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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