HomeMy WebLinkAbout05-57282022367
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 GATEWAY (CONSUMER)
10625 Techwoods Circle
Cincinnati, OH 45242
Vs.
NOLA J RAMOS
922 GOBIN DR
CARLISLE PA 17013
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO
NOTICE
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
$2,059.92.
5. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $2,059.92 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
$2,059.92 at the rate of 5% from the date of December 27, 2001,
together with costs and attorney fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. E ,DOERG, ESQUIRE
PAUL M. SCHOFIELD, 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. WEI ERG, ESQUIRE
EXHIBIT " "
ZUZZU
AFFIDAVIT OF INDEBTEDNESS
State of Ohio )
County of Hamilton ) ss.
Kim Kenney 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 Nola J Ramos, Account Number 6011766603303991, the amount of
$2445.41 (principal balance in the amount of $2059.92 plus interest up through 09/12/2005 in the amount
of $385.49). By the terms of the agreement between the defendant and the original creditor, interest is
accruing from the aforesaid date at the rate of 5.00 percent per annum. This balance reflects any payments,
credits or offsets made since the account was charged off.
Citibank USA National Association's account was issued under the name of GATEWAY (CONSUMER).
Unifund CCR Partners purchased this account from Citibank USA National Association. 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 this September 12, 2005
UN" CCR PARTNERS
By: Kim Kenney
Media Supervisor
10625 Techwoods Circle Cincinnati, OH 45242
Address
Subscribed and sworn to before me this 12 day of September, 2005
Year
I? ? w `?1 JI,GI Mid
Notary Public
My commission Expires
Client # 829
tau u u n m?r?r
1pRIA(
KAREN WILLIAMs
NOTARY PUBLIC
STATE OF O,j,O
Co''tm. Expires
July 19, 201 0
829 • 2_G22- 3u /
Balance as of: Payment Due Minimum Payment
Account Number 09/12/2005 Date Payment Enclosed
6011766603303991 $2445.41 Past Due $2445.41
Make checks payable to:
Unifund
UNIFUND STATEMENT
Nola J Ramos
922 Gobin Dr
Carlisle PA 17013-1515
MESSAGE FROM UNIFUND
Your account is past due $2445.41. 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:
Date Transaction Balance ue Payments
Balance
09/12/2005 Citibank USA National $2445.41 $2445.41 $0 $2445.41
Association's account was issued
under the name of GATEWAY
(CONSUMER). Unifund CCR
Partners purchased this account
from Citibank USA National
Association.
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.
P ?
°Q
-44
Ulz
L/A
V
S1 ??
? C7R
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-05728 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS
VS
RAMOS NOLA J
SHAWN HARRISON Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
RAMOS NOLA J
DEFENDANT
the
, at 1451:00 HOURS, on the 8th day of November , 2005
at 922 GOBIN DRIVE
CARLISLE, PA 17013
NOLA RAMOS
by handing to
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 4.80
Affidavit .00
Surcharge 10.00
.00
32.80
Sworn and Subscribed to before
me this R,0- day of
Yl rntir w Gw vc s D.
rot ary
So Answers:
R. Thomas Kline
11/09/2005
GORDON & WE RG
By:
D uty Sheriff
W -a
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 GATEWAY (CONSUMER)
vs.
NOLA J RAMOS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-5728CIVIL
STIPULATION OF SETTLEMENT
It is HEREBY STIPULATED AND AGREED that the above-entitled action
is settled by agreement of the parties under the following terms
and conditions:
1. Defendant and Plaintiff desire to settle the above captioned
matter and stipulate that Defendant will pay to the order of
Gordon and Weinberg, P.C., attorneys for the Plaintiff, at
their offices at 21 South 21?t Street, Philadelphia,
Pennsylvania 19103, the sum of One Hundred and 00/100
($100.00) Dollars in monthly installments due on the last
day of each month starting in January 2006 and continuing
until the balance of $2,559.36 is paid.
2. Defendant appears generally herein and submits to the
jurisdiction of the Court.
I 'a
3. In the event of a default of any of the above listed
conditions and payments, Plaintiff may, upon 10 days notice
enter judgment for the relief demanded in the Complaint
filed in this matter plus judicial interest of 6% running
from the date of filing.
4. Upon full and final compliance with this stipulation, this
action shall be deemed fully settled, discontinued and/or
satisfied.
5. In accordance with the terms of this agreement there appears
to be a related consent order for judgment held in escrow
which will automatically extinguish upon compliance with the
above mentioned terms.
Gordon and Weinberg, P.C.
Paul M. Schofield, Jr., Esquire
Andrew Shaw, Esquire
?>
c?
<-,
,? -_>
?,: -,,
-!?1 fl i
1 -
W
_y
`
?
.
'ill
t
S
?„
.. _
?
(.1!
? ;Y :?<
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 81894
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
UNIFUND CCR PARTNERS ASSIGNEE OF
GATEWAY (CONSUMER)
VS.
NOLA J RAMOS
2022367
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-5728CIVIL
PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER ASSESSMENT
OF DAMAGES VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE
TO THE PROTHONOTARY:
Enter judgment for want of an answer for plaintiff and against
defendant(s) above named only and assess damages certified to be
calculable as a sum certain from the complaint, as follows:
Principal $2,059.92
Interest from 12/27/01
@50 $686.46 bOPV-
Costs
Total : $2 , '1411.58
Understanding the false statements made herein are subject to penalty
under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I
verify that:
1. The last known addresses of the parties are: UNIFUND CCR
PARTNERS ASSIGNEEOF GATEWAY (CONSUMER) and that the last known
address of defendant, NOLA J RAMOS, 922 GOBIN DR, CARLISLE PA 17013.
2. The annexed notice(s) of intention to file this praecipe was
(were) mailed to all parties, defendant and to their record attorneys,
if any, after default occurred, and at least ten days prior to the
date of filing of this praecipe.
3. The said defendant(s) is (are) not in the military service
of the United States or otherwise within the coverage of the Soldiers
and Sailors Civil Relief Act and is (are`), over 18 years of age.
AND NOW, this ?0? day of I )QV6mb,e- , 2008 Judgment
is entered in favor of the plaintiff(s) and against defendant(s) by
ell,
J`r
rol OA
.r
default for want of an answer and damages assessed at the sum of
$2,634.68 as per the above certification.
),S/ P othonotary 01*
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EI ERG, ESQUIRE
JOEL M. FLI ESQUIRE
Attorney for Plaintiff
• ! r
2022367
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
UNIFUND CCR PARTNERS ASSIGNEE OF
GATEWAY (CONSUMER)
VS.
NOLA J RAMOS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-5726CIVIL
NOTICE OF INTENTION TO TAKE DEFAULT OF THE STIPULATION FOR SETTLEbZNT
TO/PARA
NOLA J RAMOS ANDREW SHAW, ESQUIRE
922 GOBIN DR 200 SOUTH SPRING GARDEN ST, ST 11
CARLISLE PA 17013 CARISLE, PA 17013
DATE OF NOTICE/FECHA DEL AVISO: September 25, 2008
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.
1 Y
BY:
FRED I I. WEINBERG, ESQUIRE
JOEL T FLINK, ESQUIRE
P10D-2
P F Q ;Jsj?
• cr)
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
2022367
UNIFUND CCR PARTNERS ASSIGNEE OF
GATEWAY (CONSUMER)
VS.
NOLA J RAMOS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-5728CIVIL
NOTICE
Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you
are hereby notified that a judgment has been entered against you in
the above proceeding as indicated below.
/x/ Judgment by Default $2,14(P.58
Money Judgment $
Judgment on Award of Arbitrators$
Judgment on Verdict$
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL
ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS
TELEPHONE NUMBER: 484/351-0500
..t / J0. "
OTHONOTARY '0t6
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
2022367
UNIFUND CCR PARTNERS ASSIGNEE OF
GATEWAY (CONSUMER)
VS.
NOLA J RAMOS
922 GOBIN DR
CARLISLE PA 17013
and
Sovereign Bank
17 West High Street
Carlisle, PA 17013
GARNISHEE
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-5728CIVIL
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
NOLA J RAMOS
defendant(s)and
(2) against
Sovereign Bank
garnishee(s)
(3) AMOUNT DUE
INTEREST
from November 6, 2008
COSTS
Prothonotary fee
Sheriff fee
(4) Less: Payments on Account
TOTAL
$2,634.68
$161.54
0
( $200.00)
FREDERIC I. EIN RG, ESQUIRE
JOEL M. FLIN SQUIRE
Attorney for Plaintiff
(9
OF T?WTATARY
20 9 DEC -7 PM 1: 0"1
PWOLV"
1?- - T, ai
so
?Q0 b? cw?'" ;t
<5,'.' ``
t,
?; v P
? Lv
4-L'
S° ?W
CY" cr cl5q 13
e a3? ?
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N005-5728 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS ASSIGNEE OF
GATEWAY (CONSUMER) Plaintiff (s)
From NOLA J RAMOS, 922 GOBIN DR., CARLISLE, PA 17013
(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 SOVEREIGN BANK, 17 WEST HIGH STREET, 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$2434.68
L.L.$.50
Interest FROM NOVEMBER 6, 2008 - $161.54
Atty's Comm %
Atty Paid $129.30
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: DECEMBER 7, 2009
(Seal)
Deputy
REQUESTING PARTY:
Name FREDERIC 1. WEINBERG, ESQUIRE
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
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
R Thomas Kline FILED-OF iCE
Sheriff OF THE: 1;n1 r-'!?'10TARY
Ronny R AndersonQag DEC 5
Chief Deputy `
Jody S Smith UNTY
Civil Process Sergeant r ?tF? PENNISYLVAMA
Edward L Schorpp
Solicitor
Unifund CCR Partners Assignee of Gateway (Consumer)
vs. Case Number
Nola J Ramos 2005-5728
SHERIFF'S RETURN OF SERVICE
12/11/2009 03:07 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on Decembei
11, 2009 at 1505 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Nola J. Ramos, in the hands, possession, or control of the
within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania
17013, by handing to Doris Dix, Customer Service Representative, personally three copies of
interrogatories together with three true and attested copies of the writ of execution and made the contents
there of known to her.
The writ of execution and notice to defendant was mailed on December 14, 2009 to Nola J. Ramos at 922
Gobin Drive, Carlisle, PA 17013.
So Answers,
l
R. Thomas Kline, Sheriff
By
Deputy S eriff
fcj CountySuite Sheriff, Teleosufl. In_
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 41360
JOEL M. FLINK, ESQUIRE
Identification No.: 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
FiLF1
T ?TgW367
2010 JAN -4 NM 1: 28
CUC, t ?!
?rl'tii ?> :fir N
L,e? IGlB ciS
UNIFUND CCR PARTNERS ASSIGNEE OF
GATEWAY (CONSUMER)
VS.
NOLA J RAMOS
and
Sovereign Bank
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 05-5728CIVIL
Garnishee
PRAECIPE TO DISSOLVE ATTACHMENT
TO THE PROTHONOTARY:
Kindly dissolve the attachment of the defendant's bank account
with Sovereign Bank, as Garnishee in the above entitled matter.
GORDON & WEINBERG, P.C.
T? 11?
BY:
FREDERIC I. E BERG, ESQUIRE
JOEL M. FLI ESQUIRE
Attorney f Plaintiff
PO11
• - ~ ' SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson f=iLEL~-~;==;~:~`
;;' T~~ ,' ~ ~ t~r,
Sheriff ,. _ r k ; ?i' ,~:RY
~,~~„tr a~ l~turtGrr/'~
Jody S Smith ~"
Chief Deputy ~- .~~ ~,~, 2Q~O J~! -~ g~1 ~~ t
~;~ >~.
Richard W Stewart ~ '~
Solicitor c~rr~t.E ,~->~= c~~RIFF ~~'~~~• :. ~~f„tJf~';`'r"~
C'L ~~,~.~ riy,•.
Unifund CCR Partners Assignee of Gateway (Consumer) Case Number
vs.
Nola J Ramos 2005-5728
SHERIFF'S RETURN OF SERVICE
12!11/2009 03:07 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December
11, 2009 at 1505 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Nola J. Ramos, in the hands, possession, or control of the
within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania
17013, by handing to Doris Dix, Customer Service Representative, personally three copies of
interrogatories together with three true and attested copies of the writ of execution and made the contents
there of known to her.
The writ of execution and notice to defendant was mailed on December 14, 2009 to Nola J. Ramos at 922
Gobin Drive, Carlisle, PA 17013.
07/06/2010 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: $87.94 SO ANSWERS,
•C~-"
July 06, 2010 RON R ANDERSON, SHERIFF
By _
aron R, Lantz
. sz~ ~ p~.
~j~t ~~ 9 D1
~ ~~ 7S~
(c Count, Suite Sheriff, Telensnft. hoc
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-5728 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS ASSIGNEE OF
GATEWAY (CONSUMER) Plaintiff (s)
From NOLA J RAMOS, 922 GOBIN DRIVE, CARLISLE, PA 17013
( l ) 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:
WELLS FARGO BANK, 604 EAST HIGH STREET, CARLISLE, PA 17013
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 $2,634.68
Interest from November 6, 2008 - - $418.67
Atty's Comm %
Atty Paid $247.24
L. L.
Due Prothy $2.00
Other Costs
Plaintitf Paid
Date: 7/5;11
(Seal)
REQUESTING PARTY
Name FREDERIC 1. WEINBERG, ESQ.
Address: GORDON & WEINBERG, P.C.
1001 E. HECTOR STREET, SUITE 200
CONSHOHOCKEN, PA 19428
Attorney for: PLAINTIFF
David D. Buell, Prothonotary
By:ti
Deputy
Telephone: 484-351-0500
Supreme Court ID No. 41360
G(RDON & WEINBERG, P.C.
B`: FREDERIC I. WEINBERG, ESQUIRE
2022367
Identification No.: 41360
OEL M. FLINK, ESQUIRE C-
identification No.: 41200
(01 E. Hector Street, Ste 220 M pq
Cc..nsho?ocken, PA 19428
Z- 4/35L-0500
y
j
UNIFUND CCR PARTNERS ASSIGNEE OF
COURT OF COMMON PLEAS C-3 q
'!
GrTEWAY (CONSUMER) CUMBERLAND COUNTY o ca
17
vs. DOCKET NO. : 05-5728CI.VIL
NOLA J RAM?OS
c)22 GOBIN DR
CARLISLE PA 17013
and
WELLS FARGO BANK
604 E HIGH. STREET
CARLISLE, PA 17013
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
NOLA J RAMS
defendant(s)and
(2)
against
WELLS FARGO BANK
garnishee(s)
(3) AMOUNT DUE $2,634.68
INTEREST
from November 6, 2008 $418.67
COSTS
Prothonotary fee
Sheriff fee
(4) Less: Post-Judgment Payments on Account( $0.00)
TOTAL
(? k ay sc? PA al"I
3 a 20 Nr-
1`l.°Iq
5 S • ?5a
? ? Sb
?. ob
FREDERIC I,. W INBERG, ESQUIRE
JOEL M. FLi?IX, ESQUIRE
Attorney for Plaintiff
Ck- 1sogcoq
Qul?6S W??t J ?x`(sNAeCA
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
.' u" 01 LUMbprf
.:
FILED-OFFICE „
OF THE PROTHONOTAFR ;
2011 JUL 12 PM 1= 34
CuPENNSYLVANI AST'
Unifund CCR Partners Assignee of Gateway (Consumer)
vs.
Nola J Ramos
Case Number
2005-5728
SHERIFF'S RETURN OF SERVICE
07/08/2011 03:17 PM - Shawn Gutshall, 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, Wells Fargo Bank at 604 East High Street, Carlisle
Borough, Carlisle, PA 17013, Cumberland County, by handing to PAUL FENTON - SERVICE MANAGER,
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 July 11, 2011 to Nola J. Ramos at 922 Gobin
Drive, Carlisle, PA 17013.
SO ANSWERS,
July 11, 2011 RON R ANDERSON, SHERIFF
a utsha 1, Deputy
tc? Cour.?ySuite Shen?f, Tei4CSOit. Inr.
UNIFUND CCR PARTNERS ASSIGNEE OF
GATEWAY (CONSUMER)
vs.
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
NOLA J. RAMOS
and
NO. 05-5728
WACHOVIA BANK, A DIVISION OF
WELLS FARGO BANK N.A. GARNISHEE ATTORNEY I.D.#
ORDER TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
C=
C' 1 ?., t" -topes
cn? ! )
v o0 c
-C ?
vn zs o ?-
.?C)
- - Orr,,
-
c -i
Kindly mark the attachment against the Garnishee, Wachovia Bank, a Division of Wells Fargo
Bank, N.A., Garnishee, discontinued, upon payment of your costs only.
FREDERIC I. ERG
Attorney for lainti
Ckwyls48
V. 216 Aqas
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
o?ci4 Qt CIJ111b,",
v
OF F ,F -'--RIFF
mr
? JAIL 19 AM 8 34
t,UMBERLAND 00UNTY
PENNSYLVANIA
Unifund CCR Partners Assignee of Gateway (Consumer)
vs.
Nola J Ramos
Case Number
2005-5728
SHERIFF'S RETURN OF SERVICE
07/0812011 03:17 PM - Shawn Gutshall, 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, Wells Fargo Bank at 604 East High Street, Carlisle
Borough, Carlisle, PA 17013, Cumberland County, by handing to PAUL FENTON - SERVICE MANAGER,
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 July 11, 2011 to Nola J. Ramos at 922 Gobin
Drive, Carlisle, PA 17013.
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 SO ANSWERS,
January 18, 2012 RON R ANDERSON, SHERIFF
arn?I, &-
&-'* ?=s-dam
y/ D
(_('C")" ysuite s?e':ff 7ele^sc°t. In :.
2022367
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No. : 41360 nTh('. N 0TA;;
JOEL M. FLINK, ESQUIRE
Identification No. : 412000I PM 14:
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428 11:1-M RL} ND COUNTY
484/351-0500 PENNSYLVANIA
_UNIFUND CCR PARTNERS ASSIGNEE OF COURT OF COMMON PLEAS
OIGATEWAY (CONSUMER) CUMBERLAND COUNTY
vs.
_NOLA J RAMOS DOCKET NO. : 05-5728CIVIL
X922 GOBIN DR
CARLISLE PA 17013
and
Orrstown Bank
=2250 Spring Road
gggCarlisle, PA 17013
GARNISHEE
PRAECIPE FOR WRIT OF EXECUTION
EEE
PTO THE PROTHONOTARY:
Issue writ of execution in the above matter,
directed to the Sheriff of Cumberland County;
(1) against
NOLA J RAMOS
defendant (s) and
(2) against
Orrstown Bank
garnishee (s)
EEE
(3) Amount Due $2, 634 . 68
Interest from November 6, 2008 $842 .52
Costs
Prothonotary fee
Sheriff fee
(4) Less: Payments on Account $ . 00
TOTAL
22d4d_
t1/2.400
Vi
SS S " +' r)/41 G.
'aH SO
nn� Spy` �` FREDERIC I. WEINBERG, SQUIRE
d N '00 �j 1L il(O9, JOEL M. FLINK, ESQUIRE
F. TT Attorney for Plaintiff
Y1F-11-i—Vr i2J:E"C29 g PO 63( 7t: (Y6, x MS4
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 05-5728 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS ASSIGNEE OF
GATEWAY(CONSUMER)Plaintiff(s)
From NOLA J. RAMOS,922 GOBIN DRIVE,CARLISLE,PA 17013
(1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed
to attach the property of the defendant(s)not levied upon in the possession
of GARNISHEE(S)as follows:
ORRSTOWN BANK,2250 SPRING ROAD,CARLISLE,PA 17013
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;
(2) 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$2,634.68 Plaintiff Paid$
Interest FROM NOVEMBER 6,2008-$842.52
Attorney's Comm. % Law Library$.50
Attorney Paid$3741.gy Due Prothonotary$2.25
Other Costs$
Date: 11/18/13
• � —
David D. Buell, Prothonotary
Deputy
REQUESTING PARTY:
Name : FREDERIC I.WEINBERG, ESQUIRE
GORDON& WEINBERG,P.C.
Address: 1001 E. HECTOR STREET,SUITE 220
CONSHOHOCKEN,PA 19428
Attorney for: PLAINTIFF
Telephone: 484-351-0500
Supreme Court ID No. 41360
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson y
�
Sheriff r r
,tiar cii c�Itarl!i.,1 ".�^r3S -,
Jody S Smith r ' ('7 tF 1 r
Chief Deputy &pk ,-,C c '
Richard W Stewart ›:c, ,c,
Solicitor - -4 r _R1Fa Z ' .,-
*- _
s
vs.
Nola J Ramos
Unifund CCR Partners Assignee of Gateway(Consumer)
Case Number ::::::
2005-5728
SHERIFF'S RETURN OF SERVICE
11/27/2013 09:12 AM - Brian Grzyboski, 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, Orrstown Bank, 22 South Hanover Street, Carlisle
Borough, Carlisle, PA 17013, Cumberland County, by handing to Kristin Ramsay- Branch Executive
Officer, personally three copies of interrogatories together with three true and attested copies of the Writ
of Execution and made the contents there of known to her.
The writ of execution and notice to defendant was mailed on December 2, 2013 to Nola J. Ramos at 922
Gobin Drive, Carlisle, PA 17013.
4 :7
N GRZY' , D-":r TY
SO ANSWERS,
December 02, 2013 RONR ANDERSON, SHERIFF
.Wily. e, csC;t.Inc_
OF
2022367 IHONOTA ,„
26/3OEc I6 P .
GORDON & WEINBERG, P.C. CUMBER, 3. 34
BY: FREDERIC I . WEINBERG, ESQUIRE ANo n,
Identification No. : 41360 PENNS Y 4, TY
JOEL M. FLINK, ESQUIRE
Identification No. : 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
UNIFUND CCR PARTNERS ASSIGNEE COURT OF COMMON PLEAS
MERVIM OF GATEWAY (CONSUMER) CUMBERLAND COUNTY
vs . DOCKET NO. : 05-5728CIVIL
NOLA J RAMOS
=. and
Orrstown Bank
Garnishee
PRAECIPE TO DISSOLVE ATTACHMENT
TO THE PROTHONOTARY:
Kindly dissolve the attachment of the defendant' s bank
account with Orrstown Bank, as Garnishee in the above entitled
matter.
GORDON & WEINBERG, P.C.
•
=ME' BY:
FREDERIC EINBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
P011
cies. Cl 0102 a
UNIFUND CCR PARTNERS : IN THE COURT OF COMMON PLEAS OF
ASSIGNEE OF GATEWAY : CUMBERLAND COUNTY, PENNSYLVANIA
(CONSUMER)
V. •
•
NOLA J. RAMOS •
AND •
ORRSTOWN BANK, : NO. 2005 — 5728 CIVIL TERM
Garnishee
•
•
ORDER OF COURT
AND NOW, this 7TH day of JANUARY, 2014, the Defendant's Claim for
Exemption from the garnishment of the property held by Orrstown Bank is GRANTED.
The statutory amount of$300.00 and monthly social security deposits of$842.00 are
exempted from garnishment.
B, e Co ,
/ Edward E. Guido, J.
✓ Frederic I. Weinberg, Esquire
1001 E. Hector Street, Suite 220
Conshohocken, Pa. 19428
��Nola J. Ramos
922 Gobin Drive
Carlisle, Pa. 17013
. .,--fYrrstown Bank
2250 Spring Road
f
Carlisle, Pa. 17013
Sheriff — '
ald
1..sz
//4M
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
(SFFIC: QF THE $H.RIFK
THE PRO1
2111 1-1 JUL -3 MID 3�)
CUMBERLAND CNN Y
PENNSYLVANIA
Unifund CCR Partners Assignee of Gateway (Consumer)
vs.
Nola J Ramos
Case Number
2005-5728
SHERIFF'S RETURN OF SERVICE
11/27/2013 09:12 AM - Brian Grzyboski, 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, Orrstown Bank, 22 South Hanover Street, Carlisle
Borough, Carlisle, PA 17013, Cumberland County, by handing to Kristin Ramsay - Branch Executive
Officer , personally three copies of interrogatories together with three true and attested copies of the Writ
of Execution and made the contents there of known to her.
The writ of execution and notice to defendant was mailed on December 2, 2013 to Nola J. Ramos at 922
Gobin Drive, Carlisle, PA 17013.
01/03/2014 Claim for exemption filed this date by defendant Nola J. Ramos. Taken to Court Administration for
assignment and scheduling.
01/07/2014 ORDER OF COURT
And now, this 7th day of January, 2014, the Defendant's Claim for Exemption from the garnishment of the
property held by Orrstown Bank is GRANTED. The statutory amount of $ 300.00 and monthly social
security deposits of $ 842.00 are exempted from garnishment.
By the Court,
Edward E. Guido, Judge
07/02/2014 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: $89.26 SO ANSWERS,
July 02, 2014 RON R ANDERSON, SHERIFF
s , 5-6 /°'I' GG
cki 9763/
307g9(
{c) CountySuite Sheriff, Teleoseft,