Loading...
HomeMy WebLinkAbout13-2277 CAPITAL ONE BANK (USA), N.A. In the Court of Common Pleas of 4851 COX ROAD CUMBERLAND County, Pennsylvania GLEN ALLEN, VA 23060 Civil Division PIaintiff vs. MIM -: r = .M - F z ZUZANA SAFOUAN cn 1101 LINDHAM CT APT 111 PRAECIPE FOR ENTRY OF JUDGMEN�C MECHANICSBURG PA 17055 -5426 - ta )'C Defendant =C) 5 C N © rl c IA To the Prothonotary of CUMBERLAND County: 1) Enter Judgment on the attached Certified copy of Judgment from a District Justice. A) Date of Instrument: October 26, 2012 B) Amount of Judgment: $2,041.23 C) Interest From: October 26, 2012 2) Enter the judgment in favor of the plaintiff; 3) I hereby certify that the address of the plaintiff is: CAPITAL ONE BANK (USA), N.A. 4851 COX ROAD GLEN ALLEN, VA 23060 4) I hereby certify that the address of the defendan t is: ZUZANASAFOUAN 1 101 LINDHAM CT APT 1 I'1 MECHANICSBURG PA 17055 -5426 ich F. Ratchford, squ e Attorney for Plaintiff Michael F. Ratchfor , Esquire Edwin A. Abraham en & Associates, P.C. 120 N. Keyser Av Scranton, PA 185 4 800 -503 -1665 Ext. 1.01 Attorney ID 86285 3 1.� a u�a .6 INC CAPITAL ONE BANK (USA), N.A. 4851 COX ROAD In the Court of Common Pleas of GLEN ALLEN, VA 23060 CUMBERLAND County, Pennsylvania Civil Division Plaintiff vs. NO: ` ZUZANASAFOUAN - 1101 LINDHAM CT APT 111 NOTICE OF FILING JUDGMENT MECHANICSBURG PA 17055 -5426 Defendant Notice is herby given that a money judgment in the above- captioned matter has been entered against you in the amount of $ 2 2, on _ By: If you have any questions regarding this notice, please contact the filing party: Edwin A. Abrahamsen & Associates 120 N. Keyser Avenue Scranton, PA 18504 Telephone: (800) -503 -1665 (Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236) CAPITAL ONE BANK (USA), N.A. 4851 COX ROAD In the Court of Common Pleas of GLEN ALLEN, VA 23060 CUM13ERLAND County, Pennsylvania Civil Division Plaintiff vs. ZUZANA SAFOUAN 1101 LINDHAM CT APT 11 I AFFIDAVIT UNDER SOLDIERS AND SAILORS MECHANICSBURG PA 17055 -5426 RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED Defendant State of Pennsylvania County of CUMBERLAND SS: Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): ZUZANA SAFOUAN 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 the defendant(s): ZUZANA SAFOUAN is(are) older than eighteen years of age; That the employment status of the defendant(s): ZUZANA SAFOUAN is(are) unknown. Mich e F. Ratchf d, squire Subscribed before me this 7 day of 20 Notary Public COMMONWEA OF PENNSYLVAfvih Notarial Seal Michael C. 50Wa, Notary Public Plains TWP., Luxerne County M �6!@9�' lovlon 91mr, Jan. 24, 2014 M @Iii @F flAS�t COMMONWEALTH OF PENNSYLVANIA a COUNTY OF CUMBERLAND Notice of Judgment/Transcript Civil Case Mag. Dist. No: MDJ- 09 -3 -05 � CAPITAL ONE BANK (USA), N.A. MDJ Name: Honorable Brenda M. Knepper V. Address: 507 North York Street Zuzana Safouan Mechanicsburg, PA 17055 Telephone: 717- 766- 4575'x C CAPITAL ONE BANK (USA), N.A. C: .� 2 3: zS c/o Edwin A. Abrahamsen & Associates, P.C. Docket No: MJ - 093 _04188 120 N. Keyser Avenue Case Filed: 9/20/201 �Q Scranton, PA 18504 mot'" tv Ul = �3 CD c� Z C ,. $ z: _J ;a Disposition Summary ........... . Docket No Plaintiff Defendant MJ 09305 - CV- 0000188 -2012 CAPITAL ONE BANK USA , Disposition Disposition Date N.A. ( ) Zuzana Safouan Default Judgment for Plaintiff 10/26/2012 Judgment Summary Participant Joint/Several Liabili Individual Liability CAPITAL ONE BANK (USA), N.A. $0.00 Amount Zuzana Safouan $0.00 $0.00 $0.00 $2,041.23 $2,041.23 Judgment Detail (*Post Judgment _ In the matter of CAPITAL ONE BANK (USA), N.A. vs. Zuzana Safouan on 10/26/2012 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Civil Judgment $0.00 Amount Filing Fees $1,941.73 $1,941.73 $0.00 $99.50 $99.50 Grand Total: _�2_,041.23 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY /CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ,r`c �ram or Date Magisterial District Judge Brenda M. Knepper cerh t at t is is a true an or crect copy Of e record o the proceedings containing t e lu gment. Date Magisterial District Judge Page 1 of 2 Printed: 10/26/2012 10:43:4 Department of Defense Manpower Data Center Results as of: APr -22- 2 0 1 306:42:45 SCRA 3.0 Status Repoit, Pursuant to Senricernembers Civil Relief Act Last Name: SAFOUAN First Name: ZUZANA Middle Name: Active Duty Status As Of: Apr -22 -2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component - NA NA t' �' No This response tom -, .. .. Ac. ,_.t espouse reflects ihein active duty status'based o_n tive Duty Status Date Left Active Duty Wittun 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component I NA This response reflects where�ttie individual left active.duty�status_ within 367 da y ' ys preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA :'NA -,� ... `c R yr.'r' -No j NA This response reflects whether the indivrduai or hisTher unit has received early notficatio o report for active duty Upon searching the data banks of the Department of Defense ManpowerData,Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty. HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Ot u-r Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 4 u R The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App.'§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: hftp: / /www.defenselink.mil /faq /pis /PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his /her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN /date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: R21612AA3022W00 f� C41Pi'rld ONIi BANk it SAL N_1. In the( ourt Of Cononoo PI.,"f Plain6R - C UM66RLAN D Cuunly, Pennsylvania Civil Di'kion vs, ZUZANA SAFOUAN 1101 LINDHAM CTAPT 111 NO 13-2?77CIV1L. _ MECHANICSBURG PA 17055-5426 Defendant MEMBERS IS'T ECU N 6280 CARLISLE, PIKE MECHANICSBURG, PA 17050 Garnishee Praedpe for Entry of Appearance Kindly enter my appearance on behalf of CAPITAL ONE BANK (USA),N.A. in the above- captioned matter. Date:May 14, 20t3 Sign re. Pri Name: Michael F. Ratcl . Esquire Address: 120 North Ke ser 0nue Scranton. A 18 4 Telephone No: 570 558- 510 V,y4. 120 Supreme Court ID No: 8 285 PRAECIPE FOR WRIT OF EXECUTION—(MONEY JUDGMENT)RULES PA.R.C.P.3252,3111 (a) CAPITAL ONE BANK(USA),N.A. In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania C.0 t Civil Division czt C— vs. �7 y O ---i CD ZUZANA SAFOUAN { r-V,, . 1101 LINDHAM CT APT l 11 NO: 13-2277 CIVIL � - MECHANICSBURG PA 17055-5426 ' Defendant X� -'S 60 _s vs. PRAECIPE FOR WRIT OF EXECUTION AN 1 ATTACHMENT MEMBERS 1.ST FCU 6280 CARLISLE PIKE MECHANICSBURG,PA 17050 Garnishee (MONEY JUDGMENT) To the Prothonotary:TO SATISFY THE JUDGMENT,ISSUE WRIT OF EXECUTON IN THE ABOVE MATTER (1) Directed to the Sheriff of CUMBERLAND County,Pennsylvania; (2) Against:ZUZANA SAFOUAN (3) And against:MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG,PA 17050 (4) and index this writ(a)against Defendant(s)(b)against MEMBERS 1ST FCU 6280 CARLISLE PIKE MECHANICSBURG,PA 17050 Garnishee(s), as a lis pendens against the real property of the defendant(s)in the name of the Gamishee(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): ***-**-8854; (5) Judgment Amount $2.041.23 Interest $.00 Payments $357.21 Clerks Fee $ Sheriff $ Poundage $ Total $ Date:May 14,2013 Michael F M ^/1' O Edwin A. raamsen ssociates,P.C. n 0Q(t`"'�� Vl Attorney for Plaintiff �fl,, �• n C /► gyp/" mratchford @eaa-law.coj 09 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-2277 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due CAPITAL ONE BANK(USA)N.A.Plaintiff(s) From ZUZANA SAFOUAN, 1101 LINDHAM CT,APT 111,MECHANICSBURG,PA 17055-5426 (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: MEMBERS 1sT FCU,6280 CARLISLE PIKE,MECHANICSBURG,PA 17050,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. 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$1,684.02 Plaintiff Paid$ Interest Attorney's Comm. % Law Library$.50 Attorney Paid$60.25 Due Prothonotary$2.25 Other Costs$ Date: JUNE 10,2013 David D.Buell,Prothonotary Deputy REQUESTING PARTY: Name: MICHAEL F.RATCHFORD,ESQUIRE Address: EDWIN A. ABRAHAMSEN&ASSOCIATES,P.C. 120 NORTH KEYSER AVENUE SCRANTON,PA 18504 Attorney for:PLAINTIFF Telephone: 570-558-5510 Supreme Court ID No. 86285 CAPITA-11,ONE BANK(USA),N.A. In the Court of Common Pleas oi" Pldiolliff CUNIBERLAND COUDI;V-,Pennsylvania Civil Division VS. ZUZANA SAFOUAN -- 1101 LINDHAM CT APT 111 NO: 1.3-2277 CIVIL rn MECHANICSBURG PA 17055-5426 Defendant 1-0 vs. INTERROGATORIES IN ATTACHMENT >,C) p t C- MEMBERS I ST FCU 6280 CARLISLE PIKE MECHANICSBURG,PA 17050 Garnishee RE: Execution of Judgment against your depositor ZU7.ANA SAFOUAN SSN# ***-**-8854 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: I At the time you were served or at any subseqent time,did the Defendant possess any bank accounts,joint or individual,that were in your custody or control?Please specify joint or individual account. Please list the legal title of any such account(s)and the primary account holder and if known whether joint account is entireties property. *-f" 2) . At the time you were served or at any subsequent time,what was the balance and account number of the bank accounts(s) identified in Interrogatory#I? 0'18 1 I-7 "��V'-U- �§ 3Qa-,'o 3) At the time you were served or at any subsequent time,please list the average daily balance in the past five(5)months for each such account identified in your answer to Interrogatories number one(1)and two(2)above rl%,k D-tz�\-!�. d-yxc' k:� pt-��40 %IS L+Cl-1' 4) At the time you were served or at any subsequent time,did the bank account(s)that the Defendant possessed contain fund derived solely from social security funds and/or disability funds? 5) At any time before or after you were served,did the Defendant(s)transfer or deliver any property or money to you or to any person or place pursuant to your direction or consent, and if so,what was the consideration therefore? OD 6) At auy 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 Depositor's direction or otherwise discharge any claim of the Depositor against you? 0 0 7) At the time you were served or any subsequent time,did you have, share,or utilize any safe-deposit boxes,pledges, documents of title, securities, notes, coupons, receivable, license,or collateral in which there was an interest claimed by Defendant(s)? 8) At the time you were served or at any subsequent time did the Defendant(s)account contain funds deposited electronically on a recurring basis and which are identified as being exempt from execution,levy or attachment. If so, state the reason for the exemption, the amount being withheld and the entity electronically depositing those funds on a recurring — C,,� o basis. ( �c,��ZA-t ­SUIU . Z'Z� , K 9) 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 42 Pa.C.S. Section 8123?If so, identify each account.tt� 10) Identify every other account(not previously noted)titled in the name of the Defendant(s) in which you believe the Defendant(s)have an interest in whole of part, whether or not styled as a payroll account,individual retirement account,tax account, lottery account,partnership account,joint or tenants by entirety account, insurance account,trust or escrow account,attorney's account,or otherwise. N/fN. 11) To the extent that you're above answers depend in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). Edwin A r ams Ass 'Wchael F Rat� 4d,Esquire 9 *Kel _!Zenue 120 North Scranton, (570) 558-5f' lO Ext. 101 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson } C._ Sheriff _ : ,LEO-OF 1 Qti3<t ., o[ iiritae f f ll THE PROTHONO (A : Jody S Smith Chief Deputy 2013 JUN 2 I AM 10: 31 Richard W Stewart Solicitor :Fg-,CE v �= „h� = CUMBERLAND COUNTY PENNSYLVANIA Capital One Bank (USA) N.A. Case Number vs. Zuzana Safouan 2013-2277 SHERIFF'S RETURN OF SERVICE 06/13/2013 09:56 AM- Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 13, 2013 at 0950 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Zuzana Safouan, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania, by handing to Ashley Hoch,Account 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 June 18, 2013 to Zuzana Safouan at 1101 Lindham Ct, Apt. 111, Mechanicsburg, PA 17055. STEPHEN B IF DER, DEPUTY SO ANSWERS, June 18, 2013 RON R ANDERSON, SHERIFF ;cuntvGuito Sherif f re,oosof. ' .,. CAPITAL ONE BANK(USA),N.A. In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvania Civil Division vs. ZUZANASAFOUAN 1101 LINDHAM CT APT 111 NO: 13-2277 CIVIL MECHANICSBURG PA 17055-5426 Defendant Praecipe to Dissolve the Attachment agaist _� vs. Garnishee rr r— _-0 rn MEMBERS 1 ST FCU -- ;' 6280 CARLISLE PIKE MECHANICSBURG, PA 17050 .— Garnishee c c:: ,. To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank you, /Mic F4RatchfVrd�,�V-squire Edwin A. Abrahvnsen&Associates, P.C. Lawyer ID# 86 85 G-2 3r-p m � 341 SHERIFF'S OFFICE OF CUMBERLAND COUNTY .onny R Anderson Sheriff „orl � rrilaa . Jody S Smith •,A ". Chief Deputy s i , r i —9 r E n • Richard W Stewart Solicitor a Y Capital One Bank (USA) N.A. vs. Case Number Zuzana Safouan 2013-2277 SHERIFF'S RETURN OF SERVICE 06/13/2013 09:56 AM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 13, 2013 at 0950 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Zuzana Safouan, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania, by handing to Ashley Hoch,Account 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 June 18, 2013 to Zuzana Safouan at 1101 Lindham Ct, Apt. 111, Mechanicsburg, PA 17055. 01/08/2014 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: $89.19 SO ANSWERS, January 08, 2014 RONIR ANDERSON, SHERIFF 07- as'p11. � •SD '& '; 3 bes ao r