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HomeMy WebLinkAbout05-6358 546 ~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , ' MONARCH CAPITAL CORPORATION NO. OS - wsf C IULLYffi..~ PO BOX 1877 ROCKVILLE, MD 20849-1877 Plaintiff vs. JEREMY FINNEGAN MICA FINNEGAN Defendant (s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Pleas'e enter Judgment in favor of Plaintiff and against Defendant (s), JEREMY FINNEGAN and MICA FINNEGAN pursuant to the District Justice Transcript. ( X ) Amount due Less credits TOTAL $ 2468.46 $ $ 2468.46, plus interest and costs ( X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. DATE: JI / S 10') , I Signature: Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1/20617 1/87737 1/87852 1/94000 Amy F. Doyle #870 / Philip C. WarhQLic,,1/86341 I aVId R. Galloway / Ronald M. ramson 94266 / Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 NOW, j)~ n , 20~. JUDGMENT IS Prothon By: Deputy PRAEDJ/PANOJ _W&A FILE NO. B3064533 COMMONWEALTH OF PENNSYLVANIA . COUNTY OF: CUllBBRLAlID Mag. Dist. No. NOTICE OF JUDGMENTfTRANSCRIPT CIVIL CASE 09-3-02 PLAINTIFF: 'MOlll'ARCH CAPl:TAL 267 B HAlUtBT ST YORK, PA 17403 NAME and ADDRESS CORP ., MDJ Name: Hon. HELBlII' B. SBULBRBBRGER Addrn" PO BOX 155 27 W BIG SPRIlII'G A~~u. lII'BWVILLB, PA Teleph". (717) 776-3187 17241 L ..J VS. ATTOJl.lll'BY POll. PLAIJl/TII!'I!' : DEFENDANT: NAME and ADDRESS IpIJlJilBGAlII', JEJl.BMY, BT AL. 10 HOLLIlII'GER ST. APT/STE 2 NT. HOLLY SPRINGS, PA 17065 L ., WOLPOI!'I!' . ABRAMSOlll' LLP 267 B HAlUtBT ST ATTH: AMY DOYLB YORK, PA 17403 Docket No.: CV-'OOb0060-05 Date Filed: 4/08/05 ..J . THIS IS TO NOTIFY YOU THAT: Judgm'lnt: ,c-" _~ I!'O~ )i!LA.IJl/TU'F [i] [i] Judgment was entered for: (Name) un....a. Dt"'A' ~a. OPT"''' T. C!nv'P Judgment was entered against: (Name) lPT'IlI1lI1fa:a.. IITeA in the amount of $ 2 4j;R 4j; on: (Date of Judgment) 7/2n/o~ . D Defendants are jointly and severally liable. D Damages will be assessed on: D This case dismissed without prejudice. (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total $ 2.341.28 $ 127.18 $ .00 $ .00 $ 2.468.46 D Amount of Judgment Subject to AttachmenV42 Pa.C.S. 9 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS'THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF TH EA~. CIVil DlVJ~. MUST INCLUDE A COpy OF tHIS Nb ",.. TOoffliia\ IC~Uf/' EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ~, :,,, 5;: ~~' ':.i "f, \~ ':t ~-,. 'Date ". :'<' J' " . . . ~. '. :~ ,Ma~si~r~#tiistricrJ~~e , .. ,-,' , I certify that this is a true and correct copy of the record of the proceedings contaifliii:iihe'juQg'ment.' . " q- J ~ -Q5ate f3 A -/h..4 l/ /t 1/f..:t!-AJ.f.A./) , Magisier.ial D!strict JUd~r "--.. , . My commission expires first Monday of January, 2006 . SEj\L AOPC 315-05 DATE PRIJl/TBD: 7/20/05 11:20:46 AM , ' ,.:..c"> __"! r' (' '~, - c,~. c' _ _.._.._~_71 t,; :~--.~"~. :', \ 2G05 , , , i ___ __.J ,.'"_.H._ IT ~~~u~~~rr JUL 2 ~ 2005 U I ~." ,. ... COMMONWEALTH OF PENNSYLVANIA ... COUNTY OF: COMBERLABD Mag, Dist. No.: g j iJriJ NOTICE OF JU[j~ENT/TRANSCRIPT CIVIL CASE NAME and ADDRESS 09-3-02 PLAINTIFF. IiOlll'ARCB: CAPJ:TAL 267 E HAUET ST YORK, PA 17403 CORP -, MDJ Name: Hon. BELBlII' B. SBULBlII'BERGER Add"". PO BOX 155 27 W BIG SPRIlII'G AV6WU& lII'BWVILLE, PA T",phO" (717) 776-3187 17241 L -.J VS. ATTOIitJllBY POR PLAIlII'TII!'P : DEFENDANT: NAME and ADDRESS IpIJrllII'BGAlII', JEREMY, ET AL. 10 BOLLIlII'GER ST. APT/STE 2 NT. BOLLY SPRIlII'GS, PA 17065 J33obt/6-:5'J Docket No.: CV-0000060-05 Date Filed: 4/08/05 -, WOLPOPI!' . ABRAMSOlll' LLP 267 E HAUET ST ATTlII': AMY DOYLE YORK, PA 17403 L -.J . THIS IS TO NOTIFY YOU THAT: Judgment: I!'OR.l'~:r.-rpr,. . .._~~_.~_~~~__. [i] [i] Judgment was entered for: (Name) vn.a.vf"lA' t"a.'DT..a.T. t"nv'D Judgment was entered against: (Name) 'JIT1IIIRtla.v r aT'll!VlnlV in the amount of $ / I l.-~ ; (Qate4,Judgment) ~,' 7/20/0" o Defendants are jointly and severally liable.' . o Damages will be assessed on: o This case dismissed without prejudice. (Date & Time) / u Amount of Judgment $ 2.341.28 Judgment Costs $ 127.18 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2.468.46 I . .post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ O Amount of Judgment Subject to Attachment/42 Pa.C.S. S 8127 $ D Portion of Judgment for physical damages arising out of residential lease $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PI "AS, CI\o'IL DIVI .'.""""'....-- MUST INCLUDE A-CCPY EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PA YS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. '\i'}''''''-- {"-~ . .' Date . . \' '" ::- ", ',:t; ',' ~ ~:.:,~.' ,," , Magrstef.ial bistrict J~dge. - ,..,:, ~,".." ''', ..' }",,' ; . '- I certify, that this is a true and correct copy of the recerd of the proceedings contairilL;g. Ine juilliment. . .' " CJ -I a -QS)ate f:h An db MJu!A-) , Magi~;e;;al Distri<;t JU~g~' , ';1 My commission expires first Monday of January, 2006 . '. SEAL AOPC 315-05 DATE PRIlII'TBD: 7/20/05 11:20:22 All - p ~ (: P 7J -:() ~ It- ~ ~ -:. - Cf) ~ ~ 2 -r- ~~~:p w -+- r ~. . /)>/ W -/r ~\ "',.~ c.) --- .' ,....) 1...' 545 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MONARCH CAPITAL CORPORATION No. O~ - 103SP . C,(,)~L I~~ PO BOX 1877 'ROCKVILLE, MD 20849-1877 . Plaintiff vs. CIVIL ACTION - LAW JEREMY FINNEGAN MICA FINNEGAN Defendant (s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: MONARCH CAPITAL CORPORATION ASSIGNEE OF AMERICAN DEBT SALES, ASSIGNEE OF WELLS FARGO BANK PO BOX 1877 ROCKVILLE, MD 20849-1877 and certify that the last known address of the within Defendant(s) is: JEREMY FINNEGAN 10 HOLLINGER ST 2 MT HOLLY SPGS PA 17065 MICA FINNEGAN 1697 WALNUT BOTTOM RD # 2 NEWVILLE PA 17241 ~~I Amy F. Doyle #87062 / Philip C. Warholic #86341 / David R. Galloway #87326 / Ronald M. Abramson #94266 / Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill. PA 17011 (717) 303-6700 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 peRES/PANOJ W&A FILE NO. l330~4533 544 , ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MONARCH CAPITAL CORPORATION No. Ot'- '-.3S~ ei(.)i '-rVL~ PO BOX 1877 ROCKVILLE, MD 20849-1877 Plaintiff vs. CIVIL ACTION - LAW JEREMY FINNEGAN MICA FINNEGAN Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter. and that to the best of my knowledge, information and belief Defendant, MICA FINNEGAN , above-named, is over 21 years of age; is last known to reside at 1697 WALNUT BOTTOM RD # 2 NEWVILLE PA 17241 County of CUMBERLAND , Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Dina A. Sweitzer, Notary Public Hampden Twp., Cumbertand County My Commission Expires Apr. 16,2008 ~ Amy F. Doyle #&J062 / J'hi.l.,ipC.Warholi,,~tl86341 / CDavrd~~R. Galloway 1~6 / IRonarn-tl. Abramson #Y4i66 / Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 SWORN and SUBSCRIBED to before me this Z- day of nDr ,...trn'oLA. ~l~,t(~ ~y Public 'L^ 1/- /' , 20C0. PNMAF7!PANOT .~ W&A FTI.F. NO. l~~OIi"'~~~ 543 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MONARCH CAPITAL c.ORPORATION No. os - ~3SP C;() L L I-k"'1 PO BOX 1877 ROCKVILLE, MD 20849-1877 Plaintiff vs. CIVIL ACTION - LAW JEREMY FINNEGAN MICA FINNEGAN Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, JEREMY FINNEGAN , above-named, is over 21 years of age; is last known to reside at 10 HOLLINGER ST 2 MT HOLLY SPGS PA 17065 County of CUMBERLAND the United States or its Allies, or Servicemembers Civil Relief Act and , Pennsylvania; is not in the military service of otherwise within the provisions of the its Amendments. COMMONWEALTH OF PENNSYLVANIA Notarial Seal . Dina A. Sweitzer, Notary Public Hampden Twp., Cumberland coun~ My Commission Expires Apr. 16, 20 8 1187062 / 41 / 118732 4266 Bruce H. Cherkis 1118837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 SWORN and SUBSCRIBED to before me this ~ day of (\l)(~nltJ~\ }:m~lHurCl~ ~ , 2008. ~ PNMAFF/PANOJ W&A FILE NO. 133064533 542 , ' . IN THE COURT OF 'COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , ' MONARCH CAPITAL CORPORATION NO. OS- - 1.:>357 CliC/cL ~.'-1' PO BOX 1877 ROCKVILLE, MD 20849-1877 : Plaintiff VS. CIVIL ACTION LAW JEREMY FINNEGAN MICA FINNEGAN 10 HOLLINGER ST 2 MT HOLLY SPGS PA 17065 Defendant (s) NOTICE OF ORDER, DECREE OR JUDGMENT TO: JEREMY FINNEGAN MICA FINNEGAN 10 HOLLINGER ST 2 MT HOLLY SPGS PA 17065 1697 WALNUT BOTTOM RD II 2 NEWVILLE PA 17241 You are hereby notified~at the entered against you on r; (' of Pa. R.C.P. 236. following ORDER, IJ dtY~ I DECREE or JUDGMENT has been in accordance with the provisions ( ) Decree Nisi in Equi ty ( ) Final Decree in Equity ( ) Judgment of ( ) Confession ( ) Verdict ( ) Defaul t () Non-sui t ( ) Non-pros () Arbitration Award ( ) Judgment is in the amount of $ , plus costs. ( X) District Justice transcript of judgment in civil action in the amount of $ 2468.46, plus costs. ( ) If not satisfied wi thin sixty (60) days, your motor ,vehicle operator's license will be suspended by the Pennsylvania Department 0' 'c.o.,oc',"oo. '" ~h~~ Pro, honotar~ /J If you have any questions this Notice, please contact the filing party. I' Amy F. 1187062 Daniel F. Wolfson 1120617 Philip. C. Warholic 1186341 Andrew C. Spears 1187737 c:-uavid R. Galloway ffo~/ Tonilyn M. Chippie 1187852 Ronald n. ADramson 1194266 / Ronald S. Canter 1194000 Bruce H. Cherkis 1118837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 / (717) 303-6700 (This Notice is given in accordance with Pa. R.C.P. 236.) 16113 , ~ PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 MONARCH CAPITAL CORPORATION ASSIGNEE OF AMERICAN DEBT SALES, ASSIGNEE OF WELLS FARGO BANK PO BOX 1877 ROCKVILLE, MD 20849-1877 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : Plaintiff vs. JUDGMENT NO. 05-6358 JEREMY FINNEGAN MICA FINNEGAN 10 HOLLINGER ST 2 MT HOLLY SPGS PA 17065 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Defendant(s) To the Prothonotary: PLEASE ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania; (2) against, JEREMY FINNEGAN MICA FINNEGAN 10 HOLLINGER ST 2 1697 WALNUT BOTTOM RD II 2 MT HOLLY SPGS PA 17065 NEWVILLE PA 17241 , Defendant(s); (3) and against, COMMERCE BANK 4860 CARLISLE PIKE MECHANICSBURG PA 17050-302 (4) and index this writ (a) against, JEREMY FINNEGAN MICA FINNEGAN (b) against, COMMERCE BANK as a lis pendens against the real property of the Garnishee(s) as follows: (Specifically describe property) *** GARNISH ONLY , Garnishee(s); , Defendant(s) and , Garnishee(s), Defendant(s) in the name of the *** You are directed to attach the property of the Defendant(s) not levied upon in the possession of COMMERCE BANK 4860 CARLISLE PIKE MECHANICSBURG PA 17050-302 Garnishee(s) All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount due Interest from 07/20/2005 At an inter st rate of 6% per year $ 2468.46 To Be Determined Dated: Total $ 2468.46 Plus costs & interest Amy F. Doyle 1187062 1 ~~PRC'r.:~~~:~~e ~:~~j Ronald M. Abramson /194266 1 Bruce H. Cherkis 1118837 WOLPOFF & ABRAMSON, L.L.P. 1 Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 1 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 (717) 303-6700 ~. ::r ':b~~ ~ ~ f\ \- l:: LJ ~ ~ ,...- , - - -- ~ ~ }J - -c ~ CI\ \) t C ("-~ r ~ ~ tlJ -.-- ~~~vt . . 'J.J 11 r-.:> l0. Vi C. V'l \Y : ,0~ .~\ __ ~?.2 :. ':1-1:- <-~ (") ~2 C~. e:,.p ::'; '-- ?::: o -n ~ i-:n;!3 ...-;..- --r:Jl" W :T)9 o ',.:!IC' -0 'J~, ":h .,<c') {Sfrl <-:? ~,:~ , en (p :.<; N .-O:;).oC.a. . - _.-.-._~ , . WRIT OF EXECUTION andlor ATTACHMENT - COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6358 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MONARCH CAPITAL CORPORATION ASSlGNEE OF AMERICAN DEBT SALES, ASSIGNEE OF WELLS FARGO BANK, Plaintiff (s) From JEREMY FINNEGAN AND MICA FINNEGAN, 10 HOLLINGER ST 2, MT HOLLY SPGS, P A 17065 (I) You are directed to levy upon the property of the defendant (,)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, 4860 CARLISLE PIKE, MECHANICSBURG, P A 17050-302 - ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the gamishee(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) Ifproperty 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 hi:mlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2468.46 L.L. $.50 Interest FROM 7/20/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Cornrn % Atty Paid $37.25 Plaintiff Paid Date: JANUARY 30, 2006 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name DAVID R. GALLOWAY, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD 3"0 FLOOR CAMP HILL, P A l7011 Attorney for: PLAlNTlFF Telephone: 717-303-6700 Supreme Court ID No. 87326 - \ , SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-06358 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND MONARCH CAPITAL CORPORATION VS FINNEGAN JEREMY ET AL And now DOUGLAS RUZANSKI ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0012:41 Hours, on the 2nd day of February, 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT FINNEGAN JEREMY in the hands, possession, or control of the within named Garnishee COMMERCE BANK 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to REBECCA BONAWITZ (TITLE T.S.M) 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: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So answers: ,,-- ~'''''''t' /2!! " R. Thomas Kline Sheriff of Cumberland County 02/02/2006 , 7 j , .~ I' . ' LCf# J'{j / , De t'y riff Sworn and subscribed to before me this 1& day of .3-~ .200l,,~.D. 1 Proc onoi:!fl#7 By \ SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-06358 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND MONARCH CAPITAL CORPORATION VS FINNEGAN JEREMY ET AL And now DOUGLAS RUZANSKI ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0012:41 Hours, on the 2nd day of February, 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT FINNEGAN MICA , in the hands, possession, or control of the within named Garnishee COMMERCE BANK 65 ASHLAND AVE CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to REBECCA BONAWITZ (TITLE T.S.M) 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: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So answers: R. T~~~<<I!~ Sheriff of Cumberland County 02/02/2006 'l / , this '7!!: day of J~ "00 ~ ~; . ,- pr9kmotar - 1 By 7 '/,,;2 f Sworn and subscribed to before me 16116 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MONARCH CAPITAL CORPORATION ASSIGNEE OF AMERICAN DEBT SALES, NO. 05-6358 Plaintiff vs. CIVIL ACTION-LAW : JEREMY FINNEGAN MICA FINNEGAN 10 HOLLINGER ST 2 MT HOLLY SPGS PA 17065 : : Defendant (s) ;J~..,ii..'Crs 7b INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION TO: PURSUANT TO RULE 3114 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE A. 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. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was issued. C. "You" means the main office and all branch offices, representatives, employees, and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. is to be as such, estimate Where exact information cannot be furnished, estimated information supplied. When an estimate is to be used, it should be identified and an explanation should be given as to the basis on which the is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. SSII 170 60 0499 16114 .. PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - JEREMY FINNEGAN MICA FINNEGAN 10 HOLLINGER ST 2 MT HOLLY SPGS PA 17065 SSII 170 60 0499 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each account. If the Defendant(s) maintains any of these jointly with any other person, or persons, give their name and address. Defendant has account 536707987 with a balance of $1,850.46 at the time served. The account is held individually. lA. DIRECT DEPOSIT ACCOUNTS: Are any of the account. you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. Yes, last deposit made 2/6. 2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons, give their full name and address. No. 3. PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not Defendant(s) owns any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumbrances or liens holders, the present balance of the encumbrance. State where and when the encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give nameS and address. See answer to question 1. 4. did are all OTHER ASSETS: At the time you were served or you know of the existence of any other asset(s) not disclosed in the preceding Interrogatories. details concerning those asset(s). at any subsequent time, of the Defendant(s) which If so, please set forth See answer to question 1. ORALE2/PAWRIT W&A FILE NO. 133064533 16115 5. PROPERTY: At the time you were served or at any subsequent time, was there in your possession, custody, or control or in the joining possession, custody, or control of yourself and one or more other persons any property of any nature owned solely or in part by any Defendant(s)? If so, please describe for each Defendant(s) each item of property including its value. See answer to question 1. 6. REAL PROPERTY: At the time you were served or at any subsequent time, did you hold legal, or equitable title to any property of any nature owned solely or in part by the Defendant(s) or in which and Defendant(s) held or claimed any interest? If so, describe for each Defendant(s) each item of property including its value and the interest held by the Defendant(s). See answer to question 1. 7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). No. 8. TRANSFER OF PROPERTY: At any time before or after you were served, did any Defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent. If so, for each Defendant(s) describe the property transferred or delivered including the dates of delivery or transfer and state the consideration paid. Defendant made deposits into teh above referenced accounts, prior to service non of which were at the direction of Commerce Bank, 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charged by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer. If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. ~ Amy F. oyle \ Phili avid R. Galloway Ronald M. Abramson Bruce H. Cherkis 1118837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 No. Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 Date: I c, ~, () " -n -,~ 1 'i :.:1 p~~ ('1~ C.J G , , -' r-,' ,:,::1 r~) cr: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA MONARCH CAPITAL CORPORATION Plaintiff NO. 05-6358 vs. CIVIL ACTION - LAW JEREMY FINNEGAN MICA FINNEGAN Defendant(s) vs. Commerce Bank Garnishee Garnishee: Commerce Bank 3 Crossgate Drive Mechanicsburg Pa 17050 PRAECIPE FOR JUDGMENT UPON ADMISSION To the Prothonotary: Please enIer judgment in favor of the Plaintiff and against the Garnishee. Commerce Bank, in the amount of $1,850.46, as admitted in the answer to Interrogatories to be in the possession of Garnishee. The amount of Ihe judgment together with interesI and cosIs of the PlaintifI againsI the Defendant is $2,468.46, 2/2- Z/o (p ( ( Dated: Respectfully Submitted, Am~2 Daniel F, Wolfson #20617 Philip C. Warholic #86341 Andrew C. Spears #87737 ,-/ David R. Galloway #87326 Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd" 3" Floor CarnpHill,PA 17011 (717) 303-6700 W &A File No. 133064533 (:) 44- t~ '- ...() C) . . \) - - ~ -.\ ...:t r ..t:: w ~ ..::c ,...() C.r) 1: .., \It ~ - . ~ ~ " :~ ,< (' ---.- .".~--------- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA MONARCH CAPITAL CORPORATION Plaintiff NO. 05-6358 VS, CIVIL ACTION - LAW JEREMY FINNEGAN MICA FINNEGAN Defendant(s) VS, COMMERCE BANK Garnishee(s) PRAECIPE TO DISSOLVE GARNISHMENT To the Prothonotary: Please release the Lis Pen des on a Judgment filed against Commerce Bank. garnishee in the above -entitled case and mark the JudgmenI againsI the garnishee as withdrawn. Dated: (' Respectfully Submitted. 1f;fJ Amy F. Doyle #87062 Daniel F. Wolfson #20617 Philip C. Warholic #86341 Andrew C. Spears #87737 David R, Galloway #87326 Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON. LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3cd Floor Camp Hill, PA 17011 (717) 303-6700 W &A File No. 133064533 N D -.(; t- r::-. ~ il \) D - "'- <1. ~ -0 I - \)" --D (\ _..... .-!'- U( r- - "- -.. ()' '-G f? C,'} ~ 0"- /-- (..:-; .~ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL 18.00 2.29 .50 1.00 4.40 40.00 40.00 1.58 9.00 116.77 Advance Costs: 150.00 Sheriffs Costs 116.77 33.23 Refunded to Atty on 10/05/06 y II> /I~/b & ~ So Answers; ~ ~#!' R. Thomas Kline, e~~ By r J 01 od ~ ~/\o.QD\oak1 ~ ~ '" \1J lJ', ""q \.,:>1:> c.t<. 5,~30 ~ I P94fl7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6358 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MONARCH CAPITAL CORPORATION ASSIGNEE OF AMERICAN DEBT SALES, ASSIGNEE OF WELLS FARGO BANK, Plaintiff (s) From JEREMY FINNEGAN AND MICA FINNEGAN, 10 HOLLINGER ST 2, MT HOLLY SPGS, P A 17065 (1) You are directed to levy upon the property of the defendant (s land to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMERCE BANK, 4860 CARLISLE PIKE, MECHANICSBURG, P A 17050-302 - ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the gamishee(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) Ifproperty 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 hirn/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2468.46 L.L. $.50 Interest FROM 7/20/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $37.25 PlaintiiIPaid Date: JANUARY 30, 2006 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name DAVID R. GALLOWAY, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD 3RD FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87326 11 x 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 FILED-OFFICE 209027 TEE FCTCCTAR Y 2011 JINN 31 PM 2: 11 CUMBERLAND COUNTY PENNSYLVANIA MONARCH CAPITAL CORPORATION VS. JEREMY FINNEGAN COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 05-6358 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the plaintiff in the above-captioned matter. GORDON & WEINBERG, P.C. BY: FREDERIC I. WE 30G, ESQUIRE JOEL M. FLINK,, ESQUIRE Attorney for Plaintiff P012 s CERTIFICATION OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Substitution of Attorney and Entry of Appearance Pursuant to Pa.R.C.P. 1028(c)(1), via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDERIC ? WEINB RG, ESQUIRE Dated: t l L