The URL can be used to link to this page

Home My WebLink About14-0851 Supreme Court;of- Eennsylvania WWR0 20248270 C A Pit ABR Co ��,of Common�P,.leas Civil Cover,. Sh eet For Protltonotan' Use Only: r C UMBERLANff '•Ao CoUno; Docket No: j The information collected on this fibrin is used solel)� for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or Arles of court. Commencement of Action: S 13 Complaint ❑ Writ of Summons ❑ Petition E Transfer from Another Jurisdiction Declaration of Takin C Lead Plaintiff's Name: Lead Defendant's Name: T MIDLAND FUNDING LLC KRISTIN BUSH I 0 Are money damages requested? ® Yes ❑ No Dollar Amount Requested: ® within arbitration limits N (check one) ❑ outside arbitration limits A Is this a Class Action Suit? 13 Yes 13 No Is this an MDJ Appeal? 13 Yes 63 No Name of Plaintiff /Appellant's Attorney: William T. Molczan 47437 ❑ Check here if you have no attorney (are a Self- Represented (Pro Se] Litigant) Nature 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 (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Protection Administrative Agencies Cl Malicious Prosecution 10 Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation S ❑ Premises Liability ❑ Statutory Appeal: Other E [3 Product Liability (does not include 13 Employment Dispute Mass tort) Discrimination C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other: ❑ Other: I ❑ Other: O N MASS TORT ❑ Asbestos B ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - DES ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Toxic Tort — Implant ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Toxic Waste ❑ Ground Rent ❑ Mandamus ❑ Other: ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Retraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Waranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: Updated 1/1/2011 1'r 0 Tno 20d4FF d R _ P, d CU � At J) CQ EN' 4SYL VA NIA TY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC o Plaintiff No: 1q-0 SI lu` VS. COMPLAINT IN CIVIL ACTION KRISTIN BUSH Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan,47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh PA 15219 -1827 (412) 434 -7955 FAX: 412- 338 -7130 20248270 C A Pit ABR amp 103,�s��1 a IN THE COURT OF COMMON PLEAS OF-, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff VS. Civil Action No KRISTIN BUSH Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249 -3166 CIVIL ACTION 1. Plaintiff, MIDLAND FUNDING LLC, is a business entity with offices located at 8875 Aero Drive, Suite 200, San Diego, CA 92123. 2. MCM� records show that the Defendant(s) KRISTIN BUSH is/ are individual(s) residing at 18 HOPE DR, BOILING SPRINGS, PA 17007 . 3. As set forth in records maintained on behalf of Plaintiff, this action is based upon a credit agreement entered into between Defendant(s) and the original credit grantor. i 4. Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was assigned all the rights, title and interest to Defendants CHASE BANK USA, N.A. account XXXXXXXXXXXX3495 (hereinafter "the account "). Midland Credit Management, Inc. (hereinafter "MCM ") services the account on behalf of Plaintiff. 5. MCM� records state that this action is based upon a credit agreement entered into between defendant(s) and the original credit grantor. MCM� records further state that defendant(s) used or authorized the use of the credit account but failed to make the payments due pursuant to the agreement. 6. MCM� records show that the defendant(s) owed a balance of $2830.10 as of 2013- 12 -04. 7. Attached hereto are records regarding the account and/or payment(s) received. WHEREFORE, Plaintiff respectfully requests that judgment be entered in favor of Plaintiff and against Defendant(s) in the amount of $2830.10, together with interest and costs of this action. By Weltman, Weinberg Reis, Co., LPA Attorney for Plaintiff Page - 1 Ilpllll�iQll��llQll��l�l�ll�l�l��l�l I��Ill�l�ll�lllQl�Qll��ll�l�l�l�ll�lll�llml i�iiii�iiidi�ii�o��i�a��i 8543493521 AFFINDEBTMEDIA 20248270 ti Payment Due Date New Balance Past Due Amount Minimum Payment 01 114110 D $2,830.10 $793.00 $923.00 REWARpS1 Account number:�3495 ao reo4 Make your check payable to: Chase Card Services. Please write amount enclosed. New address or e-mail? Print on back. 4 RSKRISTIN C Iudllrluln111nlullnrlrinr11111durllnlJuJl1111u1 MRS KRISTIN N BUSH 18 HOPE DR CARDMEMBER SERVICE BOILING SPRINGS PA 17007-9756 PO BOX 15153 WILMINGTON OE 19886 -5153 LkrIIL1JIIrrrlLldrrrllJlll ,rdJdrrllrrlydllr111111111 Statement Date: 11/21/09 - 1220/09 IQ Manage your account online: REWA vtsscnao raoM wau vA�.chese.com /disnev Minimum Payment: $923.00 Payment Due Date: 01/14/10 Additional contact Information ACCOUNT SUMMARY Account Number: 3495 conveniently located on reverse side Previous Balance $2,727.50 Total Credit Line $2,000 Purchases, Cash, Debits +$39.00 Available Credit $0 Finance Charges +$63.60 Cash Aooess Line $400 New Balance $2,830.10 Available for Cash $0 The outstanding balance on your credit card account is scheduled to be written off as a bad debt shortly. As a result your credit bureau will be updated with a negative rating that could last for up to seven years. We can still help, but you need to call us now at 1.88 &792 -7547 (collect 1- 302 - 5948200). DISNEY DREAM REWARD DOLLARS® Balance from last statement 0 Please cell 600.300 -8575 to redeem your Reward dollars earned from net purchases 0 Disney Rewards® or If you have any questions Reward dollars transferred to Rewards Card 0 about the Disney Rewards® Program. Remaining balance 0 Cardmember ID: 12440968 Use your Cardmember ID for special limited -time promotions such as Refer A Friend. Your account is past due, therefore rewards earned this period have not been posted to your account Please make the minimum payment due Immediately to avoid forfeiture of rewards. ACCOUNT ACTMTY Date of Transaction Merchant Name or Transaction Description $ Amount 12/16 LATE FEE 39.00 FINANCE CHARGES Finance Charge Transaction Daily Periodic Rate Corresp. Average Daily Due To Fee / Accumulated FINANCE Category 30 days in cycle APR Balance Periodic Rate Service Charge Fin Charge CHARGES Purchases .07668% 27.99% $2,682.04 $61.70 $0.00 $0.00 $61.70 Cash advances .07668% 27.99% $0.00 $0.00 $0.00 $0.00 $0.00 Convenience check .07668% 27.99% $82.50 $1.90 $0.00 $0.00 $1.90 Total finance charges $63.60 Effective Annual Percentage Rate (APR): 27.99% Please see Information About Your Account section for balance computation method, grace period, and other important information. The Corresponding APR the rate lfin you pry when you a balance on any transaction category. E The Effective APR represea nts your totof al finann ce charges - including transaction actin ection fees such as cash advance and balance transfer fees - expressed as a percentage. I This Statement is a Facsimile - Not an original 0000001 FIS3333r1C4 000 N Z 20 00117120 Page 1011 09272 MA MA 48450 35410000040004SIM �( 9044 4 � Address Change Request Please provide information below only If the address information on front is inoorrecL Street Address: - - -- ----- - - - - -- City. -- - - - - -- State: Zi p' -- - -- Home Phone: - -- - -- - - -- Work Phone: -- - -- - - -- E -mail Address: - -- -------- - - - - -- L To contact us regarding your account: By Telephone: In U.S. 1. 900300.8575 Espeflof 1- 888.449.3308 Send Inquiries to: Mail TDD 1- 800. 955 -8060 Payments to: Visit Our Webshe: Pay by phone 1- 800436.7958 P.O. Box 15298 P.O. Box 15153 w ffly -d se.eomldtanev Outside U.S. call collect Wlmi r=r ngtat, DE 19850.5298 Wilmington, DE 19888 -5153 ® 1- 302- 594 -8200 0 Information About Your Accounl To get the daily balance for each day of the current billing cycle, >� Crediting of Payments: For payments by regular U.S. mail, send at we take the beginning balance for each feature, add any new least your minimum payment due to our Payments address shown transactions or other debits (including fees, unpaid finance charges ■� on this statement. Your payments by mail must campy with the and other charges), subtract any payments or credits, and make other ® Instructions on this statement and must be made by check or money adjustments. Transactions are added as of the transaction date, the order, payable in U.S. Dollars, and drawn on or payable through a beginning of the billing cycle in which they are posted to your account. U.S. financial institution or the U.S. branch of a foreign financial or a later date of our choice (except that check transactions are added institution. Do not send cash. Write your account number on your as of the date deposited by the payee ora later date of our choice). Fees check or money order. Payments must be accompanied by the are added either on the date of a related transaction, the date they are payment coupon in the envelope provided with our address visible posted to your account, or the last day of the billing cycle. This gives through the envelope window; the envelope cannot contain more than its that day's daily balance. A credit balance is treated as a balance of one payment or coupon; and there can be no staples, paper clips, tape zero. If a dairy periodic rate applies to any feature, we multiply the daily or correspondence Included with your payment. If your p ayment is balance by the daily periodic rate to get your periodic finance charges In accordance with our payment instructions and Is made available for that day. We then add these periodic finance charges to your daily to us on any day except December 25 by 1:00 p.m. local time at our balance to get the beginning balance for the next day. (If more than one Payments address on this statement, we will credit the payment to daily pedodic rate could apply based on the average daily balance, we your account as of that day. If your payment is in accordance with will use the daily periodic rate thatapplies forthe average daily balance our payment instructions, but is made available to us after 1:00 p.m. amount at the end of the billing cycle to calculate the defy periodic local time at our Payments address on this statement, we will credit it finance charge each day.) to your account as of the next day. If you do not follow our payment To pet your total eriodic finance charge for a billing cycle when a Instructions or if your payment is not sent by regular U.S. mail to dairy periodic rates) applies, we add all of the daily periodic finance our Paymerits address, crediting of your pa ment may be delayed for charges for all features. To determine an average dally balance, we up to 5 days. Payments made electronicallyy through our automated add your daily balances and divide by the number of the days in the telephone service, Customer Service advisors, or our web site will be applicable bliling cyGe(s). If you multiply the average dally balance for subject to any processing times disclosed for those pay I erns. each feature by the applicable dally periodic rate, and then multiply Account Information Reported to Credit Bureaus: We may report each of these results by the number at days in the applicable billing information about your account to credit bureaus. Late payments, cycle(s), and then add all of the results together, the total will also missed payments or other defaults on your account maybe reflected in equal the periodk finance charges for the billing cycle, except for your credit report. If you think we have reported inaccurate information mtnor variations due to rounding. To get your total periodic finance to a credit bureau, you may write to us at the Inquiries address shown charge for a billing cycle when a monthly periodic rate(s) applies, on this statement multiply the average dairy balance for each feature by the applicable Notice About Electronic Check Conversion: When you pay by check, monthly periodic rate and add the results together. The total will equal you authorize us either to use information from your check to make the periodic finance charges for the billing cycle, except for minor a one -time electronic fund transfer from your account or to process variations due to rounding. the payment as a check transaction. When we use Information Grace Period (at least 20 days): We accrue periodic finance charges from your check to make an electronic fund transfer, funds may be on a transaction, fee, or finance charge from the date It is added to withdrawn from your account as soon as the same day we receive your your daily balance until payment in full is received on your account. payment, and you will not receive your check back from your financial However. we do not charge periodic finance charges on new purchases instilution. Call the Customer Service number on this statement if you billed during a billing cycle If we receive both payment of your New have questions about electronic check collection or do not want your Balance on your current statement by the date and time your payment payments collected electronically. Is due and also payment of your New Balance on your previous Conditional Payments: Any payment check or other form of payment statement by the date and time your payment was due. There Is no that you send us for less than the full balance due that is marke"paid grace period for balance transfers, cash advances, check transactions, In full" or contains a similar notation, or that you otherwise tender in or overdraft advances. full satisfaction of a disputed amount, must be sent to Card Services, BILLING RIGHTS SUMMARY P.O. Box 15049, Wilmington, DE 19850 -5049. We reserve all our In Case of Errors or Questions About Your Bill: If you think your bill rights regarding these payments (e.g., if it is determined there is no Is wrong, or if you need more information about a transaction on Your valid dispute or if any such check received at arty other address, we bill, write Customer Service on a separate sheet at P.O. Box 15299 may accept the check and you will still owe any remaining balance). Wilmington. DE 19850 -5299 as soon as possible. We must hear from We may refuse to accept any such payment by returning it to you, not you no later than 60 days after we sent you the first bill on which the cashing it or destroying it. All other payments that you make should be error or problem appeared. You can telephone us, but doing so will not sent to the regular ayments address shown on this statement. preserve your rights. In your letter, give us the following information. Annual Renewal Notice: If your account has an annual fee, it will be • Your name and account number billed eachyearor in monthly installments, whether ornotyou useyour • The dollar amount of the suspected error account, and you agree to pay it when billed. The annual fee is non- • Describe the error and explain, if you can, why you believe there is refundable unless you notity us that you wish to close your account an error. If you need more information, describe the hem you are within 30 days of the date we mail your Statement on which the annual unsure about. fee is charged and at the same time, you pay your outstanding balance You do not have to pay any amount in question while we are In full. Your payment of the annual fee does not affect our rights to Investigating, but you are still obligated t0 pay the part$ of your bill close your account and to limit your right to make transactions on that are not in question. While we investigate your question, we your account. II your account Is closed by you or us, we will continue cannot report you as delinquent or take action to collect the amount to charge the annual fee until you payyour outstanding balance In full you question. If you have authorized us to pay your credit card bill and terminate your account relationshhtp. automatically from your savings or checking account, you can stop the Explanation of Finance Charges: We calculate periodic finance charges, paYmerit on arty amount you think is wrong. To stop the payment. Your using the applicable periodic rates shown on this statement, separately letter or call (using the Inquiries address or Customer Service telephone for each feature �e.g..balance transfer /convenience checks and cash number shown on this stalemenl) must reach us al least three business advance checks ('check transaction "). purchases, balance transfers, days before the automatic payment is scheduled to occur, cash advances, promotional balances or overdraft advances). These Special Rule for Credit Card Purchases: If you have a problem with calculations may combine different categories with the same daily the quality of goods or services that you purchased with a credit card periodic rates. It there is a °V" next to a periodic rate on this statement, (excluding purchases made with a check). and you have tried in good that rate may vary, and the index and margin used to determine that taith to correct the problem with the merchant, you may not have to rate and its corresponding APR are described in your Cardmember pay the remaining amount due on the goods or services. You have this Agreement, as amended. There is a minimum finance charge in any protection only when the purchase price was more than $50 and the billing cycle in which you owe any periodic finance charges, and a purchase was made in your home state or within 100 miles of your transaction finance charge for each balance transfer, cash advance, mailing address. These limitations do not apply if we own or operate or check transaction, in the amounts stated in your Cardmember the merchant or if vie malled you the advertisement for the property Agreement, as amended. or services. MA111408 Verification Paige Duncan, being duly sworn (or affirmed) according to law deposes and says that I am employed as a Legal Specialist for Midland Credit Management, Inc. ( "MCM "), servicer of this account on behalf of plaintiff. I am a competent person over eighteen years of age, and make these statements herein based upon personal knowledge of those account records maintained on plaintiffs behalf. I am authorized to make this verification on plaintiffs behalf. The facts set forth in the foregoing pleading are true and correct. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 'JAN27PD14 Date Paigd Duncan OH 14 Weltman, Weinberg & Reis. Co., L.P.A Page - 2 8543493521 AFFINDEBTMEDIA 20248270 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ; Sheriff Jody S Smith 34„x �� er,t�� Mk FEB 25 P Chief Deputy Richard W Stewart UMBEiiLAND COUNTY Solicitor “ fz;. PENNSYLVANIA Midland Funding, LLC Case Number vs. Kristin Bush 2014-851 SHERIFF'S RETURN OF SERVICE 02/18/2014 07:17 PM- Deputy Shawn Harrison, being duly sworn according to law, served the r-•uested Complaint & Notice by handing a true copy to a person representing themselves to •- Aaron = .h, husband, who accepted as"Adult Person in Charge”for Kristin Bush at 18 Hope Drive • Mi•• ;ton, Boiling Springs, PA 17007. SH HARRISON, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, February 19, 2014 RONI�Y R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff No. 14 -851 CIVIL vs. STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT KRISTIN BUSH Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. # 47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh, PA 15219 (412) 434 -7955 WWR# 20248270 A PIT ABR pf11i.50pel a ll'-lgt,7 scarna N17 h ted IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff vs. KRISTIN BUSH Defendant TO THE PROTHONOTARY: Civil Action No. 14-851 CIVIL PRAECIPE FOR JUDGMENT BY CONSENT Kindly enter Judgment against Defendant, KRISTIN BUSH, in the amount of $2,733.85 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney for Plaintiff ISTIN BUSH 18 HOPE DR BOILING SPRINGS, PA 17007 WWR# 20248270 t= IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff vs. KRISTIN BUSH Defendant Civil Action No 14 -851 CIVIL STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, KRISTIN BUSH, above - named, in the amount of $2,733.85 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: 1. Defendant admits indebtedness to Plaintiff in the amount of $2,733.85. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, KRISTIN BUSH, in the amount of $2,733.85 plus continuing interest thereon at the statutory rate of 6.00% per annum from the date of judgment, and costs. 3. Defendant shall make an initial payment on February 19, 2014 of $300.00 and subsequent monthly payments at a rate of $100.00 commencing on March 17, 2014 and each month thereafter until the balance is paid in full. 4. All payments are to be made payable to the order of "MIDLAND FUNDING LLC." 5. The first payment due under this agreement is to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 436 7th Ave Ste 1400, Pittsburgh, PA 15219. All future payments are to be mailed to the offices of Weltman, Weinberg & Reis, Co., P.O. Box 5430, Cleveland, OH 44101 -0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fails to have in the hands of Plaintiff or Plaintiffs counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. . 9. Intending to be legal ly bound, the parties set their hands and seals this day of (DOCidif , 20 BUS 18 HOPE DR BOILING SPRINGS, PA 17007 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, E PA I.D. # 47437 WELTMAN, WEINBERG & REIS'CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh, PA 15219 WWR# 20248270 A PIT ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff vs. KRISTIN BUSH Defendant Civil Action No. 14-851 CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or J g ent was entered against you on (xx) Assumpsit Judgment in the amount of $2,733.85 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ) Court Order ) Non-Pros ) Confession ) ) ) ) (XX) Prothonotary KRISTIN BUSH 18 HOPE DRIVE BOILING SPRINGS, PA 17007 By: PROTHONOTARY (OR DEPUTY) Default Verdict Arbitration Award By Consent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff vs. Civil Action No. 14-851 CIVIL KRISTIN BUSH (7),7 Defendant(s) CORNERSTONE FCU Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against KRISTIN BUSH , Defendant 3. against CORNERSTONE FCU, , , Garnishee 4. Judgment Amount $ $2,733.85 Less Payments/credits received $ $0.00 Interest $ $33.26 Costs $ SUBTOTAL: $ $2,767.11 Costs(to be added by Prothonotary): $ WELTMAN, WEINBERG& REIS CO., L.P.A. r1G� ob;�,I (� By: ("' James P.c--1, lecko, Esquire 3� 7 (L MF PA I.D. # 596 d WELTMAN, WEINBERG& REIS CO., L.P.A. /O�. �� e( a 436 7`h Avenue, Suite 1400 l Pittsburgh, PA 15219 /60,, „ce/ (412)434-7955 ., 12d a /9- s18q.D3 .1,24,2ctAt (11 /(J/ //(pc'/c, S0 11*SOISY3 WWR No. 20248270 C/v • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff No. 14-851 CIVIL vs. PRAECIPE FOR WRIT OF EXECUTION KRISTIN BUSH (BANK ATTACHMENT ONLY) Defendant(s) CORNERSTONE FCU Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG& REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412)434-7955 WWR No. 20248270 �'; as :/ ; q THE COURT OF COMMON PLEAS ,tK'6G'' ‘/' z CUMBERLAND COUNTY PA V l° ;if- " DAVID D.BUELL PROTHONOTARY \. a� amil,nE, , �'� One Courthouse Square • Suite100 • Carlisle, PA • 17013 i%s a (717)240-6195 www.ccpa.net MIDLAND FUNDING LLC Vs. NO 14-851 Civil Term KRISTIN BUSH CIVIL ACTION—LAW WRIT OF EXECUTION (Pa R.C.P.3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against KRISTIN BUSH, 18 HOPE DRIVE,BOILING SPRINGS, PA 17007 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 CORNERSTONE FCUGARNISHEE(S), as garnishee, 5 EAST GATE DRIVE, 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 l 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 $2,733.85 Plaintiff Paid Interest$33.26 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $184.03 Other Costs Date: 6/20/14 ,/, — 4 , David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name :JAMES P.VALECKO,ESQUIRE Address: WELTMAN,WEINBERG& REIS CO., L.P.A. 436 7TH AVENUE,SUITE 1400 PITTBURGH,PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 79596 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 COUNTY,, � "of �of , c.' THE i'RO?HONC 6A,-. 2014JUN 30 AMi10:S0 CUMBERLAND COUNTY PENNSYLVANIA iJt �uuraf7r, ��10 OFFICE OF THE SHERIFF Midland Funding, LLC vs. Kristin Bush Case Number 2014-851 SHERIFF'S RETURN OF SERVICE 06/26/2014 09:41 AM - Christopher Sharpe, 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, Cornerstone Federal Credit Union, 5 Eastgate Drive, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to David G. Keffer, Manager/CEO, 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 him. The writ of execution and notice to defendant was mailed on June 27, 2014 to Kristin Bush at 18 Hope Drive, Boiling Springs, PA 17007. C ISTOP E SHARPE, DEPUTY SO ANSWERS, June 27, 2014 RONt' R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft. Inc. WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire I.D. No.47437 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 20248270 Attorney for Plaintiff(s) MIDLAND FUNDING LLC CUMBERLAND County Court of Common Pleas vs. KRISTIN BUSH NO. 14-851 CIVIL and CORNERSTONE FCU Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter settled, discontinued, and ended as to Garnishee(s), CORNERSTONE FCU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By William T. Mol n, Esquire Attorney for PI intiff 44.6o IN A711 c�* Iltotoa3aa 2, 3oB Lfs� WELTMAN, WEINBERG & REIS,CO., L.P.A. BY: William T. Molczan,47437 I.D. No. 47437 436 7th Ave Ste 2500 Pittsburgh PA 15219-1842 (412) 434-7955 FAX: 412-338-7130 File # 20248270 C A Pit SJS Attorney for Plaintiff(s) MIDLAND FUNDING LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. KRISTIN BUSH CASE NO. 14-851 CIVIL PRAECIPE TO SATISFY TO THE PROTHONTARY: Kindly mark the case and judgment entered against Defendant KRISTIN BUSH as satisfied. WELTMAN, WEINBERG & REIS CO., L.P.A. William T. Molczan Attorney for Plaintiff aw,:k %(1.0* 1,6u,„ 88 T--81`11