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HomeMy WebLinkAbout13-4640 s Supreme Court of Pennsylvania Court o C0111111oil "P leas ForProlhonolatp Use Otrlit: lvil Cover $beet Docket No: County The information collected oil this joint is used solely for coto•1 adntinist►•alion purposes. VityPorn► does not supplentent or replace the filing and seri'ice o pleadin s or othe►• a e►s as regt►ired by last) a• ►•►des of cottt•l. Cot neucennent of Action: S Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E C Lead Plaintiffs Name: Lead D ndant's Name: �) T I I Are money damages requested? es ❑ No 11 Dollar Annount Requested: vithin nrbitmtion limits / (check one) ❑outside arbitration limits N Is this a Class Ach'ar Stltl? ❑ Yes No Is this an HDJAppeal? ❑ Yes S No A Name of Plaintiff/Appellant's Attorney: ��C7 r-e O�_�U r ►- 5 ❑ Check hvre II•you have no attorn (are it Self- llepresenled (Pro tie) L.itibnot) Natitt'e of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT ( ,to not include Alass raj) CONTRACT ((to not ntcludeJudginenls) CIVIL APPEALS ❑ hntentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution Mebt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle /❑ Debt Collection: Other ❑ Board of Elections Nuisance Dept. of Transportation Premises Liability Statutory Appeal: Other S ❑ Product Liability (does not include ❑ Employment Dispute: mass lorl) ❑ Slander /LibeU Defamation Discrimination C ❑ Other: ❑ Employment Dispute: Other ❑ zoning Board T ❑ Other: ❑ Other: 0 MASS TORT ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY tNUSCELLANEOUS ❑ Toxic Waste ❑ Order. El Ejectment ❑Common Lnw /Statutory Arbitration B ❑ Eminent Domain /Condemnation ❑ Declaratory Aidgnncnt ❑ Ground Rent Mandamus ❑ Landlord/Tenant Dispute Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo WRrranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Titlo ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 111/1011 i u IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK Plaintiff ) NO. r V. AUTUMN ELLIOTT ) r t Defendant(s) ) "'� NOTICE TO DEFEND You have been sued in Court. If you wish to defend against Usted ha sido demandado en torte. Si usted desea defenderse the claims set forth in the following pages, you must take de las demandas que se presentan mas adelante en las action within TWENTY (20) DAYS after this Complaint and siguientes paginas, debe tomar accion dentro de Jos proximos notice are served, by entering a written appearance personally veinte (20) dias despues de la notificacion de esta Demanda y or by an attorney, and filing in writing with the Court your Aviso radicando personalmente o pot medio de un abogado defenses or objections to the claims set forth against you. You una comparecencia escrita y radicando en la Corte pot escrito are warned that if you fail to do so the case may proceed sus defensas de, y objecciones a, las demandas presentadas without you and a judgment may be entered against you by the aqui en contra suya. Sc le advierte de que si usted fall de court without further notice for any money claimed in the tomar accion como se describe anteriormente, el caso pude Complaint or for any other claim or relief requested by the proceder sin usted y un fallo pot cualquier suma de dinero Plaintiff. You may lose money or property or other rights reclamada en la demanda o cualquier reclamacion o remedio important to you. solicitado pot el demandante puede set dictado en contra suya pot la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad au otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER USTED DEBE LLEVAR ESTE DOCUMENTO A SU AT ONCE.IF YOU DO NOT HAVE A LAWYER GO TO OR ABOGADO INMEDIATAMENTE. SI USTED NO TIENE TELEPHONE THE OFFICE SET FORTH BELOW. THIS UN ABOGADO, LLAME O VAYA A LA SIGUENTE OFFICE CAN PROVIDE YOU WITH INFORMATION OFICINA. ESTA OFICINA PUEDE PROVEERLE ABOUT HIRING A LAWYER INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE OFFICE MAY BE ABLE TO PROVIDE YOU WITH UN ABOGADO, ES POSSIBLE QUE ESTA OFICINA LE INFORMATION ABOUT AGENCIES THAT MAY OFFER PUEDA PROVEER INFORMACION SOBRE AGENCIAS LEGAL SERVICES TO ELIGIBLE PERSONS AT A QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O REDUCED FEE OR NO FEE. BAJO COSO A PERSONAS QUE CALIFICAN. CUMBERLAND COUNTY BAR CUMBERLAND COUNTY BAR ASSOCIATION ASSOCIATION 32 SOUTH BEDFORD STREET 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 CARLISLE, PA 17013 717- 249 -3166 717 - 249 -3166 s PA 21Notice to Defend P &F File No. 12 -44515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) Plaintiff ) NO. V. ) AUTUMN ELLIOTT ) Defendant(s) ) COMPLAINT IN CIVIL ACTION AND NOW, comes Plaintiff, GE CAPITAL RETAIL BANK, by and through its attorney, GREGG MORRIS, ESQUIRE and the law offices of PATENAUDE & FELIX, A.P.C. and files the following Complaint in Civil Action, and in support thereof aver as follows: 1. Plaintiff, GE CAPITAL RETAIL BANK, is a National Bank and for the purpose of this litigation, maintaining a place of business c/o PATENAUDE AND FELIX, A.P.C., 213 East Main St Carnegie, PA 15106. 2. Defendant is AUTUMN ELLIOTT, an adult individual, believed to currently reside at 401 W DAUPHIN STREET ENOLA, PA 17025 -2214. 3. Heretofore, the Defendant(s) opened a account with Plaintiff being Account No. XXXXXXXXXXXX4917, for the purchase of good and services. A copy of the agreement is not currently available. The agreement provided in effect that Defendant will make minimum required monthly payments, and that if Defendant fails to make those payments, the account will be in default and the entire balance will be due. 4. The Defendant(s) has /have made or authorized a number of purchases and as of PA Civil Cmplt Crdt Crd P &F File No. 12 -44515 October 29, 2012, Defendant(s) owes $2,632.23 on said account plus costs. 5. Plaintiff maintains accurate books of account recording all credits and debits for this account. 6. Defendant assented to the correctness of the balance by making payments on the account. 7. Plaintiff mailed to Defendant billing setting forth the nature and amount of all charges made by Defendant(s), and the transactions between Plaintiff and Defendant(s) give rise to an account stated, upon which Plaintiff has relied by continuing to extend credit to Defendant(s). 8. The Defendant(s) made payments, but have /has refused to pay, and now refuses to pay the balance due and owing on the aforesaid account in the sum of $2,632.23, plus costs. 9. By making payments and by failing to object or dispute the statements, Defendant(s) have /has assented to and agreed to the correctness of the balance due on the credit card account so as to constitute and account stated. 10. Despite repeated demands, Defendant(s) have /has failed to make the required installment payments when due and therefore the full amount of the account is now due and payable. PA_05 Civil Cmplt Crdt Crd P &F File No. 12 -44515 WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amount of $2,632.23, plus interest as set forth herein from the date of breach, with continuing interest at the legal rate thereon from the date of Judgment plus costs. The damages requested are less than the maximum amount for compulsory arbitration as set by the Court. Respectfully submitted• Patenau & Feli , A.P.C. Date: August 01, 2013 M EL. Mor Main Street gie, PA 15106 (412) 429 -7675 PA_05 Civil Cmplt Crdt Crd P &F File No. 12- 44515 In Court 44515 PA Judicial (Circuit/District) Creditor Name: GE Capital Retail Bank Debtor Name: ELLIOTT, AUTUMN Account Number: *********'***4917 AFFIDAVIT OF ACCOUNT BALANCE STATE OF GEORGIA :SS COUNTY OF FULTON BEFORE ME, the undersigned authority personally appeared and personally known by me, this day, Aaron Robinson and who after being duly sworn deposed and says as follows: 1. 1 am a competent person over eighteen years of age. I am an employee of GE Capital Retail Bank ( "GE Capital "), which is the creditor for the account of the Debtor identified above. I am authorized to make this Affidavit.. 2. I have personal knowledge of the facts set forth in this affidavit. 3. The business records maintained by GE Capital in the ordinary course of its business show that as of the date of this affidavit, the unpaid balance of Debtor's account is $2,632.23. 4. The business records maintained by GE Capital in the ordinary course of its business show that as of the date of this affidavit the last payment was received from the Debtor on 2/13/2012 in the amount of $100.00. 5. The business records maintained by GE Capital in the ordinary course of its business show that the account of the Debtor was charged off on 10/29/2012 in the amount of $2,632.23. 6. Based on my search of the Department of Defense Service members Civil Relief Act (SCRA) website, it is my belief that the Debtor is not in military service. I declare nder the penalty of perjury that the foregoing is true and correct. 3/8/2013 Aaron Robinson RECOVERY LIAISON SPECIALIST - Affiant Th orgoi id t sworn to and subscribed before me this v ii ®�ayC "of�fi , 2013. d . JUNE N tary Public m 14, e 9018 V My commission expires: � - Version - 1.0.3_PA 09_19_2012 Ref:3N18832AEAN 88Nola�eu��o Det'endants Name: ELLIOTT, AUTUMN Account Number: * * * * * * * * * * ** *4917 VERIFICATION I hereby state that I am an employee for the plaintiff herein, with authority to sign this verification; and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. Section 4904 which provides for certain penalties for making false statements. Aaron Robinson Version - 1.0.3 PA 09 19 2012 Ref:3N18832AEAN SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ''4F "'i- "` Sheriff rrt THE THEL P R i'H O II W iii W Jody S Smith f, Chief Deputy w r 70 113 AU 1 PH 3: t TY Richard W Stewart � �-**` CUM MA Solicitor OFFICE OF THE SKERiF= P E W,4 S Y LV A N i A GE Capital Retail Bank Case Number V& 2013-4640 Autumn Elliott SHERIFF'S RETURN OF SERVICE 0810812013 08:01 PM-Deputy Jeff Kolodzi, being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Brenda Elliott, mother, who accepted as"Adult Person in Charge"for Autumn Elliott at 401 W. Dauphin Street, East Pennsboro, Enola, PA 17025. J KOL DZI, DEPUTY SHERIFF COST:$44.95 SO ANSWERS, August 09, 2013 R-ONO R ANDERSON, SHERIFF {c}CountySulte Sheriff,7eleosot#,Inc- °71LE D-far r I C E F THE F"ROTIHOINOTARY 2013 SEP 13 AM 10: 5 Si CUMBERLAND COUNT' PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) Plaintiff ) NO. Plaintiff V. ) AUTUMN ELLIOTT ) Defendant(s) ) PRAECIPE FOR DEFAULT JUDGMENT Filed on behalf o£ GE CAPITAL RETAIL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 0`,�A V'114.5� a cr-4 691) $2,632.23 vaas�3s PA-1 19 Prep Def Jg Both P&F File No.12-44515 yuv IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) Plaintiff ) NO. V. ) AUTUMN ELLIOTT ) Defendant(s) ) PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY Please enter a judgment against the defendant, above named, for failure to file an Answer to Plaintiffs complaint. Amount claimed in Complaint $2,632.23 Interest from October 29, 2012 $0.00 Less payments received $0.00 Attorney's fees $0.00 TOTAL $2,632.23 With continuing interest on the principal amount of$2,632.23, with interest at the legal rate,plus costs of suit. I hereby certify that a written notice of intention to file this praecipe was mailed to the defendants and defendants' counsel (if known), after the default had occurred and at least ten (10) days prior to the date of the filing of this praecipe. A copy of the Notice is ched. Respectful y subm'-"e . Patenau & , A.P.C. Date: September 10, 2013 Gr gg L. Mb s, Esquire 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_119 Prep Def Jg Both P&F File No.12-44515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) Plaintiff ) NO. V. ) AUTUMN ELLIOTT ) Defendant(s) ) PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF NOTICE PURSUANT TO PA.R.C.P. 1037(bl COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared GREGG MORRIS, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and states that the defendant(s), AUTUMN ELLIOTT, is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that Notice of Intent to take Default Judgment was mailed in accordance with Pa.R.C.P.237.1, as evidenced by the attached copy. Respectfully submittt Patenaude & Fel' /A.P.C. Date: September 10, 2013 Grg . Mo s, Esquire_ 34E. Main�treet- 9a/,megie, '— PA 15106 x(412) 429-7675 Sworn to and subscribed before me this �� NOTARIAL SEAL to day of , 2 MELINDA S PERRY Notary Public CARNEGIE BORO.,ALLEGHENY COUNTY My Commission Expires Jun 2, 2015 N tary Public w PA 120 Aff of Non Mil P&F File No. 12-44515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) Plaintiff ) NO. V. ) AUTUMN ELLIOTT ) Defendant(s) ) IMPORTANT NOTICE Filed on behalf of: GE CAPITAL RETAIL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude &Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA_113 10 Day Dl D2 P&F File No.12-44515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) Plaintiff ) NO. V. ) AUTUMN ELLIOTT ) Defendant(s) ) To: Autumn Elliott 401 W Dauphin Street Enola PA 17025-2214 Date of Notice: August 29, 2013 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 NOTICE TO A 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 32 South Bedford Street Carlisle PA 17013 717-249-3166 r . )2'13�naude ctfully submitted &Felix,A.P.C. Date: August 29, 2013 g L.Mo squire E. n Street rnegie,PA 15106 (412)429-7675 PA_113 10 Day Dl D2 P&F File No. 12-44515 I,GREGG MORRIS,attorney for Plaintiff, GE CAPITAL RETAIL BANK,hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: Autumn Elliott 401 W Dauphin Street Enola PA 17025-2214 /S/ Date: August 29,2013 egg . Morris,Esquire 13 . Main Street Ca egie,PA 15106 (412)429-7675 PA_113 10 Day Dl D2 P&F File No. 12-44515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) NO. 2 ) /J_ `fib yv Plaintiff V. ) AUTUMN ELLIOTT ) Defendant(s) ) NOTICE OF ORDER,DECREE OR JUDGMENT Filed on behalf o£ GE CAPITAL RETAIL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude &Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA 123 Ntc Jgmt Both P&F File No.12-44515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK j C CUl Plaintiff ) NO. ✓"�� V. ) AUTUMN ELLIOTT ) Defendant(s) ) NOTICE OF ORDER,DECREE OR JUDGMENT AGAINST AUTUMN ELLIOTT ONLY TO: ( )Plaintiff ( x)Defendant ( )Garnishee ( )Additional Defendant You are hereby no ifie that the following Order, Decree, or Judgment has been entered against you on � \3 ( ) Decree Nisi in Equity ( ) Final Decree in Equity (X) Judgment of( ) Confession ( ) Verdict ( ) Court Order (X) Default ( ) Non-suit ( ) Non-Pros ( ) Arbitration Award (X) Judgment in the amount of$2,632.23,plus costs. ( ) District Justice Transcript of Judgment in the amount of$ , plus costs. { ) If not satisfied within sixty(60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Prothonota By eputy If you have questions concerning the above,please Contact: Name of Attorney: GREGG MORRIS, Esquire 213 East Main St Carnegie PA 15106 (412)-429-7675 PA-123 Ntc 7gmt Both P&F File No.1244515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) Plaintiff ) ) NO. 13-4640 v. ) ) AUTUMN ELLIOTT ) 401 W Dauphin Street Enola Pa 17025-2214 ) Defendant(s) ) ) PNC BANK ) 235 N Enola Rd Enola Pa 17025 ) Garnishee ) PRAECIPE FOR WRIT OF EXECUTION Filed on behalf of: GE CAPITAL RETAIL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 • Patenaude &Felix,A.P.C. 213 E. Main Street Carnegie, PA 15106 (412)429-7675 PA 134 Prep Writ of Exe P&F File No.12-44515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) Plaintiff ) ) NO. 13-4640 v. ) ) AUTUMN ELLIOTT ) 401 W Dauphin Street Enola Pa 17025-2214 ) Defendant(s) ) ) PNC BANK ) _. 235 N Enola Rd Enola Pa 17025 ) Fri ; Garnishee ., PRAECIPE FOR WRIT OF EXECUTION To The Prothonotary: c° Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; y` (2) against, AUTUMN ELLIOTT Defendant(s); (3) against, PNC BANK, Garnishee; (4) and index this writ (a) against, Defendant(s)AUTUMN ELLIOTT, Defendant(s); and (b) against PNC BANK, Garnishee; as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows: (5) Amount due $2,632.23 .kdq.00 POMP/ Interest from September 13, 2013 W.q5 CU- At 0.00 % per annum $52.65 103."/5 " Court Cost I(y.50 Less: Payment $0,;0 Nit 6/0- Po Ally Total :,2,684.: OSTS d a5 ey for Plaintiff -5o U. or 70q 39 . 9987a U)rit c4) CE PA 134 Prep Writ of Exe P&F File No.12-44515 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-4640 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GE CAPITAL RETAIL BANK, Plaintiff(s) From AUTUMN ELLIOTT,401 W.Dauphin Street,Enola,PA 17025-2214 (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 GARNISHEE(S)as follows: PNC BANK,235 N Enola Rd,Enola,PA 17025 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$2,632.23 Plaintiff Paid$ Interest at 0.00% per annum 4rom Cl/13/13 -- 5a.(o5 Attorney's Comm. % Law Library$.50 Attorney Paid$194.20 Due Prothonotary$2.25 Other Costs$ Date: 12/30/13 111 411111i■I I'd D. B ell,Prothonotary By: Deputy REQUESTING PARTY: Name : GREGG L. MORRIS,ESQUIRE Address: PATENAUDE &FELIX APC 213 E MAIN STREET CARNEGIE,PA 15106 Attorney for: PLAINTIFF Telephone: 412-429-7675 Supreme Court ID No. 69006 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff - r r � 11 02 01 24;11)110,22 f Jody S Smith Chief Deputy .�. '-± -- Richard W Stewart • Solicitor .}N P S t,. ( 1"� I� i � , , GE Capital Retail Bank Case Number vs. Autumn Elliott 2013-4640 SHERIFF'S RETURN OF SERVICE 01/06/2014 02:05 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Natasa Torres, Assistant 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 January 7, 2014 to Autumn Elliott at 401 W Dauphin Street, Enola, PA 17025-2214. 411PI//� - w'TSHALL, DE-• SO ANSWERS, January 07, 2014 RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) Plaintiff ) NO. 13-4640 c: V. C" -�' AUTUMN ELLIOTT ) Nr-- Defendants(s) z C_- PNC BANK Garnishee ) PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY Filed on behalf of: GE CAPITAL RETAIL BANK Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix,A.P.C. 213 E. Main Street Carnegie, PA 15106 (412)429-7675 C1. 5D Soo P7 PA-193 Prcp Disc with Prjdc Garnishee only P&F File No.12-44515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE CAPITAL RETAIL BANK ) Plaintiff ) NO. 13-4640 V. ) AUTUMN ELLIOTT ) Defendant(s) ) PRAECIPE TO SETTLE AND DISCONTINUE WITHOUT PREJUDICE AS TO GARNISHEE ONLY TO: Prothonotary Please settle and discontinue the matter captioned above without prejudice as to Garnishee only. Thank you. Rgee.d d: P .P.C. Date: January 21, 2014 ire 2 , 412)429-7675 Sw orn to and subscribed before me this NOTARIAL SEAL day of__�Qn , 20 MELINDA S PERRY Notary Public �-- CARNEGIE BORO.,ALLEGH`ENrYC COUNTY My Commission Notary Public PA-193 Prep Disc with Prjdc Garnishee only P&F File No.12-44515 I, GREGG MORRIS, attorney for Plaintiff, GE CAPITAL RETAIL BANK , hereby certify that a true and correct of the foregoing document was served this date by US First Class Mail,postage prepaid upon the following: PNC BANK 235 N ENOLA RD ENOLA PA 17025 Date: January 31 2014 e . Morris, Esquire ate ude & Felix, A.P.C. 1 Main Street rnegie, PA 15106 (412) 429-7675 PA-193 Prcp Disc with Prjdc Garnishee only P&F File No.12-44515 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY I }' L. PROTHOh3i/ ret cuiro !„ OFr i�E QF THE $HERIFR gli4 AUG 29 PM 2: 03 CUMBERLAND COUNTY PENNSYLVANIA GE Capital Retail Bank vs. Case Number Autumn Elliott 2013-4640 SHERIFF'S RETURN OF SERVICE 01/06/2014 02:05 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Natasa Torres, Assistant 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 January 7, 2014 to Autumn Elliott at 401 W Dauphin Street, Enola, PA 17025-2214. 08/28/2014 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, August 28, 2014 (c) CountySuite Sherif', Teleosofi. i.nc RONR ANDERSON, SHERIFF