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HomeMy WebLinkAbout05-3400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MONARCH CAPITAL CORPORATION NO. OS - 3-100 ~.J~ P,O. BOX 1877 ROCKVILLE, MD 20849-1877 Plaintiff VS. CIVIL ACTION - LAW BRANDON J DIEHL 602 CENTERVILLE RD NEWVILLE PA 17241 Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT TO, BRANDON J DIEHL 602 CENTERVILLE RD NEWVILLE PA 17241 You are hereby notified entered against you on of Pa. R,C,P. 236, that the following ORDER, DECREE or JUDGMENT has been in accordance with the provisio Decree Nisi in Equity Final Decree in Equity Judgment of ) Confession Verdict ) Default Non-suit ) Non-pros Arbitration Award Judgment is in the amount of $ I plus costs. X District Justice transcript of judgment in civil action in the amoun of $ 2350.92, plus costs, If not satisfied within sixty (60) days, your motor vehicle operator license will be suspended by the Pennsylvania Department of Transportation. C:-'~ ~.~ Prothonotary If you have any questions regarding this Notice, please contact th~~ filing party, By, Amy oyl / F, Wolfson #20617 Bruce H. C / C, Warholic #86341 Ronald S. / M, Abramson #94266 Donald p, Shiffer #89451 / Andrew C, Spears #87737 WOLPOFF & ABRAMSON, L,L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 / (717 (This Notice is given in accordance with Pa. R.C.P. 236.) DJNTC/PANOJ W&A FILE NO, 128118508 Q ~, . ,..., = = """ <- c: ,- I U1 ~ 3!--n rf'lFfi =B9 06 ~-Yi :.1...-:0 Qo (Sm .c-{ :t, ~ "'U ;:lr. ~ o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MONARCH CAPITAL CORPORATION No. ps~ 310-0 ~ Je.M...-.... " P.O. BOX 1877 ROCKVILLE, MD 20849-1877 Plaintiff v s. CIVIL ACTION LAW BRANDON J DIEHL Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK The undersigned counsel, being duly sworn according to law, depose and that I am the Attorney for the Plaintiff in the above-captioned matter, and the best of my knowledge, information and belief Defendant, say that to BRANDON J DIEHL above-named, is over 21 years of age; is last known to reside at 602 CENTERVILLE RD NEWVILLE PA 17241 County of CUMBERLAND the United States or its Allies, Pennsylvania; is not in the military service of or otherwise within the provisions of the Servicemembers civil Relief Act and its Amendments. m-e Amy F. Doyle Daniel F. Canter (!>>~mm_ #87062 #20617 #18837 #86341 #94266 #94000 #89451 #87737 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Dina A. Sweitzer, Notary Public City of York, York County My Commission Expires Apr. 16, 2008 Bruce H. Philip C. Ronald M. Ronald S. Donald p, Andrew C. WOLPOFF & Attorneys Cherkis Warholic Abramson Shiffer Spears ABRAMSON, L.L.P. I Counsel for Plain in the Practice of Debt Collection SWORN and SUBSCRIBED to before me this ::tiill' PA 17 Notary PNM,AFF I PANOJ W&A FILE NO. 128118508 o S;~ ~~~ ,..., "" "" en <- c:: r- \ Ul ..., :;!:: r;? c::> 9n ::r!..,.., ~~r:~ -0 q. ~-r. B:!J '00:;9. 010. -'4 ..",. 0:0 '< - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MONARCH rAPT~hT rnODnDh~TnN No. os-- S'iao . '.e C:'.. -. .Jc:>..M...... P.O. BOX 1877 ROCKVILLE, MD 20849-1877 Plaintiff VS. CIVIL ACTION LAW BRANDON J DIEHL Defendant (s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: MONARCH CAPITAL CORPORATION ASSIGNEE OF AMERICAN DEBT SALES, ASSIGNEE OF WELLS FARGO BANK P.O. BOX 1877 ROCKVILLE, MD 20849-1877 and certify that the last known address of the within Defendant (s) is: BRANDON J DIEHL 602 CENTERVILLE RD NEWVILLE PA 17241 ;~;-;~DOY 1 e Daniel F. Bruce H. Philip C, Ronald M. Ronald S. Donald P. Andrew C, WOLPOFF & Attorneys (!_lI~_m___ #87062 #20617 #18837 Warholic #86341 Abramson #94266 Canter #94000 Shiffer #89451 Spears #87737 ABRAMSON, L.L.P. j Counsel for Plain in the Practice of Debt Collection Trind1e Road, 3rd Floor, Camp Hill, PA 17 4660 (717) 303 - 6700 PCRESjPANOJ W&A FILE NO. 128118508 o ~,~ --'(}'; '-~;", " '..-'~.' ;1--;, -?~""-::.. ":;"-,""::- ,~, '~'::::'\:: """ '<-;< ~ --'- ...;! q., ~ ~ <r fr.~ 'y. :9.,~ \ '?-.~ <J' -66 ..-0 2:.('0 -::s; <5 .,0\ r:-?~ o -- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MONARCH CAPITAL CORPORATION NO. OS-.3 </0-0 ~ .Jvv.... P.\.!. BOX 1877 ROCKVILLE, MD 20849-1877 Plaintiff vs, BRANDON J DIEHL Defendant(s) PRAECIPE FOR JUDGMENT Mr. IMs, Clerk: Please enter Judgment in favor of Plaintiff and against Defendant(s), BRANDON J DIEHL and pursuant to the District Justice Transcript. (X Amount due Less credits TOTAL $ 2350,92 $ 600,00 $ 1750.92, plus interest and costs ( X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain fro the complaint. ( X) Pursuant to Pa,R.C,P, 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other par who has appeared in the action or to his/her Attorney of Record. NOW, 20 Amy F, Doy e 87 62 Daniel F, Wo1 #20617 Bruce H. Cher is #18837 Philip C, Warho1ic #86341 Ronald M. Abramson #94266 Ronald S, Canter #94000 Donald p, Shiffer #89451 Andrew C, Spears #87737 WOLPOFF & ABRAMSON, L,L.P, I Counsel for Attorneys in the Practice of Debt Collect 4660 Trind1e Road, 3rd Floor, Camp Hill, (717) 303-6700 JUDGMENT IS ENTERED AS ABOVE, DATE: ~//;,; Signature: Prothonotary/Clerk, Civil Division By: Deputy PRAEDJlpANOJ W&A FILE NO. 128118508 CI. <;.., . .-<J'(::;' .;-t'~ \ ; "~;~"~~;', '?,~,:- .'~~~\;;f 0-. .-.' q., ~ ....\ ~ .~~ <f' ~ \ -q" q, c)'\ ".<"."0 "at, ,,0 .:;r r'(\ ~ .~ ..", ~ t-;1 o - 09-3-04 O:F~34OO ~.J~ NOTICE OF JUDGMENTfTRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'MOHARCH CAPITAL CORPORATION I 267 EAST JlARDT ST. C/O WOLPOPP & ABRAMSON L!OU:, PA 17403 -1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBBRLA1IID Mag.Dlst.No MDJ Name: Hon. THOJlAS A. PLACBY Adde." 104 S SPORTING BILL RD MBCBANICSBURG, PA VS, ...., 'Te"ph""~,(11'7) 761:"S230 17050 NAME and ADDRESS J I MOHARCB CAPITAL CORPORATION 267 EAST MARKBT ST. C/O WOLPOPP & ABRAMSON YOU:, PA 17403 -1 . ----:-- ~ THIS IS TO NOTIFY YOU THAT: dudgm~ ".. ,.;...,., --->. ,~ _DRlra.'IT1''P -~. PLT:r _",'~' [iJ [iJ Judgment was entered for: (Name) unDa.v.-.'R' t"aDTTa.T. t"n'DVnva....Tn'l1" Judgment was entered against (Name) nTHRI. R1)a'llnnW J in the amount of $ 2,'10;0 Q2 on: (Date of Judgment) '1/24/00;; , D Defendants are jointly and severally liable. D Damages will be assessed on: D This case dismissed without prejudice, D Amount of Judgment Subject to Attachment/42 Pa.C.S. S 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ (Date & Time) , Amount of Judgment $ 2.244.9~ Judgment Costs $ '106.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2.350.92 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS T~RIG~T TQAPPEAL WITHIN 30 DA YSAFTER TH~ENTRY Of JUPGMENT IlY FILING A NOTICE OF APPEAL WITH TH~PRonioNOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DiVisION. YOU MUST INCLUDE A COPV OF THIS NOTICE OF JUDGMENTrrRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE ISSUED BV THE MAGISTERIAL DISTRICT JUDGE, UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MA Y FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. '.$lc2.4\bS Date Magisterial District Judge I certify that this is a true a d correct cop of ther coro of the p oceedings containing the jUOgmenl. . ~1V\- \ D5 Date , Magisterial District Judge My commission expires first Monday of January, 2010 . SEAL AOPC 315.05 DATB PRIlIITBD: 3/24/05 2:44:31 PM . , (') r-> ~ = c: = ~ c.n ':':- c..... ~ -urn n-lrr c:: 01::!! 2::n r- r- ?~ I ~~ ~~ {IJ<,"'- Ul -<.,..: r;::.c; "'Q ~C1 :;J; 90 :>~ ~ 15m ~ 0 ~ '< ~~ r~'i ~~ (g.;;;' ~.. -il'%'l-~-:~~ I r\~1 "';' ,. (',d ill j ,1, ~,A,l I' j l\pJ,J dol tH 1 t__,__<..,^.,v..-.w..~_.~~,~".,_,~_. I . ; l 1_.__..,..,,_..."._._...."'~__...J ET:'~';7,~~";--.....-:':"""---""--. ___"c------_ !, .~OMMONWEALTI_;I OF PENNSYLVANIA COUNTY OF: CUMBBRLABD r,~ Mag. Dist_ No. 09-3-04 MDJ Name: Hon TBOMAS A. PLACBY Addco>,' 104 S SPORTl:NG Bl:LL IitD JlBCllAlII'l:CSBtJRG, PA T""hoo< (717) 761-8230 17050 ATTORlllBY POR ,4Al:NTl:PF : BRUCB B. CBBRXl:S BSQ 267 BAST ~VT.T ST. YOU, PA 17403-0 THIS IS TO NOTIFY YOU THAT: Judgment: ~' -, , ,!: ",..., _) ~1 '-,'- . ~ 9 :_--,.,,~--,'-' -'. I "'__...i ,;7,_" \/'l'v>~. NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE ~;=CB CA1>l:TAL co~~ii";i;;:ti -1'" 267 BAST ~V~BT ST. C/O WOLPOFF ...~ ABRAMSON t!OU, PA 17403 ..J VS, DEFENDANT: NAME and ADDRESS Inl:BBL, BRAlIDON 01. 1 Fl:BLI!CRBST.. DJl, ~I~~~tJRG, PA17050-7913 L) ,.J 11!! 5 ;; '_/ ,--,; , (,' . Dooket.No,:. CV - 0 0 0.0 0-03 -&5- Date Filed: 12/31/04 -, ..J , '" Judgment was entered for: (Name) .D1!I:I!'AULT .TIIJ1aM_ PLTP vnWa"Rl"'R' t"aItT....aT. ~n"Rltn"Ra.....TO. [i] [i] Judgment was entered against: (Name) in the amount of $ nTW'RT., 'R'Da.'IIIlnw aT "1/24/00; 2 "10;0 q2 on: o o o Defendants are jointly and severally lia'ble. Damages will be assessed on: . This case dismissed without prejudice. O Amount of Judgment Subject to' Attachment/42 Pa.C,S. 9 8127 $ . o Portion of Judgment for physical damages arising out of residential lease $ . (Date of Judg,rnent) (Date & Time) Amount of Judgment $ 2.244.92 Judgment Costs $ 106.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2.350.92 " .rf f'g$t J~dgment Qregits j /$ I .- , $ ( ( 'p st Judgment Costs ----------- .....----------- Certified Judgment Total $ ANY PARTY HAS Tt.tE RIGHT TO ,APPEAL WITHIN .30 DA Y5 AFTER THE ENTRYOF.JUDG!/IENT By FiliNG ~OTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVil PROCEDURE FOR MAGISTERIAL DISTRICT JUDG~HE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER ST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGI L Ot~;miCTJUDGE , UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE UDGMENT\lA Y FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SEtTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT, '1 ," ' . ' ,~:,: 4-""1 \:.'<~' J', ~5~ ,''I 'M~istertal DistrilJtJudge .~ . , . e..mc.QL!LQ1 the p oceedings containing the judgment. " ..---'-''' , > Date I certify that this is a true a d correct co -\, l, '"'' ';, , i" .....__~.....-......--.~"'~.,..... (-.141 \ '.. Date My commission expires first Monday of January, 2010 AOPC 315.05 DATI!: PRl:NTJm: 3/24/05 /' , Magisterial District Judge Sl:iAL 2:44:31 PH r ~ . ~~ \ \: ~ ~ q., (} ~ ~~- ~; ~ -<t'Q d.... '('" --''''\12 ~'\\" \ ~~, (l}\.>-', V' "~-:Q "J''-y o..~ '("\, .. .., Z:. ::t:_ ~:_, -:S- ~ 'L, ," _~ = 'Z,,~':, \--: ~ -".. . - ~'? <::> V'k- ..... 2 ~ \ ';>\ \ 'i, ~:\:' L "'-- \ -- ~ " '. ~ ;:::::.(~ -- ~-:I ......0..'" ~ "" 0 V, -:. ~ "\ -.\ 0' , :,..:;-\ 1\';,:;;;;1 1\ ';\1 "--"'-;"""'\.\,"'0 ~ \ 'IiI ----..., " /P' ~ _-:--- '\ '\'\ r::..",,,,~ \ \ \.iil\f\ l \ _ i \ '\ \ ,,, --'----11 \\\...- -' \ Ul._....- _,,_-- i __-- . -- '",- 4257 ~ PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 . . MONARCH CAPITAL CORPORATION ASSIGNEE OF AMERICAN DEBT SALES, ASSIGNEE OF WELLS FARGO BANK P.O. BOX 1877 ROCKVILLE, MD 20849-1877 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. I JUDGMENT NO. 053400CIVILTERM BRANDON J DIEHL 602 CENTERVILLE RD NEWVILLE PA 17241 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Defendant (s) To the Prothonotary: PLEASE ISSUE WRIT OF EXECUTION (I) Directed to the Sheriff of CUMBERLAND (2) against, BRANDON J DIEHL 602 CENTERVILLE RD NEWVILLE PA 17241 IN THE ABOVE MATTER. COUNTY, Pennsylvania; , Defendant (s) ; (3) and against, COMMERCE BANK 100 SENATE AVE CAMP HILL PA 17011-2309 (4) and index this writ (a) against, BRANDON J DIEHL , Garnishee (s); (b) against, COMMERCE BANK as a lis pendens against the real property of the Garnishee(s) as follows: (Specifically describe property) *** GARNISH ONLY , Defendant(s) and , Garnishee (s) , Defendant(s) in the name of the *** You are directed to attach the property of the Defendant(s) not levied upon in the possession of COMMERCE BANK 100 SENATE AVE CAMP HILL PA 17011-2309 Garnishee(s) All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount due Interest from 03/24/2005 At an interest rate of 6% per year Dated: ~ $ II/?D.q().. To Be Determined Total $ C~~ ^ __ Amy F. Doyle- #87062 / Philip C. Warholic #86341 / David R. Galloway #87326 / Ronald M. Abramson #94266 / Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Attorneys in the Practice of 4660 Trindle Road 3r Flo r 17")0.9:7, Plus costs & interest Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1!20617 1!87737 1!87852 1!94000 Counsel for Plaintiff Debt Collection m Hill A G -e' -r ~ ~ ~ - V) Q ~ \) .0 ~l\- ~ ~ ~ ~ \) 't'\.:) )0 ~ l E. L ~ ~ r--- ~ iA. W __ ~ ~ ..c 1I1 . . t-.> ~ l...> '\11 V'l 0 It) \) \ \ ~ : ~ ~r : ~fJ c-2 -'. I z"~~ :,:.j -' ,-' r~~? rJ< c-.::> WRIT OF EXECUTION and/or ATTACHMENT , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-3400 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY, To satisfy the debt, interest and costs due MONARCH CAPITAL CORPORATION, ASSIGNEE OF AMERICAN DEBT SALES, ASSIGNEE OF WELLS FARGO BANK, Plaintiff (s) From BRANDON J. DIEHL, 602 CENTERVILLE RD" NEWVILLE, PA 17241 (I) You are directed to levy upon the property oflhe defendant (s)and to sell (2) You are also directed to attach the property oflhe defendant(s) not levied upon in the possession of COMMERCE BANK, 100 SENATE AVE., CAMP HILL, PA 17011-2309 - ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE SECURITIES, COUPONS AND SAFE DEPOSIT BOXES, GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any properly of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject 10 attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a galllishee and is enjoined as above stated. Amount Due $1,750,92 L.L. $.50 Interest FROM 3/24/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Carom % Atty Paid $37,25 Plaintiffpaid Date: JANUARY 11, 2006 Due Prothy $1.00 Other Costs ~~ (Seal) By: Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON 4660 TRINDLE ROAD 3"D FLOOR CAMP HILL, P A 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87737 SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-03400 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND MONARCH CAPITAL CORPORATION VS DIEHL BRANDON J And now SHARON LANTZ ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:15 Hours, on the 23rd day of January 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT DIEHL BRANDON J in the hands, possession, or control of the within named Garnishee COMMERCE BANK 100 SENATE AVE CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to SHONDA STERNER (ADMIN, ASST) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her , Sheriff's Costs: Docketing Service Affidavit Surcharge ,00 ,00 .00 ,00 ,00 ,00 sO~/L R, Thomas Kline Sheriff of Cumberland County 01/24/2006 Sworn and subscribed to before me this 2{,JV day of l]~~_ ).00(" A'D'~J J (!tvu?1 prothonotar~. ;;r By IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MONARCH WELLS FARGO Plaintiff NO. 053400CIVILTERM vs. CIVIL ACTION - LAW BRANDON J DIEHL AND COMMERCE BANK 100 SENATE AVE CAMP HILL PA 17011 Defendant PRAECIPE TO SETTLE AND SATISFY Please mark the judgment in the above-entitled cause as paid and satisfied. Respectfully Submitted, BY~~ Amy F. Doyle #87 62 Daniel F. Wolfson #20617 Philip C. Warholic #86341 Andrew C. Spears #87737 David R. Galloway #87326 ----- Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3" Floor Camp Hill, PA 17011 (717) 303-6700 Cc: BRANDON J DIEHL W&A File No. 128118508 ....., ~= ::.;;;:) ':~~'.. o " ~J fh2 L..., '" ~-, 1..".' , t.) ..,., r"1 CJ 1 -.J --, '\ -~..; ".: ('~ ;'5(":: So! ~JJ --( L.) en 4260 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . MONARCH CAPITAL CORPORATION ASSIGNEE OF AMERICAN DEBT SALES, NO. 053400CIVILTERM Plaintiff vs. CIVIL ACTION-LAW BRANDON J DIEHL 602 CENTERVILLE RD NEWVILLE PA 17241 Defendant (s) IltI5i0YrS --!z) INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION TO: PURSUANT TO RULE 3114 OF THE. RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS 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. The term "Defendant (s)" means the individual (s) or enti ty agains t whom the Writ of Execution was issued. c. "You" means the main office and all branch offices, representatives, employees, and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. is to be as such, estimate Where exact information cannot be furnished, estimated information supplied. When an estimate is to be used, it should be identified and an explanation should be given as to the basis on which the is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. ORALEX!PAWRIT ssll 178 70 6723 W&A FILE NO. 128118508 4258 . PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - BRANDON J DIEHL 602 CENTERVILLE RD NEWVILLE PA 17241 SS!1 178 70 6723 1. DEPOSITORY ACCOUNTS: At the time you were served or'at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate, of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each account. If the Defendant(s) maintains any of these jointly with any other person, or persons, give their ~ame and, address. ,,' 11\ lA' ''', '.' '-'~V \,., Dull \ tcfCiYiCtn-t' 1):1) C\CCCLlItI lr1lC'h\\~/N'j ,jOU ..:J \\Jet ()(Y.,t , . \'\It\\\ C\ YJ:.\\u\lc.e. Of ~\D'X1.,bb ~'fend~\'" CU.>') I'Ll') C\ (OL,nt- :)Q~".hbl(J() r\elc\, )OLi'\T\ ~\ \\l\.iY\ '01t\C~ L \)UY\ \ C\I\C\ C\ \.):1,\0\ \C(' C '\ \ ll-~y~~~1 b~R~~ ~~~IT'i1C~b~TS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. 2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons, give their full name and address. \\10, 3. PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not Defendant(s) owns any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also 'whether or not there are any encumbrances or liens holders, the present balance of the encumbrance. State where and when the encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. jx CH\SN.rr -\0 Cbues't IOY) \ . 4. OTHER ASSETS: At the time you were served or did you know of the existence of any other asset(s) are not disclosed in the preceding Interrogatories. all details concerning those asset(s). at any subsequent time, of the Defendant(s) which If so, please set forth ~l C\Ds\~e\ -\0 Ctl't31\0\\ \, ORALE2/PAWRIT W&A FILE NO. 128118508 4259 . 5. PROPERTY: At the time you were served or at any subsequent time, was there in your possession, custody, or control or in the joining pOlsession. custody" or control of yourself and one or more other persons any property of' any nature owned solely or in part by any Defendant (s)? If so, please descd be for each Defendant (s) ,each item' of property including its value. SJ..l (n\S\~ -to CbLle.~t\OVl ) , 6. REAL PROPERTY: At the time you were served or at any subsequent time, did you hold legal, or equi~able title to any property of any nature owned solely or in part by the Defendant(s) or in which and Defendant(s) held or claimed any interest? If so, describe for each Defendant(s) each item of property including its value and the interest held by the Defendant(s). ~ee C\\\~\;~ef-\(J ~ue3~\Jf\ \, 7. PROPER TY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). ~ 8. TRANSFER OF PROPERTY: At any time before or after you were served, did any Defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent. If so, for each Defendant(s) describe the property transferred or delivered including the dates of delivery or transfer and state the consideration paid. .tt'ft\ICIC\irr 1'\\CICle -1\O.\\S-ftr3 \\,\ \\"t f)(C\\Y\C\r~ COUf-.t, ~\\O( to \'rY\J\Ce) \"tJf\t or \\lI\\CJ\ \\ltre ()\- -\-Ve d\ fC'Ci/01l ()f CO VV\ fl"tfCO ikI RK. 9. FEES OUTSTANDINGLfblGARNISHEE: Are there any attorneys fees or processing fees charged by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer. If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for 'the garnishee for the preparation of the Answer. ND c~~). Amy F. Doyle #87062 / Philip C. Warholic #86341 / David R. Galloway #87326 / Ronald M. Abramson #94266 / Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 #87852 1194000 Date: __ r<J ~:..~:;~ (j t.:' -fl -i< -f"l r"-'l OJ \ (;:l -'r:; ....",:' C) {..: W1 ~ c:::z== M- ~. ~ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL 18.00 1.85 .50 1.00 13.20 30.00 20.00 .74 9.00 J n 94.29 ../ 10 /J'/~(' --r Advance Costs: 150.00 Sheriffs Costs 94.29 55.71 Refunded to Atty on 10/04/06 ~~~4t!~ R. Thomas Kline, Sheriff By c; tluJl~ ~~:>~/ ~ V\ w ~ ~ Q I :b 'V 8 I NVr qOal Vd 'A1Nfl03 Otf'tlij3BHna .:L:lIM3HS 3Hl 30 331:UO .. ..J\ ~ ;J r-. i,~.: ~-=-...;:. ~Vh, ~-:1 ~ \ ' .p {Ir< 6, r.24 /2t-c, i I '1 '-I (, ')... WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 05-3400 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MONARCH CAPITAL CORPORATION, ASSIGNEE OF AMERICAN DEBT SALES, ASSIGNEE OF WELLS FARGO BANK, Plaintiff (s) From BRANDON J. DIEHL, 602 CENTERVILLE RD., NEWVILLE, P A 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMERCE BANK, 100 SENATE AVE., CAMP HILL, P A 17011-2309 - ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) 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; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $1,750.92 L.L. $.50 Interest FROM 3/24/05 AT AN INTEREST RATE OF 6% PER YEAR Arty's Comm % Arty Paid $37.25 Plaintiff Paid Date: JANUARY 11, 2006 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQillRE Address: WOLPOFF & ABRAMSON 4660 TRINDLE ROAD 3RD FLOOR CAMP HILL, P A 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No, 87737 i\.)