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Home My WebLink About13-4286 ►= LE G O f- FICE 7013 JUL. 22 PM 2: 07 CUMBERLAND COUNTY PENNSYLVANIA Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610 - 696 -2120 Attorney for Plaintiff MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. Susan Jumper Defendant : CIVIL ACTION - LAW Praecipe for Assessment of Damages To the Prothonotary: Kindly assess damages in the above matter as follows: District Justice Judgment $7,404.53 Less Post - Judgment Payments $3,414.56 Balance Due $3,989.97 Burto eil & sso fates, P.C./ B al D. einstein, Esquire A mey for Plaintiff This is an attempt to collect a debt, and any information o ained will be used for that purpose. This communication is from a debt collector. �� COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ 09 - 3 - 03 Midland Funding LIc �\ MDJ Name: Honorable Susan K. Day V. Address: 229 Mill Street Susan M Jumper P.O. Box 167 C-- ' Mount Holly Springs, PA 17065 M CO Telephone: 717 486 - 7672 .. r" - o Midland Funding lc tv � 9 Docket No: MJ- 09303 -, 94r000D@46 -R:4 C/O Burton Neil & Assoc Case Filed: 2/22/2012�C –o 1060 Andrew Drive Suite #170 =r West Chester, PA 19380 CD bisposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09303 -CV- 0000046 -2012 Midland Funding LIc Susan M Jumper Default Judgment for Plaintiff 04/17/2012 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Midland Funding LIc $0.00 $0.00 $0.00 Susan M Jumper $0.00 $7,404.53 $7,404.53 Judgment Detail (* *Post Judgment) In the matter of Midland Funding LIc vs. Susan M Jumper on 4/17/2012 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $7,246.53 $7,246.53 Filing Fees $0.00 $158.00 $158.00 Grand Total: $7,404.53 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. Date M isteria District Judge Susan K. Day certify that this is a true and correct copy of the record of the procee ings ontaining t � Date M steri District Judge MDJS 315 Page 1 of 2 Printed: 05/30/2012 12:35:21 PM • �4 1 � Midland Funding Llc Docket No.: MJ- 09303 -CV- 0000046 -2012 V. Susan M Jumper Participant List 1 �, Private(s) Yale D Weinstein, Esq. Burton Neil & Associates, P.C. 1060 Andrew Drive, Suite 170 - West Chester, PA 19380 Plaintiff(s) tV :7j r.3 ' - Midland Funding Uc C/O Burton Neil & Assoc — 1060 Andrew Drive Suite #170 ? West Chester, PA 19380 D • • �� Defendant(s) Susan M Jumper 247 N Middlesex Rd Carlisle, PA 17013 MDJS 315 Page 2 of 2 �� r� Priited: 05/30/2012 12:35:21 PM CdMMONWEALTH OF PENNSYLVANIA CIVIL COMPLAINT COUNTY OF: CUMBERLAND Mag. Dist No.: PLAINTIFF: NAME and ADDRESS 09 -3 -03 r MIDLAND FUNDING LLC � DJ Name: Hon. Go Burton Neil & Associates, P.C. 1060 Andrew Drive, Suite 170 Susan K. Day Address: 229 Mill Street, PO Box 167 West Chester, PA 19380 L � Mt Holly Springs, PA 17065 Telephone: 7171486 -7672 VS. DEFENDANT: NAME and ADDRESS r SUSANJUMPER 247 North Middlesex Road L Carlisle PA 17013 J Docket No.: C Date Filed: AMOUNT DATE PAID FILING COSTS $ / 1 POSTAGE $ 1 1 SERVING COSTS $ 1 I Social security numbers and financial information (e.g. / / PINS) should not be listed_ If the identity of an account CONSTABLE ED. $ t i 1�aJ t number must be established, list only the last four digits. TOTAL 204 Pa.Code §§ 213.1 - 213.7. Pa.R_C.P.D.J. No. 206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $7,246.53 together with costs upon the following claim: Plaintiff is the owner of a certain credit card account (hereafter, "the Account') by virtue of the assignment of the Account As a result of the assignment, plaintiff now holds all rights, title and interest in and to the Account. Upon information and belief, defendant entered into a revolving credit agreement with CITIBANK (SOUTH DAKOTA), N.A. SEARS PREMIER CARD, received a credit card for the Account bearing number 0533 and used or authorized the use of the credit card to obtain loans for the purpose of obtaining goods and/or services and /or cash advances. Based upon review of records kept on behalf of plaintiff, the last payment posted to the account on April 1, 2009. The account shows that the defendant owes a balance of $7,246.53. I � Ashley La shlf ls k i verity that the facts set forth in this complaint are true and correct to the best of my knowledge, information and belief. This statement is made subject to the penalties of Section 490 of the Crimes Code (18 PA. C. S. § 4904} related to unsworn falsification to authorities. mct . (Signature of Plaintiff or Authori ed Agent) The plaintiffs attorney shall file and entry of appearance with the magisterial district court pursuant to Pa.R.C.P.M.D.J. 207.1. IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. It you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five days before the date set for the hearing. If you are disabled and require reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. 8540459902 AOPC 308A -11 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610 - 696 -2120 Attorney for Plaintiff MIDLAND FUNDING LLC : IN THE COURT OF COMMON PLEAS 8875 Aero Drive Suite 200 San Diego CA 92123 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Susan Jumper 247 North Middlesex Road Carlisle PA 17013 Defendant :CIVIL ACTION - LAW Certification of Address and Affidavit of Non - Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last -known addresses of the judgment creditor and debtor. 2. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA) the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. Burton eil As ciates, P.C. Yal einstein, Esquire orney for Plaintiff This is an attempt to collect a debt, and any informati obtained will be used for that purpose. This communication is from a debt collector. Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610- 696 -2120 Attorney for Plaintiff MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Susan Jumper Defendant : CIVIL ACTION - LAW Rule of Civil Procedure No. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on Prothonotiary By: If you have any questions concerning the above, please contact: Yale D. Weinstein, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610- 696 -2120 This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. 158531 / 232 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 MIDLAND FUNDING LLC : IN THE COURT OF COMMON PLEAS 8875 Aero Drive Suite 200, San Diego CA 92123 Plaintiff v. : CUMBERLAND COUNTY, PENNSYLNANIA Susan Jumper -0 co 247 North Middlesex Road, Carlisle PA 17013 Defendant(s) : NO. 13-4286 CIVIL▪ < — WELLS FARGO 604 E. High Street, Carlisle, PA 17013 < C- -3 Garnishee(s) : CIVIL ACTION - LAW '-- c--) z cp 5 ---( To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER N.) 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. against Susan Jumper , Defendant(s) 3. and against WELLS FARGO , Garnishee(s) 4. and index this writ (a) against Defendant(s) (b) against Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) NO LEVY - GARNISHMENT ONLY Serve interrogatories on garnishee at: 604 E. High Street, Carlisle, PA 17013 49R.co WITTY Ik .95 0_t3 F 5. Amount Due $3,989.97 (00 • rk Credit - 1,000.00 Interest from 04/17/2012 • 706.72 Total $3,696.69* *Plus writ costs Dated: November 4, 2014 Yale D. , squire Atto y for Plaintiff NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as thorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgrnent may be directed only to the sheriff of the county in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). This is an attempt to collect a debt, and any information obtained will be used for that purpose. This 6 communication is from a debt collector. 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. MIDLAND FUNDING LLC Vs. SUSAN JUMPER WRIT OF EXECUTION (Pa R.C.P. 3252). NO 13-4286 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against SUSAN JUMPER, 247 NORTH MIDDLESEX ROAD, CARLISLE, PA 17013 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 WELLS FARGOGARNISHEE(S), as garnishee, 604 E. HIGH 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 $2,989.97 Plaintiff Paid Interest FROM 4/17/2012 - $706.72 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $60.25 Other Costs Date: 11/10/14 (Sea I) David D. Buell, Prothonotary REQUESTING PARTY: Name : YALE D. WEINSTEIN, ESQUIRE Address: LAW OFFICES BURTON NEIL & ASSOCIATES, P.C. 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No, PLAINTIFF MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $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 AND COU UNTY 411 Cilligieef OFF' 4L-; Or,r�� r-|i-D-^c�!�� ^ TAFpROTHONO r�AR`` Z014 NOV � | 8� |O� �g ��'`"°`�' ~'''` ~` CUMBERLAND COUNTY PENNSYLVANIA Midland Funding, LLC vs. Susan Jumper Case Number 2013-4286 SHERIFF'S RETURN OF SERVICE 11/20/2014 09:52 AM - William Cline, Deputy, who being duly sworn accoringhzlaw.ettanhedmsherencommanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Jennifer Hammerbacker, 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 detendant was mailed on November 21 20 o Susan Jumper at 247 North Middlesex Road, Carlisle, PA 17013. ^/ WILL ~ '^'— ~—~'—`' vmumw�uw�.u�ru/, SO ANSWERS, SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee MIDLAND FUNDING, LLC vs. : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND SUSAN JUMPER : NO. 13-4286 and WELLS FARGO, GARNISHEE ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf Wells Fargo, Garnishee in the above - captioned matter. Date: \\---C=;-\\\ SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee MIDLAND FUNDING, LLC vs. C.•; 1.11 A : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND SUSAN JUMPER : NO. 13-4286 and WELLS FARGO, GARNISHEE ANSWERS TO INTERROGATORIES IN ATTACHMENT TO: MIDLAND FUNDING, LLC, Plaintiff 1. No. 2-6. Judgment Debtor has an interest in the following accounts, withdrawals from which has/have been restricted pursuant to this writ; Benjamin A. Jumper, Susan M. Jumper (1853) with a balance of $135.01 Benjamin A. Jumper, Susan M. Jumper (0957) with a balance of $2,458.85 Pursuant to the terms and conditions of the deposit agreement between the bank and the depositor, the bank claims a priority lien in, and a right of set-off against the account consisting of $125.00 Legal Processing Charge, leaving a balance for execution purposes of $2,593.86. In addition, pursuant to 42 Pa.C.S.A. Section 2503, a garnishee's attorney fee in the minimum amount of $350.00 is authorized and will be deducted from the attached funds, if any. See New Matter below for further answer and defense. 7. (Q) 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 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? (A) No. 8. (Q) 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 42 Pa.C.S. § 8123? (A) The first $300.00 on deposit (if any) may be exempt pursuant to Judicial Code, 42 Pa.C.S. Section 8123 and therefore has not been held. This amount is not included in Number 2 above. NEW MATTER YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS OF SERVICE THEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. 9. Garnishee incorporates by reference its Answers to Interrogatories one through eight above as though fully set forth herein. 10. One or more of the listed accounts is/are titled to joint tenants and as such may be exempt or immune from attachment. Such account(s) cannot be executed upon without competent proof by Plaintiff that some or all of the attached assets belong solely to the judgment debtor and are subject to this execution. As such, Garnishee cannot release the attached assets without an appropriate order of Court directing the Garnishee to permit execution in whole or in part by Plaintiff against such assets or such other relief as is deemed just and proper by the court. Garnishee will stay further action pending a prompt hearing and determination by the appropriate court. Dated: `)"�-\''\ JON . ". RLIN Att • ev • Garnishee Wells Fargo Bank, N.A. Liens, Levies & Garnishments 101 N. Independence Mall East MAC Code# Y1372-113 Philadelphia, PA 19106 VERIFICATION Ednita Johnson, being duly sworn according to law, deposes and says that she is the Legal Order Processing Associate of Wells Fargo Bank, NA Garnishee herein, and verifies that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made subject to penalties of i8 Pa. C.S. Section 4904, relating to sworn falsification to authorities. Date: 2)4,31y Ednita J Legal 0 son Processing Associate