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Home My WebLink About01-4492 .. COMMONWEALTH OF PENNSYLVANIA , COUNTY OF: CUMBERLAND Mag. Dist. No.. 09-1-02 Ol~ .LI49~ Cl~ll "-r&"-r NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rcITIBANK (SOUTH DAKOTA), N .A. I PO BOX 356 WEST CHESTER, PA 19381-0356 L ~ VS. DJ Name: Hon. ROBERT V. MANLOVE Address 1901 STATE STREET CAMP HILL, PA Telephone (717) 761- 0583 17011-0000 DEFENDANT: NAME and ADDRESS rsHOWERS, CONNIE QO--S'13 314 ERFORD RD CAMP HILL, PA 17011 L Docket No.: CV- 0000390 - 00 Date Filed: 10/30/00 I ~ % OLIN, NEIL & HALTRECHT PO BOX 356 WEST CHESTER, PA 19381-0356 THIS IS TO NOtiFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF Ii] Judgment was entered for: (Name) C'.TTTR~NK" (~OTTTH n~ 'K'OT~). N ~ Ii] Judgment was entered against: (Name) SHOWRRS, CONNTE in the amount of $ 6,ElQl:i 7R on: (Date of Judgment) 12/12/00 .. .. D Defendants are jointly and severally liable. D Damages will be assessed on: (Date & Time) Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Amount of Judgment $ 6,498.78 Judgment Costs $ 97.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 6,595.78 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ D This case dismissed without prejudice. D D D Levy is stayed for days or D generally stayed. Objection to levy has been filed and hearing will be held: Date: Place: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITH N 30 DAYS AFT HE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOT I K OF TH C T OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS J N RANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. J ~- \ a- ODDate , District Justice ord of the proceedings containing the judgment. Ja-I a-OODate , District Justice My commission expires first Monday of January, AOPC 315-99 2006 SEAL 00-813 CIVIL COMPLAINT PLAL1\JTIH. - , ..". -I COMMONWEAL TH OF PENNSYLVANIA . COUNTY OF: CUMBERLAND Mag Disl. No. 09-1-02 . D.I Na1l1c HOIl Robert Manlove Addrcss 1901 State Street Camp Hill, PA 17011 NAME alld ADDRESS Citibank (South Dakota), N.A. c/o Olin, Neil & Haltrecht 610-696-3030 P.O. Box 356, West Chester, PA 19381-0356 VS. DEFENDANT Telephone: 717-761-0583 NAME and ADDRESS Connie Showers 314 Erford Road Camp Hill, PA 17011 AMOUNT DATE PAlO I --- I I --- L12-1 ~3() I...QO FILING COSTS SERVING COSTS TOTAL $ $ $ Q7. OD TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $ $6,498.78 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): For past due balances for goods and merchandise purchased and/or cash advances made by the defendant on a credit card issued by the plaintiff in the name of Mary E. Duras, plus reasonable attorneys fees per terms and conditions of account and court costs. The defendant agreed to repay the balance pursuant to an Acknowledgement of Responsibility. $5,415.65 Principal Credi t Interest $1,083.13 Atty.Fees $6,498.78 Balance I, Burton Neil, Esquire, Att. for Plaintiff , verify that the facts set forth in this complaint are true and correct to the best of my knowledge, information, and belief. This statement is made subject tQ_the penalties of Section 4904 of the Crimes Code (18 P A. S.C.A. S 4904) related to unsworn falsification to authorities: . _~,P - >("" (Signature of Pla;;;ii fforAuthmi zed Agent) Plaintiffs Attorney: Burton Neil, Esquire Address: 26 S. Church St., P.O. Box 356 Telephone: 610-696-3030 Wps.t (;hpster. P A 1 q::\R 1-n::\SR IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER_ YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT WILL BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within the district justice jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five (5) days before the date set for the hearing. If you have a claim against the plaintiff which is not within district justice jurisdiction, you may request information from this office as to the procedures you may follow. If you are disabled and require assistance, please contact the Magisterial District office at the address above. ~ . OLIN, NEIL & HALTRECHT By: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 East 60th Street North Sioux Falls, SD 57117 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. CONNIE SHOWERS 314 Erford Road Camp Hill, P A 17011-1115 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 ofthe judgment creditor and debtor. 2. The said defendant is not in the Military Service of the United States or its Allies or otherwise within the coverage of the Soldiers' and Sailors' Relief Act of 1940, as amended, is over 18 years of age and has a civilian occupation. ~rClIT ~~ ~ Y- Burton Neil, Esquire Attorney for Plaintiff In making this communication, we advise that our firm is a debt collector. tp ~ ~ ~ ~ \i- 9J r ~ ~ i ' '"""- 0 "- ~ - 3 ~ ~ ~ ~1 i. ,.. - fl! ~ ~ g---..:t ~ N ~ +- V\ ~ ('J . , -. VI -, ""1:;) ;5 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.c.P. ~ 3103 to 3149 CITIBANK (SOUTH DAKOTA) N.A. Plaintiff : IN THE COURT OF COMMON PLEAS VS. CONNIE SHOWERS : CUMBERLAND COUNTY, PENNSYLVANIA Defendant FISRT UNION NATIONAL BANK Garnishee : NO. 01-4492 : CIVIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. 3. against Connie Spowers and against First Union National Bank _, Defendant( s) , Garnishee( s) 4. and index this writ (a) against (b) against Defendant( s) Garnishee( s) as a lis pendens against the real property ofthe defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) NO LEVY-GARNISHMENT ONLY Serve interrogatories on garnishee at: 804 E. High Street, Carlisle, P A 17013 5. Amount Due Interest from 12/12/00 Total *Plus writ costs Dated: September 25,2001 $6,595.7' 4-*' $ 311.33 $6,917.12* / " .......... . . l/ "--. . '~....., _'d. '~~ Burton Neil, Esquire Attorney for Plaintiff NOTE: Under paragraph I when the writ is directed to sheriff of another county as authorized by Rule 31 03(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 count 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 31 04( a), When the writ issued to another county indexing is required as of course in that county. See Rule 31 04(b). Paragraph 4(b) should be completed only ifreal property in the name of the garnishee is attached and indexing as a lis pendens is desired, See Rule 3104(c). The firm of Olin Neil & Haltrecht is attempting to collect a debt. t rr ~ r- t. r ~ .- r C J:- (.) ~ ~ 7i - 9v , ........ t ,l<l. :G ~ ..:l , -!: ~ P , . C/t Ql ~ -_.,.... ~ c. C .~ & 0 :~} d I C> ,,1 ~ L I I : ...::) ....0 r ~ 0 I' ._~ "- ~ .,...... ~ r I" -, .() .. + - " r i." G>v ........ I' ~ - . ,., N ....' . 't ~ .."--, :'~., .- f;, ~ . ~ N ~.-:) ~ ..... - cr. ~ r ~ (' SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-04492 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND CITIBANK VS SHOWERS CONNIE And now KENNETH GOSSERT ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:20 Hours, on the 5th day of October ,2001, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT SHOWERS CONNIE in the hands, possession, or control of the within named Garnishee FIRST UNION NATIONAL BANK 804 E. HIGH ST CARLISLE" PA 17013 Cumberland County, Pennsylvania, by handing to WANDA SHAFFER (FINANCIAL SPECIALIST) personally three copies of interogatories together with 3 true and attested copies of the within JUDGMENT - DJ and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So answers~/?~ ~~ ~~~r~~ R. Thomas Kline Sheriff of Cumberland County 00/00/0000 this --.L;L~ day of m~ --Jevl A.D. C) a ~ ~;z; PlI~otary , By Sworn and subscribed to before me OLIN, NEIL & HALTRECHT By: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-4492 CONNIE SHOWERS Defendant and First Union National Bank Garnishee : CNIL ACTION - LAW Praecipe to Dissolve Attachment To the Prothonotary: Dissolve the attachment against First Union National Bank, garnishee. O~HALTRECHT . BY: ~ L0 Burton Neil, Esquire Attorney for Plaintiff In making this communication, we advise that we are a debt collector. 7? r: 10 ~- r~ b (> ~ CN ~ D~ ~ \Vi " ~ J:- dJ . ::=:.: / =~': r---; , -. L"'_.. .;,:,:" / (-) l.p...' :"''j C c.. --- ---:: .......} WRIT OF EXECUTION and/or A IT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-4492 CIVIL ~ TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Citibank (South Dakota) N.A. PLAINTIFF(S) lrom Connie Showers, 314 Erford Rd, Camp Hill, PA 17011 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell NO LEVY- GARNISHMENT ONLY (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of First Union National Bank, 804 E. High St., Carlisle, PA 17013 - Serve Interrogatories GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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) If property 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 himlherthat he/she has been added as a garnishee and is enjoined as above stated. L.L. Due Prothy Other Costs $.50 $1.00 $.50 due garnishee Amount Due $6.595.78 Interest fran 12/12/00 - $311.33 Atty's Comm 0/0 Atty Paid $31.75 Plaintiff Paid Date: October 2, 2001 Curtis R. Long Prothonotary, Civil Division ~: A~p - P ~OllZ~-' Deputy REQUESTING PARTY: Name Address: Burton Neil, Esq. Olin, Neil & Haltrecht 2& Sautl1 CllUrch St., r.O.Box West Chester, PA 19381-0356 356 Attorney lor: Plaintiff Telephone: 610-696-3030 Supreme Court 10 No. 11348 'l!c:JL!j ~~ == lb!b, l1!b. ~, R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing 18 . 00 Poundage 1 . 43 Advertising Law Library . 50 Prothonotary 1. 00 Mileage 3 . 25 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee 9 . 00 73.18 Sworn and Subscribed to before me this ~ day of Qt, 1'~ 2002 A.D. ~/LL-O ~. ~ pro onotary V' .~ t) '~,. -",' 1''\ ~ ,] d In' f.'1 !1 l~n 0"1 nl -It );,.;ji~:, ~ 1:tJ:1:' H" ,i:l..J ,,:.t:J1W Advance Costs: Sheriffs Costs: 150.00 73.18 76.82- Refunded to Atty on 7 / 15 /02 ~ , So Answers; .J ..., ~~ut:~ R. Thomas Kline, Sheriff B~J Q..tltiioll~~4/ (:', -:::~-_. ;0-: e \;.--- I. $V t-k _~ 7L(Cj(, ~. ptJ31