HomeMy WebLinkAbout05-5789BURTON NEIL & ASSOCIATES, P.C.
By: Burton Neil, Esquire
Identification No. 11348
1060 Andrew Drive, Suite 170
West Chester, PA 19380
(610) 696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA) N.A.
701 East 60th Street North, Sioux Falls, SD
Plaintiff
V.
KELLY L MCMEANS
625 Boslee Avenue, Lemoyne PA 17043-1817
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ?S - 57 9 clot rEe lr
CIVIL ACTION - LAW
COMPLAINT
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 (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 claim 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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.
LAWYER REFERENCE AND
INFORMATION SERVICE
Cumberland County Bar Assoc.
32 South Bedford Street
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
C-8047
BURTON NEIL & ASSOCIATES, P.C.
By:Burton Neil, Esquire
Identification No. 11348
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK (SOUTH DAKOTA) N.A.
701 East 60th Street North, Sioux Falls, SD
Plaintiff
V.
KELLY L MCMEANS
625 Boslee Avenue, Lemoyne PA 17043-1817
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. C)S - S "IP? ( l cx l???1L>?
CIVIL ACTION - LAW
Complaint
1. The plaintiff is CITIBANK (SOUTH DAKOTA) N.A., with place of business located at 701
East 60th Street North, Sioux Falls, South Dakota.
2. The defendant is Kelly L McMeans, who resides at 625 Boslee Avenue, Lemoyne,
Cumberland County, Pennsylvania.
3. Plaintiff, a national banking association, engages in various types of banking business
including consumer lending through the issuance of credit cards.
4. Plaintiff furnished consumer credit to the defendant by means of a credit card with account
number 4621206010704009 hereinafter referred to as the credit card account.
5. Plaintiff maintained an accurate and running record of all debits and credits to the credit card
account in its books of account.
6. Plaintiff mailed defendant a written statement each month which accurately stated the debits
and credits to the credit card account for the prior billing period.
7. Defendant received the monthly statements from plaintiff for the credit card account including
the statement attached hereto as Exhibit A statement without protest, dispute or objection.
8. Defendant in not protesting, disputing or objecting to the statements including the Exhibit A
statement thereby assented and agreed to the correctness of the balance due on the credit card account so
as to constitute an account stated.
9. The amount due plaintiff on the account stated, less credits, if any issued subsequent to the
Exhibit A statement, is $3,716.43.
Wherefore, plaintiff demands judgment against defendant for the sum of $3,716.43, and the costs
of this action.
BURTON N IL & ASSOCIATES, P.C.
Y?
Burton Neil, Es ire
Attorney for Plai iff
The law firm of Burton Neil & Associates, P.C. is a debt collector.
I
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09/16/05 $3766.43 $3766.43 SITE:KC-CL TM:CO-5000 ACID:KCB7150
[:en3<6u€aaE? sn(=akGnpe><'=s E-e?ivS!;a#z>-'sp> 09/28/05 2 2: 5 3: 0 0
CITI CARDS
PO BOX 183065
KELLY L MCMEANS COLUMBUS, OH
625 BOSLEE AVE 43218-3065
LEMOYNE PA
17043-1817000
Citi" Platinum Select` Card
Account Number
4621 2060 1070 4009
Customer Service:
1-800-382-3334 Total Credit Line Available Credit Line Cash Advance Limit
$3110 $0 $2410
PO BOX 142319
IRVING, TX statement/
Closing Data Amount Over
Credit Line
Past Due
75014-2319 08123/2005 $656.43 + $572.65
8/01 15494063
8/23
8/23
8/23
Available Cash Limit
$0
142
ray ments, Credits & Adjustments
PAYMENT THANK YOU
70 0000 0 0
Standard Porch
667E 0FEE - 000 JUL PAYMENT PAST DUE
PPURCH0000"FINANCE CHARGED*PERIODIC RATE
84
Standard Adv
ADVANCES*FINANCE CHARGEaPERIODIC RATE
84 0000 0
Your late fee was based on your account balance as of the payment due date
(08/16/05), which was $3,628.78.
C tie
New Balance
$3766.43
Minimum
Amount Due
$3766.43
Amount
-50.00
39.00
70000000000
86.61
70000000000
12.04
70000000000
Help is available! Please call the toll-free number shown above to learn about
our special payment options. Call Monday - Friday, 7 am to 9 pm, or Saturday,
8 am to 5 pm, Central Time. Please give us the opportunity to assist you.
Our records show home phone 717-576-8213 and business phone 717-975-8781.
Please update coupon if incorrect.
EXHIBIT A-
Account Summary Previous (+) Purchases Payments (+I
ANCE
FI
Balance
&Advances
&Credits H
CHARGE
Balance
PURCHASES
ADVANCES $3 225.90 $39.00 38.33 $86.61 $3,313.18
452.88 $0.00 11.67 12.04 $453
25
TOTAL $3,678.78 $39.00 50.00 98.65 .
$3,766.43
Rate Summary °'°m.r J°OlQ4 '. rerloalc Nominal ANNUAL
Finance Charge Rate APP lsrcll a.IAIr Darr
Sd Purch $3,240.21 0.08353%(D) 30.490% 30.490%
rd Adv $450.33 0.08353%(D) 30.490% 30.490%
Verification
1 Courtney Gilbert am an employee of Citicorp Credit
Services, Inc., (USA) which is by contract the service provider for plaintiff
Citibank (South Dakota) N.A. retained to perform services including but not
primarily limited to collecting delinquent debt. I am authorized to make this
verification as attorney-in-fact for plaintiff under powers of attorney from
plaintiff to Citicorp Credit Services, Inc. (USA) and to me. The foregoing
averments of fact in the within pleading are true and correct to the best of
my knowledge, information and belief. I understand that the statements
made herein are subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsification to the authoFitie .
tj? / ? f ? lr f;
Date: ( Signature:L't ?
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-05789 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIBANK (SOUTH DAKOTA) N A
VS
MCMEANS KELLY L
SHANNON SHERTZER
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
MCMEANS KELLY L
the
DEFENDANT
at 1538:00 HOURS, on the 9th day of November , 2005
at 625 BOSLER AVENUE
LEMOYNE, PA 17043-1817
DAVID MCMEANS, FATHER
by handing to
a true and attested copy of COMPLAINT & NOTICE - together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs
Docketing 18.00
Service 15.36
Affidavit .00
Surcharge 10.00
.00
43.36
Sworn and Subscribed to before
me this/4h day of
r??OVeM?Z? ??lO A.D.
Pr to
So Answers:
R. Thomas Kline
11/14/2005
BURTON NEIL & ASSOCIATES
By.
Deputy She iff
CITIBANK (SOUTH DAKOTA) N.A.
701 East 60th Street N, Sioux Falls, SD 571 l 7
Plaintiff
vs.
KELLY L MCMEANS
625 Bosler Avenue
Lemoyne PA 17043-1817
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5789 civil
CIVIL ACTION - LAW
Praecipe for Default Judgment
To the Prothonotary:
Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and
against the defendant, and assess damages as follows:
Principal:
Credit:
TOTAL
$3,716.43
$150.00
$3,566.43
Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities, I verify that:
1. The above are the precise last-known addresses of the judgment debtor and creditor.
2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is
to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of
the filing of this praecipe.
3. Pursuant to Section 201 (b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant
is not in the military service of the United States based on information received from the defendant and/or the
Department of Defense website. f
JUDGMENT BY DEFAULT ENTERED
AND DAMAGES ASSESSED AS ABOVE.
NOTICE GIVEN UNDE A.R.CIV.P. 236
Pro P 70thonota
The law firm of Burton Neil & Associates is a debt collector.
BURTON NZILA'ASSOCIATES, P.C.
BY:
ire
Attorney for Plaintiff
I.D. #11348
1060 Andrew Drive, Suite 170
W. Chester, PA 19380
C-8047
C-8047
CITIBANK SOUTH DAKOTA N.A. IN THE COURT OF COMMON PLEAS
Plaintiff
vs.
KELLY L MCMEANS
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5789 civil
CIVIL ACTION - LAW
Notice of Intention to File Praecipe for Default Judgment
TO: Kelly L McMeans
625 Bosler Avenue
Lemoyne PA 170431817
IMPORTANT NOTICE
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 obligations to the claims set forth against you. Unless you act within ten (10)
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 notice to your lawyer at once. If you do not have a lawyer
or cannot afford one, go to or telephone the following office to find out where you can get legal help. 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.
LAWYER REFERENCE AND
INFORMATION SERVICE
Cumberland County Bar Assoc.
32 South Bedford Street
Carlisle, PA 17013
Telephone No. 717-249-3166 or 800-990-9108
DATE OF NOTICE: December 1, 2005 BURTON NEI/& ASSOCIATES, P.C.
By:
Attorney for P aintiff
Identification No. 11348
In making this communication, we advise our office is a 1060 Andrew Drive, Suite 170
debt collector. West Chester, PA 19380
(610) 696-2120
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BURTON NEIL & ASSOCIATES, P.C.
BY: Burton Neil, Esquire
Identification No. 11348
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
ATTORNEY FOR: Plaintiff
CITIBANK (SOUTH DAKOTA) N.A. IN THE COURT OF COMMON PLEAS
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
KELLY L MCMEANS
NO. 05-5789 civil
Defendant : CIVIL ACTION - LAW
RULE OF CIVIL PROCEDURE NO. 236 (REVISED)
Notice is given that a JUDGMENT in the above captioned matter has been entered against you on
--
-26t .2nO a c
Prothonotary
By:__??<JI7?/9
If you have any questions concerning the above, please conta6f:
Burton Neil, Esquire
Attorney for Party Filing
1060 Andrew Drive, Suite 170
West Chester, PA 19380
Phone: 610-696-2120
The law firm of Burton Neil & Associates is a debt collector.
IN PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
Pa.R.C.P. § 3103 to 3149
CITIBANK SOUTH DAKOTA N.A
Plaintiff
V.
KELLY L MCMEANS
Defendant(s)
COMMERCE BANK
Garnishee(s)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05-5789 civil
: CIVIL ACTION - LAW
To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER
1. Directed to the Sheriff of Cumberland County, Pennsylvania
2. against KELLYL CMEANS , Defendant(s)
LzS ew Rue.. AArmoy"'34L' t7 -rl'j
3. and against COMMERCE BANK , Garmshee(s)
4. and index this writ
(a) against
(b) against
Defendant(s)
Garnishee(s)
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows:
(specifically describe property)
NO LEVY. GARNISHMENT ONLY
Serve interrogatories on garnishee at: 65 Ashland Avenue, Carlisle, PA 17013
5. Amount Due $3,566.43
Interest from 12/20/05 $210.63
Credit $1,890.00
Total $1,887.06*
*Plus writ costs
Dated: May 23, 2007
Burton Neil, Esquire
jj Attorney for Plaintiff
NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be
indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the count in which issued.
Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule
3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should
be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c).
The firm of Burton Neil & Associates, P.C. is attempting to collect a debt.
C-8047
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-5789 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITIBANK SOUTH DAKOTA N.A., Plaintiff (s)
From KELLY L. MCMEANS, 625 BOSLER AVE., LEMOYNE, PA 17043-1817
(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 COMMERCE BANK, 65 ASHLAND AVENUE, CARLISLE, PA 17013 - SERVE
INTERROGATORIES
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 $1,676.43
Interest FROM 12/20/05 - $210.63
Atty's Comm %
Atty Paid $134.86
Plaintiff Paid
Date: MAY 29, 2007
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
Deputy
REQUESTING PARTY:
Name BURTON NEIL, ESQUIRE
Address: BURTON NEIL & ASSOCIATES, P.C.
1060 ANDREW DRIVE, SUITE 170
WEST CHESTER, PA 19380
Attorney for: PLAINTIFF
Telephone: 610-696-2120
Supreme Court ID No. 11348
,s
Burton Neil & Associates, P.C.
By:Burton Neil, Esquire ID. NO. 11348
1060 Andrew Drive, Suite 170
West Chester, PA 19380 - 610-696-2120
Attorney for Plaintiff
CITIBANK SOUTH DAKOTA N.A
Plaintiff
V.
KELLY L MCMEANS
625 Bosler Avenue, Lemoyne PA 17043-1817
Defendant(s)
COMMERCE BANK
Garnishee(s)
To: COMMERCE BANK
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05-5789 civil
: CIVIL ACTION - LAW
h3u) er5 4v,
Interrogatories to Garnishee
65 Ashland Avenue Carlisle. PA 17013
You are required to file answers to the following Interrogatories within twenty (20) days after service
upon you. Failure to do so may result in judgment against you.
1. At the time you were served or at any subsequent time, did you owe the defendants any money or
where you liable to it by virtue of monies held by you on deposit or otherwise on any negotiable or written
instrument or did defendants claim that you owed them money or were liable to them for any reason.
Defendant had account 536322761 with a balance of $-15.56 at time served. Account is individually awned. Account
is a dire1-tA4q mWf&e6WRdR& "u&A t % t o ur possession, custody or
control or in the joint possession, custody or control of yourself and one or more other persons any property of
any nature owned solely or in part by the defendants?
See answer to question 1.]
3. If the answer to 1 and/or 2 is yes, please specify the nature of the property and, if money, the amount?
See answer to question 1.
4. At the time you were served or at any subsequent time, did you hold legal title to any property of any
nature owned solely or in part by the defendants or in which defendants held or claimed interest?
See answer to question 1.
5. At the time you were served or at any subsequent time, did you hold fiduciary any property in which
the defendants had an interest?
No
6. At the time before or after you were served, did the defendants transfer or deliver any property to you
or to any person or place pursuant to your direction or consent and if so, what was the consideration therefor?
Defendant made deposits into the above referenced account in the ordinary course prior to service, non of which
were at TeAl amime ?affteraym8% WerBWkefved, did you pay, transfer or deliver any money or property to the
defendants or to any person or place pursuant to its direction or otherwise discharge any claim of the defendants
against you?
No
Burton Neil & As_ ates, P.C.
By:
Burton Neil, Esq
The firm of Burton Neil & Associates, P.C. is attempting to collect a debt.
r
VERIFICATION
The undersigned does hereby verify under penalty of perjury, that he/she is the legal
representative of Garnishee herein, that he/she
is duly authorized to make this Verification and that the facts set forth in the foregoing
INTERROGATORIES are true and correct to the best of his/her knowledge, information and
belief.
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Burton Neil & Associates, P.C.
By: Burton Neil, Esquire ID. NO. 11348
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK SOUTH DAKOTA N.A.
Plaintiff
V.
KELLY L MCMEANS
Defendant
and
COMMERCE BANK
Garnishee
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05-5789 civil
CIVIL ACTION - LAW
Praecipe to Dissolve Attachment
To the Prothonotary:
Dissolve the attachment against COMMERCE BANK, garnishee.
Burton it & Associates, P.C.
By:
Neil, Esquire
Atto ev for Plaintiff
The law firm of Burton Neil & Associates is a debt collector.
C-8047
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff's Costs: Advance Costs: 150.00
85.99
Docketing 18.00 $ 64.01
Poundage 1.69
Advertising
Law Library .50
Prothonotary 2.00 Refunded to Atty on 06/11/07
Mileage 4.80
Surcharge 30.00
Levy 20.00
Certified Mail
Post Pone Sale
Garnishee 9.00
Postage nn
TOTAL $ 85.99 4.1499 7"- So Answers;
R. Thomas Kline, S er ff
y Claudia A. Brewbaker
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-5789 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITIBANK SOUTH DAKOTA N.A., Plaintiff (s)
From KELLY L. MCMEANS, 625 BOSLER AVE., LEMOYNE, PA 17043-1817
(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 COMMERCE BANK, 65 ASHLAND AVENUE, CARLISLE, PA 17013 - SERVE
INTERROGATORIES
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 $1,676.43
Interest FROM 12/20/05 - $210.63
Atty's Comm %
Atty Paid $134.86
Plaintiff Paid
Date: MAY 29, 2007
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
/' / I d' I -') ? 72
Eft s R. Long, Prothonotary
Y
Deputy
REQUESTING PARTY:
Name BURTON NEIL, ESQUIRE
Address: BURTON NEIL & ASSOCIATES, P.C.
1060 ANDREW DRIVE, SUITE 170
WEST CHESTER, PA 19380
Attorney for: PLAINTIFF
Telephone: 610-696-2120
Supreme Court ID No. 11348
Burton Neil & Associates, P.C.
By: Burton Neil, Esquire ID. NO. 11348
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK SOUTH DAKOTA N.A.
Plaintiff
V.
KELLY L MCMEANS
Defendant
and
COMMERCE BANK
Garnishee
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5789 civil
: CIVIL ACTION - LAW
Praecipe to Dissolve Attachment
To the Prothonotary:
Dissolve the attachment against COMMERCE BANK, garnishee.
Burton Neil & ssociates, P.C.
By:
Burton eil, Esquire
Attom for Plaintiff
The law firm of Burton Neil & Associates is a debt collector.
C-8047
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2005-05789 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
CITIBANK (SOUTH DAKOTA) N A
VS
MCMEANS KELLY L
And now MARK CONKLIN
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:37 Hours, on the 5th day of June , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
MCMEANS KELLY L
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND AVE
, in the
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
DENEEN RAUDABAUGH (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 answ
Docketing .00 ;,;;
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
0000 f Glr?/a7
06/04/2007
Sworn and Subscribed to
before me this day of By
Dep ty Sfieriff
A.D
M
Burton Neil & Associates, P.C.
By Burton Neil, Esquire ID. NO. 11348
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
CITIBANK SOUTH DAKOTA N.A.
Plaintiff
V.
KELLY L MCMEANS
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5789 civil
CIVIL ACTION - LAW
Praecipe to Satisfy Judgment
To the Prothonotary:
Mark the judgment Satisfied on payment of your costs only.
Burton Neil Associates, P.C.
By:
- ..-. on Neil, Esquire
Attorney for Plaintiff
The law firm of Burton Neil & Associates is a debt collector.
C-8047
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