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Home My WebLink About13-6402 IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY,PENNSYLVANIA _ CIVIL DIVISION PLAINTIFF ACC, LLC P.O. BOX 264 TAYLOR, PA 18517 _ - NO.: 2013-2127 VS. CIVIL i DEFENDANT HEATHER JUNKER 208 LONG STRETCH ROAD PINE GROVE, PA 17963 GARNISHEE Y WELLS FARGO BANK _FT" ? _ 604 E. HIGH STREET CARLISLE,PA 17101 '' PRAECIPE TO AMEND AND REISSUE WRIT OF EXECUTION - GARNISHMENT ONLY TO THE PROTHONOTARY: PLEASE BE KIND ENOUGH TO AMEND AND REISSUE WRIT OF EXECUTION, IN CONNECTION WITH THE ABOVE CAPTIONED MATTER. DIRECTED TO THE CUMBERLAND COUNTY SHERIFF ONCE FILED, PLEASE FORWARD TO US AND AS WE WILL BE FORWARDING TOANOTHER COUNTY. THANK YOU. RESPECTFULLY SUBMITTED DATE: l0 16 1, ^� J es T. Mulligan, Jr., sq. O. Box 264 Taylor,PA 18517 PA ID# 51794 (570)207-3383 x235 In House Counsel for Plaintiff ATTEST A TRIJE COPY LINDA L.DEARD;PROTHONOTARY IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA ACC,LLC P.O.BOX 264 TAYLOR,PA 18517 Plaintiff J.D.No.: 2013-2127 VS. HEATHER JUNKER E.D. 208 LONG STRETCH ROAD PINE GROVE,PA 17963 Defendant C� WELLS FARGO BANKJ' 380 FLORAL AVENUE 1V iu CHAMBERSBURG,PA 17201 w CD Garnishee PRAECIPE FOR WRIT OF EXECUTION tv TO THE PROTHONOTARY: Issue writ of execution on the above matter,directed to the Sheriff of Franklin County (1) against Heather Junker,Defendant;and (2) against Wells Fargo Bank,garnishee;and (3) and enter this writ in judgment Index (a) against Heather Junker,Defendant,and (b) against Wells Fargo Bank,as garnishee,as a lis pendens against real property of the defendant In the name of garnishee as follows: n/a JUDGMENT:$7,749.74 INTEREST:$2,444.28 PROTHONOTARY:$ SHERIFF: $ TOTALS RESPECTFULLY SUBMITED, Dated am s T.Mulligan,Jr.,Esq. .Box 264 Taylor,PA 18517 PA ID#51794 (866)760-6205 ext.235 In-House Counsel for Plaintiff ATT S -A TRUE OP c LINDA L.BEARD,PR0 MONO TARY IN THE COURT OFF COMMON PLEAS OF FRANKLIN COUNTY,PENNSYLVANIA WRIT OF EXECUTION (MONEY JUDGMENTS) Rules P.R.C.P.3101 to 3144 ACC, LLC P.O. BOX 264 TAYLOR, PA 18517 Plaintiff J.D. No.2013-2127 VS. HEATHER JUNKER. E.D. 208 LONG STRETCH ROAD PINE GROVE, PA 17963 Defendant WELLS FARGO BANK 380 FLORAL AVENUE CHAMBERSBURG, PA 17201 Garnishee GARNISHEE:WELLS FARGO BANK COMMONWEALTH OF PENNSYLVANIA,COUNTY OF FRANKLIN TO THE SHERIFF OF FRANKLIN COUNTY, PENNSYLVANIA To satisfy the judgment,interest and costs against Defendant, Heather Junker (1) You are directed to levy upon the property of the defendant and sell his interest therein; (2) You are also directed to attach the property of the defendant not levied upon in the possession of Wells Fargo Bank,380 Floral Avenue,Chambersburg, PA 17201 as a Garnishee and notify Garnishee that (a) An attachment has been issued; (b) Except as provided in paragraph (c),the garnishee is enjoined from paying and debt to or for the account of the defendant and from delivering and property of the defendant or otherwise disposing thereof; (c) The attachment shall not include any funds in an account of the defendant with a bank or other financial institution (i) the first$10,000.00 of each account of the Defendant with a bank or other financial institution containing any funds which are deposited electronically on a recurring 7LINDA A TRUE O Y ARD,PRO TT/O,",OTARY 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 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 with a bank or other financial institution that total$300.00 or less. If multiple accounts are attached, a total of$300.00 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 not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify such person that he or she has been assessed as a garnishee and is enjoined as above stated. Amount due:$7,749.74 Interest:$2,444.28 Protonotary:$ Sheriff:$ Total :S Date 023 1� (seal) Prothonotary Court Of Common Pleas of Franklin County By: r V//;"-(I.PZ eputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson RTHONO r,T ±l Sheriff 0 Jody S Smith rfi- 20 13 Noy -8 AM 8- 47 Chief Deputy - "�1'Z' CUMBERLAND COU Richard W Stewart Solicitor pEN�$` ,dAH�A ,�f,.�., r� � 13 -'6`/O)-- ACC, LLC Case Number vs. Heather Junker 2013-2127 SHERIFF'S RETURN OF SERVICE 11/04/2013 12:45 PM -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, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Kristen Darhower, Teller, 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 November 6, 2013 Heather Junker, 208 Long Stretch Road, Pine Grove, PA 17963. MCLTAV CLINE, DEPUTY SO ANSWERS, November 05, 2013 RONIV R ANDERSON, SHERIFF ACC, LLC, Plantiff 01001 � 11 ✓i.11 �'�' v. die HEATHER JUNKER, IN THE COURT OF COMMON PLEAS Defendant OF THE NINTH JUDICIAL DISTRICT v. WELLS FARGO BANK Garnishee 2013 06402 CIVIL TERM IN RE: CLAIM FOR EXEMPTION ORDER OF COURT AND NOW, this 12t" day of December 2013, upon receipt of the Claim for Exemption, pursuant to statute, Defendant's claim for a $300.00 statutory exemption in cash is GRANTED without a hearing. Tho 71, A. Placey C.P.J. Distribution List: . James T. Mulligan, Esq. /F'1eather Clevenger (a/k/a/ Heather Junker) W' rico .77::17-E-77 c3c:tn—)1 (: Cumberland County Sheriff Department - '� � wells Fargo Bank _ -e- Mai < - Copies ri2_ ,L,L, N., lapaft3 A out v 4f eurrrhPr�� 'td RONNY R.ANDERSON 1�`At ��""".1�. °14 RICHARD W.STEWART Sheriff ' 410.1 , , �+ 4fr ob ) Solicitor JODY S.SMITH Chief Deputy OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 November 14, 2013 Cumberland County Court Administration 1 Courthouse Square Carlisle, PA 17013 Enclosed please find a Claim for Exemption, pertaining to Franklin County Civil Case Number 13-2127, filed by Heather Clevenger A/K/A Heather Junker, which was received in the Cumberland County Sheriff's Office on November 14, 2013. Please note that this pertains to a bank garnishment ONLY and the defendant is already entitled to a$ 300.00 statutory exemption. If a hearing is scheduled, please forward a copy of the Notice of Hearing to my attention in the Sheriff's office, however it is the Court's responsibility to notify all parties involved. Thank you for your consideration to this matter. / f Sharon R. Lantz Staff Assistant Involved Parties: James T. Mulligan, Attorney for Plaintiff PO Box 4031, Wyming, PA 18644 866-760-6205 ext 235 Heather Clevenger, Claimant 208 Long Stretch Road, Pine Grove, PA 17963-8659 570-617-9370 , . : IN THE COURT OF COMMON PLEAS OF FRAN K LI N COUNTY, PENNSYLVANIA WRIT NO. 20 l 3 -212 7 CIVIL TERM CLAIM FOR EXEMPTION To the Sheriff: I,the above named defendant, claim exemption of property from levy, or attachment: 1. From my personal property in my possession which has been levied upon, (a) I desire that my$300 statutory exemption be (i) set aside in kind (specify property to be set aside in kind): (ii) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption(specify property and basis of exemption): 2. From my property which is in the possession of a third party, I claim the following exemptions: (a) my$300 statutory exemption: in cash ❑in kind (specify property): (b) Social Security benefits on deposit in the amount of$ (c) other(specify amount and basis of exemption): • I request a prompt court hearing to determine the exemption. Notice of the hearing of the hearing should be given to me at: 20 g Lonj 61-rch Address Ff\torcilc,fil- Telephone Number I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: ii11113 THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6390 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SHERIFF'SSolicitor OFFICE OF CUMBERLAND ��x�U U��TY COUNTY �� p -H- �.c'"—'THO��^ JUN l6 PM3: 05 COUNTY CUMBERLAND ' �°^.~-.—`/y�A�\� P��.�.`'` ��141101. A*�~ /� �� /3 [\ ACC, LLC vs. Heather Junker Case Number 2013-2127 SHERIFF'S RETURN OF SERVICE 11804/2013 12:45 PM - VVilliam 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, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Cadio\e, PA 17013, Cumberland County, by handing to Kristen Qadhowar. ToUer, 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 wriof execution and notice to defendant was mailed on November 6, 2013 to Heather Junker, 208 Long Stretch Road, Pine Grove, PA 17963. 11/14/2013 Claim for Exemption filed this date, requesting statutory exemption $ 300.00 in cash. Taken to Court Administrators office. 12/13/201a In Re: Claini for Exemption ORDER OF COURT And now, this 12th ""yofDacember2013.upmreceiptofthclaim for Exemption, Defendant's claim for a $300.00 statutory exemption in cash is GRANTED without a hearing. By the Court, Thomas A. PlaceyJudge 06/13/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. SHERIFF COST: $132.35 June 13, 2014 SO ANSWERS, RONZ'RANDERSON, SHERIFF