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HomeMy WebLinkAbout13-5124 A PROFESSIONAL CORPORATION x hereby certify that I have served a copy of this raper upon all other BY: EDWARD L. BERGER, ESQUIRE or the if attorneys by: Identification No. 34116 �lar mail. 1760 Market Street • Suite 600 ® certified mail Philadelphia, Pennsylvania 19103 o ther (215)564 -2031 B FAX (215)972 -5390 VALLEY FORGE MILITARY ACADEMY CUMBERLAND COUNTY & COLLEGE COURT OF COMMON PLEAS 1001 Eagle Road CIVIL DIVISION Wayne, Pennsylvania 19087 Plaintiff C / / fi ., V. NO. J��`� 6 � 1 c � BENJAMIN R. THORSON T" f�l ' 507 N. Bedford Street v- �� � Carlisle, Pennsylvania 17013 Defendant "'w o I �- PRAECIPE TO TRANSFER JUDGMENT v o `� TO THE PROTHONOTARY: Please enter judgment against the above captioned Defendant in accordance with Pennsylvania Rules of Civil Procedure 3002 as follows: Amount of Judgment entered in C.P. Delaware County $13,823.82 Interest at 6% from 04/25/13 to 07/25/13 + 204.72 Less Payments - 307.04 AMOUNT OF JUDGMENT $13,721.50 Dated: EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff �c C��.IySDAy ��agslo? ATTESTATION COMMONWEALTH OFPENNSYLVANIA) } ss: COUNTY OF DELAWARE } I, Chad F. Kenney, Sr., President Judge of the Court of Common Pleas of Delaware County, Pennsylvania, do hereby certify that the said, ANGELA L. MARTINEZ, by whom the attached CERTIFICATION and/or EXEMPLIFICATION was made, was, at the time of so making the same, and is now the Director of the Office of Judicial Support (Prothonotary and Clerk of said Court, duly commissioned and qualified; to all of whose acts as such, full faith and credit are and ought to be given, as well in courts of judicature as elsewhere; that the seal thereto annexed is the seal of the said Co ; that the said CERTIFICATION and/or EXEMPLIFICATIO in due form f law a d made by the proper officer. Dated this �-�s �' day of 7' geChaM A.D. 2013 P F. ney, COMMONWEALTH OFPENNSYLVANIA} } ss: COUNTY OFDELA WARE } I, ANGELA L.IVIARTINEZ, Director of the Office of Judicial Support (Prothonotary and Clerk) of the Court of Common Pleas of Delaware County, Pennsylvania, do certify that the Honorable CHAD F. KENNEY, SR., by whom the foregoing attestation was made, and who has thereunto subscribed his name, was, at the time of making thereof, and still is, President Judge of the Court of Common Pleas, in and for said County, duly commissioned and qualified; to all of whose acts as such, full faith and credit are and ought to be given, as well in courts of judicature as elsewhere. In testimony whereof, I have hereunto Set my hand and affixed the seal of said Court, this day of A.D. 2013 gela L. Martinez, it ctor I I DELAWARE COUNTY OFFICE OF JUDICIAL ° x ° 8 SUPPORT EXEMPLIFICATION Civil Docket Report COURT OF COMMON L PLEAS Report generated on: 711212013 9.52:38 AM COUNTY OF DELAWARE : S S Criteria : Case Number: 2013- 050374 CERTIFIED ATRUE AND CORRECT _ COPY FROM THE RECORD THIS � DAY O A.D�LO i L. MARTIN 2, 4Q., DIRECTOR am OF JU IAL SUPPORT Case Number S a us Jud e 2013- 050374 Active In The Matter Of Case Type VALLEY FORGE MILITARY ACADEMY AND COLLEGE V BENJAMIN R THORSON AND Debt Collection: Other CHARLENETHORSON Party Balance Attorneys VALLEY FORGE MILITARY ACAD & COLL Plaintiff $0.00 BERGER, EDWARD L SUITE 600, 1760 MARKET STREET PHILADELPHIA, PA 19103 BENJAMIN R THORSON Defendant $0.00 507 BEDFORD N ST CARLISLE, PA 19013 CHERLENE THORSON Defendant $0.00 507 BEDFORD N ST Delaware County Courthouse Page 1 of 3 201 West Front Street Media, PA 19063 DELAWARE COUNTY OFFICE OF JUDICIAL 8 ; K SUPPORT Civil Docket Report Report generated on: 711212013 9:52:38 AM Criteria : Case Number: 2013 - 050374 CARLISLE, PA 17013 Opened Court Type 2/22/2013 CIVIL (AOPC) No. Date of Pleadings Filed, Orders and Decrees Comments 1 2/22/2013 11:49:00 AM COMPLAINT FILED FEE AMOUNT: 0257.50 2 2/22/2013 11:49:00 AM ARBITRATION HEARING DATE:11 -20 -13 3 2/22/2013 11:49:00 AM CIVIL COVER SHEET I 4 2/22/2013 11:49:00 AM VERIFICATION FILED 5 2/22/2013 11:49:00 AM NOTICE TO DEFEND 6 2/22/2013 5:45:00 PM SCHEDULED DATE: 11/20/2013; SCHEDULE SEQ 0011; SCHEDULE STATUS: SCHEDULED; 7 4/9/2013 9:15:36 AM Sheriff's Service Process Receipt, and Affidavit BENJAMIN R. THORSON 3.11.2013 of Return 8 4/9/2013 9:16:53 AM Sheriff's Service Process Receipt, and Affidavit CHERLENE THORSON SERVED 3.8.2013 of Return 9 4/25/2013 11:21:37 AM Stipulation of Judgment IN THE AMOUNT OF $13,823.82 Delaware County Courthouse Page 2 of 3 201 West Front Street Media, PA 19063 DELAWARE COUNTY OFFICE OF JUDICIAL SUPPORT Civil Docket Report Report generated on: 711212013 9:52:38 AM Criteria : Case Number: 2013 - 050374 10 4/25/2013 11:32:20 AM Receipt# 018551 generated for the amount of $ 16.50 ALL FILINGS ARE LISTED END OF DOCUMENT JUDGMENT IS ENTERED IN THE AMOUNT OF $13 IN FAVOR OF THE PLAINTIFFS) AND AGAINST THE DEFENDANT(S). CERTIFIED A TRUE AND CORRECT COPY FROM THE RECORD. OFFICE OF JUDICIAL SUPPORT i CERTIFIED A TRUE AND CORRECT COPY FROM THE RECORD THIS 2 .' DAY 0 A.D&/3 ANGE L. MARTINEZ, E Q., DIRECTOR E OF JUDICI PPORT i Delaware County Courthouse Page 3 of 3 201 West f=ront Street Media, PA 19063 �os�aOiz 9 BY: EDWARD L. BERGER, ESQUIRE ✓ pr S 4/f//; 2 1760 Mark Street 4 S uite 600 p �pgNi�,(' Philadelphia, Pennsylvania 19103 (215)564 -2031 FAX (215)972 -5390 VALLEY FORGE MILITARY ACADEMY DELAWARE COUNTY & COLLEGE COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V . BENJAMIN R. THORSON and NO. 13 -50374 CHERLENE THORSON Defendants STIPULATION FOR JUDGMENT AND NOW, this �_ day of .� 2015, it is hereby Stipulated by and between EDWARD L, BERGER, ESQUIRE, Attorney for Plaintiff, VALLEY FORGE MILITARY ACADEMY & COLLEGE, and BENJAMIN R. THORSON, Defendant, as follows: 1. That Judgment be and is hereby entered in favor of the Plaintiff and against the Defendant, BENJAMIN R. THORSON, in the amount of $13,823.82 calculated as follows: Total Amount Due as set forth in the Complaint $ 9,556.30 Attorneys fees at 40% + 3,822.52 Subtotal $13,378.82 PLUS: Court Costs + 445.00 TOTAL $13,823.82 2. Defendant agrees to pay Plaintiff the sum of $13,823.82, together with interest at the rate of Six percent (6 %) per annum on the unpaid balance until such sum shall be paid in full pursuant to the following payment schedule: CERTIFIED ATRUE AND CORRECT CO��yP,Y FROM THE RECORD THIS " DAY ANG MARTINEZ, E ,DI RECTOR CE OF JUDI SUPPORT A. $80.00 beginning March 28, 2013 and due by the 28th day of each succeeding month for a 24 month period until, but including, the month of February 2015. B. Defendant agrees to make monthly payments in an amount to be negotiated between the parties hereto at a rate acceptable to Plaintiff, in its sole discretion, beginning March 2015, and continuing each succeeding month thereafter on the 28th day of each month until the total amount as set forth above shall be paid in full together with all interest accrued thereon. Defendant recognizes that said monthly installments must be at a rate acceptable to Plaintiff and that said monthly installments may include a graduated plan whereby the monthly installments increase in amount. 3. All payments hereunder shall be payable to "GORDIN & BERGER TRUST ACCOUNT" at 1760 Market Street, Suite 600, Philadelphia, Pennsylvania 19103, unless otherwise directed in writing by EDWARD L. BERGER, Attorney for Plaintiff. 4. Plaintiff agrees not to seek execution upon the Judgment entered herein so long as Defendant is in compliance with the above terms. Upon default of any term hereunder, and specifically upon a default of any payment due hereunder, Plaintiff is permitted to immediately seek execution pursuant to the Judgment entered herein. In the event Plaintiff chooses not to execute, but rather accepts payments and applies payment to the account, the acceptance of said default payment will not constitute a waiver by Plaintiff of the default. 5. The terms, provisions and conditions of this Stipulation shall be binding upon and shall inure to the benefit of the parties hereto and their respective heirs, successors and assigns. 2 6. This Stipulation contains the entire agreement between the parties hereto with respect to the transactions contemplated hereby and shall not be changed or terminated except by written instrument signed by the parties hereto. 7. This Stipulation is declared to be made under the laws of the Commonwealth of Pennsylvania. 8. It is intended that this Stipulation shall be filed with the Court of Common Pleas of Delaware County, Pennsylvania to be kept on record in the above captioned matter. 9. It is hereby represented by EDWARD L. BERGER, Attorney for Plaintiff, that he is duly authorized to execute this Stipulation under and pursuant to the instructions and authorizations of the Plaintiff. VALLEY FORGE MILITARY ACADEMY & COLLEGE By: EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff Witness IN R. R ON, Defendant STATE OF PENNSYLVANIA ss COUNTY OF DELAWARE Before me on this day of �` , 20L5, personally appeared BENJAMIN R. THORSON, who being duly sworn according to law, hereby deposes and says that he is the Defendant named in the above Stipulation for Judgment and that this person signed, sealed and delivered this document as his act and deed. NOTARY PUBLIC 3 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS To: Mr. Benjamin R. Thorson 7 Pine Road, Apartment #1607 Mount Holly Springs, PA 17065 Valley Forge Military Academy & College DELAWARE COUNTY Plaintiff COURT OF COMMON PLEAS V. Benjamin R. Thorson and No. _ 13 -50374 Cherlene Thorson Defendant Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. ❑ Judgment by Default Money Judgment ❑ Judgment in Replevin ❑ Judgment for Possession ❑ Judgment on Award of Arbitrators ❑ Judgment on Verdict ❑ Judgment on Court Findings If you have any questions concerning this notice, please call: ATTORNEY EDWARD L. BERGER Esquire (lnserl Attorney's Nmne) at this telephone number: 215 -564 -2031 10-232 (ar. 2100) r A PROFESSIONAL CORPORATION - 4 w-w- BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564 -2031 FAX (215)972 -5390 VALLEY FORGE MILITARY ACADEMY CUMBERLAND COUNTY & COLLEGE COURT OF COMMON PLEAS 1001 Eagle Road CIVIL DIVISION Wayne, Pennsylvania 19087 Plaintiff ` 5 (a CU' f V. No. l 3 BENJAMIN R. THORSON 507 N. Bedford Street Carlisle, Pennsylvania 17013 Defendant ASSESSMENT OF DAMAGES AND NOW, to wit, this %b day of Q , 2013, Judgment is entered in favor of the above referenced Plaintiff, and against BENJAMIN R. THORSON, the above referenced Defendants, for failure to file an Answer and Plaintiff s damages are assessed in the sum of $ 13,721.50. w Prothonotary A PROFESSIONAL CORPORATION .iT.LLUM"CJI 6 a!t-? Z, BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street - Suite 600 Philadelphia, Pennsylvania 19103 (215)564 -2031 FAX (215)972 -5390 VALLEY FORGE MILITARY ACADEMY CUMBERLAND COUNTY & COLLEGE COURT OF COMMON PLEAS 1001 Eagle Road CIVIL DIVISION Wayne, Pennsylvania 19087 Plaintiff V. NO. BENJAMIN R. THORSON 507 N. Bedford Street Carlisle, Pennsylvania 17013 Defendant AFFIDAVIT OF NON - MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND EDWARD L. BERGER, ESQUIRE, being duly sworn according to law, hereby deposes and says that I am the attorney for the Plaintiff in the above captioned action, and that the following Defendant is not in the Military Service of the United States of America or any State or Territory thereof, or its allies, and that the Defendant is not in any manner subject to the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended: Benjamin R. Thorson 507 N. Bedford Street Carlisle PA 17013 SWORN TO AND SUBSCRIBED �C BEFORE ME THIS o48 DAY OF �pl,� EDWARD L. BERGER, ESQUIRE X F Attorneys for Plaintiff NOTZ PUBLIC ON • PENN�,VA§" NOTARIAL SEAL DANA M. STEPHAN NoWy pu* City of Philad ia, PhikL Commission JUN Za 17 A PROFESSIONAL CORPORATION .�&� at-raar BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564 -2031 FAX (215)972 -5390 VALLEY FORGE MILITARY ACADEMY CUMBERLAND COUNTY & COLLEGE COURT OF COMMON PLEAS 1001 Eagle Road CIVIL DIVISION Wayne, Pennsylvania 19087 Plaintiff V. NO. BENJAMIN R. THORSON 507 N. Bedford Street Carlisle, Pennsylvania 17013 Defendant AFFIDAVIT OF ADDRESS COMMONWEALTH OF PENNSYLVANIA : ss COUNTY OF CUMBERLAND I, EDWARD L. BERGER, ESQUIRE, being duly sworn according to law, hereby deposes and says that I am the attorney for the Plaintiff, VALLEY FORGE MILITARY ACADEMY & COLLEGE, in the above captioned action, and that the last known address for the Defendant, BENJAMIN R. THORSON, is as follows: Benjamin R. Thorson 507 N. Bedford Street Carlisle PA 17013 SWORN TO AND SUBSCRIBED Af-t &v 8c ZeCVei; -0. 0 BEFORE ME THIS oV DAY OF A EDWARD L. BERGER, QUIRE NOTARY PUBLIe Attorneys for Plaintiff COMMONW OF I� VL.VM" NOTARIAL SEAL DONNA M. STEPNAN, Pubk �� Jt�e�t OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS To: Mr. Benjamin R. Thorson 507 North Bedford Street Carlisle, PA 17013 Valley Forge Military Academy & College CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEA V. Benjamin R. Thorson No. Defendant Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. ❑ Judgment by Default Money Judgment ❑ Judgment in Replevin ❑ Judgment for Possession ❑ Judgment on Award of Arbitrators` " . 3 ❑ Judgment on Verdict ❑ Judgment on Court Findings . If you have any questions concerning this notice, please call: ATTORNEY EDWARD L. BERGER Esquire (Insert Attorney's Name) at this telephone number: 215 -564 -2031 10-232 (Rev. 2100) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION VALLEY FORGE MILITARY • File No. 2013-5124 ACADEMY & COLLEGE • Amount Due 13,721.50 v. • Interest 08/30/13 BENJAMIN R. THORSON • Atty's Comm -_- Vt7, '60: SI" Costs 5te,-Pp Olt ci.)1— TO THE PROTHONOTARY OF THE SAID COURT: t'- The undersigned hereby certifies that the below does not arise out of a retail instant contract, or account based on a confession of judgment, but if it does, it is based on the a triae , original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant tc44ActE of 1974 as amended. PRAECIPE FOR WRIT OF EXECUTION Issue writ 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) MEMBERS 1ST FEDERAL CREDIT UNION 130 Ol& Lior 1G oa Tyl 1\)cw C�xv .v La t'/ PRAECIPE FOR ATTACHMENT EXECUTION (1010 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) Checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee belonging to the Defendant, BENJAMIN R. THORSON. and all other property of the Defendant(s) in the possession, custody or control of the said Garnishee(s). (Indicate) Index this writ against the Gary'.--_ as • • pendens against real estate of the Defendant(s) described in the attached exhibit. DATE: f 14i Signature: Print Name: Edward L. Berger, Esquire a.t,W\ ,t3:(?A Address: Gordin & Berger, P.C. 5 p ('r13 F 1760 Market Street, Suite 608 33. 50 I.t " Philadelphia, PA 19103 ^� a Attorney for: Plaintiff Telephone: 215-564-2031 Supreme Court ID No. 34116 Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (Pa. R.C.P No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. 0a,a6 a� n Iy(oW oN t &Jd WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-5124 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due VALLEY FORGE MILITARY ACADEMY & COLLEGE Plaintiff(s) From BENJAMIN R.THORSON,507 NORTH BEDFORD STREET,CARLISLE,PA 17013 (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: MEMBERS FIRST FCU, 130 OLD YORK ROAD,NEW CUMBERLAND,PA 17070-CHECKING ACCOUNTS,SAVINGS ACCOUNTS,MONIES ON DEPOSIT,SAFETY DEPOSIT BOXES,OR ANY OTHER PERSONALTY OR REALTY WHICH MAY BE IN THE POSSESSION OF THE GARNISHEE BELONGING TO THE DEFENDANT BENJAMIN R.THORSON 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$13,721.50 Plaintiff Paid$ Interest 8/30/13 Attorney's Comm. % Law Library$.50 Attorney Paid$320.00 Due Prothonotary$2.25 Other Costs$ Date: JANUARY 23,2014 �.� _ ! David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : EDWARD L. BERGER,ESQUIRE Address: GORDIN& BERGER,P.C. 1760 MARKET STREET,SUITE 608 PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-2031 Supreme Court ID No.34116 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson �i ,� Sheriff �r Jody S Smith t t �1! if}li"'F r Chief Deputy 2014 JAN 29 b 3. O? Richard W Stewart CUMBER 1.AN© ®DINT y Solicitor PENNSYLVANIA t.vaNla Valley Forge Military Academy& College vs. Case Number Benjamin Thorson 2013-5124 SHERIFF'S RETURN OF SERVICE 01/27/2014 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Kathleen Nissley, Sales Assistant, 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 28, 2014 to Benjamin R. Thorson at 507 N Bedford Street, Carlisle, PA 17013 (NOTE: Attorney had provided an envelope for defendant, but had an address of 131 Center Street, Carlisle, PA-there does not appear to be a 131 Center Street in Carlisle; address on writ was 507 N Bedford Street, Carlisle). ILLIAM CLINE, DEPUTY SO ANSWERS, X"://) January 28, 2014 RONNY R ANDERSON, SHERIFF • , ;L 0- 4'H ..r �orz �L/�e/[. 1i0tTN:: PHOFF'SIO\:ti('ORPORATIOO', :011-iiiirEEP8R_Ol PM '• go 4 o we5.v at%waw BY: EDWARD L. BERGER, ESQUIRE t�UMBERLANt) COUNTY Identification No. 34116 PENNSYLVANIA 1760 Market Street • Suite 608 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 VALLEY FORGE MILITARY CUMBERLAND COUNTY ACADEMY & COLLEGE COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. BENJAMIN R. THORSON Defendant NO. 2013-5124 -and- MEMBERS Isl.FEDERAL CREDIT UNION Garnishee INTERROGATORIES IN ATTACHMENT TO: MEMBERS 1ST FEDERAL CREDIT UNION; 130 Old York Road,New Cumberland, PA 17070 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 a default judgment being entered against you. 1. At the time you were served, or at any subsequent time, did you owe the Defendant(s) any money or were you liable to Defendant(s) on any negotiable or other written instrument, or did Defendant(s) claim that you owed Defendant(s) any money or were liable to him/her for any reason? nL 2. At the time you were served, or at any subsequent time, was there in your possession, custody, control, or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the Defendant(s)? fLi 3. At the time you were served, or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the Defendant(s) or in which Defendant(s) held or claimed any interest? nL 4. At the time you were served, or at any subsequent time, did you hold as fiduciary any property in which the Defendant(s) had an interest? fl3 • • 5. At any time before or after you were served did the Defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and what was the consideration thereof? 6. At the 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 Defendant(s) direction or otherwise discharge any claim of the Defendant(s) against you? nc� 7. If you are a bank or other financial institution, at the time you were served or any subsequent time did the Defendant (s) 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? If so, identify each account and state the reason for the exemption and the entity electronically depositing those funds on,/a�nn j recurring basis. 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) 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 exemption under 42 Pa. C.S. §8123? If so, identify each account. 10 — Nr) 'uRdS 9. How much is the value of any property in your possession belonging to the Defendant(s)? UO vc7o,duri Bc Oeiyer; a EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff • A PROFESSIONAL CORPORATION 2014 J I Iii f j -i i A k ,iR 24 p� BY: EDWARD BERGER,ESQUIRE °JN'N (' Identification No.34116 p A'S ° cow" "� 1760 Market Street•Suite 608 L t/,4 VA t Philadelphia,Pennsylvania 19103 (215)564-2031 FAX(215)972-5390 VALLEY FORGE MILITARY CUMBERLAND COUNTY ACADEMY & COLLEGE COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. BENJAMIN R. THORSON NO. 2013-5124 Defendant -and- MEMBERS 1ST FEDERAL CREDIT UNION Garnishee ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against Garnishee, MEMBERS 1ST FEDERAL CREDIT UNION, discontinued, upon payment of your costs only. .ora z' c t,/ • , �� EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff RVA Nu ass ,k •SUPict c1 gb5\L Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE ?'ROTI HONO ?.alis AUG 29 PM 2: , QF wry=rirr CUMBERLAND COMTY PENNSYLVANIA Valley Forge Military Academy & College vs. Benjamin Thorson Case Number 2013-5124 SHERIFF'S RETURN OF SERVICE 01/27/2014 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Kathleen Nissley, Sales Assistant, 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 28, 2014 to Benjamin R. Thorson at 507 N Bedford Street, Carlisle, PA 17013 (NOTE: Attorney had provided an envelope for defendant, but had an address of 131 Center Street, Carlisle, PA - there does not appear to be a 131 Center Street in Carlisle; address on writ was 507 N Bedford Street, Carlisle). 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 RONNY R ANDERSON, SHERIFF (c) CountvSuito Sheriff, Teleosofj, Inc.