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Home My WebLink About14-4418 Burton Neil&Associates,P.C. F;I EU-0F iC--- By: Trenton A. Farmer, Esquire ID.NO. 209422 CIF THE E PRO 7 H G u Q L.d j�i�y 1060 Andrew Drive, Suite 170 West Chester, PA 19380 2014 JUL 28 Ppb 3: 610-696-2120 CUMBERLAND COUNTY Attorney for Plaintiff PENNSYLVANIA CITIBANK,N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. DAWN M SHOEMAKER NO. 14- 44/8 0 Defendant : CIVIL ACTION-LAW Praecipe to Transfer Judgment Pursuant to PA.R.C.P. 3002 To the Prothonotary: Please enter judgment on behalf of Plaintiff, CITIBANK,N.A. , and against defendant, DAWN M SHOEMAKER in the sum of$13,459.97 less credit of$500.00 for a total judgment of$12,959.97 plus costs in accord with Pa.R.C.P. 3002 and attached are certified copies of the Cumberland County Judgment. Burton Neil &Asso ' s, P.C. By: Tre n A. Farmer, Esquire AttOmey for Plaintiff AND NOW this a$ day of \�4 , 201 ,judgment is entered on behalf of plaintiff, CITIBANK,N.A., and against defendant, DAWN M SHOEMAKER in the sum of$13,459.97 less credit of$500.00 for a total judgment of $12,959.97 plus costs. i ";Pf Gonotary 4 33.50 Po ATTV &135750 In making this communication, we advise that our firm is a debt collector. `'*�R 1)q Nl7�t W mol��ry COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF FULTON I,Patty Suders Fix,Prothonotary,of the Court of Common Pleas in and for said County,do hereby certify that the foregoing is a full,true and correct copy of the Case Details therein stated,wherein the Case of Citibank N.A.v.Dawn M. Shoemaker so full and entire as the same remains of record before the said Court,as 331 of 0 IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the s al of sa ourt,thi ''` day of July,2014. Prothonotary I, Jeremiah D. Zook,Judge of the Court of Common Pleas of the 39`h Judicial District, Fulton County Branch,do certify that Patty Suders Fix,.Prothonotary,by whom the annexed record,certificate and attestation were made and given,and who,in her own proper handwriting,thereunto subscribed her name and affixed the seal of the Court of Common Pleas of said County,was at the time of so doing and now is Prothonotary in and for said County in the Commonwealth of Pennsylvania,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,and that the said record,certificate and attestation a in due form of law and made by the proper officer. Ju e COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF FULTON I,Patty Suders Fix,Prothonotary of the Court of Common Pleas of the 39`h Judicial District,Fulton County Branch,do hereby certify that the Honorable Jeremiah D. Zook, by whom the foregoing attestation was made,and who has hereunto subscribed his name,was at the time of making thereof and still is Judge of the Court of Common Pleas,in and for said County, duly commissioned and qualified; to all 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 h ve hereu o set my hand and a fixed the se -sai ourt this St day of J 014, - Prothonotary PS511 Fulton County Prothonotary Page 1 Civil Case Print 2.005-60331 CITIBANK SOUTH DAKOTA NA (vs) DAWN M SHOEMAKER . Reference No. . : #331 OF 2005-C Filed. . . . . . . . : 11/01/2005 Case Type. . . . . : COMPLAINT/CIVIL ACTION Time. . . . . . . 9 : 50 Judgment . . . . . : 13 , 459 . 97 Execution Date 0/00/0000 Judge Assigned: WALSH RICHARD J Jury Trial . . . . Disposed Desc . : Disposed Date . 0/00/0000 ------------ Case Comments ------------- Higher Crt 1 . : Higher Crt 2 . : ******************************************************************************** .General Index Attorney Info CITIBANK SOUTH DAKOTA NA PLAINTIFF NEIL BURTON 701 EAST 60TH STREET NORTH BLASKER DEREK SIOUZ FALLS SD SHOEMAKER DAWN M DEFENDANT 9236 WATERFALL ROAD HUSTONTOWN PA 17229 ******************************************************************************** Judgment Index Amount Pate Desc SHOEMAKER DAWN M 13 , 459 . 97 1/19/2007 JUDG/COURT ORDER ******************************************************************************** * Date Entries ******************************************************************************** - - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - - 11/01/2005 COMPLAINT FILED - CIVIL ACTION. ------------------------------------------------------------------- 1/30/2005 LETTER FROM DAWN SHOEMAKER FILED. ------------------------------------------------------------------- 12/05/2005 SHERIFFS SERVICE FILED (SERVED DAWN M SHOEMAKER 11/19/05) . ------------------------------------------------------------------- 6/05/2006 ENTRY OF APPEARANCE OF JAY PRESSMAN ESQ ON BEHALF OF PLAINTIFF CITIBANK SOUTH DAKOTA NA FILED. ------------------------------------------------------------------- 6/05/2006 MOTION OF PLAINTIFF FOR JUDGMENT ON THE PLEADINGS FILED BY JAY PRESSMAN ESQ. ------------------------------------------------------------------- 6/05/2006 PLAINTIFFS MEMORANDUM OF LAW IN SUPPORT OF JUDGMENT ON THE PLEADINGS FILED. ------------------------------------------------------------------- 6/05/2006 CERTIFICATE OF SERVICE FILED. ------------------------------------------------------------------- 6/05/2006 PRAECIPE TO LIST FILED. ------------------------------------------------------------------- 7/05/2006 ORDER DATED JUNE 28, 2006 SIGNED BY JUDGE RICHARD J WALSH. . . "A RULE IS ISSUED UPON THE RESPONDENT TO SHOW CAUSE WHY THE PETITIONER IS NOT ENTITLED TO THE RELIEF REQUESTTTED. THE RESPONDENT SHALL FILE A VERIFIED..) Ad,SYJER TO THE PETITION WITHIN 20 DAYS OF SERVICE iuPO1v THE RESPONDENT; IN DEFAULT OF AN ANSWER JUDGMENT MAY BE ENTERED - -- UPON PRAECIPE OF PLAINTIFF. . .NOTICE OF THE ENTRY OF THIS ORDER SHALL BE PROVIDED TO ALL PARTIES BY THE PETITIONER. . . " ------------------------------------------------------------------- 7/13/2006 CERTIFICATE OF SERVICE FILED BY JAY H PRESSMAN ESQ ATTY FOR PLAINTIFF. ------------------------------------------------------------------- 1/19/2007 ENTRY OF APPEARANCE FILED BY DEREK BLASKER ESQ ATTY FOR PLAINTIFF. ------------------------------------------------------------------- 1/19/2007 PRAECIPE FOR ENTRY OF JUDGEMENT ON COURT ORDER FILED BY DEREK BLASKER ESQ ATTY FOR PLAINTIFF. ------------------------------------------------------------------- 1/19/2007 CERTIFICATION OF ADDRESS AND AFFIDAVIT OF NON-MILITARY FILED BY DEREK BLASKER FILED. ------------------------------------------------------------------- 1/19/2007 RULE OF CIVIL PROCEDURE NO 236 (REVISED) . ------------------------------------------------------------------- 1/19/2007 AND NOW JANUARY 19, 2006 IN ACCORDANCE WITH PRAECIPE JUDGMENT IS ENTERED IN FAVOR OF THE PLAINTIFF AND AGAINST DAWN M SHOEMAKER DEFENDANT IN THE AMOUNT OF $13 , 459 . 97 . PATTY SUDERS FIX, PROTHONOTARY ------------------------------------------------------------------- 'PYS511 Fulton County Prothonotary Page 2 Civil Case Print 2-0'b5-00331 CITIBANK SOUTH DAKOTA NA (vs) DAWN M SHOEMAKER , Reference No. . : #331 OF 2005-C Filed. . . . . . . . : 11/01/2005 Case Tye. . . . . : COMPLAINT/CIVIL ACTION Time. . . . . . . . : 9 : 50 Judgmen�. . . . . : 13 , 459 . 97 Execution Date 0/00/0000 Judge Assigned: WALSH RICHARD J Jury Trial . . . . Disposed Desc . : Disposed Date . 0/00/0000 ------------ Case Comments ------------- Higher Crt 1 . : Hiqher Crt 2 . : 1/19/2007 NOTICE OF ENTRY OF JUDGMENT MAILED TO DEFENDANT. ------------------------------------------------------------------- 6/23/2014 REQUEST FOR EXEMPLIFIED JUDGMENT FILED BY TRENTON A. FARMER. - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - - * Escrow Information * Fees & Debits Bw Bal Pmts/Ad End Bal TAX ON ,CMPLT . 50 . 50 . 00 JCS/ATJ 10 . 00 10 . 00 . 00 DISCONTINUANCE 7 . 00 7 . 00 . 00 AUTOMATION FEE 5 . 00 5 . 00 . 00 JUDG/CT ORDER 15 . 00 15 . 00 . 00 COMPLAINT FILED 87 . 50 87 . 50 . 00 EXEMP RECORD 16 . 00 16 . 00 . 00 141 . 00 141 . 00 . 00 *************************************************************** ** * End of Case Information *************************************************************** ** Burton Neil &Associates,P.C. By: Trenton A. Farmer,Esquire ID.NO. 209422 1060 Andrew Drive, Suite 170 West Chester,PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK,N.A. IN THE COURT OF COMMON PLEAS 701 East 60th Street N Sioux Falls, SD Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. a DAWN M SHOEMAKER NO. 23 Short Ln Shippensburg PA 17257-9453 Defendant : CIVIL ACTION-LAW Certification of Address and Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment creditor and debtor. 2. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA)the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. Burton Neil ociates, P.C. y: Trenton A. Farmer, Esquire Attorney for Plaintiff In making this communication, we advise that our firm is a debt collector. Burton Neil&Associates,P.C. By: Trenton A. Farmer,Esquire ID.NO. 209422 1060 Andrew Drive, Suite 170 West Chester,PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK,N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. DAWN M SHOEMAKER NO. Defendant : CIVIL ACTION-LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that JUDGMENT in the above captioned matter has been entered against you on 71681b y .e Prothono ary By: Deputy If you have any questions concerning the above, please contact: Trenton A. Farmer, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 In making this communication, we advise that our firm is a debt collector. C-8175 / 232 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 CITIBANK, N.A. 701 East 60th Street N, Sioux Falls, SD 57117 Plaintiff v. DAWN M SHOEMAKER 23 Short Ln, Shippensburg PA 172579453 Defendant(s) F&M Trust 1901 Ritner Highway, Carlisle, PA 17013 Garnishee(s) : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-4418 Civil : CIVIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION 1N THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. against DAWN M SHOEMAKER 3. and against F&M Trust 4. and index this writ (a) against Defendant(s) (b) against Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) NO LEVY - GARNISHMENT ONLY Serve interrogatories on garnishee at: 1901 Ritner Highway, Carlisle, PA 17013 7:G -r , Defendant(s) , Garnishee(s) 5. Amount Due Interest from 01/19/2007 Total *Plus writ costs Dated: August 6, 2014 $12,959.97 6,178.47 $19,138.44* Yale stein, Esquire Att. ey for Plaintiff NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. &,c)5(/, - —01 /3$.R31 -P-N-Soengs 03 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net CITIBANK, N.A. Vs. DAWN M. SHOEMAKER WRIT OF EXECUTION (Pa R.C.P. 3252) NO 14-4418 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against DAWN M. SHOEMAKER, 23 SHORT LANE, SHIPPENSBURG, PA 17257-9453 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 F&M TRUSTGARNISHEE(S), as garnishee, 1901 RITNER HIGHWAY, 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 1 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 $12,959.97 Interest FROM 1/19/2007 - $6,178.47 Attorney's Comm. % Attorney Paid $187.50 Date: 8/13/14 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs ate, David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : YALE D. WEINSTEIN, ESQUIRE Address: LAW OFFICES BURTON NEIL & ASSOCIATES, P.C. 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLANTIFF Telephone: 610-696-2120 Supreme Court ID No. 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson u�?-Ci J J ty Sheriff r i HE t RO I'HONO R`t oo �r at Curor r `� Jody S Smith 2014 AUG 26 AM 10: 09 Chief Deputy?„_ Richard W Stewart . ,� CUMBERLAND COUNTY Solicitor OFFICE OF THE SHERIFF PENNSYLVANIA Citibank, N.A. vs. Dawn M Shoemaker Case Number 2014-4418 SHERIFF'S RETURN OF SERVICE 08/22/2014 10:30 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, F & M Trust Company. 214A Westminster Drive, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Melissa McGowan, Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on August 25, 2014 Dawn M. Shoemaker at 23 Short Lane, Shippensburg, PA 17257. 7/i 4 August 25, 2014 (c) CountySuite Sheriff, TOleosoft, Inc. L AM CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF • Burton Neil & Associates, P.C. By: Yale D Weinstein, Esquire ID. NO. 87678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK, N.A. 21) f y'UG 27i Cutle- t Pfd i' PENNSYL D cot", : IN THE COURT OF COMMON PLEAS Plaintiff v. DAWN M SHOEMAKER 23 Short Ln, Shippensburg PA 172579453 Defendant(s) F&M Trust : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-4418 Civil Garnishee : CIVIL ACTION -LAW To: F&M Trust 1901 Ritner Highway, Carlisle, PA 17013 7-1°Gu1SL4JL S Interrogatories to Garnishee 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 judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant or 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 t any reason? yes, -�e de( ehclar\ - ho (CC'S 4� Gh e C,ic V19 ct C,Co 4. 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 owed solely or in part by the defendant? KVO 3. If the answer to 1 and/or 2 is yes, please specify the nature of the property and, if money, the amount? bs oc 8%aahq , e bci ot.nce in -tine de-realci cec nt acGD Is a 193,00-* 4. 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? M 0 5. At the time you were served or at any subsequent time did you hold as fiduciary any property in which defendant had an interest? JJo 6. At any time before you were served did the defendant transfer or deliver any property to you or any person or place pursuant to your direction or consent and if so what was the consideration therefor? A Io 7. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant 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 being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 'VQ 9. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.0:S. § 8123? If so, identify each account. NJ 0, L[n2 b cut an ce -Px ce ed,5- e eoxerlAffiofti 6tAiLotArzt, TRUST FINANCIAL SOLUTIONS... FROM PEOPLF, YOU KNOW Memorial Square Office 20 South Main Street PO Box 6010 Chambersburg, PA 17201 www.fmtrustonline.com Christie L Taylor Compliance & Security Support Specialist (717) 261-3681 (717) 2646116 fax: (717) 261-3646 christie.taylor@f-mtrust.com Burton 0•c �af �i1H— 2. 193'00 ssociate lis 3 0 0: 0 0 - P�por► C� , 8 9 3 • 01.0) Ho41? Avouerr Rap f insteir y information obtained will be used for that purpose. or. Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff CITIBANK, N.A. Plaintiff V. DAWN M SHOEMAKER Defendant and F&M Trust Garnishee To the Prothonotary: ILE-0-0117CE JF FHE PROTHONO h: 204 OCT 6pf 3:j T CUMBERLA/10 COUNTY P E 'rt. VAT; IA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-4418 Civil : CIVIL ACTION - LAW Praecipe to Dissolve Attachment Dissolve the attachment against F&M Trust, garnishee. Burton eil: 'Associates, P.C. f i . rney I r Plaintiff i This is an attempt to collect a debt, and any information ob tined will be used for that purpose. This communication is from a debt collector. By: Weinstein, Esquire C-8175