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HomeMy WebLinkAbout13-5577 .( h 2162734 F''L '9L -0F f= E P1 -", 01 i 0 TA. "i Y CORDON & WEINBERG, P.C. �' '' 0t " ' BY: FREDERIC I. WEINBERG, ESQUIRE 20i3 JET, 23 P11 2: 2 Identification No.: 41360 JOEL M. FLINK, ESQUIRE CUMBERLAND COLfl"iTY Identification No.: 41200 PENNSYLVANIA 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351 -0500 CAPITAL ONE BANK (USA), N.A. COURT OF COMMON PLEAS 4851 Cox Road CUMBERLAND COUNTY Glen Allen, VA 23060 VS. DOCKET NO. : 13- 5577 3 i1 - F& r► KEITH A GARDNER 134 HUMMEL AVE LEMOYNE PA 17043 -1435 PRAECIPE FOR ENTRY OF APPEARANCE, TRANSFER OF JUDGMENT ASSESSMENT OF DAMAGES AND VERIFICATION OF ADDRESSES) VALIDITY AND NON MILITARY SERVICE TO THE PROTHONOTARY: Enter my appearance for the Plaintiff in the above matter; enter judgments in favor of Plaintiffs) against Defendants) on the duly authenticated copy of the magisterial district justice judgment hereto attached, entered in the jurisdiction noted therein, and assess damages as follows: $3,211.03 Judgment $41.17 Post Judgment Interest $.00 Post Judgment Costs �3(,a5 pp A77 $.00 Post Judgment Payments atl %l q $3,252.20 Total # a9� 97 a No-kc� ma +lec� Pursuant to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: (1) the precise last known address(es) of the Plaintiff(s) and Defendant(s) are as above.; (2) that said judgments were entered by the Magisterial Court in the said jurisdiction in said amount with costs and interest due as noted, no part of which has been paid (except as noted) and which is valid, enforceable and unsatisfied; find a copy of which is attached hereto; (3) and that the Defendant(s) is (are) over 18 years of age and not in the military service of the United States or its allies or otherwise within coverage of the Soldiers and Sailors Relief Act of i 1940, as amended, and had (have civilian occupation(s). Date: [( FREDERIC INBERG, ESQUIRE JOEL M. FL K, ESQUIRE DAMAGES ASSESSED AND JUDGMENT(S) ENT ED AS ABOVE NOTICE(S) GIVEN UNDE PA. I .236 2162734 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351 - 0500 CAPITAL ONE BANK (USA), N.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. VS. KEITH A GARDNER 134 HUMMEL AVE LEMOYNE PA 17043 -1435 NOTICE Pursuant to Pa.R.Civ.P. 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 $3,252.20 /x / Money Judgment $$3,252.20 Judgment on Award of Arbitrators$ �L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. NK, ESQUI AT THIS ELEPHONE NUMBER: 484/351 -0500 fay r 4 PROTHONOTARY Department of Defense Manpower Data Center Results as of: Sep -12- 201307:54;02 SCRA 3.0 Status Deport I yus Pursuant to Servicernemben Civil Relief Act Last Name: GARDNER First Name: KEITH Middle Name: A Active Duty Status As Of: Sep -12 -2013 On Active Duty On Active Duty Status Date Active Duty Start Dale Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA I No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. MaI l L Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty' responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: hftp: / /www.defenselink .mil /faq /pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his /her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN /date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: U4K1 G8A890DCY10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOtICe Of Judgment/Transcript CIVIC Case Mag. Dist. No: MDJ- 09 -1 -02 Capital One Bank (USA) NA MDJ Name: Honorable Elizabeth S. Beckley v Address: 1901 State Street Keith A Gardner Camp Hill, PA 17011 Telephone: 717- 761 -0583 Frederic Ivan Weinberg, Esq. Docket No: MJ- 09102 -CV- 0000089 -2013 1001 E. Hector Street, Suite 220 Case Filed: 5/22/2013 Conshohocken, PA 19428 Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09102 -CV- 0000089 -2013 Capital One Bank (USA) NA Keith A Gardner Default Judgment for Plaintiff 06/25/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Capital One Bank (USA) NA $0.00 $0.00 $0.00 Keith A Gardner $0.00 $3,211.03 $3,211.03 Judgment Detail (Post Judgment) In the matter of Capital One Bank (USA) NA vs. Keith A Gardner on 6/25/2013 the judgment was awarded as follows: Judament Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $3,082.77 - $3,082.77 Filing Fees $0.00 $128.26 $128.26 Grand Total: $3,211.03 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTIC&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. N 2013 0 JUN Z ffi Date Elizabeth S. Beckley ri i' Wi certify that this is a true and correct copy of the record ol the proceedings contai t e lu nt. D isteri Dis rict Judg MDJS 315 Page 1 of 2 Printed: 06/26/2013 12:01:36PM Capital One Bank (USA) NA Docket No.: MJ- 09102 -CV- 0000089 -2013 V. Keith A Gardner Participant List Private(s) Frederic Ivan Weinberg, Esq. 1001 E. Hector Street, Suite 220 Conshohocken, PA 19428 Plaintiff(s) Capital One Bank (USA) NA 4851 Cox Road Glen Allen, VA 23060 Defendant(s) Keith A Gardner 43 N 9th St Lemoyne, PA 17043 -1435 F C�TOdC� AUG 2 2 2013 MDJS 315 Page 2 of 2 Printed: 06/26/2013 12:01:36PM COMMONWEALTH OF PENNSYLVANIA Notice Of Judgment/Transcript Civil COUNTY OF CUMBERLAND, Case Mag. Dist. No: MDJ- 09 -1 -02 Capital One Bank (USA) NA MDJ Name: Honorable Elizabeth S. Beckley v Address: 1901 State Street Keith A Gardner Camp Hill, PA 17011 Telephone: 717- 761 -0583 Capital One Bank (USA) NA Docket No: MJ- 09102 -CV- 0000089 -2013 4851 Cox Road Case Filed: 5/22/2013 Glen Allen, VA 23060 Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09102 -CV- 0000089 -2013 Capital One Bank (USA) NA Keith A Gardner Default Judgment for Plaintiff 06/2512013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Capital One Bank (USA) NA $0.00 $0.00 $0.00 Keith A Gardner $0.00 $3,211.03 $3,211.03 Judgment Detail ('Post Judgment) In the matter of Capital One Bank (USA) NA vs. Keith A Gardner on 6/25/2013 the judgment was awarded as follows: Judgment Component . Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $3,082.77 $3,082.77 Filing Fees $0.00 $128.26 $128.26 Grand Total: $3,211.03 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. JUN 26 2013 Date Elizabeth S. Beckley certify that this is a true and correct copy o t recor of the proceedings contain the lu t. M isteri Dis rict Judg MDJS 315 Page 1 of 2 Printed: 06/26/2013 12:01:36PM Capital One Bank (USA) NA Docket No.: MJ- 09102 -CV- 0000089 -2013 V. Keith A Gardner Participant List Private(s) Frederic Ivan Weinberg, Esq. 1001 E. Hector Street, Suite 220 Conshohocken, PA 19428 Plaintiff(s) Capital One Bank (USA) NA 4851 Cox Road Glen Allen, VA 23060 Defendant(s) Keith A Gardner 43 N 9th St Lemoyne, PA 17043 -1435 MDJS 315 Page 2 of 2 Printed: 06/26/2013 12:01:36PM 2162734 GORDON & WEINBERG, P.C. BY: Identification No. : 41360 + dye i'F Oi' GL JOEL M. FLINK, ESQUIRE � � _5 Identification No. : 41200 pm 3: 35 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 CU R�� COUNTY 484/351-0500 PENNSYLVANIA °▪ CAPITAL ONE BANK (USA) , N.A. COURT OF COMMON PLEAS —4851 Cox Road CUMBERLAND COUNTY =Glen Allen, VA 23060 EMM vs. DOCKET NO. : 13-5577 CT gggKEITH A GARDNER °134 HUMMEL AVE IgILEMOYNE PA 17043-1435 and ijiMetro Bank =3201 Trindle Rd. Camp Hill, PA 17011 GARNISHEE EE- E PRAECIPE FOR WRIT OF EXECUTION EMETO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; aaa (1) against KEITH A GARDNER defendant (s) and (2) against Metro Bank EEE garnishee (s) _ (3) Amount Due $3, 211 . 03 Interest from September 23, 2013 $68 . 43 Costs Prothonotary fee Sheriff fee (4) Less : Payments on Account $ . 00 TOTAL ,ash . aqaL- Ok , i 31. s Nea : 0 . as a FREDERIC I . WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff IL l# igaa'1 UN A- v( 6u D.: WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-5577 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Capital One Bank(USA),NA Plaintiff(s) From KEITH A. GARDNER, 134 HUMMEL AVENUE,LEMOYNE,PA 17043 (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 GARNISHEE(S)as follows: METRO BANK,3201 TRINDLE ROAD,CAMP HILL,PA 17011 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$3,211.03 Plaintiff Paid$ Interest FROM SEPTEMBER 23,2013-$68.43 Attorney's Comm. % Law Library$.50 Attorney Paid$60.25 Due Prothonotary$2.25 Other Costs$ Date: FEBRUARY.5,2014 / _ 111 _ David D. Buell,Prothonotary Deputy REQUESTING PARTY: Name : FREDERIC I.WEINBERG, ESQUIRE Address: GORDON& WEINBERG,P.C. 1001 E.HECTOR STREET,SUITE 220 CONSHOHOCKEN,PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson :a +"'�- Sheriff f', P U w. t a j v ,',.y 4q.',"'t, f €tar€for. ,, Jody S Smith Mk FEB 19 AN : 3,c Chief Deputy Richard W Stewart 'CUMBERLAND COUNTY Solicitor G EstERIFr, PENNSYLVANIA Capital One Bank Case Number vs. Keith Gardner, Jr 2013-5577 SHERIFF'S RETURN OF SERVICE 02/12/2014 10:18 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, Metro Bank, 65 Ashland Ave, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Suzzanne Yingling, Customer Service, 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 February 14, 201, to K-ith A. Gardner at 134 Hummel Avenue, Lemoyne, PA 17043-1435. i LA, CLINE, EP SO ANSWERS, February 14, 2014 RON6 R ANDERSON, SHERIFF GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 u.. j `1r M IL 1001 E. Hector Street, Ste 220 04,1% 1 484/351�0500, PA 19428 20111 FEB 9 Pm 1+ Cues-RL VDU CAPITAL ONE BANK (USA) , N.A. COURT OF COMMON PLEA�Efluor VA1fUN, 4851 Cox Road CUMBERLAND COUNTY Glen Allen, VA 23060 vs . DOCKET NO. 13-5577 CT KEITH A GARDNER 134 HUMMEL AVE LEMOYNE PA 17043-1435 and 3201 Trindle Rd. Camp Hill, PA 17011 GARNISHEE ZflSi INTERROGATORIES IN ATTACHMENT TO: Metro Bank - GARNISHEE You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so my result in judgment 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 the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? Defendant has account xxxxx5707 with a balance of $.17 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. 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 or in which defendant held or claimed any interest. 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? 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 if so what was the consideration therefore? 6. At any 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 his (her, their) direction or otherwise discharge any claim of the defendant (s) against you? 7. 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 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, the amount of. funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis . 8 . 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 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? If so, identify each account. 9. How much is the value of any property in your possession belonging to the defendant (s) ? FREDERIC -I,--GSEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff DATED: /0 7( VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. „„ (SIGN s TURE) 2162734 GORDON & WEINBERG, P.C. � � ,,� y BY: FREDERIC I . WEINBERG, ESQUIRE cup'ta,j'�A � � 09 JOEL M. Identification ESQUIRE NIA�NNSy A i �ti Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 _ CAPITAL ONE BANK (USA) , N.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY VS . DOCKET NO. : 13-5577 CT KEITH A GARDNER and Metro Bank Garnishee PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment against Metro Bank, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. BY: FREDER WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P011 IP t D tf ! #t, y 7 _1 ONO it �� ��162734 ���� � �� �'�' � CORDON & WEINBERG, P. C. BY: FREDERIC I . WEINBERG, ESQUIRE CUMBE R L AN0 C0 UNIT Y Identification No. : 41360 PENNSYLVANIA VANjA JOEL M. FLINK, ESQUIRE Identification No. : 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 CAPITAL ONE BANK (USA) , N.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY VS . DOCKET NO. 13-5577 CT KEITH A GARDNER SUGGESTION OF BANKRUPTCY OF DEFENDANT TO THE PROTHONOTARY: AND NOW, this 17Mar14, it is suggested of record that Defendant, KEITH A GARDNER, filed a petition in bankruptcy under Chapter 13 of the Bankruptcy Code on or about March 11, 2014, in the United States Bankruptcy Court for the Middle District of Pennsylvania, docket number 1401027 . Therefore, this matter should be stayed until further notice. GORDON & WEINBERG, P.C. BY: FREDERI I . W NBERG, ESQUIRE JOEL M F K, ESQUIRE Attorney for Plaintiff Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF.ICE ti^.f THE SKEF,IFF iiILISES' 17 Phi CUMBERLAND COUNT`t PENNSYLVANIA Capital One Bank vs. Keith Gardner, Jr Case Number 2013-5577 SHERIFF'S RETURN OF SERVICE 02/12/2014 10:18 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, Metro Bank, 65 Ashland Ave, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Suzzanne Yingling, Customer Service, 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 February 14, 2014 to Keith A. Gardner at 134 Hummel Avenue, Lemoyne, PA 17043-1435. 09/16/2014 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. However, attorney did file a suggestion of bankruptcy of defendant, indicating that defendant filed a Chapter 13 bankruptcy on or about March 11, 2014. SHERIFF COST: $88.26 SO ANSWERS, September 16, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teieosefi, inc. .2`S#,d _ f$/7 ietti 3 /I)3/.