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HomeMy WebLinkAbout05-40412019869 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK UNIVERSAL CARD SVCS 10625 Techwoods Circle Cincinnati, OH 45242 COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. BARBARA K LEHMAN 1434 THREE SQUARE HOLLOW NEWBURG PA 17240 DOCKET NO NOTICE 05 -46w/ et YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGEMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT IN CIVIL-ACTION 1. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the plaintiff under the terms of which the plaintiff agreed to extend to defendant(s)the use of plaintiff's credit facilities. 2. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the plaintiff for the use of said credit card. 3. The defendant (s) received and accepted goods and merchand- ise and/or accepted services or cash advances through the use of the credit card issued by the Plaintiff. A true and correct copy of the Statement of Account is attached hereto as Exhibit "A" 4. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due in the amount of $2,991.34. 5. Plaintiff has made demand upon the defendant(s)for payment of the balance due of $2,991.34 but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. WHEREFORE, plaintiff claims of the defendant(s) the sum of $2,991.34 at the rate of 23.9% from the date of September 19, 2001, together with costs and attorney fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE BERG, ESQUIRE PAUL M. SCH LD, JR., ESQUIRE Attorney for Plaintiff P01h FREDERIC I. WEINBERG, ESQUIRE, hereby states that he is the attorney for the Plaintiff (s) in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. FREDERIC I. WEIN E , ESQUIRE EXHIBIT "A" AFFIDAVIT OF INDEBTEDNESS State of Ohio ) County of Hamilton ) ss. Bharati Lengade being sworn, deposes and says that she is Media Supervisor of Unifund CCR Partners herein called assignee, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and that she is authorized to make the statements and representations herein. The defendant is not in any branch of the military. There is due and payable from Barbara K Lehman, Account Number 5398420008023748, the amount of $6089.97 (principal balance in the amount of $2991.34 plus interest up through 06/16/2005 in the amount of $3098.63). By the terms of the agreement between the defendant and the original creditor, interest is accruing from the aforesaid date at the rate of 23.90 percent per annum. This balance reflects any payments, credits or offsets made since the account was charged off. Citibank (South Dakota) NA's account was issued under the name of Citibank Universal Card Svcs. Unifund CCR Partners purchased this account from Citibank (South Dakota) NA. Said account has been referred to Gordon & Weinberg P.C. with full power and authority to do and perform all acts necessary for the collection, settlement, adjustment, compromise or satisfaction of said claim. DATED a n 16, 2005 UNHqJND-GM PARTNERS By: Bharati Lengade Media Supervisor 10625 Techwoods Circle Cincinnati, OH 45242 Address Subscribed and sworn to before me this 16 day of June, 2005 Year Notary Public /My commission Expires 1111/1, Client # 829 829 Balance as of: Payment Due Minimum Payment Account Number 06/16/2005 Date Payment Enclosed 5398420008023748 Past Due $6089.97 1$ Make checks payable to: UnBund UNIFUND STATEMENT Barbara K Lehman 1434 Three Square Hollow Rd Newburg PA 17240-9351 MESSAGE FROM UNIFUND Your account is past due $6089.97. The past due amount is included in the minimum payment. Please remit immediately. If you have already sent payment for the above amount, thank you. TRANSACTIONS: a e Transaction glance ue ayments Balance 06/1612005 Citibank (South Dakota) NNs $6089.97 $6089.97 $0 $6089.97 account was issued under the name of Citibank Universal Card Svcs. Unifund CCR Partners purchased this account from Citibank (South Dakota) NA. Prompt crediting of payments. To receive credit for payments as of the date of receipt, we must receive your check or money order at: Unifund 10625 Techwoods Circle Cincinnati, OH 45242 Payments received at the above address in the manner specified after that time will be credited to your account as of our next business day. The crediting to your account of payments received at any location other than the above address may be delayed up to 5 days of receipt This communication is from a debt collector. Federal law requires us to inform you that this is an attempt to collect a debt and any information obtained will be used for that purpose. b c aol q S&q 0000021 KANSAS CITY ACID: KCTSOIID TM: C063SO SITE: KCCL XXXXXXXXXXXXXXXXXXXXXXXXXX 5398420008023748 k YourAWIWversal Card Statement e 1 I ftT April 24 - May 22, 2002 Page 1 of 3 How to Reach Us Account Online: www.universalcard.com BARBARA K LEHMAN Account OnCall: 1 600636-8330 Account 5398 4200 0802 3748 (For Automated Service Only) Calling Card +PIN Customer Service: 1600 423-4343 or write Cardmember Services, PO Box 44167 Jacksonville, FL 32231-4167 grt<tr-: Help is availablel Please call the - toll-free number shown above to learn Minimum Payment Due ............................ .....$3.048.67 about our special payment options. Due Date• .................................... - ...DUE NOW Please give us the opportunity to assist •PeYment must be received by 1:0o pm lmaltime on the payment due date. you. Amount Past Due ................................... ........$660.21 Amount Over Limit ................................. .........$48.67 We're listening: Customers tell us making statements Credit Line ......................................................... ............$0.00 easier to read is important. Now _ Available Credit ................................................. ............ $0.00 keeping track of spending just got Cash Advance Limit ........ .................................. ...-.......$0.00 easier. See page 2 "Small Change" for Available Cash Advance Limit ......................... ............$0.00 details. AciwuatftDlrtfai' PreviousBalance - - $2,991.34 - - Payments and Adjustments 000 MasterCard Activity 57.33 Total AT&T Services 0.00 Now Balance $3,048.67 Note: Detailed activity starts on page 2. Payment Record Amount Paid: Date Check Number: Please follow payment instructions in the "Important Instructions for Makinu Payments" section of the original Account Number Pa mem Due New Balance Minimum Pa ment Enter Amunt Enclosetl 5398 4200 0802 3748 DUE NOW $3,048.67 $3,048.67 Make changes to address and phone number below: Address Apt.,Suke City State Zip Home phone Business phone 1 1 1 1 o xx 539663 15 eo H Make check payable to: ATTNYRACCOUNTMCODE=URP1 AT&T Universal Card NEWBURG PA 17240-9351 PO BOX 8215 SOUTH HACKENSACK NJ 07606-8215 BARBARA K LEHMAN Account 5398 4200 0802 3748 April 24-May 22, 2002 Page 2 of 3 Small change to help track spending: Now look for purchases and cash advances broken out by transaction type. Even promotional activity like balance transfers are listed separately. In the return envelope, please: 1 Enclose your check or money order, Include your account number and name on the front of your check or money order. Please, no cash or foreign currency. 2 Enclose your payment coupon. Do not staple or tape it to your payment. Insert the payment coupon so that the entire AT&T Universal Card address appears through the window of your remittance envelope. BARBARA K LEHMAN Page 3 of 3 Account 5398 4200 0802 3748 April 24-May 22, 2002 AUT IJOYMO mart _Slmtmar Purchases .....................................................................................__.......''_-__................ SO.QQ. Cash Advances and Checks ................................................................................................. W.W. Finance Charges ...............................................................................................................$53.33 Total MasterCard Activity .................................................................................................$52.33 W Purchases Total MasterCard Purchases.. ® Cash Advances and Checks Cash Advance Limit ................................$0.00' 'This represents a portion of your total credit line. Finance Charge Information Days in Balance Periodic Nominal Periodic x Billing x Subject to = RNANCE + APR Rate Perio Finance Charge LAA7w Standard Purch 23.900% .06548%IDI x 29 x $3,018.92 = 957.33+ $0.00 23.900% CASH ADVANCES Standard CashAdy 23.900% .06548%(D) x 29 x $0.00 = $0.00+ $0.00 23.900% Total RNANCECHANGE- $57.33 ----------- -- ?i'f$rv-Srlntmarg AT&T Universal Calling Card Cells ................................................................................................................$0.00 r,?N 4Q a b T SHERIFF'S RETURN - REGULAR CASE NO: 2005-04041 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS LEHMAN BARBARA K JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT Sc NOTICE LEHMAN BARBARA DEFENDANT was served upon the , at 1606:00 HOURS, on the 11th day of August , 2005 at 1434 THREE SQUARE HOLLOW NEWBURG, PA 17240 by handing to BARBARA LEHMAN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 15.20 Affidavit .00 Surcharge 10.00 .00 43.20 Sworn and Subscribed to before me this ")IAP day of ( A.D. Proth tart' So Answers: s R. Thomas Kline 08/12/2005 GORDON & WEINBERG By: ?. De t Sheriff GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK UNIVERSAL CARD SVCS VS. BARBARA K LEHMAN COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO PRAECIPE FOR JUDGMENT : 05-4041 CIVIL The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, BARBARA K LEHMAN, and assesses the damages as per statement below. FREDERIC I. WEINBERG, E UIRE PAUL M. SCHOFIELD, J ., E )QUIRE Attorney for Plain iff Principal $2,991.34 Interest from September 19, 2001 Q23.9°s $2,863.63 Total: $5,854.97 I hereby certify that written notice of the intention to file this Praecipe was mailed or delivered to the parties against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. FREDERIC I. WE N , ESQUIRE PAUL M. SCHOFIELD, JR., ESQUIRE Attorney for Plaintiff Filed: By the Prothonotary: AND NOW, this 194?-- day of () C , 2005 Judgment is entered in favor of the plaintiff(s) and against defendant, for want of an answer and damages assessed at the sum of , $5,854.97 as per the above certification. Proth4 otary / GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK UNIVERSAL CARD SVCS Vs. BARBARA K LEHMAN COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO 05-4041 CIVIL CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF CITIBANK UNIVERSAL CARD SVCS and that the last known address of defendant, BARBARA K LEHMAN, 1434 THREE SQUARE HOLLOW, NEWBURG PA 17240. GORDON & WEINBERG, P.C. BY: FREDERIC I. W NB G, ESQUIRE PAUL M. SCHOL?ELD, JR.,ESQUIRE Attorney for Plaintiff GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK UNIVERSAL CARD SVCS VS. BARBARA K LEHMAN COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05-4041 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE FREDERIC I. WEINBERG, ESQUIRE, being duly sworn according to law, deposes and says that he represents the plaintiff in the above- entitled case; that he is authorized to make this affidavit on behalf of the plaintiff; and that the above-named defendant is over twenty- one years of age; that the address of the defendant is, 1434 THREE SQUARE HOLLOW, NEWBURG PA 17240; that the occupation of the defendant is unknown; and that the defendant is not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Sworn to and Subscribed Before me this Day of 22Q00--//5. nn Notary Public NOTARIAL SEAL CHRISTINE MARSHALL, Notary Public Wayne, Chester County Camtssion Expires October 24, 2005 FREDERIC ?w 2 2 D'31, ESQUIRE PAUL M. SCHOFIELD, JR. ESQUIRE Attorney for Plaintiff GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR. , ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 2019869 UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK UNIVERSAL CARD SVCS VS. BARBARA K LEHMAN TO/PARA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05-4041 CIVIL NOTICE OF INTENTION TO TARE DEFAULT BARBARA K LEHMAN 1434 THREE SQUARE HOLLOW NEWBURG PA 17240 DATE OF NOTICE/FECHA DEL AVISO: September 6, 2005 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: P10D-2 FREDERIC PAUL M. ESQUIRE ESQUIRE 7, 2019869 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK UNIVERSAL CARD SVCS VS. BARBARA K LEHMAN COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO 05-4041 CIVIL NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING IN THE AMOUNT OF $5,854.97. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-9600. GORDON & WEINBERG, P.C BY: 41- FREDERIC .WEINBERG, ESQUIRE PAUL M. OFIELD, JR.,ESQUIRE Attorney for Plaintiff Dated: September 20, 2005 ? i GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 PAUL M. SCHOFIELD, JR., ESQUIRE Identification No.: 81894 21 SOUTH 21ST STREET PHILADELPHIA, PA 19103 215/988-9600 UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK UNIVERSAL CARD SVGS VS. BARBARA K LEHMAN 1434 THREE SQUARE HOLLOW NEWBURG PA 17240 and Farmers & Merchants Trust Co. 3 E. First Street Boiling Springs, PA 17007 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05-4041 CIVIL PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against BARBARA K LEHMAN defendant(s)and (2) against Farmers & Merchants Trust Co. garnishee(s) (3) AMOUNT DUE $5,854.97 INTEREST from October 19, 2005 $371.48 COSTS Prothonotary fee $15.00 Sheriff fee $150.00 TOTAL $6,391.45 FREDERIC I. WEIN RG, ESQUIRE PAUL M. SCHO, JR., ESQUIRE Attorney for Plaintiff -YJ C 9? ? C 'C V , k ? N w T? WRIT OF EXECUTION and/or ATTACHMENT t COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4041 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK UNIVERSAL CARD SVCS, Plaintiff (s) From BARBARA K. LEHMAN, 1434 THREE SQUARE HOLLOW, NEWBURG, PA 17240 (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 FARMERS & MERCHANTS TRUST CO., 3 E. FIRST STREET, BOILING SPRINGS, PA 17007 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) 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $5,854.97 L.L. $.50 Interest FROM 10/19/05 - $371.48 Atty's Comm % Due Prothy $1.00 Atty Paid $125.20 Other Costs Plaintiff Paid Date: DECEMBER 1, 2006 Curti . Long, Prq?he otary (Seal) By: Deputy REQUESTING PARTY: Name FREDERIC I. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, P.C. 21 SOUTH 21s' STREET PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-988-9600 Supreme Court ID No. 41360 TRUE COPY PPDM RECORD '1 Tim MMq wh -f "`^-^ un0 set my hsnd 800 a sf, -z Qd0, Pa. Age J.F-f-- ago" A SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-04041 P , COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND UNIFUND CCR PARTNERS VS LEHMAN BARBARA K And now ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0010:15 Hours, on the 15th day of December , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT LEHMAN BARBARA K in the hands, possession, or control of the within named Garnishee` FARMERS & MERCHANTS TRUST CO 3 EAST FIRST ST BOILING SPRINGS, PA 17007 Cumberland County, Pennsylvania, by handing to CINDY KECK (TELLER) 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: So ans?y -- Docketing .00 Service .00 Affidavit .00 R. Thomas Kline -? Surcharge .00 Sheriff of Cumberland County .00 00 ?? / n,07 12/19/2006 Sworn and Subscribed to before me this day of Deputy S eri f A.D 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 18.00 Poundage 1.66 Advertising Law Library .50 Prothonotary 1.00 Mileage 4.40 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 84.56 ? Advance Costs: 150.00 Sheriff's Costs 84.56 65.44 Refunded to Atty on 09/11/07 '7/2't/07 So Answers, R. ThomasKline, Sh 81 C d L - 310 9001 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4041 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK UNIVERSAL CARD SVCS, Plaintiff (s) From BARBARA K. LEHMAN, 1434 THREE SQUARE HOLLOW, NEWBURG, PA 17240 (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 FARMERS & MERCHANTS TRUST CO., 3 E. FIRST STREET, BOILING SPRINGS, PA 17007 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) 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $5,854.97 Interest FROM 10/19/05 - $371.48 Atty's Comm % Atty Paid $125.20 Plaintiff Paid L.L. $.50 Due Prothy $1.00 Other Costs Date: DECEMBER 1, 2006 (Seal) Curtis R. Lo othono By: Deputy REQUESTING PARTY: Name FRF.DRRIC L WEINBERG, ESQUIRE Address: GORDON & WEINBERG, P.C. 21 SOUTH 21sT STREET PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-988-9600 , ' Supreme Court ID No. 41360 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N005-4041 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS ASSIGNEE OF CITIBANK UNIVERSAL CARD SVCS Plaintiff (s) From BARBARA K. LEHMAN, 1434 THREE SQUARE HOLLOW, NEWBURG, PA 17240 (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 GARNISHEE(S) as follows: F&M TRUST, 3 EAST FIRST STREET, BOILING SPRINGS, PA 17007 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) 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$5,854.97 Interest FROM OCTOBER 19, 2005 - $2,020.74 Atty's Comm % Atty Paid $231.76 Other Costs Plaintiff Paid Date: 6/17/11 L. L. Due Prothy $2.00 i Davi4-D-.-Buell, Prothonotary a (Seal) REQUESTING PARTY: By: Deputy Name FREDERIC I. WEINBERG, ESQ. Address: GORDON & WEINBERG, P.C., 1001 E HECTOR STREET, STE. 220, CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 2019869 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 rN JOEL M. FLINK, ESQUIRE .ti -- - Identification No.: 41200 _MCD rn - 1001 E. Hector Street, Ste 220 7r; 0 M Conshohocken, PA 19428 7Q U) 1 484/351-0500 r UNIFUND CCR PARTNERS ASSIGNEE OF COURT OF COMMON PLEAS c-' C- CD UNIVERSAL CARD SVCS CUMBERLAND COUNTY Vs. DOCKET NO. : 05-4041 CIVIL BARBARA K LEHMAN 1434 THREE SQUARE HOLLOW NEWBURG PA 17240 and F&M Trust 3 East First Street Boiling Springs PA 17007 GARNISHEE PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against BARBARA R LEHMAN (2) against F&M Trust (3) AMOUNT DUE INTEREST from October 19, 2005 COSTS defendant(s)and garnishee (s) $5,854.97 $2,020.74 Prothonotary fee Sheriff fee (4) Less: Payments on Account TOTAL ( $.00) t- 13 . di-0 cow FF _ rr rr G, 0o ?. J r r ? ? s, 0 U rr T a,ov°. FREDERIC I. W N G, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor w r20111 JLN 27 ft;`i 0 `UIMBERLA i; u0U'4 PEN111SYLVAN1 , Unifund CCR Partners, Assignee of Citibank Case Number I 2005-4041 vs. Barbara Kay Lehman SHERIFF'S RETURN OF SERVICE attached as herein 06/22/2011 l goods, - William riCline, Deputy, ghts, debts, credits, being duly sworn accoring to and monies of the Defendant,aiin the hands, possession, or anded all goods, chatte ghts, control of the within named garnishee, F&M Bank at 3 East First Street, S. Middleton Twp., Boiling Springs, PA 17007, Cumberland County, by handing to KEVIN STONER, ASSISTANT MRG., personally 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 June 23, 2011 to Barbara K. Lehman at 1434 Three Square Hollow, Newburg, Pennsylvania, 17240. SHERIFF COST: $202.10 June 23, 2011 c) CoumySuite S'!:arPf. I eleosott.. InC. SO ANSWERS, 4RON ANDERSON, SHERIFF W iakmC 1 i rne, Deputy Sheriff N C) 2019869 .v3 0 =? zrn mF GORDON & WEINBERG, P.C. X= -ap BY: FREDERIC I. WEINBERG, ESQUIRE -<2> p, Identification No.: 41360 er =-n JOEL M. FLINK, ESQUIRE )PP « -rIdentification No.: 41200 ?q p 1001 E. Hector Street, Ste 220' N' Conshohocken, PA 19428 ?tv 484/351-0500 UNIFUND CCR PARTNERS ASSIGNEE OF COURT OF COMMON PLEAS CITIBANK UNIVERSAL CARD SVCS CUMBERLAND COUNTY VS. BARBARA K LEHMAN and F&M Trust. Garnishee DOCKET NO. : 05-4041 CIVIL PRAECIPE TO DISSOLVE ATTACSMNT TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant's bank account with F&M Trust, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. Poll BY: FREDE C I. WE NBERG, ESQUIRE JOEL M. F IN ESQUIRE Attorney Plaintiff *8. w PQ Am/ C* rsas54 &.261&5y SHERIFF'S OFFICE OF CUMBERLAND COUNTY 9 R Anderson riff ady S Smith Chief Deputy Richard W Stewart Solicitor Unifund CCR Partners, Assignee of Citibank vs. Barbara Kay Lehman Case Number 2005-4041 SHERIFF'S RETURN OF SERVICE 06/22/2011 01:04 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, F&M Bank at 3 East First Street, S. Middleton Twp., Boiling Springs, PA 17007, Cumberland County, by handing to KEVIN STONER, ASSISTANT MRG., personally 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 June 23, 2011 to Barbara K. Lehman at 1434 Three Square Hollow, Newburg, Pennsylvania, 17240. 01/18/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.60 January 18, 2012 _ FILED-OFF-iCE err 0t40 FH0N10 2012 JAN 19 AM 8: 314 CUMBERLAND CoUt4-f Y PENNSYLVANIA SO ANSWERS, RON R ANDERSON, SHERIFF 0 -e)o fd , Co. cj Gckjmy5uilc herff. Teecsoft. Inc-