HomeMy WebLinkAbout04-6378IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
NANETTE M. STAINS,
Defendant.
CIVIL DIVISION
ARBITRATION DIVISION
No. QL,l
COMPLAINT IN CIVIL ACTION
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
LIT:345277-1 014636-115176
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
vs.
Plaintiff,
No. 04 - Qto%,-
NANETTE M. STAINS,
NOTICE TO DEFEND
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(800) 990-9108
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI LISTED NO TIENE UN
ABOGADO, VAYA O LLAME POR TELEFONEE LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMAC16N DE COMO CONSEGUIR UN ABOGADO.
SI LISTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEER?
INFORMAC16N ACERA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(800) 990-9108
Defendant.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
No. OLl
NANETTE M. STAINS,
Defendant.
COMPLAINT IN CIVIL ACTION
AND NOW, comes the Plaintiff, UNIFUND CCR PARTNERS, by its
counsel, Tucker Arensberg, P.C. and files this Complaint stating as follows:
1. The Plaintiff is Unifund CCR Partners, a Delaware partnership, with
offices located at 10625 Techwoods Circle, Cincinnati, Ohio 45242.
2. The Defendant, Nanette M. Stains is an individual and a resident of
25 Spring Garden Est., Carlisle, PA 17013.
3. On or about November 29, 1999, the Defendant applied for and was
approved to receive a Providian National Bank Credit Card (hereinafter "Account"). Such
Account was issued at Account Number 4465670100832005.
4. The Defendant utilized such Account and incurred a balance due
and owing.
5. As of July 21, 2003, the Defendant owed $1,442.76 in principal, and
$158.91 in interest. The total amount owed is $1,601.67. See the Affidavit of
Indebtedness attached hereto as Exhibit "A" and incorporated by reference as if fully set
forth at length herein.
6. Despite written and oral demands for payment, the Defendant has
failed and refused to pay the amount due and owing.
7. Reasonable attomeys' fees in the amount of 20% of the principal
balance are due and owing.
8. The following amounts are currently due and owing from the
Defendant:
Principal and Interest $1,601.67
Reasonable Attorney's Fees (20%) $ 320.33
TOTAL: $1,922.00
9. The Account has been assigned by Providian National Bank to the
Plaintiff including all rights to collect the amount due from the Defendant.
-2-
WHEREFORE, the Plaintiff, Unifund CCR Partners demands that judgment
be entered in its behalf and against the Defendant, Nanette M. Stains, in the sum of
$1,922.00 plus costs and interest.
TUCKER ARENSBERG, P.C.
By
Jonath r S. cAnney, Esquire
Pa. I. . 50041
Counsel for Unifund CCR Partners:
TUCKER ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
Attorneys for Plaintiff
-3-
VERIFICATION
The undersigned verifies that the statements made in the foregoing
Complaint are true and correct to the best of her knowledge, information and belief and
understands the statements therein made are made subject to the penalties of 1.8
Pa.C.S. §4904 relating to unswom falsification to authorities.
Christina M. Bry
Unifund CCR Partners
//5 /?4
AFFIDAVIT OF INDEBTEDNESS
State of Ohio )
County of Hamilton ) ss.
Jessica Bergholz being sworn, deposes and says that she is Media Supervisor of Unifund CCR Partners
herein called assignee, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and that
she is authorized to make the statements and representations herein.
The defendant is not in any branch of the military.
There is due and payable from Nanette M Stains, Account Number 4465670100832005, the amount of
$1700.54 (principal balance in the amount of $1442.76 plus interest up through 07/27/2004 in the amount
of $257.78). By the terms of the agreement between the defendant and the original creditor, interest is
accruing from the aforesaid date at the rate of 6.00 percent per annum. This balance reflects any payments,
credits or offsets made since the account was charged off.
This account was originated with Providian National Bank. Unifund CCR Partners purchased this;account
from Providian National Bank. Said account has been assigned, transferred and set over unto, Tucker
Arensberg with full power and authority to do and perform all acts necessary for the collection, settlement,
adjustment, compromise or satisfaction of said claim, on behalf of Unifund CCR Partners.
DATED this Jul 004
PARTNERS
By: Jessica Bergholz
Media Supervisor
10625 Techwoods Circle Cincinnati, OH 45242
Address
Subscribed and
27 day of July 2004
Year
Notary Public
My commission Expires
, ` , ANGELA !_. FRECKMAN, NOTARY ?P!
-r, r n
°' , -of " MY COMMISSION EXPIRES MARCH 5, 20?
Client # 215 ?''??°?
?7 4
ty
CD
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06378 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
STAINS NANETTE M
JASON VIORAL
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
STAINS NANETTE M
was served upon
the
DEFENDANT , at 1515:00 HOURS, on the 3rd day of January , 2005
at 25 SPRING GARDEN EST
CARLISLE, PA 17013
by handing to
NANETTE STAINS
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.70
Affidavit .00
Surcharge 10.00
.00
31.70
Sworn and Subscribed to before
me this J y = day of
A. D.
rothonotary
So Answers:
R. Thomas Kline
01/05/2005
TUCKER ARENSBERG
By:
7 ?.
De uty Sheriff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff
vs.
NANETTE M. STAINS,
Defendant.
No. 04-6378 Civil Term
PRAECIPE FOR ENTRY OF DEFAULT
JUDGMENT
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
LIT:355682-1 014636-115176
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff
vs.
NANETTE M. STAINS,
Defendant.
No. 04-6378 Civil Term
PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT
To Prothonotary:
Please enter Judgment by Default in the above-captioned case for the
Plaintiff and against Defendant, in the amount of $1,922.00 plus costs and interest, for
failure to answer or otherwise respond to the Complaint.
I hereby certify that the attached written Notice of Intention to take a
Default Judgment was mailed to the Defendant ten days prior to the filing of the
Praecipe for Entry of Default Judgment.
Date: 3, 7o or By:
Jon am S. McAnney, Esquire
Pa. P.P. #50041
Co n el for Unifund CCR Partners:
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
412-566-1212
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS, CIVIL DIVISION
ARBITRATION DIVISION
Plaintiff,
No. 04-6378 Civil Term
vs. TEN DAY NOTICE
NANETTE M. STAINS,
Defendant.
Filed on behalf of Unifund CCR
Partners, Plaintiff
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
LIT:350480-1 014636-115176
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
NANETTE M. STAINS,
Defendant.
TO: Nanette M. Stains
25 Spring Garden Est.
Carlisle, PA 17013
DATE OF NOTICE: February2, 2005
CIVIL DIVISION
ARBITRATION DIVISION
No. 04-6378 Civil Term
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN (10) 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(800) 990-9108
Jonah 6. McAnney, Esquire
Pa. I. 0041
Coun for Plaintiff
TUCK R ARENSBERG, P.C.
1500 One PPG Place
Pittsburgh, PA 15222
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within Ten Day Notice
was served on the following by first class mail, postage pre-paid on February 2, 2005:
Nanette M. Stains
25 Spring Garden Est.
Carlisle, PA 17013
Jonathan . McAnney, EsquirE
Pa. I.D. 041
TUCKS RENSBERG, P.C.
1500 On PPG Place
Pittsburgh, PA 15222
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
w
Caption:
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
) Confessed Judgment
) Other
File No. 04-6378 Civil Term
Amount Due $1,697.00
NANETTE STAINS, $101.82
Defendant, Interest
from 3 t ru
COMMERCE BANK, s1£` U3: Atty's Comm
Garnishee.
TO THE PROTHONOTARY OF THE SAID COURT:
Costs
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, 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 pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of County,
for debt, interest and costs, upon the following described property of the defendant(s)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list) Commerce Bank,
20 Noble Boulevard, Carlisle, PA 17013. Any and all bank accounts in the name of the Defendant.
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s)
0 (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date April 7, 2006 Signature:
Print Name:
Address:
Attorney for: Plaintiff
Telephone: (412) 566-1212
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Supreme Court ID No.: 50041
(over)
Pittsburgh, PA 15222
Notes: If real property, supply six copies of description including improvements and an original and copy of
affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
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To index writ, file separate praecipe with writ.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS, Plaintiff (s)
From NANETTE STAINS, 25 SPRING GARDEN ST., CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of COMMERCE BANK, 20 NOBLE BOULEVARD, CARLISLE, PA 17013 - ANY AN ALL
BANK ACCOUNTS IN THE NAME OF THE DEFENDANT
GARNISHEE(S) as follows:
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;
(3) 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 $1,697.00
L.L. $.50
Interest FROM 3/31/05 THRU 3/31/06 - $101.82
Atty's Comm % Due Prothy $1.00
Arty Paid $114.20
Plaintiff Paid
Date: APRIL 12, 2006
Other Costs
CURTIS R. LONG
Prothonotary
(Seal)
NO 04-6378 Civil
CIVIL ACTION - LAW
By:
Deputy
REQUESTING PARTY:
Name JONATHAN S. MCANNEY, ESQUIRE
Address: TUCKER ARENSBERG, P.C.,
1500 ONE PPG PLACE
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-566-1212
Supreme Court ID No. 50041
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
NANETTE M. STAINS,
Defendant,
VS.
COMMERCE BANK
Garnishee.
CIVIL DIVISION
No. 04-6378 Civil Term
INTERROGATORIES TO
GARNISHEE
Filed on behalf of:
Plaintiff, Unifund CCR Partners
Counsel of Record for this Party:
Jonathan S. McAnney, Esq.
Pa I. D. #50041
TUCKER ARENSBERG, P.C.
Firm No. 287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
L17389883-1 014636-115176
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS,
Plaintiff,
vs.
NANETTE M. STAINS,
Defendant,
VS.
COMMERCE BANK
Garnishee. )
N,?sW£/tS 1 d
CIVIL DIVISION
No. 04-6380 Civil Term
INTERROGATORIES TO GARNISHEE
TO: Commerce Bank
20 Noble Blvd.
Carlisle, PA. 17013
YOU ARE REQUIRED TO FILE ANSWERS WITH THE COURT UNDER OATH
TO THE FOLLOWING INTERROGATORIES WITHIN TWENTY DAYS AFTER SERVICE
UPON YOU. FAILURE TO DO SO MAY RESULT IN JUDGMENT AGAINST YOU.
FOR THE PURPOSE OF THESE INTERROGATORIES THE SOCIAL
SECURITY NUMBER OF THE DEFENDANT IS 196-48-3856 AND THE LAST KNOWN
ADDRESS OF THE DEFENDANT IS 25 SPRING GARDEN EST. CARLISLE, PA. 17013.
SEE INTERROGATORY NUMBER NO. 1 FOR ACCOUNT NUMBER.
1. At the time you were served or at any subsequent time, has the
defendant, either individually or jointly with any other party, maintained a checking, savings,
commercial, or other type of account at your institution, either as owner, agent, maker of or in
any other capacity? This interrogatory is deemed to include, but is not limited to, account
number 536704034, known to be held in the name of the defendant.
ANSWER: D.-, Frzh?Of}N f 146ri Ff cc ov NT 5370%l'94(.- w l"
p ib;,-*zc-, oti= # 13-.19 r-hT Tl!' 'T,Mt SL>Lo eO r i rtt Ncc oQeo
1°j INOrUlt7U At/..-`? Ov,INLP.
2. If the answer to Interrogatory No. 1 is "yes", state for each account:
(a) Names in which such was maintained;
(b) Names and addresses of all persons or entities having an interest
therein;
(c) Names and addresses of all persons or entities authorized to
draw thereon;
(d) Account number;
(e) Location of office where account maintained;
(f) Date opened;
(g) Dollar amount therein on date of service;
(h) Date and amount of each deposit or withdrawal therefrom after
the date of service.
ANSWER:
f O
1FfI- ACCO.>JJT IS INO'UIOJ0.wq OWU?? rJ? l?MJ4??,
SCµao.OZtz. (5? A,NS) Or- SS So ti,ra? Gpla-D-.p `L5m C.A"k%LL Po 17013,
TNt_ t1,000V NT L ffl,S OP£e_7£A 1/4 IOS Rup IS AAAAOV AU)M A,(
Cpf .v?t4t? PA-OV, (05 RS.RLAmWp Pk,),,_ , CAQ..,)5Ljr- PA 17013:
Twz- Rcccok VOAvPeoc? IS #j 3a.Ig . ?o p?Pos-rs o?
W ??-u?O?AwS I?z ?4?a M?oZ f3? Q?Gta?Dawrc?S?n?C?-
T,rAZ ?4?J zfl
3. At the time you were served or at any subsequent time, did you have in
your possession, custody or control (as fiduciary, trustee or otherwise) any property, tangible or
intangible, in which the defendant had any interest whatsoever, including but not limited to, trust
accounts, certificates of deposit, pledges, promissory notes, etc.
ANSWER:
5?C-ti IZ-2 j o QJ?t 1u ?l D.
2
4. If the answer to No. 3 is "yes", state:
(a) Brief description thereof;
(b) Location thereof;
(c) Date that you received same;
(d) Dollar amount or value thereof;
(e) Terms upon which the property is being held;
(f) Names and addresses of all persons, entities, or companies
having an interest therein.
ANSWER:
5. At the time you were served or at any subsequent time, did you have a
security interest in any property in which the defendant had an interest either individually or
jointly with any other party or were you holding any document or title or other collateral of any
land as security for any loan or time purchase transaction in which your institution was a party?
ANSWER:
Q O
6. If the answer to No. 5 is "yes", state for each loan:
(a) Names and addresses of parties thereto;
(b) Original loan amount and present balance owed;
(c) Amount of monthly payments and whether current;
(d) With regard to the collateral for such loan, the names and
addresses of the owner thereof, a brief description thereof, and
the dollar amount or value thereof.
ANSWER:
3
7. If the answer to No. 6 includes any motor vehicles, are you listed as an
encumbrance holder on the certificate of title and do you physically possess such certificate?
ANSWER: N (y
8. If the answer to No. 7 is "yes", for each such motor vehicle, state the
year, make and type, title number and vehicle identification number.
ANSWER:
9. At the time you were served or at any subsequent time, did the defendant
maintain any safe deposit box with your institution, either as owner, agent, trustee or in any
other capacity, whether in her own name or under any other name?
ANSWER:
PL)
10. If the answer to No. 9 is "yes", state:
(a) Name and address of each person or other entity to whom the
safe deposit box is rented;
(b) Name of office where box is located and the number of such box;
(c) Name and address of each person or other entity having access
to the box;
4
(d) Date such box was originally rented;
(e) Whether access was made to such box subsequent to the time
you were served with these interrogatories.
ANSWER:
TUCKER ARENSBERG, P.C.
COMMERCE
By:
Jonat n S.I nney
1500 ne PPG Place
Pittsburgh, PA 15222
(412) 566-1212
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JAI63HS 3H1 30 301330
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS CIVIL DIVISION
10625 Techwoods Circle ARBITRATION DIVISION
Cincinnati, OH 45242
No. 04 - 6378 CIVIL
Plaintiff,
V. PRAECIPE TO SETTLE AND
DISCONTINUE AS TO GARNISHEE
NANETTE M. STAINS ONLY
Defendant
V.
COMMERCE BANK
Garnishee,
Filed on behalf of Plaintiff:
Unifund CCR Partners
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
(412) 566-1212
L I T: 3 94403-1 014636-115176
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
UNIFUND CCR PARTNERS
10625 Techwoods Circle
Cincinnati, OH 45242
Plaintiff,
V.
NANETTE M. STAINS,
Defendant
V.
COMMERCE BANK
CIVIL DIVISION
ARBITRATION DIVISION
No. 04 - 6378 CIVIL
Garnishee
PRAECIPE TO SETTLE AND DISCONTINUE
AS TO GARNISHEE ONLY
TO: Prothonotary
Please mark the docket as settled and discontinue as to the Garnishee,
Commerce Bank, ONLY.
Jonathan`. WcAnney, Esquire
Counsel for Unifund CCR Partners:
Jonathan S. McAnney, Esquire
Pa. I.D. #50041
TUCKER ARENSBERG, P.C.
Firm #287
1500 One PPG Place
Pittsburgh, PA 15222
CERTIFICATE OF SERVICE
1 hereby certify that a true and correct copy of the foregoing Praecipe to
Settle and Discontinue Against to Garnishee ONLY was served by first class mail,
postage prepaid, this day of June, 2006 upon:
Nanette M. Stains
25 Spring Garden Est.
Carlisle, PA 17013
Mindi Sprout
Commerce Bank
3801 Paxton Street
Harrisburg, PA 17111
Jonathan S. Pcl4nney, Esquire
ITI -n
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2004-06378 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
STAINS NANETTE M
And now SHANNON SHERTZER Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:06 Hours, on the 3rd day of May , 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
STAINS NANETTE M
hands, possession, or control of the within named Garnishee
COMMERCE BANK 20 NOBLE BLVD
, in the
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
PAM WILT (CUSTOMER SERVICE)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to Her .
Sheriff's Costs: So answ s
Docketing .00 A-
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
00
05/04/2006
Sworn and subscribed to before me
By - SL
th' day of Deputy Sheriff
V.19 0 t. A.D. A
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
TOTAL
Advance Costs: 150.00
Sheriff's Costs 84.56
18.00 65.44
1.66
.50
1.00 Refunded to Atty on 04/27/07
4.40
30.00
20.00
9.00
84.56 ? 5/•?Q/D7
So Answers;
L ,?
R. Tho as Kline, Sh riff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-6378 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS, Plaintiff (s)
From NANETTE STAINS, 25 SPRING GARDEN ST., CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of COMMERCE BANK, 20 NOBLE BOULEVARD, CARLISLE, PA 17013 - ANY AN ALL
BANK ACCOUNTS IN THE NAME OF THE DEFENDANT
GARNISHEE(S) as follows:
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;
(3) 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 $1,697.00 L.L. $30
Interest FROM 3/31105 THRU 3/31/06 - $101.82
Atty's Comm % Due Prothy $1.00
Atty Paid $114.20 Other Costs
Plaintiff Paid
Date: APRIL 12, 2006
C TIS R. ONG
Prothonotary
(Seal) By:
REQUESTING PARTY:
Name JONATHAN S. MCANNEY, ESQUIRE
Address: TUCKER ARENSBERG, P.C.,
1500 ONE PPG PLACE
PITTSBURGH, PA 15222
Attorney for: PLAINTIFF
Telephone: 412-566-1212
Deputy
Supreme Court ID No. 50041
IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO!,N
COMMONWEALTH OF PENNSYLVANIA .- G ,
"X- V3 Com.
UNIFUND CCR PARTNERS, �,r cP
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Plaintiff
NANETTE M. STAINS,
Defendant
DOCKET NO. 2004-06378
WITHDRAWAL OF APPEARANCE
I, Jonathan S. McAnney, Esquire, hereby withdraw my appearance as counsel in
the above stated matter.
Date:
e(00
By:
Pathan S. McAn e Esquire,
quire ,
A ID# 50041
ENTRY OF APPEARANCE
I, Angela L. Mattis, Esquire, hereby enter my appearance on behalf of Unifund
CCR Partners, Plaintiff, in the above stated mat
Date: Gj iz 3 /14 By:
Angela L. Mattis, Esquire
PA ID# 309229
Attorney for Plaintiff
36 West Main Street
Bloomsburg, PA 17815
Telephone: 570-387-1873
Fax: 570-387-6474