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