HomeMy WebLinkAbout06-08642023828
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 FIRST CARD CONV
10625 Techwoods Circle
Cincinnati, OH 45242
VS.
DENAH TALMADGE
539 HERMAN AVE
LEMOYNE PA 1V043
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. 5
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 'PO 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
merchandise 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"
9. All the credits to which the defendant(s)is entitled
have been applied and there remains a balance due in the amount
of $6,678.73.
5. Plaintiff has made demand upon the defendant(s)for
payment of the balance due of $6,678.73 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
$6,678.73 at the rate of 11.65° from the date of March 18, 2002,
together with costs and attorney fees.
GORDON & WEINBERG, P.C.
BY:
FREDERIC WEI ERG, ESQUIRE
PAUL M. S LD, JR., ESQUIRE
Attorney for Plaintiff
POlh
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. WE E
EXHIBIT "A"
829 Z.oz-3(5, S
Balance as of: Payment Due Minimum Payment
Account Number 11130/2005 Date Payment Enclosed
5544562011601805 $9424.94 Past Due $9424.94 $
Make checks payable to:
Unifund
UNIFUND STATEMENT
Denah Talmadge
539 Herman Ave
Lemoyne PA 17043-1823
MESSAGE FROM UNIFUND
Your account is past due $9424.94. 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 Due Payments ew
Balance
11/30/2005 Bank One Delaware NA's $9424.94 $9424.94 $0 $9424.94
account was issued under the
name of FIRST CARD CONY.
Unifund CCR Partners purchased
this account from Bank One
Delaware NA.
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.
Statement for account number. 554 4 56 20 1160 1805
u2 3r?
FIRST CARD'
New Balance Payment Due Data Past Due AmouN Minimum Payment
66,67813 ?-1192N2 3 5771.00 1
Amount Enclosed Is. 1M6myo orw pl?pd onwU BeA.NA
?LL±????JJM addersor ffAPrWF bark
554456201160180500256673006678733
FIRST USABANK, NA
P.O. BOX 1519
WILMINGTON DE 199855153
!198865153536!
DENAH TALMADGE
539 HERMAN AVENUE
LEMOYNE PA 17D43.1B23
1170431823399!
?frotPo]egaarUatew.
A
yy?
t1
J
SNhmanIDMIr. 09718.@-102892 CUSTOMER SERVICE
j]?(?A j]
FIRS CA" 1
Minimum Payment Due: $2
.566.73 Espa/o11E88446-3300
TOO 14715956J83E0
Outside U.S. call coned
1302-S4E200
MASTERCARD ACCOUNT SUYWIY Amaum Numbs 5544 5®11601805
Previous Balance 56577.00 Total Cast Line 15000 11000UNT INOUWEB
Payments, Credits -$0,00 Avagable Credit 6p PPO?, 1a?aeao
Punciases,Cash,Debcs 5$64 DO Cash Access Lee I
Finance Charges 1586.83 Available for Cash 50 p4yygly lgOgBgg
New Baance ./? P.o. toe: as
TRANSACTIONS
Trans Amount
Date RMerance Number Merchant Name or Transaction Description Credd Debb
IM11 OVERLIMR FEE 29.00
1558
1559 99 e3
AN OVERUM1T FEE WAS ASSESSED WHEN YOUR ACCOUNT BALANCE
EXCEEDED THE ESTABLISHED CREDIT LIMIT ON 101211102.
FINANCE CHARGES PERIODIC RATE(S) AND API MAY VARY
sty eno s Rate corresponding APK rerage sty nce
Category 31 days in cide Previous Cycle Cuuent Cycu FINANCECHARGES
Purchases 113192% 11.65% $0.00 $3.417.20 Si
Cashadvari 05425% 1980% SOTS $3,15261 Si
Total finance charges 56683
EStodlre Annual Ptouemege Rae (APR): III
GracePenod Type' B (Pbeae mslech of staMnwM fcrtM Cwero Period explanation.)
The Corresponding APR is the rate d intense you pay when you story a ba w on purchases Or cash advan®s.
The ERechwe APR represents your total finance charges -including benaadion fees such as cash advance and balance tmnsfer
less. expressed w a percentage.
TIOU20U USE OUR E-PAY SERVICE TO MWE PAYMENTSOVER THE PHONE)
IT'S A CONVENIENT WAY TO BRING YOUR FIRST CARD CREDIT CARD
UPTODATE. CALL TOLL FREE,1-B6549G8226 TO LEARN HOW
This Statement is a Facsimile - Not an Original
sago case em eas 1 11 ouoza axa.ee t er z aeoz asoo asoese ozmzeao
Statement for account number.5644592011601805 FI Win CAMS
+w+
New Balance Payment Due Date Past Due Amount Minimum Payment
$0.00 lia5m $000 sow
Amount Enclosed 15Nk,NA
Mdmyourd
kpdetlato
W
hed,
cr m
New etltr ua m
Pdra on bark
554456201160180500000000000000004
DERAH TALMADGE
FIRST USA BANK. NA
A 539 HERMAN AVENUE
P.O. BOX
15153
LEMOYNE PA 17043-1823
WLMING70N DE 19086-5153
!198865153536! 1170431823399!
7mlteoasma nmlaW[
e 9atemenl Date'. 1fuZ -10/31,02 CUSTOMER SERVICE
F1W IJAIVJ Payment Due Dols 114642 InU.S. 1-80075631100
Minimum Paymard Do.: $0.00 Espaaal 1-88B446-3308
TOO IMO.95SMSO
Ouiaide U.S. a0 called
MASTERCARD ACCOUNT SIYIAfiY Account Number: 551d 56201760 /a6- 1-302-594-8200
Previous Balance 51 Total Credit Line 55000 Ae=Wm am
Payments, Credits -$6578.73 Available Credit so ro. a...
Purchases, Cash, Debda .10.00 Cash Access Do. $200 vu. vp as 1Y..
Finance Charges .3900 Available for Cash 7D PAYMENT ADDRESS
N av Balance $000 1.. a.a rec.
way o- as I...
TRANSACTIONS
Trans Amount
Dole Reference Number Merchant No.. or Transaction Description Credit Debi)
1061 F96Mahno)(mmiso) CHARGE OFF ACCOUNT-PRINCIPALS 4,90305
10!31 F9W200RM09999g0 1,)15.69
FINANCE CHARGES PERIODIC ,WE(S)AND APRISL MAY VARY
ffe
-OTPenadic ate Corresponding AM Mempe 6a'ir ante
Category 03 days in cycle Prenicus Cycle Current Cycle FINANCE CHARGES
Punch.... U3192% 1155% $0.00 $0.00 70.00
Cash advanma 05425% 1960% Saw $0.00 sow
Tmal finance charges $003
ERecsNe An...[Paumnge Ram(APR(: NA
Grace Perod Type: B (Phosae we bscA of etebmerd be tyre Grace Period exomatioa,)
The Corresponding APR isths role of inland you pay when you carry a balance on purchases or cash advances
Th e Effective APR represents your btelfinance charges - including bansaaion fees such ea cash advance and balance transfer
fees expressed as a percentage.
This Statement is a Facsimile - Not an Original
sea. 0000 a. 600 6 19 OS3091 2%gea 1 ere 1 asol 6e0000#6 clause"
??,?
??? ? ?_?'
w
ti
??
v.
??
._, l
-?, ?r,
_?
?: ;:
,?.
:
? :?:
_ `;
?=? -
=<
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-00864 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS ETC
VS
TALMADGE DENAH
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
TALMADGE DENAH the
DEFENDANT , at 2005:00 HOURS, on the 17th day of February 2006
at 539 HERMAN AVENUE
LEMOYNE, PA 17043 by handing to
DENAH TALMADGE
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 14.08
Affidavit .00
Surcharge 10.00
.00
42.08
Sworn and Subscribed to before
me this /e¢ day of
)1Lr d6U(r A. D.
Protho ry
So Answers:
R. Thomas Kline
02/21/2006
GORDON & WEINBE,VtG
By: i
','Deputy Sl{kriff
QORDON & 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
FIRST CARD CONV
VS.
DENAH TALMADGE
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 06-864 CIVIL
PRAECIPE FOR JUDGMENT
The Prothonotary will please enter Judgment in the above matter by
default for want of an answer against the Defendant, DENAH TALMADGE, and
assesses the damages as per statement below.
ESQUIRE
FREDERIC I. WCliff
PAUL M. SCHOF R., ESQUIRE
Attorney for Principal $6,678.73
Interest from March 18, 2002
@11.650 $3,120.81
Total: $9,799.54
I hereby certify that written notice of the intention to file this
Praecipe was mailed or delivered to the parties against whom judgment is
to be entered and to his attorney of record, if any, after the default
occurred and at least ten (10) days prior to the date of the filing of
this Praecipe.
FREDERIC I. WEI ERG ESQUIRE
PAUL M. SCHOFIEL , JR., ESQUIRE
Attorney for Plaintiff
Filed:
By the Prothonotary
AND NOW, this moo= day of Lc( l1LL!? , 204 Judgment is
entered in favor of the plaintiff(s) and against defendant, for want of
an answer and damages assessed at the sum of $9,799.54 as per the above
certification.
Proth notary j
4
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
FIRST CARD CONV
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
DENAH TALMADGE
DOCKET NO
CERTIFICATION OF ADDRESS
06-864 CIVIL
I hereby certify that the precise residence of the holder of the
within judgment is; UNIFUND CCR PARTNERS ASSIGNEEOF FIRST CARD CONV
and that the last known address of defendant, DENAH TALMADGE, 539 HERMAN
AVE, LEMOYNE PA 17043.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EI ERG, ESQUIRE
-73?-
PAUL M. SCHFIEL , JR.,ESQUIRE
Attorney for intiff
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
FIRST CARD CONV
VS.
DENAH TALMADGE
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 06-864 CIVIL
AFFIDAVIT OF NON-MILITARY SERVICE
FREDERIC I. WEINBERG, ESQUIRE, being duly sworn according to law,
deposes and says that he represents the plaintiff in the above-entitled
case; that he is authorized to make this affidavit on behalf of the
plaintiff; and that the above-named defendant is over twenty-one years
of age; that the address of the defendant is, 539 HERMAN AVE, LEMOYNE PA
17043; that the occupation of the defendant is unknown; and that the
defendant is not in the Military Service of the United States, nor any
State or Territory thereof or its allies as defined in the Soldiers' and
Sailors' Civil Relief Act of 1940 and the amendments thereto.
Sworn to and Subscribed
Before me this Day
2006.
z? K /,-4.
Notary Public
CGMMONWEALrH of PENNSYLVANIA
NOTARIAL SEAL
CHRISTINE M. COLON Notary Public
City of Philadelphia Phila. County
° Com,i is r Fr,8ira5 Nove,R1¢at ]8 ,2999
FREDERIC I. W NBER , ESQUIRE
PAUL M. SCHOF JR. ESQUIRE
Attorney for Plaintiff
2023828
GORDON & WEINBERG, P.C.
BY: FREDERIC I. WEINBERG, ESQUIRE
Identification No.: 91360
PAUL M. SCHOFIELD, JR., ESQUIRE
Identification No.: 81899
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
UNIFUND CCR PARTNERS ASSIGNEE OF
FIRST CARD CONV
VS.
DENAH TALMADGE
TO/PARA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 06-869 CIVIL
NOTICE OF INTENTION TO TAKE DEFAULT
DENAH TALMADGE
539 HERMAN AVE
LEMOYNE PA 17093
DATE OF NOTICE/FECHA DEL AVISO: March 9, 2006
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 1'7013
(717) 299-3166
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. OEINBE G, ESQUIRE
PAUL M. SC OFIE , JR., ESQUIRE
P10D-2
C
w
k-lL
G
w
t ;.
a'
T
2023828
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
FIRST CARD CONV
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
VS.
DENAH TALMADGE
DOCKET NO. : 06-864 CIVIL
NOTICE
PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY
NOTIFIED THAT A JUDGMENT BY DEFAULT HAS BEEN ENTERED AGAINST YOU IN THE
ABOVE PROCEEDING IN THE AMOUNT OF $9,799.54. IF YOU HAVE ANY QUESTIONS
CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 215/988-
9600.
GORDON & WEINBERG, P.C.
BY:
FREDERIC I. EIN ERG, ESQUIRE
PAUL M. SCH FI , JR.,ESQUIRE
Attorney for Plaintiff
Dated: March 21, 2006
} ,
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 FIRST CARD CONV
VS.
DENAH TALMADGE
539 HERMAN AVE
LEMOYNE PA 17043
and
Commerce Bank
1249 Market Street
Lemoyne, PA 17043
GARNISHEE
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 06-864 CIVIL
PRAECIPE FOR WRIT OF EIMCUTION
TO THE PROTHONOTARY:
Issue writ of execution in the above matter,
directed to the Sheriff of Cumberland County;
(1)
against
DENAH TALMADGE
defendant(s)and
(2)
against
Commerce Bank
garnishee(s)
(3) AMOUNT DUE $9,799.54
INTEREST
from March 28, 2006 $517.83
COSTS
Prothonotary fee $15.00
Sheriff fee 150.00
TOTAL $10,482.37
FREDERIC I. INB G, ESQUIRE
PAUL M. SCHO , JR., ESQUIRE
Attorney for Plaintiff
4--?
CIA
e
Q , ASV
d
ti
C
U1 _
c =r ??
32
-
-
r?o j-TI
1
A . N
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-864 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS ASSIGNEE OF FIRST
CARD CONV Plaintiff (s)
From DENAH TALMADGE, 539 HERMAN AVE., LEMOYNE, PA 17043
(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
GARNISHEE(S) as follows:
COMMERCE BANK, 1249 MARKET STREET, LEMOYNE, PA 17043.
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 $9,799.54
Interest FROM MARCH 28, 2006 - $517.83
Atty's Comm %
Atty Paid $133.08
Plaintiff Paid
Date: 04-27-07
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
Curtis . Long, Proth
By:
Deputy
REQUESTING PARTY:
Name FREDERIC E WEINBERG, ESQUIRE
Address: GORDON & WEINBERG, P.C.
21 SOUTH 21sT STREET
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-988-9600
Supreme Court ID No. 41360
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 FIRST CARD CONV
VS.
DENAH TALMADGE
539 HERMAN AVE
LEMOYNE PA 17043
and
Commerce Bank
1249 Market Street
Lemoyne, PA 17043
GARNISHEE
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 06-864 CIVIL
,4h5cD&5 -L,
INTERROGATORIES IN ATTACffi4ENT
TO: Commerce Bank - GARNISHEE
1. You are required to file answers to the following
Interrogatories within twenty (20) days after
service upon you. Failure to do so my result in
judgment against you.
2. At the time you were served or at any subsequent
time did you owe the defendant(s) any money or
were you liable to him (her, them) on any
negotiable or other written instrument, or did he
(she, they) claim that you owed him (her, them)
any money or were liable to him (her, them) for
any reason? Defendant had account 536277197 with a balance of
$1511.27 at time served. Account is held jointly with Troy Talmadge of 12 Ross Ave, New amberland. Account is a
direct deposit accguit _ 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
defendant or in which defendant held or claimed
any interest?
See answer to qu ion "At the time you were served or at any subsequent
time did you hold a fiduciary any property in
No
r 4
which the defendant(s) had any interest?
No
5. At any time before or after you were served did
the defendant(s) transfer or deliver any property
to you or to any person or place pursuant to your
direction or consent and what was the
consideration thereof? Defendant made deposits into the above referenced accoun
in the ordinary course prior to service, none of which were at the direction of Cannerce Bank.
6. At any time after you were served did you pay,
transfer or deliver any money or property to the
defendant(s) or to any person or place pursuant to
his(her, their) direction or otherwise discharge
any claim of the defendant(s) against you?
No
7. How much is the value of any property in your
possession belonging to the defendant(s)?
See answer to question 1.
FREDERIC . WEI ERG, ESQUIRE
PAUL M. SCJUIF?ELD, JR., ESQUIRE
Attorney for Plaintiff
DATED: commerce Bank
3801 Paxton Street
Harrisburg, 11
Date °
?-a
?? ?-'3
?:.? :, ?
-- --i
? - ?
_
ems l
;
.
h? _ ,
., ?
[? -
_" ,gin
{" (?
?? ??
...;.
2023828
ELM
_s
ism
z
s
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 FIRST CARD CONV
VS.
DENAH TALMADGE
and
Commerce Bank
Garnishee
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 06-864 CIVIL
PRAECIPE TO DISSOLVE ATTACM4ENT
TO THE PROTHONOTARY:
Kindly mark the attachment of the defendant's bank account
with Commerce Bank, as Garnishee in the above entitled matter
satisfied and dissolve the attachment of the defendant's bank
account.
GORDON & WEINBERG, P.C.
BY: 1--?
FREDERIC I. WE BE ESQUIRE
PAUL M. SCHOFIELD, JR., ESQUIRE
Attorney for Plaintiff
Poll
";4
Cll) °O
ra
L, pz
r`? Q«K;
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-00864 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
UNIFUND CCR PARTNERS ETC
VS
TALMADGE DENAH
And now SHARON LANTZ
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0013:37 Hours, on the 16th day of May , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
TALMADGE DENAH in the
hands, possession, or control of the within named Garnishee
COMMERCE BANK 1249 MARKET ST AD
LEMOYNE, PA 17043
Cumberland County, Pennsylvania, by handing to
DAVID WAGNER (HEAD TELLER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to His .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
true
and made
So answer :
.00
.00 Moe
.00 R. Thomas Kline
.00 Sheriff of Cumberland County
.00 7 9
00
05/16/20 07
Sworn and Subscribed to
before me this day of
A.D
CS
c?
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs:
Docketing 18.00
Poundage 1.90
Advertising
Law Library .50
Prothonotary 2.00
Mileage 15.36
Misc.
Surcharge 30.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage
Garnishee 9.00
aS? ?
'
s
TOTAL ?
-
?a5
96.76
I b 'V ;? 1 ,1VIJ L001
Advance Costs: 150.00
Sheriff's Costs 96.76
53.24
Refunded to Atty on 04/30/08
4
So Answers,
R. Thomas Kline, eriff
By_0 Lu
Q.F? ?JC?IP
?a
46338?
VW. ; nCjWz
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-864 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due UNIFUND CCR PARTNERS ASSIGNEE OF FIRST
CARD CONV Plaintiff (s)
From DENAH TALMADGE, 539 HERMAN AVE., LEMOYNE, PA 17043
(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
GARNISHEE(S) as follows:
COMMERCE BANK, 1249 MARKET STREET, LEMOYNE, PA 17043.
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 $9,799.54
Interest FROM MARCH 28, 2006 - $517.83
Atty's Comm %
Atty Paid $133.08
Plaintiff Paid
Date: 04-27-07
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
- P', I, A Al
Curti .Long, Pro 0
By:
Deputy
REQUESTING PARTY:
Name FREDERIC E WEINBERG, ESQUIRE
Address: GORDON & WEINBERG, P.C.
21 SOUTH 21sT STREET
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-988-9600
Supreme Court ID No. 41360