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HomeMy WebLinkAbout14-5686 ' r IN THE COURT OF COMMON PLEAS O�MBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING,LLC (� ,^,�((D Plaintiff No. U , (� VS. PRAECIPE TO TRANSFER JUDGMENT SETH ANDERSON Defendant c C � � FILED ON BEHALF OF P,D (A� t" Plaintiff —` T' U1 C)c ---i c) COUNSEL OF RECORD OF r-1 - THIS PARTY: �:'' William T Molczan,Esquire c.r '� PA I.D. #47437 WELTMAN, WEINBERG &REIS CO.,L.P.A. 2500 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 (41.2)434-7955 WWR#20044685 $7002.54 s 3�. # 117&SW E // �# 1311 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING,.LLC Plaintiff VS. Civil Action No. C1 , SETH ANDERSON Defendant PRAECIPE TO TRANSFER JUDGMENT TO THE PROTHONOTARY: Please transfer the within Judgment entered in The Court of Common Pleas of PERRY County, Pennsylvania, known as No. 2013-525, and index it against the Defendant above named, in the amount of $7002.54- PERRY County costs to follow Judgment. WELTMAN, WEINBERG &REIS CO.,L.P.A. By: ---- William T Molczan,Esquire PA I.D. #47437 WELTMAN, WEINBE.RG &.REIS CO.,L.P.A. 2500 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 WWR#20044685 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg&Reis Co.,L.P.A., 2500 Koppers Building, 436 7th Avenue,Pittsburgh,PA 15219 And that the last known address of the Defendantis: 4637 ENOLA AVE,NEWVILLE,PA 17241 Pmg County BrsZnda J.g9lbright Court Mous¢ - e§ P¢rrg County y y Prothonotary Pronootar ofPerr TizI phonQ yY and /�y (717)552-2131 t� � '' � C Lill y C19rk of Courts a A 0.BOX 325 • M M- (717�552-5167 . . . _��� .. y NOW$loomfl¢1d.Pli 17068 CV-CV-2013-525 MIDLAND FUNDING LLC,plaintiff VS SETH ANDERSON, defendant EXEMPLIFICATION OF RECORD 1� CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, BRENDA J. ALBRIGHT, PROTHONOTARY OF THE COURT OF COMMON PLEAS OF PERRY COUNTY , PENNSYLVANIA, DO HEREBY CERTIFY THAT THE FOLLOWING IS A TRUE, CORRECT AND FULL COPY OF THE DOCKET ENTRIES IN THE ABOVE CAPTIONED CASE. FURTHER, I DO HEREBY CERTIFY THAT JUDGMENT WAS ENTERED ON 07/15/2013 IN FAVOR OF PLAINTIFF MIDLAND FUNDING LLC, AND AGAINST DEFENDANT, SETH ANDERSON, IN THE AMOUNT OF $7.002.54+COSTS+INTEREST. BRENDA J. ALBRIGHT August 26, 2014 /S/ BRENDA J. ALBRIGHT, PR HONOTARY ,5679 BY. R ,UYH HOWE EPUTY Date: 8/26/2014 41st Judicial District of PA, Perry County Branch User: RUTH S Time: 10:32 AM Complete Case History Page 1 of 2 Case: CV-CV-2013-00525 MIDLAND FUNDING LLC vs. SETH ANDERSON Filed: 5/20/2013 Subtype: COMPLAINT Physical File: Y Appealed: N Comment: Status History Pending 5/20/2013 DEFAULT JUDGMENT 7/15/2013 Judge History Date Judge Reason for Removal 5/20/2013 MORROW, KATHY A. Current Plaintiff Name: MIDLAND FUNDING LLC, SSN: Address: ASSIGNEE OF BENEFICIAL DOB: SAN DIEGO CA 92123 Sex: > Ix Phone: Home: Work: O Employer: Send notices: Y 0 Litigant Type: 0 Comment: Q J" 0 0 CL Attorneys z MOLCZAN, WILLIAM T ESQ (Primary attorney) Send Notices cr Defendant Name: ANDERSON, SETH SSN: Address: DOB: Landisburg PA 17040 Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Register of Actions 5/20/2013 Complaint filed . Exit cc and time stamp MORROW, KATHY A. copy to Atty. EXIT CC TO SHERIFF WITH CHECK FOR SERVICE Filing: Complaint Paid by: WELTMAN MORROW, KATHY A. WEINBERG & REIS Receipt number: 0053362 Dated: 5/20/2013 Amount: $68.75 (Check) For: [NONE] CONTRACT DEBT COLLECTION : MORROW, KATHY A. OTHER LOAN PERSONAL LINE OF 5/21/2013. Sheriffs Return served upon Seth UNASSIGNED, Anderson, filed. 7/15/2013 DEFAULT JUDGMENTS MORROW, KATHY A. Praecipe for Entry of Judgement by MORROW, KATHY A. Default for Failure to Plead filed. Exit is to Atty Molczan, file. .Date: 8/26/2014 41st Judicial District of PA, Perry County Branch User: RUTH S Time: 10:32 AM Complete Case History cf age 2 of 2 Case: CV-CV-2013-00525 MIDLAND FUNDING LLC vs. SETH ANDERSON Register of Actions 7/15/2013 Judgment entered by praecipe in the MORROW, KATHY A. amount of :$7,002.54+costs+interest Exit 236 notice to defendant. 7/26/2013 Filing: Default Judgment Paid by: MORROW, KATHY A. WELTMAN WEINBERG REIS CO LPA Receipt number: 0054218 Dated: 7/26/2013 Amount: $19.81 (Check) For: MIDLAND FUNDING LLC, (plaintiff) 8/26/2014 Filing: Exemplified Record Paid by: MORROW, KATHY A. WELTMAN WEINBERG REIS Receipt number: 0058144 Dated: 8/26/2014 Amount: $20.90 (Check) For: MIDLAND FUNDING LLC, (plaintiff) Praecipe for Exemplified Record filed. MORROW, KATHY A. Exit exemplified record to atty, file. Judgment Order date In Favor Of Disposition Judgment 07/15/2013 Plaintiff 00/00/0000 Def. Judgment Comment: $7,002.54+costs+int Plaintiff: MIDLAND FUNDING LLC, 2 Defendant: ANDERSON, SETH O a � O Q h L1? � 4 !1J � U . Q ,Date: 8/26/2014 41st Judicial District of PA, Perry County Branch User: RUTH S Time: 10:30 AM CIVIL CASE JUDGMENTS REPORT j Page 1 of 1 Case: CV-CV-2013-00525 MIDLAND FUNDING LLC vs. SETH ANDERSON Filing date In Favor Of Judgment Judgment 07/15/2013 Plaintiff 00/00/0000 Def. Judgment Plaintiff: MIDLAND FUNDING LLC, Judgment amount or comment: Defendant: ANDERSON, SETH $7,002.54+costs+int A TRL1g, �',"b�'TJTY PRQ`rG=��y�"nl'ARY 1 IN THE COURT OF COMMON PLEAS PERRY COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff VS. Civil Action No. 2013-525 G e� SETH ANDERSON rice G _4 NOTICE OF JUDGMENT OR ORDER TO: ( } Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that eollawin Order of Judgment c was entered against you on T=, (xx) Assumpsit Judgment in th amount of $7002 . 54 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) Default { ) Verdict { ) Arbitration Award Prothon ry ! BY: PR 0NOTARY OR DEPUTY SETH ANDERSON CERTIFIEDATRU COPY 4637 ENOLA LANE NEWVILLE, PA 17241 ' 'OTARY CERTIFIED A TRU bPY Plaintiff's address is:0-- tITYPR0`cFIUI�C}rARY c/o WELTMAN, WEINBERG & REIS CO. , L.P.A. , 436 Seventh Avenue, Suite 1400 D PUTYPRaTHO!`!OTARY Pittsburgh, PA 15219 (412) 434-7955 1 ' IN THE COURT OF COMMON PLEAS PERRY COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC -9 r Plaintiff ; o vs . Civil Action No. 2013-525 SETH ANDERSONCD ; �o PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant SETH ANDERSON above named, in the default of an Answer, in the amount of $7002 . 54 computed as follows: Amount claimed in Complaint $7002 .54 Less payments / adjustments made $0. 00 Interest on the remaining principal balance from July 02, 2013 to July 02, 2013 ® the interest rate of 6. 000% per annum $0. 00 Attorney' s fees $0 . 00 TOTAL $7002 .54 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237 .1 on the dates indicated on the Notices. WELTMA/N,/WEINBERG & REIS CO. , L.P.A. By: !!" Willi-am T. Mol an, 47437 20044685 C A it DKB Plaintiff ' s address is: c/o WELTMAN, WEINBERG & REIS CO. , L.P.A. , COPY 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 CERTIFIEDATRU And that the last known address of the Defendant is SETH ANDERSON 4637 ENOLA LANE pEpUTY PROTHONOTARYNEWVILLE, PA 17241 WELTMAN,WEINBERG&REIS CO.,L.P.A. BY: William T. Molczan Attorney for Plaintiff(s) I.D.No. 47437 436 Seventh Avenue, 2500 Koppers Bldg Pittsburgh,PA 15219 p Phone: 412.434.7955 . Fax: 412.434.7959 ' �I File#20044685 '� c. tv C" -�-! N MIDLAND FUNDING, LLC r "� PERRY Countyc1 G? Court of Common Pleas VS. No.: 2013-525 SETH ANDERSON PRAECIPE FOR EXEMPLIFIED RECORD TO THE PROTHONOTARY: Kindly provide an exemplified record in order to transfer the judgment entered in the above captioned case. WELTMAN,WEINBERG&REIS CO., L.P.A. By William T Molczan, quire Attorney for Plainti CERTIFIED ATRU COPY D DUTY PROT9-0N'0l'ARY Date: 8/26/2014 41st Judicial District of PA, Perry County Branch NO. 0058144 Time: 10:29 AM Receipt Page 1 of 1 Received of: WELTMAN WEINBERG REIS $ 20.90 Twenty and 90/100 Dollars Case: CV-CV-2013-00525 Plaintiff: MIDLAND FUNDING LLC vs. SETH ANDERSON Amount Exemplified Record 20.90 Total: 20.90 Check: 11723528 Bank: HUNTINGDON NATIONAL BK Payment Method: Check Brenda J.Albright, Pr ota rk of Court Amount Tendered: 20.90 By: Clerk: RUTH S Deputy Clerk Duplicate IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING,LLC Plaintiff VS. Civil Action No. SETH ANDERSON Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ).Plaintiff (xx)Defendant ( )Garnishee You are hereby notified that thef_ ollowipg Order or Judgment was entered against you on 5 L{ (xx) Assumpsit Judgment in the amount of$7002.54 plus costs. ( ) Trespass Judgment in the amount of$ 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 ( ) Default ( ) Verdict ( ) Arbitration Award Prothonotary SETH ANDERSON By: 4637 ENOLA AVENUE PROTHONO NEWVILLE,PA 17241 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING, LLC Plaintiff vs. SETH ANDERSON Defendant(s) PNC BANK ACNB BANK Garnishee(s) No. 14-5686 CIVIL PRAECIPE FOR WRIT OF EXECUJON. (BANK ATTACHMENT ONLY) 3 zW o y --4 cnr` tv -<> o cp D c co 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 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 20044685 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING, LLC Plaintiff vs. Civil Action No. 14-5686 CIVIL SETH ANDERSON 4631 Enda lane *milk PA 170 Defendant(s) PNC BANK, 105 NOBLE IN.VD,CARIASLE Pik Ir101-3 ACNB BANK WIRLMLE. RD, Nuovi PR if76+41 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 SETH ANDERSON , Defendant 3. against PNC BANK, ACNB BANK, Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): q,eoPr3 AT11 oar 33 - 50 " —1-1-8 1 .0 ID Pr) A-rry els-macro,/ 031a4-75 of SioUSILed $7,002.54 $1,600.00 $468.35 $5,870.89 WELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. 14Mecko, Esquire PA I.D. #7 596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 20044685 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 MIDLAND FUNDING, LLC Vs. NO 14-5686 Civil Term CIVIL ACTION — LAW SETH ANDERSON WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against SETH ANDERSON, 4637 Enola Lane, Newville, PA 17241 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 PNC BANK, 105 Noble Blvd, Carlisle, PA 17013 ACNB BANK, 37 Carlisle Rd, Newville, PA 17241 GARNISHEE(S), as garnishee, (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. 1 (3) if property of the defendant (s) 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 other person that he or she has been added as a garnishee and is enjoined as above stated. " Amount Due $5,402.54 Interest -- $468.35 Attorney's Comm. % Attorney Paid $151.06 Date: Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs 0/20/14 i Q.. 4.4,CL/ . yLpZ David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : JAMES P. VALECKO, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 436 7T11 AVENUE, SUITE 2500 PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 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 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY _ED-Ctr F (CL THE PROTHONO iAR1t 20111 NOV -3 PM 3: 56 CUMBERLAND COUNTY PENNSYLVANIA Midland Funding, LLC vs. Seth Anderson Case Number 2014-5686 SHERIFF'S RETURN OF SERVICE 10/29/2014 04:51 PM - Jason Kinsler, 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, ACNB Bank, 37 Carlisle Road, West Pennsboro Township, Newville, PA 17241, Cumberland County, by handing to Douglas Lindsay, Office 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 him. The writ of execution and notice to defendant was mailed on October 31, 2014 to Seth Anderson at 4637 Enola Road, Newville, PA 17241. (ASON KINSLER, DEPUTY SO ANSWERS, October 31, 2014 RONNY R ANDERSON, SHERIFF (c) CountySute Sheriff, Toleosoft, Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson F ` ']-Ot FiC.: Sheriff E P P CHL Jody S Smith 201 Li NOV-4 ` 10: Chief Deputy .? CUMBERLAND COUNTY PENNSYLVANIA Richard W Stewart Solicitor OFF ICG Cpl, TH:'.SH_RIFF Midland Funding, LLC vs. Seth Anderson Case Number 2014-5686 SHERIFF'S RETURN OF SERVICE 10/29/2014 12:21 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Carla Crozier, Sales, personally three copies of ' terrogatories together with three true and attested copies of the Writ of Execution and made the co'ten ,here of known to her. CLI F , DEPUTY SO ANSWERS, October 31, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuito Sheriff, To eosoft, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MIDLAND FUNDING, LLC, Plaintiff, v. SETH ANDERSON, Defendant, and PNC BANK and ACNB BANK, No. 14-5686 CIVIL Attachment Execution Proceedings Garnishee(s). PROOF OF NOTICE TO DEFENDANT COMMONWEALTH OF PENNSYLVANIA, COUNTY OF ADAMS. CD . 7-7 • , . On this, the 5* day of November, 2014, before me, a Notary Public, in and for said Commonwealth and County, the undersigned officer, personally appeared Edward G. Puhl, Esquire, attorney for ACNB Bank, the Garnishee in the above entitled attachment execution proceedings, who having been by me duly sworn, according to law, on his oath, does depose and say that on November .5 , 2014, he forwarded to the Defendant, Seth Anderson, a copy of the writ issued in said proceedings on October 30, 2014, and a copy of ACNB Bank's Answer to Interrogatories, by mailing the same certified mail deposited at the post office in Gettysburg, Adams County, Pennsylvania, addressed to the Defendant at the following address: 4637 Enola Lane, Newville, PA 17241. Attached to this Proof of Notice is the certified mail receipt showing the aforesaid mailing of the items hereinbefore mentioned. Sworn to and subscribed before me this LT day of November, 2014. X141,4° ve. 0"Aiiyhd Notary Public My commission expires: Edward G. Puhl, Esquire COMMONWEALTH OF PENNSYLVANIA Notarial Seal Leslie R. Grimes, Notary Public Gettysburg Boro, Adams County My Commission Expires Oct 23, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES U.S. Postal ServiceTM CERTIFIED MAILTM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.come ill Postage r71 f=1 Return Recelpt Fee CI(Endorsement Required) O Restricted DeliveryFee c](Endorsement Required) .,0 Certified Fee Total Postage & Fees To street, Apt No.; or PO Box No. , `F(4937 CM`(Le- • Postm Here ,&Soth Anders 7328 City, State, ZIP+4 v;l(e. PA I)?! PS Form 3800, August 2006 See Reverse for instructions IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MIDLAND FUNDING, LLC, No. 14-5686 CIVIL Plaintiff, vs. SETH ANDERSON, VS. PNC BANK and ACNB BANK, Defendant, Garnishee(s). : CERTIFICATE OF SERVICE AND NOW, this ,..541 day of November, 2014, I, Edward G. Puhl, Esquire, of Puhl, Eastman & Thrasher, attorney for Garnishee, ACNB Bank, hereby certify that I have this date served Garnishee's Answers to Interrogatories, by mailing the original and one true copy first class mail, postage prepaid, to James P. Valecko, Esquire, at the address shown below: c.: x `n Weltman, Weinberg & Reis Co., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 PUHL, EASTMAN & THRASHER By: Edward G. Puhl, Esquire Attorney ID# 55709 Attorney for Garnishee 220 Baltimore Street Gettysburg, PA 17325 (717) 334-2159 FIED-0F.Fic; OF THE PROTHOiiDTA: • 2014NOV A1111: 16 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING, LLC Plaintiff vs. Civil Action No. 14-5686 CIVIL SETH ANDERSON Defendant(s) AtitEPERS TO INTERROGATORIES IN ATTACHMENT PNC BANK ACNB BANK 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 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 20044685 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING, LLC Plaintiff vs. SETH ANDERSON Defendant(s) PNC BANK ACNB BANK Garnishee(s) Civil Action No. 14-5686 CIVIL TO: PNC BANK, 105 NOBLE BLVD, CARLISLE, PA 17013 ACNB BANK, 37 CARLISLE RD, NEWVILLE, PA 17241 SETH ANDERSON , 4637 ENOLA LANE, NEWVILLE, PA 17241 Suggested Reference No.: XXX -XX -0030 XXX -XX - IMPORTANT NOTICES TO GARNISHEE! A. 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. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee -Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. WWR No. 20044685 AlsEVERS 10 INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of deposit)? RESPONSE: No. 1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. RESPONSE: n/a 2. At the time you were served or at any subsequent time was there in your 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. RESPONSE: No. 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 part by the defendant or in which defendant held or claimed any interest? RESPONSE: No. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? RESPONSE: No. 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? RESPONSE: No. 6. 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 his direction or otherwise discharge any claim of the defendant against you? RESPONSE: No. 7. 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 amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. RESPONSE: No. WWR No. 20044685 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 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. RESPONSE: No. 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. RESPONSE: n/a 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. RESPONSE: n/a 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not 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? RESPONSE: n/a 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. RESPONSE: n/a WELTMAN, WEINBERG & REIS CO., L.P.A. By: J alecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 W WR No. 20044685 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 William A. Kauffman, (Name) Assistant Vice President of ACNB Bank , garnishee herein, (Title) (Company) that he/she is 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 ACNB BANK BY: William A. (SI&NAT Kauffman Assistant Vice President 1/1/WR No. 20044685