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HomeMy WebLinkAbout06-1457IN THE. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA GREATSENECA FINANCIAI CORP. Plaintiff VS WAYNE A MCDONOUGH S MCDONOUGH Defendant(s) No. N( -NS77 CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT ?Gvt,(? l?c/LYrI Please enter Judgment in favor of Plaintiff and against Defendant(s), WAYNE A MCDONOUGH S MCDONOUGH, for want of ANSWER TO COMPLAINT. (X) Amount due Less credits TOTAL $3,954.54 $3,954.54, 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. (X) Pursuant to Pa.R.C.P. 237. 1 certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his(her Attorney of Record, if any, after the default occured and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. Date: Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C, SpeRrs #87737 David R. Galloway #8732 Tonilyn M. Chippie:#? 852 Sarah E. Ehasz #86469 / Robert N. o as, r. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff NOW, ?. 20,(?L, JUDGME [S ENTERED ABOVE. W&A File No. 126431131 c.. Prothonot• JClerk. Cyvil Divlsi( Bv: Deputy n ?; T71? ?. ? r:?;: ?. ?-? i-i'1 _n;? ?:. r _ 1 ' - i- s* ; , r t,? _; ?. COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND 09-2-01 MDJ Name: Hon. PAULA P. CORRRAL Adtlfe$$1 2260 SPRING RD SUITE #3 CARLISLE, PA Teiaphone: (717) 218-5250 17013-0000 ATTORNEY FOR PLAINTIFF : ANY F. DOYLE WOLPOFF r& ABRAM 4660 TRINDLE RD THIRD FL CAMP HILL, PA 17011 v NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME and ADDRESS rGREAT SENECA FINANCIAL CORP 7 4660 TRINDLE ROAD 3RD FLOOR LCAMP HILL, PA 17011 J VS. DEFENDANT: NAME and ADDRESS FMCDONOUGH, WAYNE A, HT AL. ? 1053 REBECCA STREET CARLISLE, PA 17013 L J Docket No.: CV-0000515-OS Date Filed: 11/21/05 THIS IS TO NOTIFY YOU THAT., Judgment: FOR PLAINTIFF ® Judgment was entered for: (Name) ritRLT ammra FTiuxr!T - AT. ROTtA ® Judgment was entered against: (Name) MmnNnvcN, wAm A in the amount of $ 3„ 956.56 on: Defendants are jointly and severally liable. El Damages will be assessed on: El This case dismissed without prejudice. t - Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 $ 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 PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. 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 MAY BE 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. Date (certify that this is a true d correct co of the cord a oc gs ?-/ ?-D 6Date My commission expires first Monday of January, 2012 . AOPC 315-05 DATE PRINTED: 1/16/06 10:04:37 AM (Date of Judgment) lIn9/n6 (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Post Judgment Credits Post Judgment Costs Certified Judgment Total Magisterial District Judge to/ih'"i fthe judgment ,"'fvlagisterial District Judge SEAL 196( 1 i. n jj k; F O cT C ?' C? t i c COMMONWEALTH OF PENNSYLVANIA ' COUNTY OF: CUMBERLAND 09-2-01 MDJ Name: Hon. PAULA;P. CORREAL Add,ess: 2260 SPRING RD SUITE #3 CARLISLE, PA Telephone (717) 218-5250 17013-0000 ATTORNEY FOR PLAINTIFF : ANY F. DOYLE WOLPOFF Ec ABRAM 4660 TRINDLE RD THIRD FL CAMP HILL, PA 17011 NOTICE OF JUDGMENT 41 4SRIP T CIVIL CASE PLAINTIFF: NAME and ADDRESS F GREAT SENECA FINANCIAL CORP 4660 TRINDLE ROAD 3RD FLOOR LCAMP HILL, PA 17011 _J VS. DEFENDANT: - NAME and ADDRESS FRCDONOUGH, WAYNE A, ET AL. 1053 REBECCA STREET CARLISLE, PA 17013 L .J Docket No.: CV-0000515-OS Date Filed: 11/21/05 . w - , .____ I -*iHISi3TU NOT1Fif.YOt1 T1iA+?;?*+t;`^^ - _ y.-,H , , ..? ° , .,_ ._ __ . Judgment FOR PLf?INTIFF - ,, ® Judgment was entered for: (Name) r_sexsT agimCA 1r=NAN_,T., AT, r•012y ® Judgment was entered against: (Name) m®nun>icg, _q_ in the amount of $ a IF 994 -::?4 ow j (Det'e of Judgment) I In9/n6 Defendants are jointly and severally liable. (Date & Time) ;Damages well be assessed on: E This case dismissed without prejudice.' Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 $ -' Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 4 3,863.5 Judgment Costs $ 91.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 3,954.54 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total -- $ ---------- ANY PARTY-HU tF1r A1GR1`YO AIPPEAG WITAIN 50 DAYS AFtEFF'THE ENTRY OF JUDGMENT SY FIttNG--A--NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU - MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. ,. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENT& THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE, UNLESS THE JUDGMENT IS ENTERED[N-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. Magisterial, District Judge i My commission expires first Monday of January, 2012. SEAL, AOPC 315-05 DATE PRINTED: 1/16/06 10:05:06 AM 2 PA J -cni .?q CO' C/A ?1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. No. ©(o - 111,57 Plaintiff VS CIVIL ACTION - LAW WAYNE A MCDONOUGH S MCDONOUGH Defendant(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 1, hereby certify that the precise residence of Plaintiff is: Great Seneca Financial Corp. P.O. Box 165) Rockville MD 20849-1 65 1 and certify that the last known address of the within Defendant(s) is: Wayne A Mcdonough S Mcdonough 1053 Rebecca St 1053 Rebecca St Carlisle PA 17013-1631 Carlisle PA 17013-1631 Date: ab Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. Galloway #873 Tonil n_M. Chino 87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 126431131 M1? ? n cry ' i ?, ?? _? 'f-1 ' ' 1 , ? 1 ? _. : 3 _ ' _ y : 1 _ _i ? . _ . ( "? L' t.s ?1 :{ p IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. No. C>(. - 1y$/ C-lu'C Plaintiff VS CIVIL ACTION - LAW WAYNE A MCDONOUGH S MCDONOUGH 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, Wayne A Mcdonough, above-named, is over 21 years of age; is last known to reside at 1053 Rebecca St Carlisle, 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. Date: l) /? Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. Galloway #8732KT1oni-lyn _M_Chippie # 852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 COMMONWEALM OF PENNSYLVANIA ?y-- No;ardl Se;.! LKberlY Lsenhauar, Notary Public den vm_ Cumberland County mrm,c?on Ex)fres Nov. 17, 7.009 Member °onm,,fi, r55ocialion of Notaries WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff SWORN and SUBSCRIBED to before me this ID day of QCIKj 20OU m itart' Public ? ?; ? s - ?. ? -T, r', c'' ?? nt?__ ?i i c( S'C C.) s- 'i) ? C-? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. No. O(o _ / Y S? ?tvt ???/z 7? Plaintiff VS WAYNE A MCDONOUGH S MCDONOUGH Defendant(s) CIVIL ACTION - LAW NOTICE OF ORDER, DECREE OR JUDGMENT TO: WAYNE A MCDONOUGH S MCDONOUGH 1053 REBECCA ST 1053 REBECCA ST CARLISLE, PA 170131631 CARLISLE, PA 170131631 You are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on a Lk I 4? I .1K in accordance with the provisions of Pa. R.C.P. 236. ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( ) Judgment of ( ) Confession ( ) Verdict ( ) Default ( ) Non-suit ( ) Non-pros ( ) Arbitration Award (X) Judgment is in the amount of $3,954.54, plus costs. (X) District Justice transcript of judgment in civil action in the amount of $2,958.68, attorney's fees in the amount of $0.00, interest in the amount of $904.86, plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's I' e ;wi ed by the. :JEL) Pennsylvania Department of Transportation. By. rothIf you have any questions regarding this Notice, please contact the filing party. Date: 4w"_ Amy F. Doyle #870621 Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew-C,_ Spears #87737 David R. Galloway #873 / Tonilyn M. Chipp 7852 Sarah E. Ehasz #864691 RobertN. PoFas,-Jr . 59 Brice H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON. L.L.P. Attorneys in the Practice of Debt Collection W&A File No. 126431 131 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 f .p 1 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 GREAT SENECA FINANCIAL CORP. ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF HOUSEHOLD/ORCHARD BANK Plaintiff VS. WAYNE A MCDONOUGH Defendant(s) To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $3,954.54 (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against,WAYNE A MCDONOUGH located at 1053 REBECCA ST, CARLISLE, PA 17013-1631, Defendant (s); (3) and against, MEMBERS 1ST FCU located at 1000 BRYN MAWR RD, CARLISLE, PA 17013-1588, Garnishee (s); (4) and index this writ (a) against, WAYNE A MCDONOUGH , Defendant (s) and (b) against, MEMBERS 1 ST FCU, Garnishee (s), as a lis pendens against the real property of the Defendant (s) in the name of the Garnishee (s) as follows: (Specifically describe property) 1053 REBECCA ST CARLISLE, PA 17013-1631 All personal property of any nature located within the household or immediate vicinity of the Defendant(s) address and all other personal property within the dominion and control of the Defendant(s) wherever it is located shall be subject to the levy. ALSO: You are directed to attach the property of the Defendant (s) not levied upon in the possession of MEMBERS 1 ST FCU located at 1000 BRYN MAWR RD, CARLISLE, PA 17013-1588, 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 3/15/2006 At an interest rate of 6% per year Date: $3,954.54 To Be Determined IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 06-1457 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) $3,954.54 Plus costs & interest Amy F. Doyle 87062 / Danie o Philip C. Warh is #86 / avi R. Galloway #8732 Tonilyn M. Chippie # ar Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 126431131 XXX-XX-3061 cz? K? `o r- 0 ?t4 cf i f=- 44 ` pr ' un a SU V't o to $ Q ? O rr . '+?? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1457 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP. ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF HOUSEHOLD/ORCHARD BANK Plaintiff (s) From WAYNE A MCDONOUGH, 1053 REBECCA ST, CARLISLE, PA 17013-1631 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE VICINITY OF THE DEFENDANT'S ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FCU, 1000 BRYN MAWR RD, CARLISLE, PA 17013-1588 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. 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 $3,954.54 L.L. $.50 Interest FROM 3/15/06 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $46.25 Plaintiff Paid Date: 04-27-07 (Seal) Due Prothy $2.00 Other Costs Curtis k Long, Pr nota By: Deputy REQUESTING PARTY: Name DAVID R GALLOWAY, ESQUIRE Address: WOLPOFF & ABRAMSON, LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 w r ??* Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87326 .1? Y" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF HOUSEHOLD/ORCHARD BANK Plaintiff No. 06-1457 VS WAYNE A MCDONOUGH CIVIL ACTION - LAW Defendant(s) ?n5wers INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION TO: MEMBERS 1 ST FCU 1000 BRYN MAWR RD CARLISLE, PA 17013-1588 PURSUANT TO RULE 3253 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. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, and an explanation should be given as to the basis on which the estimate 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. W&A File No. 126431131 XXX-XX-3061 J PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - WAYNE A MCDONOUGH 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. V`C& 2-347(o I SON 0s 0,6_7 , Ch Cf_-kk nr - A 15.35 - Su lan VV fynoo# s'?u. ?ddrl?, ACGV, 30;3L3 --,,,T - $ DM,C}necbA 47,D5 -5uzz(Kn PkC0Mkg l IA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. ?Nuc . 2.34-741 2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. Nx 3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. 2?? t? 1 E 3D23?k3 4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any pers n or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? 14O 5. 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. N O W&A File No. 126431131 XXX-XX-3061 6. REAL OR 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. No 7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset. 8. 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 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. Date: J Amy F. Doyle 87062 / Daniel F. Wolff NLn 10061 Philip C. Warh lic #86 avid. Galloway #873.2 Tonilyn M. Chippie #8 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 126431131 XXX-XX-3061 c O li l ? .L , - _1 rT R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, DUE TO BANKRUPTCY. Sheriff's Costs: Docketing $ 18.00 Poundage 2.39 Advertising Law Library .50 Prothonotary 2.00 Mileage 9.60 Surcharge 40.00 Levy 40.00 Post Pone Sale Garnishee 9.00 Postage ? ? a ? ? D ? ?? TOTAL $ 121.49 Advance Costs: 150.00 Sheriff's Costs: 121.49 28.51 Refunded to Atty on 06/27/07 So Answers- R. Thomas Kline, heriff . By?j 0,QI Q? ?c- J WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1457 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP. ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF HOUSEHOLD/ORCHARD BANK Plaintiff (s) From WAYNE A MCDONOUGH, 1053 REBECCA ST, CARLISLE, PA 17013-1631 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE VICINITY OF THE DEFENDANT'S ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FCU, 1000 BRYN MAWR RD, CARLISLE, PA 17013-1588 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. 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 $3,954.54 L.L. $.50 Interest FROM 3/15/06 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $46.25 Plaintiff Paid Date: 04-27-07 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs Curti . Long, Pro ry By: Deputy Name DAVID R GALLOWAY, ESQUIRE Address: WOLPOFF & ABRAMSON, LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-01457 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GREAT SENECA FINANCIAL CORP VS MCDONOUGH WAYNE A ET AL And now MICHAEL BARRICK ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:47 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 MCDONOUGH WAYNE A hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BETH WAGNER (ASST MANAGER , in the personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: So answers: Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 06/11/2007 Sworn and Subscribed to before me this day of By Deputy Sheriff A.D