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Home My WebLink About06-11472019744 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 Genesis Financial Solutions, Inc. as successor in Interest to Conseco Finance d/b/a consumer Finance 8405 Sw Nimbus Ave. Beaverton, OR 97008--718 VS. Virginia A Jenks 6 Pocono Dr Mechanicsburg PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. COMPLAINT IN ASSUMPSIT NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGEMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 1. The defendant, for valuable consideration received, executed and delivered to plaintiff a promissory note under the terms of which the defendant promised to pay to the plaintiff consecutive monthly payments under the terms and conditions set forth in the promissory note. A true and correct copy of the aforesaid promissory note is attached hereto, made a part of this complaint and marked Exhibit "A" 2. Contrary to the terms of the aforesaid promissory note, the defendant failed to make the required payments when due as a result of which the unpaid balance of $4,551.29 became due and payable. 3. As a result of defendant's default, defendant is indebted to plaintiff in the amount of $4,551.29 plus interest thereon and attorney's fees as provided for in the promissory note. 4. Plaintiff has made demand upon the defendant for payment of the amount due but the defendant has failed and refused and still refuses to pay the said sum or any part thereof. WHEREFORE, plaintiff claims of the defendant the sum of $4,551.29 plus interest and attorney's fees as provided for in the promissory note. GORDON & WEINBERG, P.C. BY: FREDERIC I. W INB G, ESQUIRE PAUL M. SCHOFI LD, JR., ESQUIRE Attorney for Plaintiff POIC 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. W NBE , ESQUIRE EXHIBIT "A" Exhibit A Genesis Financial Solutions, Inc. P.O. Box 4865 Beaverton, OR 97076-4865 VIRGINIA A JENKS 6 POCONO DR MECHANICSBURG, PA 17055 Statement of Account Current Statement Date: November 14, 2005 Original Creditor: CONSUMER FINANCE - FUNANCING Original Creditor Account Number: #0007074500100116412 GFS Account Number: #2970411 Charge-off Date: 04/30/03 Principal Balance: $4712.14 Interest Rate: N/A From: 612 664 6222 Virginia A Jenke. 0001074500100111412 Page: 12/40 Date: 11/11/2005 6:49.43 AM 2019744 Genesis Financial Solutions, Inc, as Successor in Interest to Conseco Finance d/b/a Consumer Finance AFFIDAVIT 1, Jeraldf Jensen , being duly served sworn according to law, depose and say that: 1. 2 am the agent for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I has'e personal knowledge of the facts and circumstances in connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages ar,° sought as a direct result of said breach; 5. Afte:: allowing for all offsets and credits, a balance remains on the :aubjeot account having account number 0007074500100115412in the amount of $4,551.29; and 6. If c,illed upon, affiant can testif? trial as to the facts pertaining to tiis mater. n \ A The above facts are true information and belief. tq jtpe pest of 4?r knowledge, Aff Sworn to and Suoscribed -r < before me this day of dB?i?u 2005 Notary Pul:,lic Jerald F. Jen*n Agency and Attorney Network Manager Genesis Financial Solutions, Inc. QF'Ft DOAINA 14 RONDEMA NOTARY PUBUO{1FiEGON COMMISSION No. 37MI MMISSION No. 378081 bBrCOMNNSSION ,PIRESFE8.3,2008 This fax was received by GFI FAXmaker fax server. For more information, visit. http://www.gfi.com IV) IL cri? Y 7 2019744 • 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Consumer Finance VS. Virginia A Jenks COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO 06-1147 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 $4,712.14. 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. EINBE , ESQUIRE PAUL M. SCHO , JR.,ESQUIRE Attorney for Plaintiff Dated: April 4, 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Consumer Finance COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Virginia A Jenks DOCKET NO PRAECIPE FOR JUDGMENT 06-1147 The Prothonotary will please enter Judgment in the above matter by default for want of an answer against the Defendant, Virginia A Jenks, and assesses the damages as p ement below. FREDERIC I. WEINBE , ESQU RE PAUL M. SCHOFIELD, JR., QUIRE. Attorney for Plai Principal $4,551.29 Interest from April 8, 2005 @0% $160.85 Total: $4,712.14 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. i FREDERIC I. WEINBERG, ESQUI E PAUL M. SCHOFIELD, JR. IRE Attorney for Plaintiff Filed: By the Prothonotary: ?j AND NOW, this 0 day of - V 't 2006 Judgment is entered in favor of the plaintiff(s) and against defendant, for want of an answer and damages assessed at the sum of , $4,712.14 as per the above certification. Iq ' -4 1-4 Prothonot ry 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Consumer Finance Vs. Virginia A Jenks COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 06-1147 CERTIFICATION OF ADDRESS I hereby certify that the precise residence of the holder of the within judgment is; Genesis Financial Solutions,Inc. as successor in Interest to Conseco Finance d/b/a Consumer Finance and that the last known address of defendant, Virginia A Jenks, 6 Pocono Dr, Mechanicsburg PA 17055. GORDON & WEINBER^G, P.C. BY: FREDERIC WEINBE ESQUIRE PAUL M. SC E-Pl, JR.,ESQUIRE Attorney for Plaintiff 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Consumer Finance COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Virginia A Jenks DOCKET NO. : 06-1147 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, 6 Pocono Dr, Mechanicsburg PA 17055; 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 Subsscrribed Before me this `T Day 2006. Notary Public CHRISTI ARIA PEtNS? ?vv1A "?. F ubk ftop r 2009 FREDERIC I. WEI , ESQUIRE PAUL M. SCHOFIELD, JR. ESQUIRE Attorney for Plaintiff 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 2019744 Genesis Financial Solutions, Inc. as COURT OF COMMON PLEAS Successor in Interest to Conseco CUMBERLAND COUN',Y Finance d/b/a Consumer Finance Vs. DOCKET NO. : 06--1147 Virginia A Jenks TO/PARA NOTICE OF INTENTION TO TAKE DEFAULT Virginia A Jenks 6 Pocono Dr Mechanicsburg PA 17055 DATE OF NOTICE/FECHA DEL AVISO: March 23, 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 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FREDERIC I. WE NBERG, ESQUIRE PAUL M, SCH ELD, JR., ESQUIRE P10D-2 N IJ cx?, r_? SHERIFF'S RETURN - REGULAR CASE NO: 2006-01147 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GENESIS FINANCIAL SOLUTIONS VS JENKS VIRGINIA A ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - ASSUMPSIT was served upon VIRGINIA A the DEFENDANT , at 1935:00 HOURS, on the 2nd day of March , 2006 at 6 POCONO DRIVE MECHANICSBURG, PA 17055 by handing to VIRGINIA JENKS a true and attested copy of COMPLAINT - ASSUMPSIT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.68 Affidavit .00 Surcharge 10.00 .00 37.68 Sworn and Subscribed to before me this/a! day of allflG A. D. Proth tary So Answers: R. Thomas Kline 03/03/2006 GORDON & WEINBERG B i Deputy Sheriff 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Consumer Finance 8405 Sw Nimbus Ave. Beaverton, OR 97008--718 VS. Virginia A Jenks 6 Pocono Dr Mechanicsburg PA 17055 and Americhoice FCU 2175 Bumble Bee Hollow Rd Mechanichsburg, PA 17055 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 06-1147 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against Virginia A Jenks defendant(s)and (2) against Americhoice FCU garnishee(s) (3) AMOUNT DUE $4,712.14 INTEREST from April 18, 2006 $241.60 COSTS Prothonotary fee $15.00 Sheriff fee $150.00 TOTAL $5,118.74 FREDERIC I. ffINB'RG, ESQUIRE PAUL M. SCH JR., ESQUIRE Attorney for Plaintiff 1 !^ p O ??rJ ?-3 (Aj 0 w fi ?r 46 a c a o -J A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1147 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GENESIS FINANCIAL SOLUTIONS, INC. AS SUCCESSOR IN INTEREST TO CONSECO FINANCE DB/A CONSUMER FINANCE, Plaintiff (s) From VIRGINIA A. JENKS, 6 POCONO DR., MECHANICSBURG, PA 17055 (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 AMERICHOICE FCU, 2175 BUMBLE BEE HOLLOW RD., MECHANICSBURG, PA 17055 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) 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 $4,712.14 Interest FROM 4/18/06 - $241.60 Atty's Comm % Atty Paid $128.68 Plaintiff Paid Date: JULY 6, 2007 (Seal) L.L. $.50 Due Prothy Other Costs iiepury REQUESTING PARTY: Name FREDERIC I. 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 SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-01147 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GENESIS FINANCIAL SOLUTIONS VS JENKS VIRGINIA A And now VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 1526:00 Hours, on the 26th day of July , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT JENKS VIRGINIA A in the hands, possession, or control of the within named Garnishee AMERICHOICE FEDERAL CREDIT UNION 2175 BUMBLEBEE HOLLOW ROAD MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to NICHOLE ELICKER, GREETER , personally three copies of interogatories together with THREE true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing .00 So answers: C Service .00 ?a Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 00 00/ 00/0000 Sworn and Subscribed t before me this o day of f' By Deputy Sheriff A.D GENESIS FINANCIAL IN THE COURT OF COMMON PLEAS OF SOLUTIONS, CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 06-1147 CIVIL VIRGINIA A. JENKS IN RE: CLAIM FOR EXEMPTION ORDER AND NOW, this Z 2-4 day of August, 2007, a hearing in the above matter is set for Friday, September 7, 2007, at 11:00 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. BY THE COURT, 4rederick I. Weinberg, Esquire For the Plaintiff rginia A. Jenks 6 Pocono Drive Mechanicsburg, PA 17055 Cumberland County Sheriff :rlm A f; ! a cs ?'?-IPJ L. 0Z AUG 162007 :IN TEE COURT OF COMMON PLEAS OF- CUZiSERLAND COUNTY, PENNSYLVANIA. WRIT NO.CIVIL TERM To fne Sheriff: CLAIM FOR EXEMPTION . I, the above named defendant, claim exemption of property from levy, or attachment: 1. From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be (i) set aside in kind (specify property to be set aside in kind): (n") paid in cash following the sale of the property levied upon; or (b) I claim the following exemption (specify property and basis of exemption): 2. From my property which is in the possession of a third party, I claim the following exemptions: (a). my $300 statutory exemption: p in cash [3 in kind (specify property):. (b) Social Security benefits on deposit in the amount of $ (c) other (specify amount and basis of exemption): OJ rz 1 request a prompt court hearing to dete=ine the exemption. Notice of the hearing of the hearing should be given to me at: GG? i Address " l Telephone Number I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: THIS CLAIM-To BE FILED WITH THE OFFICE OF TEE SHERIFF OF CU1vIBERLAND COUNTY: CUlvIBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6390 GENESIS FINANCIAL SOLUTIONS, INC., AS SUCCESSOR IN INTEREST TO CONSECO FINANCE d/b/a CONSUMER FINANCE, Plaintiff V VIRGINIA A. JENKS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-1147 CIVIL TERM IN RE: CLAIM FOR EXEMPTION ORDER OF COURT AND NOW, this 7th day of September, 2007, this matter having been called for hearing, the claim for exemption herein filed is granted, and amounts within the control of the garnishee, Americhoice Federal Credit Union, and specifically account number 40154, are herewith deemed exempt from execution. By the Court, (vi- .A .evin/A. Hess, J. Frederic I. Weinberg, Esquire For the Plaintiff Ms. Virginia A. Jenks 6 Pocono Drive Mechanicsburg, PA 17055 :bg 0 w ?r 2019744 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 81894 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Genesis Financial Solutions, Inc. COURT OF COMMON PLEAS as Successor in Interest to CUMBERLAND COUNTY Conseco Finance d/b/a Consumer Finance 8405 Sw Nimbus Ave. Beaverton, OR 97008--718 VS. DOCKET NO. : 06-1147 Virginia A Jenks and Americhoice FCU Garnishee PRAECIPE FOR JUDGMENT UPON ADMISSION TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff, Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Consumer Finance and against the Garnishee, Americhoice FCU, in the amount of $4,284.69, admitted in the Answer to Interrogatories to be in the Garnishee's possession, together with interest and costs. The amount of the judgment of the Plaintiff against the Defendant together with post judgment costs and post judgment interest is $5,460.88. Date: l n,1 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINB RG, ESQUIRE JOEL M. F NK, E UIRE Attorney for Plaintiff 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 ?0i 97yy Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Consumer Finance 8405 Sw Nimbus Ave. Beaverton, OR 97008--718 VS. Virginia A Jenks 6 Pocono Dr Mechanicsburg PA 17055 and Americhoice FCU 2175 Bumble Bee Hollow Rd Mechanichsburg, PA 17055 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 06-1147 INTERROGATORIES IN ATTACHMENT TO: Americhoice FCU - 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? KJO 3. 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? NO 1 vO 4. At the time you were served or at any subsequent time did you hold a fiduciary any property in which the defendant(s) had any interest? W) 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? O b 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)? K qi?g ?q FREDERI I. WBT?BERG, ESQUIRE PAUL M. OFIELD, JR., ESQUIRE Attorney for Plaintiff ??? DATED: MARC R. GORDON FREDERIC I. WEINBERG* JOEL M. FLINK* CHRISTOPHER S. FROBA* *Also member NJ Bar PHONE: (484) 351-0500 FACSIMILE: (484) 351-0501 A t t o r n e y s a t L a w September 17, 2007 Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 RE: Genesis vs. Virginia A Jenks Our File No. : 2019744 Dear Sir/Madam: 1001 E. HECTOR STREET SUITE 220 CONSHOHOCKEN, PA 19428 1200 LAUREL OAK ROAD SUITE 104 VOORHEES, NJ 08043 (Reply to PA office) Enclosed for filing please find an original and two copies of the Praecipe to Enter Judgment on Admissions regarding the above matter. Kindly file same with the Court and return a time-stamped copy in the enclosed self-addressed stamped envelope provided herein for your convenience. Thank you for your attention to this matter. Very truly yours, GORDON & WEINBERG, P.C. FREDERIC I. W NB RG, ESQUIRE FIW/NK cc: Americhoice FCU (w/encl.) E020 www.gordonweinberg.com 00 2019744 t 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Consumer Finance COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. Virginia A Jenks and Americhoice FCU Garnishee DOCKET NO. : 06-1147 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. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL FREDERIC I. WEINBERG, ESQUIRE AT 215-988-9600. vla7/0'7 /5/ " Q Cv, Pza 2019744 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 Genesis Financial Solutions, Inc. as Successor in Interest to Conseco Finance d/b/a Consumer Finance VS. Virginia A Jenks and Americhoice FCU Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 06-1147 PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly mark the attachment of the defendant's bank account with Americhoice FCU, as Garnishee in the above entitled matter satisfied and dissolve the attachment of the defendant's bank account. GORDON & WEINBERG, P.C. BY: FREDERIC I WEI ERG, ESQUIRE JOEL M. FL N ESQUIRE Attorney for Plaintiff Poll f7 1 n 0 00 C L'_ f ' 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: Advance Costs: 150.00 Sheriff's Costs 91.87 18.00 58.13 Docketing Poundage 1.81 Advertising Law Library .50 2.00 Refunded on 05/19/08 Prothonotary Mileage 10.56 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee •00 TOTAL 91.87 51 a P jDt So Answers, Thomas Kline, eriff R. j Byr, ; W ? 4yb?9 3 0 C` -14 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1147 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GENESIS FINANCIAL SOLUTIONS, INC. AS SUCCESSOR IN INTEREST TO CONSECO FINANCE D/B/A CONSUMER FINANCE, Plaintiff (s) From VIRGINIA A. JENKS, 6 POCONO DR., MECHANICSBURG, PA 17055 (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 AMERICHOICE FCU, 2175 BUMBLE BEE HOLLOW RD., MECHANICSBURG, PA 17055 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 $4,712.14 Interest FROM 4/18/06 - $241.60 Atty's Comm % Atty Paid $128.68 L.L. $.50 Due Prothy a,60 Other Costs Plaintiff Paid Date: JULY 6, 2007 (Seal) REQUESTING PARTY: Name FREDERIC I. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, P.C. 21 SOUTH 211T STREET PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-988-9600 Supreme Court ID No. 41360 Lepury