HomeMy WebLinkAbout05-5064BELCO COMMUNITY CREDIT UNION
VS.
SHANNON L. R
SHANNAN L. S
Plaintiff
OGERS .
TALNAKER _
Defendants
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
CIVIL ACTION-LAW
NO: nS -.5?? ?lCJc??
N 0 T I C E
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 judgment 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, 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.
Legal Services, Inc.
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
N 0 T I C I A
Le han demandado a usted en la corte. Si usted quiere
defenderse de estas demandas expuestas en las paginas siguientes,
usted tiene viente (20) dias de plazo al partir
de la fecha de la demanda y la notificacion. Usted debe
presentar una apariencia escrita o en persona o por abogado y
archivar en la corte en forma escrita sus defensas o sus
objeciones a las demandas en contra de su persona. Sea
avisado que si usted no se defiende, la corte tomara medidas y
puede entrar una orden contra usted sin previo aviso o
notificacion y por cualquier queja o alivio que es pedido en la
peticion de demanda. Usted puede perder dinero o sus propiedades
o otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Legal Services, Inc.
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
BELCO COMMUNITY CREDIT UNION COURT OF COMMON PLEAS
. CUMBERLAND COUNTY, PENNSYLVANIA
SHANNON L. ROGE
SHANNAN L. STAL
Plaintiff
NO. Ci
RS
NAKER
CIVIL ACTION - LAW
Defendants
COMPLAINT
Ci L?? Wl
1. Plaintiff is Belco Federal Credit Union, hereinafter referred
to as "BELCO", a Pennsylvania Corporation with an office at
403 N. 2nd Street, Harrisburg, Dauphin County, Pennsylvania
17108.
2. Shannon L. Rogers, a Defendant, is an adult individual with
an address at 235 Constitutional Court, Mechanicsburg,
Cumberland County, Pennsylvania 17050.
3. Shannan L. Stalnaker, a Defendant, is an adult individual
with an address at 235 Constitutional Court, Mechanicsburg,
Cumberland County, Pennsylvania 17050.
4. Defendants applied for a Ll Signature loan from Plaintiff
pursuant to the Application dated June 2003 which is
available but not attached because it contains social
security numbers and other personal information.
5. Defendants' delinquent balance on the account is $7,111.55.
6. Because of Defendants' failure to make monthly payments and
in accordance with the standard Security Agreement, a copy
which is attached hereto, marked Exhibit "A" and made part
hereof, Defendants owe an attorney commission of $1066.73 for
a total of $8,178.28.
7. Defendants have failed and refused to bring their account
current.
8. Defendants are not members of the Armed Forces of the United
States of America, nor engaged in any way which would bring
them within the Soldiers and Sailors Relief Act of 1940, as
amended.
WHEREFORE, Plaintiff requests entry of judgment against Defendants
in the amount of $8,178.28 together with costs of suit thereon.
Respectfully, Submitted,
Date:
Arthur M. Feld, Esquire
Attorney I.D. No. 07172
1309 Bridge Street
New Cumberland, PA 17070
(717)770-0292
SECURITY AGREEMENT
m
In this agreemerlt all references to "credit union" mean the credit union whose
name appears on this agreement and anyone to whom the credit union assigns
the LOANLINER? Credit Agreement. All references to "the advance'' mean the
amount in the box labeled "New Balance". All references to "you" mean each
person who signs this agreement.
THE SECURITY FOR THE LOAN - By signing this security agreement in the
sionature area or under the statement referring to this agreement which is on.
the back of the check you receive for the advance, you give the credit union
what is known as a security _'interest in the property described in the `Security
Offered' section. -the security interest you give includes all accessions.
Accessions are things which are attached to or installed in the property now
or in the.future. The security interest also includes any replacements for the
property which you buy within 10 days of the advance or any extensions. renewals
or refinancing of the advance. It also includes any money you receive from
selling the property er from insurance you have on the property. if the value
of the property declines, you promise to give the credit urlien more property
and to deliver the pc icy or proof of coverage to t;e cr,d : unman f asked to do
If you cancel your insurance and get a refund, the credit union has a rigf
he refund. If the property is lost or damaged the credit union can use
insurance settlement to repair the property or apply it towards what you c
;'cu authorize the credit union to indorse any draft or check which may be pay
tic you in order for the credit union to collect any refund or benefits due ur
your insurance policy.
if you do not pay the taxes or fees on the property when due or keep it insu
the credit union may pay trese obligations, but is not required to do so.
money the credit union spends for taxes, fees or insurance will be adder
the unpaid balance of the advance and you will pay interest on those amot
at the same rate you agreed to pay on the advance. If the credit union a
amounts for taxes, fees, or insurance to the unpaid balance of your advai
your payments may be increased by the amount necessary for the adva
to be paid oft in the same number of months originally scheduled.
as security if asked to do so.
DEFAULT - "ou viii be in default if you break any, promise you make ur
this agreement. You will also be in default if you, are in default under
LOANLINER ' credit Agreement. If you are pledging property, but have not sic
,L 1
LOANLINER1Credit Agreement, you will be in default If anyone is in def
who has signed the LOANLINl Credit Agreement.
WHAT HAPPENS IF YOU ARE IN DEFAULT - When you are in default,
credit union can, without advance notice to you, require immediate payn
of wtwt.you owe under the LOANLINERIf, Credit Agreement and take posses'.
of the` property. You agree the credit union has the right to take posses'
of the property without going to court and without giving you advance not
If you are asked to do so !:y the credit union, you promise to deliver the prop
at a time and place the credit union chooses. The credit union will not
responsible for any of your other" property, not covered by this agreement,
you leave inside the property. The credit union wili try to return that prop
to you or make it available for you to claim.
After the credit union has possession of the property, it can sett it and al
the money received to any amounts you owe the credit union. The credit of
,,dill give you notice of any public sale or the date after which a private
will be held The expenses of the credit union for taking possession of and se
the property will be deducted from the money received from the sale. TP
costs may include the cost of storing the property, preparing it for sale
attorney's fees to the extent permitted under state law or awarded under §50
of the Bankruptcy Code. The rest of the sale money will be applied to V
you owe under the LOANLiNER? Credit Agreement.
If you have agreed to pay the advance, you will also have to pay any amt
t:`-iai remains unpaid after the sale money has been applied to the unpaid bala
of the advance and to what you owe,under this agreement. You agree to
interest on that amount at the same rate as the advance until that amount
been paid.
DELAY IN, ENFORCING RIGHTS AND CHANGES IIN THE AGREEMENT -
credit union can delay enforcing any of its rights under this agreement any nun
PROPERTY INSURANCE, TAXES AND FEES - You I rr lrlisc to pay, all #axes _ of times without losing the ability to exercise its rights later. The credit or
and fees (like registration fees) due on the property and to keep the'pfdoerty can enforce this agreement against your heirs or legal representatives. If
insured agains
loss and damage. The amount and coverage of the property cied,t union changes the terms of the LOANLINER° Credit Agreement, you al
t
,
insurance must be acceptable to the credit union. You may provide the property that -tis-agreament will continue to protect the credit union
insurance through a policy you already have, or through a policy you get anrf CONTINUED EFFECTIVENESS - If any part of this agreement isdetermi
pay for. You promise to make the insurance policy payable to the credit union by a court to be unenforceable; the rest will remain in effect.
FOR TENNESSEE CREDIT UNIONS ONLY - FOR NORTH DAKOTA CREDIT UNIONS ONLY - APPLI
USE WHEN AUTOMOBILE IS PURCHASED ONLY WHEN A MOTOR VEHICLE IS PURCHASED
NOTICE: If you do not purchase the insurance iequirec on the automobile PJOTICE: THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE S
and the credit union purchases the insurance. the insurance-puxcha'sed 1- TO REPOSSESSION I,E lT IS REPOSSESSED AND SOLD TO SOME(
by the credit union will cover only the credit umo^'s interest in the property. ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE f
The insurance will not be liability insurance. RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE`DIFFEREN
You have read the above statement and acknowledge that the credit union
has explained it to you.
-
SIGNATURE
DA'E THE PROPERTY DESCRIPTION
-----_.DA IS PART OF THIS AGREEMENT.
SIGNATURE
TF
X .
NOTICE: SIGN THIS AGREEMENT ON THE REVERSE SIDE
DO NOT WRITE BELOW - FOR CREDIT UNION USE ONLY CHECK APPLICABLE BOX(ES) -
APPROVED $ $ w w
--- LIMITS
DATE SIGNATURE - LINE OF CREDIT
OTHER - OTHER - DEBT RATIO
?LOAN OFFICER. ADVANCE APPROVED: _''YES '. INO '.- .COUNTER OFFER WILL BE MADE, IF ACCEPTED, ADVANCE APPROVED
?CREDIT COMMITTEE OR OTHER OUTSIDE INFORMATION CONSIDERED:- - -YES I_'NO IF YES. ATTACH ADDITIONAL SHEET A.ND-DESCRIBE
-
WHAT THE SECURITY INTEREST COVERS -The security interest secures the
advance and any eraensions, renewals or refinancings of the advance. It aisi'
secures any other advances you have now or receive in the future under the
LOANLINO Credit Agreement and any other amounts you owe the credit union
for any reason now or in the future. If the property description is marked with
tovo stars or the property is household goods as defined by the Credit
Practice Rule, the property will secure only the advance and not other amounts
you owe. -
OWNERSHIP OF THE PROPERTY - You promise that you oven the property.
or if this advance is to buy the property, you promise you will use the advance
for that purpose. You promise that no one else has any interest in or claim
against the property that you have not already told the credit union about. You
promise not to sell or lease the property or to use it as security for a loan with
another creditor until the advance is repaid. You promise you will allow no security
interest or lien to attach to the property either by your actions or by operation
of law.
PROTECTING THE SECURITY INTEREST - If your state issues a title for the
property, you promise to have the credit union's security interest shown on
the title. The credit union may have to file what is called a financing statement
to protect its security interest from the claims of others It asked tc do so,
you promise to sign a financing statement. You also promise tit do whatever
else the credit union thinks is necessary to protect its security interest in the
property.
USE OF PROPERTY - Until the advance has been paid oft you promise you
will: (t) Use the property carefully and Keep it in good rc;.mir. (2) Obtain written
permission from the credit union before making major changes to the prdperty.
(3) Inform the credit union in writing before changing your audress or the address
where the property is kept. (4) Allow the credit union to inspect the'p[Qpprty.
(5) Promptly notify the credit union it the property is dar aged, stulen or alt u6eij.-
(6) Not use the property for any unlawful purpose.
REFERRED TO/REASON(S) FOR REFERRAL:"
DESCRIBE COUNTER OFFER:
SPECIFIC REASON(S) FOR REJECTION:
SIGNATURES: -
`
?
-Ci,N (
, 71CER _..-------
' CREDIT COMMITTEE._ X - _-"--. _---- -
E:COA NOTICE AND R -.,SCN ?CF ., SE?-.- ,.
-f`I IFIO r,AiITiIPI itucl r ? ?, ?+P--^ >ri n4 - ,..
DATE DATE
X
ATE
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VERIFICATION
Helen Lorwey states subject to the
penalties of 18 Pa C.S.Section 4904 relating to unsworn
falsification to authorities, that he/she is the
Loss Prevention Specialist for the Plaintiff in
this matter, that he/she is authorized to make this
affidavit on its behalf and that the facts set forth in the
foregoing pleading is true and correct to the best of
his/her knowledge, information and belief.
A"
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-05064 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BELCO COMMUNITY CREDIT UNION
VS
ROGERS SHANNON L ET AL
WILLIAM CL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
ROGERS SHANNON L the
DEFENDANT
at 1507:00 HOURS, on the loth day of October 2005
at 235 CONSTITUTIONAL COURT
MECHANICSBURG, PA 17050 by handing to
SHANNON ROGERS
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 9.60
Postage .37
Surcharge 10.00
.00
37.97
Sworn and Subscribed to before
me this y ? day of
7 ?GVCa -?) OvD ) A. D.
Pro on tart'
So Answers:
R. Thomas Kline
10/11/2005
ARTHUR FELD
By:
?DepSheriff
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-05064 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BELCO COMMUNITY CREDIT UNION
VS
ROGERS SHANNON L ET AL
WILLIAM CLINE
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
STALNAKER SHANNAN L the
DEFENDANT , at 1507:00 HOURS, on the 10th day of October 2005
at 235 CONSTITUTIONAL COURT
MECHANICSBURG, PA 17050 by handing to
SHANNON ROGERS, WIFE
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: So Answers:
Docketing 6.00 /-
Service .00 ?:r,• '° i??P
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
16.00 10/11/2005
ARTHUR FELD
Sworn and Subscribed to before By: / -
me this '-/`- day of eputy Sheriff
A. D.
Prod ary
f ..4
BELCO COMMUNITY CREDIT UNION
Plaintiff
vs.
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
NO. 2005-05069
SHANNON L. ROGERS
SHANNAN L. STALNAKER
Defendants
CIVIL ACTION - LAW
Would you please enter judgment in favor of Plaintiff and against
Defendants, Shannon L. Rogers & Shannan L. Stalnaker, 235
Constitutional Court, Mechanicsburg, PA 17050 for failure to plead
to the Complaint within twenty days of service thereof. I hereby
certify that the Default Notice required by Rules of Court was
sent to the Defendants as shown on the copy attached hereto.
Assess damages as follows:
$8178.28, together with interest thereon from date of judgment
together with costs of suit thereon.
i
IA-
Arthur M. Feld, Esq.
November 16, 2005
BELCO COMMUNITY CREDIT UNION
Plaintiff
SHANNON L. ROGERS
SHANNAN L. STALNAKER
Defendants
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO.: 2005-05064
CIVIL ACTION - LAW
IMPORTANT NOTICE
To: SHANNON L. ROGERS
DATE OF NOTICE: November 1, 2005
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY 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.
Legal Services, Inc.
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
Arthur M. Feld, Esquire
1309 Bridge Street
New Cumberland, PA 17070
(717) 770-0292
I.D. No. #07172
BELCO COMMUNITY CREDIT UNION
Plaintiff
SHANNON L. ROGERS
SHANNAN L. STALNAKER
Defendants
. COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO.: 2005-05064
CIVIL ACTION - LAW
IMPORTANT NOTICE
To: SHANNAN L. STALNAKER
DATE OF NOTICE: November 1, 2005
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY 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.
Legal Services, Inc.
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
Arthur M. Feld, Esquire
1309 Bridge Street
New Cumberland, PA 17070
j717) 770-0292
I.D. No. #07172
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BELCO COMMUNITY CREDIT UNION
Plaintiff
VS
SHANNON L. ROGERS
SHANNAN L. STALNAKER
Defendant/s
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
. No.2005-05069
To SHANNON L. ROGERS & SHANNAN L. STALNAKER
You are hereby notified that on NOVEMBER , 2005, the following
judgment has been entered against you in the above captioned case.
JUDGMENT IN THE AMOUNT OF $8178.28
PLUS INTEREST FROM DATE OF JUDGMENT PLUS COSTS
OF SUIT THEREON
DATE: NOVEMBER 2005
Prothonotary
I hereby certify that the name and address of the proper person/s to
receive this notice under Pa. R. Civ. P. 236 is/are:
SHANNON L. ROGERS
SHANNAN L. STALNAKER
235 CONSTITUTIONAL COURT
MECHANICSBURG, PA 17050
. y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
BELCO COMMUNITY CREDIT UNION
(X) Other DISTRICT JUSTICE
Vs.
SHANNON L. ROGERS
SHANNAN L. STALNAKER
235 CONSTITUTIONAL COURT
MECHANICSBURG, PA 17050
Defendants
( ) Confessed Judgment
File No. 2005-05064
Amount Due $8048.02
Interest FROM 12/27/05
Atty's Comm
. Costs Total
SOVEREIGN BANK
12 NOBLE BLVD.
CARLISLE, PA 17013
Garnishee
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not
arise out of a retail installment sale, contract, or account based
on a confession of judgment, but if it does, it is based on the
appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as
amended.
Issue Writ of Execution in the above matter to the Sheriff of
CUMBERLAND County, for debt, interest and costs upon the
following described property of the defendant(s) LEVY ON
DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of CUMBERLAND
County, for debt, interest and costs, as above, directing
attachment against the above-named garnishee(s) for the following
property (if real estate, supply six copies of the description;
supply four copies of lengthy personalty list)
and all other property of the
defendant(s) in the possession, custody or control of the said
garnishee(s).
(Indicate) Index this writ against
DATE:
Signature: -(<?f" V?/l L'
Arthur M. Feld, Esquire
1309 Bridge Street
New Cumberland, PA 17070
Attorney for Plaintiff
(717) 770-0292
ID No.. #07172
Cjl
cq 'IS
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WRIT OF EXECUTION and/or ATTACHMENT
l
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BELCO COMMUNITY CREDIT UNION, Plaintiff (s)
From SHANNON L. ROGERS AND SIIANNAN L. STALNAKER, 235 CONSTITUTIONAL
COURT, MECHANICSBURG, PA 17050
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON
DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of SOVEREIGN BANK, 12 NOBLE BLVD. CARLISLE, PA 17013
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(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 $8,048.02
Interest FROM 12/27/05
Atty's Comm %
Arty Paid $136.47
Plaintiff Paid
Date: DECEMBER 29, 2005
L.L. $.50
Due Prothy $1.00
Other Costs
Prothonotary-
(Seal)
NO 05-5064 Civil
CIVIL ACTION - LAW
By:
:Deputy
REQUESTING PARTY:
Name ARTHUR M. FELD, ESQUIRE
Address: 1309 BRIDGE STREET
NEW CUMBERLAND, PA 17070
Attorney for: PLAINTIFF
Telephone: 717-770-0292
Supreme Court ID No. 07172
BELCO COMMUNITY CREDIT UNION
Plaintiff
VS.
SHANNON L. ROGERS
SHANNAN L. STALNAKER
Defendant/s
SOVEREIGN BANK
Garnishee
} IN THE COURT OF COMMON PLEAS
} CUMBERLAND COUNTY
}
}
}
}#05-05064
}
}
}
}
}
}
Would you please dissolve the attachment against Sovereign Bank
Garnishee, in the above captioned matter.
To
Prothonotary
January 12, 2006
()- V k ? 4, `
Attorney for Plaintiff
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2005-05064 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BELCO COMMUNITY CREDIT UNION
VS
ROGERS SHANNON L ET AL
And now SHANNON SHERTZER Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:25 Hours, on the 11th day of January , 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
ROGERS SHANNON L in the
hands, possession, or control of the within named Garnishee
SOVEREIGN BANK 269 PENROSE PLACE
(NOTE: 12 NOBLE BLVD IS AN ATM MACHINE)
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JOSHUA GEBERS (BANKING REP) ,
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 His
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
.00
01/13
Sworn and subscribed to before me
this day o z
A.D. ,
So an s ?n??? t
R. Thomas Kline
Sheriff of Cumberland County
/2006
By
Deputy Sher ff
Pr'othon
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2005-05064 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BELCO COMMUNITY CREDIT UNION
VS
ROGERS SHANNON L ET AL
And now SHANNON SHERTZER Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:25 Hours, on the 11th day of January , 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
STALNAKER SHANNAN L , in the
hands, possession, or control of the within named Garnishee
SOVEREIGN BANK 269 PENROSE PLACE
CARLISLE. PA 1701
Cumberland County, Pennsylvania, by handing to
JOSHUA GEBERS (BANKING REP)
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 His
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
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Sworn and subscribed to before me
this /S day of
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R. Thomas Kline
Sheriff of Cumberland County
By A/Z-t
Deputy Sher-if
Python
01/13/2006
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CS
& Thomas Kline, Sheriff, who being duly sworn according to law, states this
gjt? is returned ABANDONED, no action taken in six months.
Sheriff's Costs: Advance Costs: 150.00
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
TOTAL
Sheriff's Costs 123.24
18.00 26.76
2.42
.50
1.00 Refunded to Atty on 10/04/06
12.32
40.00
40.00
9.00
123.24 ? iu?i4?ou..
So Answer
R. Thomas Kline, Sheriff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-5064 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BELCO COMMUNITY CREDIT UNION, Plaintiff (s)
From SHANNON L. ROGERS AND SHANNAN L. STALNAKEft, 235 CONSTITUTIONAL
COURT, MECHANICSBURG, PA 17050
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON
DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of SOVEREIGN BANK, 12 NOBLE BLVD. CARLISLE, PA 17013
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 $8,048.02
Interest FROM 12/27/05
Atty's Comm %
Atty Paid $136.47
Plaintiff Paid
Date: DECEMBER 29, 2005
L.L. $.50
Due Prothy $1.00
Other Costs
Prothonotary(Seal)
By:
Deputy
REQUESTING PARTY:
Name ARTHUR M. FELD, ESQUIRE
Address: 1309 BRIDGE STREET
NEW CUMBERLAND, PA 17070
Attorney for: PLAINTIFF
Telephone: 717-770-0292
Supreme Court ID No. 07172
M
BELCO COMMUNITY CREDIT UNION
Plaintiff
VS
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PA
No.05-05064
SHANNON L. ROGERS
SHANNAN L. STALNAKER
Defendants CIVIL ACTION - LAW
PRAECIPE TO SATISFY THE JUDGMENT
Would you please satisfy the judgment against Defendants in the
above captioned matter.
Thank you.
To
Prothonotary
June 1, 2009
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Attorney for Plaintiff
Arthur M. Feld
ID #07172
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