVIL RELIEF ACT OF 1940 AS AMENDED Commonwealth of Pennsylvania SS County of Chester JEFFREY S. WILSON, ESQUIRE being duly sworn according to law deposes and says that the above named Defendant(s), LINDA R. SCOTT-REED is/are not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; that said Defendant(s) is over 21 years of age and is/are employed. Sworn to and subscribed Before me this /0'/day 20 3. OTARY PUBLIC COMMONWEALtb AF PENNSYLVANIA Notarial seal Joanne Gutzler,Notary Public Tredyffrin Twp.,Chester County My Commission Expires tune 21,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES JEFFREY S.WILSON,ESQUIRE ATTY.NO. 50503 POST OFFICE BOX 42321 Attorney for Plaintiff PHILADELPHIA,PA 19101-2321 610-543-0434 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SAMUEL AINBINDER NO. 13-1293 Civil Term vs. LINDA R. SCOTT-REED CERTIFICATION OF ADDRESS 1, Jeffrey S. Wilson, Esquire counsel for Plaintiff in the above captioned matter hereby certifies that the correct address for each parties is as follows: Plaintiff's correct name and address: SAMUEL AINBINDER 1195 Coney Island Avenue Brooklyn, NY 11230-2911 Defendant's correct name and address: LINDA R. SCOTT-REED 8 Pine Creek Drive Carlisle, PA 17013 eff 06. Esquire Attorney r Plaintiff (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION --LAW SAMUEL AINBINDER } } NO. 13-1293 Civil Term Plaintiff(s) VS. } LINDA R. SCOTT-REED } Defendant(s) NOTICE IS GIVEN THAT A JUDGMENT IN E ABOVE CAPTIONED M TER HAS BEEN u ENTERED AGAINST YOU ON l.r �i`llt � If you have any questions concerning the above, please contact: JEFFREY S.WILSON, ESQUIRE Post Office Box 42321 Philadelphia, PA 19101-2321 (610) 543-0434 -IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY.PENNSYLVANIA CINTL DIVISION _ PRAECIPE FOR WRIT OF EXECUTION Confessed Jucl meat SAMUEL AINBINDER ��� , , Plaintiff ®Other V`>_ S, File No. 13-1293 $1 , 327 . 62 LINDA R. SCOTT—REED norurtDue_ '�_ ' Defendant Interest_ $ 6 .63 C_— Address-: Atty's Conlin Costs $ 384. 03 TO THE PROTHONOTARY OF THE SAID COURT: The umlersigned hereby certifies that the below does not arise out of a retail irrstallmeat sale, contract, or account based on a confession of,judgmeat,but if it does,it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pill',"an t to Act 6 of 1974 as <unended. Issue grit of execution in the above matter to the Sheriff of Cumberland County,for debt..interest and costs,upon the following described property of the defendant(s) METRO BANK account PR AECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County,for debt,iritere,:t anct costs,as abot-e,directnrg attachment aganrst the above-named garnishee(s)for the following property (if real estate.sDplilv,cyx rMlies of the description. supply four copies of lengthy personalty list) Bank Account and all other property of the defendant(s)is the possession,custody or control of the said garnishee(s). (Indicate)Lrcle4 this Writ against the garirishee(s)as a lis peudens against real estate of th defend.urt(s)described nr the attached exhibit, p Date 7-26-2013 Siana.ture: /(f PrintNme: Jeff Wilson Adzh'ess: P.O. Box 42321 00 (�Ny Philadelphia, PA 19101-2321 00 Attorney for Plaintiff 4lu Telephone: 610-543-0434 0 5,-1 s e t Supreme Court ID No: 50503 11. '15 U H 8 U dii. so u- PSR) e# Vv t� d WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-1293 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SAMUEL AINBINDER Plaintiff(s) From LINDA R.SCOTT-REED,653 DEVONSHIRE DRIVE,CARLISLE,PA 1701.3 (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 GARNISHEES)as follows: METRO BANK ACCOUNT,65 ASHLAND AVENUE,CARLISLE,PA 17013 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$1,327.62 Plaintiff Paid$ Interest$6.63 Attorney's Comm. % Law Library$.50 Attorney Paid$234.78 Due Prothonotary$2.25 Other Costs$384.03 Date:07/29/2013 David D.Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name:JEFFREY S.WILSON,ESQUIRE Address: P.O.BOX 42321 PHILADELPHIA,PA 19101-2321 Attorney for: PLAINTIFF Telephone: 610-543-0434 Supreme Court ID No.50503 SHERIFF'S OFFICE OF CUMBERLAND COUNTY zz z P -: Ronny R Anderson s 'err Sheriff r" s Sx a of c2utibet'j, CID Jody S Smith CD, C" Chief Deputy f y , _tea Richard W Stewart C= ma�yy ` Solicitor o rtflr OF n.r-C p3;x ale C a ~ Samuel Ainbinder Case Number vs Linda R Scott-Reed 2013-1293 SHERIFF'S RETURN OF SERVICE` 08/07/2013 11:25 AM-William Cline, 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,65 Ashland Ave, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Nicole Erickson,Assistant Branch 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 August 8, 2013 to Li da R. Scott-Reed at 8 Pine Creek Road, Carlisle, PA 17013. L YMM CLINE, DEPUTY SO ANSWERS, August 08, 2013 RONW R ANDERSON, SHERIFF {c}CountyWte Sheriff,Telecsoft,Inc. JEFFREY S. WILSON,ESQUIRE ATTORNEY NO. 50503 0 � 1��C0 POST OFFICE BOX 42321 �� a PHILADELPHIA,PA 19101-2321 Pr's 2: 2 610-543-0434 CU IWERLAP~{D COUNTY PENNY YeWlfity', Pennsylvania. In the Court of Common Pleas Cumberlan y SAMUEL AINBINDER VS. NO. 13-1293 LINDA R. SCOTT-REED and METRO BANK, Garnishee INTERROGATORIES TO GARNISHEE 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. These Interrogatories are to be deemed continuing. Unless otherwise specified, the questions are directed to the "time" of service of the attachment all "time" subsequent thereto. The answers should specify and clearly describe the information requested, including, but not limited to amounts of money held or owing, account numbers, serial numbers, and detailed description of property, your interest therein, and any claims by you or others therein, including addresses and phone numbers where they maybe reached. 1. At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? If so, describe the property and state its value. Delendant has account which has less than $inn exemption and is held as joint entities 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 or others any property or any nature, including but not limited to checking account and promissory notes and saving accounts, owed solely or in part by the Defendant? If so, state the property and/or the joint possessor, custodian,or entity controlling said property. 3. At the tithe.you were served or at any subsequent time did you hold legal title to any property of any nature owed solely or in part by the Defendant? If so, please describe. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant has interest? If so, please describe. 5. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the Defendant against you? If so, to what extent? 6. At any time before or after you were served, did the Defendant 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? 7. At any time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? 8. Please describe and state the value of all property.belonging to Defendant in your possession. DATED: July 26, 2013 At rney � Plaintiff 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. 1 (SIGN ORE) i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ; r;ifii 'ar , a ar et climber's. Jody S Smith i [ Chief Deputy e Au Richard W Stewart CUMBERLANDr{ N ,. Solicitor C.F{.° , ta , - PENNSYLVANIA Samuel Ainbinder vs. Case Number Linda R Scott-Reed 2013-1293 SHERIFF'S RETURN OF SERVICE 08/07/2013 11:25 AM-William Cline, 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, 65 Ashland Ave, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Nicole Erickson,Assistant Branch 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 August 8, 2013 to Linda R. Scott-Reed at 8 Pine Creek Road, Carlisle, PA 17013. 03/03/2014 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: $89.26 SO ANSWERS, March 03, 2014 RONNW ANDERSON, SHERIFF �.aS s� l� pd. 037/ 9,raGo AO- 30)vvi