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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,