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HomeMy WebLinkAbout06-1845IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff NO. vs. Karen L. King Defendant CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF EXEMPLIFIED JUDGMENT To the Prothonotary: Please enter the attached Exemplified record as a civil judgment. Dated: I Andrew C. Spears #87737 David R. Galloway #87326 Tonilyn M. Chippie #87852 Sarah E.Ehasz #86469 Robert N. Polas, Jr. #201259 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3`d Floor Camp Hill, PA 17011 (717) 303-6700 W&A File No. 106897611 Respectfully Submitted, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff vs. Karen L. King Defendant NO. C)1? - ) yq CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT CAUL Please enter Judgment in favor of Plaintiff and against Defendant(s), Karen L. King , pursuant to the attached Exemplified Judgment Record. ( X) Amount due $7,118.54 Less Post Judgment Credits $0.00 TOTAL = $7,118.54, plus interest & court 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, I 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 occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. n DATE: 3 V Signature: 7 j ./ Amy F. Doyle #8706 fl/ Daniel F. Wolfson #20617 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 /Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3`a Floor, Camp Hill, PA 17011 / (717) 303-6700 NOW, 20 , JUDGMENT IS ENT JED AS ABO E. 21 Proth &otary/ Civil vision By: Deputy OFFICE OF THE PROTHONOTARY Of York County Pamela S. Lee Prothonotary Billie Jo Bones Deputy Prothonotary Gregory E. Gettle Solicitor MBNA AMERCIA BANK NA Plaintiff Vs. KAREN L KING Defendant To Whom It May Concern: York County Judicial Center 45 North George Street York, Pennsylvania 17401 Telephone (717) 771-9611 Case No. 2004-SU-595-Y01 I certify that judgment was entered in favor of MBNA AMRRIC BANK NA and against KAREN L KING on the 27TH day of APRIL, 2004 in said case in the amount of $ 7118.54. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of the Court, on the 7TH day of MARCH, 2006. By Prothonotary XI-76l Deputy YORK COUNTY COURTHOUSE 03103106 PAGE: 1 CIVIL ACTION DOCKET MBNA AMERICA BANK NA CASE NO: 2004-SU-000595-Y31 YK Y01 FILING DATE: 02/26/04 VS. JUDGE: KING, KAREN L PARTY TYPE LITIGANT PARTY NAME -------------------- -------------------- -------- ATTORNEY ------------ -------- P00l WOLFSON, AMY F PLAINTIF F FOR CIVI P00l MBNA AMERICA BANK NA DEFENDAN T FOR CIVI D001 KING, KAREN L DATE -------------------------------- FEE/AMOUNT --------- --------------- -------- 04/27/04 ------------- 00058 00563 *NOTICE GIVEN RE: PA RCP 236 W/DOCUMENTS FILED TO DEFT ON 4/27/04 11AM 04/27/04 00058 00563 AS TO MBNA AMERICA BANK NA 7,118.54 *JUDGMENT BY DEFAULT ENTERED AGAINST= JUDGMENT AMT: $7,118.54 PLUS ATTORNEY'S,COSTS INTEREST DEBTOR(S): <DOOIDEFT >KING, KAREN L 04/27/04 00058 00563 *CERTIFICATE OF RESIDENCE 04/27/04 00058 00563 *AFFIDAVIT OF NON-MILITARY SERVICE 04/27/04 00058 00563 *DEFAULT NOTICE RE: PA R C P 237.1 (DEFENSE) TO DEFT 3/31/04 03/22/04 00039 00110 41.13 *SHERIFF RETURN OF SERVICE CICA SERVED TO KAREN KING 3/10/04 BY YORK CO SHF 02/26/04 00027 00438 113.75 *COMPLAINT IN A CIVIL ACTION= TOTAL NUMBER OF ENTRIES: 7 REQUESTED BY: HMK ******* END OF REPORT ******* CERTIRED from the records of the Court of Common Pleas of York County, Pennsylvania this day of ?\, A.D. 20 Pamela S. Lee, Prothonotary ClS ? IN THE COI iRT OF COMMON PLI of YORK COUNTY. PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff vs. KAREN L. KING Defendant PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff and against Defendant, KAREN L. KING, for want of ANSWER TO COMPLAINT. No. 2004-S U -000595-Y01 (X) Amount due Interest from August 26, 2002 Attorneys Commission Filing Costs TOTAL $ 6,904.79 $ to be determined $ to be determined $ 213.75 $7,118.54 plus costs & interest ( 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, I 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 occurred and at least 10 days prior to the date of the filing of 17 this Praecipe and a copy of the notice is attached. DATE: _ Signature: Amy F; olfson, uire ID# 87062 NOW, ?1/&? CERTIFIED from the records of the Court of Common Pleas of York County, Pennsylvania this day of MQC A.D. 20 Pamela S. Lee, Prothonotary Attorney for Plaintiff 267 East Market Street YORK, PA 17403 (717) 846-1252 200-/ , JUDG NT IS ENTERED AS B E. Prothonotary/Clerk, Civil Division By: K3Z?s Deputy 111'090 580563 M IN THE COURT OF COMMON PLI OF YORK COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff No. 2004-SU-000595-YOI VS. KAREN L. KING, Defendant CERTIFICATE OF RESIDENCE I, Amy F. Wolfson, Esquire, due hereby certify that the last known address of the above referenced Defendant is as follows: KAREN L. KING 1538 BALTIMORE RD DILLSBURG, PA 17019-9751 Respectfully submitted, Date: April 12, 2004' Amy F. Wolfson, Esqu WOLPOFP & ABRAN 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 87062 Attorney for Plaintiff L.L.P. MAIN OFFICE TWO IRVINGTON CENTRE 702 KING FARM BLVD, ROCKVILLE, MO 20850 BRANCH OFFICES 10605 JUDICIAL DR., BLOC. A-5, FA19FAX, VA 22030 1108 E. MAIN ST_ STE. 1003, RICHMOND, VA 23216 5122 GREENWICH RD., VIRGINIA BEACH, VA 23462 919 N. MARKET ST., STE. 1300, WILMINGTON, DE 19899 1954 GREENSPRING DR., STE. 400, TIMONIUM, MD 21093 1 VA11EY BANK BLDG., BOX 1226, CLARKSBURG, WV 26302 2625 TOWNSGATE RD #330, WESTLAKE VILLAGE, CA 91361 267 E MARKET ST., YORK, PA 17403 NATIONAL COLLECTION ATTORNEY NETWORK AFFILIATED FIRM LOCATIONS [NOT BRANCH OFFICES OF WOLPOFF & ABRAMSON LA-P.1' BIRMINGHAM, ALABAMA SAN DIEGO, CALIFORNIA ANCHORAGE. ALASKA EDGEWOOD, COLORADO PHOENIX, ARIZONA FT. LAUDERDALE, FLORIDA CABOT,ARKANSAS NORCROSS, GEORGIA March 31.2004 LAW OFFICES WOLPOFF & ABRAMSON, L.L.P Attorneys in the Practice of Debt Collection (A National Collection Attorney Network Firm) 267 E. MARK ET STREET YORK, PA 17403 (TOLL FREE) 1-800-758-0675 FACSIMILE 717-848-1146 PLEASE DIRECT ALL INQUIRIES TO YORK OFFICE KAREN L. KING 1515 BALTIMORE RD DILLSBURG. PA 17019-9751 RE: MBNA AMERICA BANK, N.A. / KAREN L. KING Docket No. 2004-SU-000595-Y01 (CP YORK COUNTY) Collection Matter Dear Mr/Ms King: We enclose a 10-day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, WOLPOFF & ABRAMSON, L.L.P. A Amy F. Wo fson, Esqu' AFW/llb Enclosure THIS LETTER AND ANY FUTURE LETTERS FROM OUR FIRM ARE AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1 1090 880563 ,a P NATIONAL COLLECTION ATTORNEY NETWORK AFFILIATED FIRM LOCATIONS NOT BRANCH OFFICES OF WOLPOFF & ABRAMSON, L.L.P.1' HONOLULU. HAWAII FARGO, NORTH DAKOTA BOISE, IDAHO CLEVELAND, OHIO MERRILLVILLE INDIANA OKLAHOMA CITY, OKLAHOMA CHICAGO, ILLINOIS EUGENE, OREGON KANSAS CITY, KANSAS PROVIDENCE, RFIODEISLAND LEXINGTON, KENTUCKY COLUMBIA, SOUTH CAROLINA METAIRIE, LOUISIANA KNOXVILLE, TENNESSEE NEEDHAM,MASSACHUSETTS HOUSTON, TEXAS SOUTHFIELD, MICHIGAN SANDY, UTAH MINNEAPOLIS, MINNESOTA MILWAUKEE, WISCONSIN ST. LOUIS, MISSOURI RAWLINS, WYOMING GREAT FALLS, MONTANA OMAHA, NEBRASKA 'The National Collection LAS VEGAS, NEVADA Attorney Network is an aflillatior MANCHESTER, NEW HAMPSHIRE of separate law firms. CEDAR KNOLLS, NEW JERSEY SYOSSET NEW YORK W8A Hens of Operation: n. , RALEIGH, NORTH CAROLINA . a zm. - n p m. E.S.T. cop v U N THE COURT OF COMMON PLE. OF YORK COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff vs. KAREN L. KING, Defendant No. 2004-SU-000595-Y01 (X) Notice is hereby given that a DEFAULT JUDGMENT in the above-captioned matter has been entered against you in the amount f $7,118.54 plus interest, ?/ reasonable attorney's fees and costs, on W ? -7 20 Q 1 . (X) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. I (/- \Sr Prothonotary Civil Division By: (? If you have any questions regarding this Notice, please contact the filing party. Amy F. Wolfson, Esquire 267 East Market Street York, PA 17403 (717) 846-1252 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: KAREN L. KING 1538 BALTIMORE RD DILLSBURG, PA 17019-9751 c.- 11??0? X80 63 _ _, -- __. i ;i ? 6 • dY?l IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff No. 2004-S U-000595-Y01 VS. KAREN L. KING Defendant TO: KAREN L. KING 1538 BALTIMORE RD DILLSBURG, PA 17019-9751 DATE OF NOTICE: March 31, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU FAILED TO TAKE THE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. York County Lawyer Referral Service 137 East Market Street York, PA 17401 (717) 854-8755 BY: 'K/V? "%' "G cffS/T Amy F. Wolf&, Esqui WOLPOFF & ABRA ON, LLP 267 East Market Street York, Pennsylvania 17403-2000 Telephone: (717) 846-1252 I.D. # 87062 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. No. 2004-SU-000595-Y01 Plaintiff vs. KAREN L. KING, Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK I, Amy F. Wolfson, Esquire, 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, KAREN L. KING, above named, are over 21 years of age; is last know to reside at 1538 BALTIMORE RD, DILLSBURG, PA 17019-9751, YORK County, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. n _ Amy F. Wlfson,:Escjdire Attorney or the Plaintiff Attorney fD# 87,(j2 Wolpoff & Abramson, L.L.P. 267 East Market Street York, PA 17403 SWORN and SUBSCRIBED To before me this ?- day Of j"A1 ` 20Lq . Notary Public ;;? '?M1JEAiYk OF PLI?._ h tit 5°dl nw .++??r???? I florn:rec Fc - . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff NO. OL - oIv????jLY?L vs. Karen L. King Defendant CIVIL ACTION - LAW 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, Karen L. King, above named, is over 21 years of age; is last know to reside at 1538 BALTIMORE ROAD, DILLSBURG, 17019, CUMBERLAND County, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. Amy F. / Daniel F. Wolfson #20617 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 / Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 / (717) 303-6700 SWORN and SUBSCRIBED to before me this day of fflFIRCH 20 OLD . Public CO 1 O ALT -4-0""A t"'e"M Seal Gem Goodaln, Nohry Pubk Hampden Twp., Cumberland Cotaty Member, Pennsylvania Aseooletion of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. nn Plaintiff NO. O? UcL ?FJL yr vs. Karen L. King Defendant CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: MBNA AMERICA BANK, N.A. 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON. DE 19884- And certify that the last known address of the within Defendant(s) is: Karen L. King 1538 BALTIMORE ROAD DILLSBURG. PA 17019 P/4 Amy F. Doyle #87062 / Daniel F. Wolfson #20617 W ON Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3`d Floor, Camp Hill, PA 17011 (717) 303-6700 C -?--- ?? ,,,_ b j}'.? 1? -u?. C d F ;? , { _; 4J, r; r , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA MBNA AMERICA BANK, N.A. Plaintiff vs. Karen L. King Defendant NO. CIVIL ACTION - LAW NOTICE OF JUDGMENT ?LVC I, ??/L-? (x) Notice is hereby given that a JUDGMENT in the above-captioned matter has been entered against you in the amount of $7,118.54, plus interest, on (y5„? -.19 2006. (x) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. 121, ki??171_0 Prot onotar?ivisi By: If you have any questions regarding this Notice, please contact the filing party. I ? 414 Amy F. Doyle 11 #87062/ Daniel F. Wolfson #20617 00P Mo / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 /Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3`d Floor, Camp Hill, PA 17011 / (717) 303-6700 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: Karen L. King 1538 BALTIMORE ROAD DI LLSBURG, PA 17019 AUG-11-06 03:01 PM VISA 324 II 0' +, 7955208 IN THE COURT OF COMMON PLEAS OF CUMBERLAND MINA AMERICA BANK, N.A. 655 PAPER HILL ROAD Plaintiff vs. KAREN L KING 5020 RICHARD LANE MECHANICSBURG PA 17055 NO. 06-1845 P.03 COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Defendant(s) IV INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION TO RULE 3114 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING ES HAVE BEEN SERVED UPON YOUR INSTITUTION, GARNISHEE IS HEREBY NSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND E COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE 'FORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE STOR (S) , IPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE are required to file answers to the following Interrogatories (20) days after service upon you. Failure to do so may result gainst you. term "Defendant (A)" means the individual(s) or entity against of Execution was issued, puff means the main office and all branch offices, ,es, employees, and agents of your organisation. service of the Writ of Execution upon you, all property of the subject to attachment which Is in your possession, custody or tached, including all property of the Defendant(s) which comes session thereafter. se Interrogatories are considered to be continuing and iuld be modified or supplemented as you receive further or ,formation. pre exact information cannot be furnished, estimated information plied. When an estimate in to be used, it should be identified an explanation should be given as to the basis on which the lade, and the reason the exact information cannot be furnished. ere knowledge or information in possession of a party is 1ch request includes knowledge of the party's agents. ies, and attorneys. SS# 163 54 1319 W&A FILE NO. 106897611 AUG-11-06 03:02 PM VISA 322 0% 7955208 P.04 PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEPENDANT(S) - KAREN L RING 5020 RICHARD LANE MECHANICSBURG PA 17055 SS/ 163 54 1319 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 ¦o, 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 joint? with any other or persons, give their name and address. Y A?{,? 14(032 Primary -Keureh I- .K%ng SAV1n ZOZ.33 1539 Nithmore 9d- HolidqClub -$351,27 bl?)sburg,t'A (7019 clnecbr? - $ 459.59 b,n} - pbv„\ D. King -&WA Address IA. DIRECT DEPOSIT ACCOUNISs Are any of the accounts you have listed above direct deposit accounts? If yet, please state the identification numbers of those accounts. yOS Rc& --tt- 1910732 2. SAFE DEPOSIT BORES: At the ties you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box w 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 amounl 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. X1 3. PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not Defendant(s) owns any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumbrances or lions 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. 0 4. 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) whlol are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). NV ne 11w9/A?WITT WLA FILE NO. 106897611 HUG-11-06 03:02 PM VISA 323 S 7955208 P.05 3. PROPERTY; At the time you were served or at any subsequent time, was there in' your possession, custody, or control or in the joining possession, custody, or control of yourself and one or more other parsons any property of any nature owned solely or in part by any Defendant(s)? If to, please describe for each Defendant(s) each item of property including its value. Mt 6. REAL PROPERTY: At the time you were served or at any subsequent ties, did you hold legal, or equitable title to any property of any nature owned solely or in part by the Defendant(s) or in which and Defendant(s) held or claimed any interest? If so, describe for each Defendant(s) each item of property including its value and the interest held by the Defendant(s). Nh? 7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If to, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). No' S. TRANSFER OF PROPERTY: At any time before or after you were served, did any Defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent. If so, for each Defendant(s) describe the property transferred or delivered including the dates of delivery or transfer and state the consideration paid. /VU 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 garnish ea or the attorney for the garnishee for the preparation of the Answer. NN n Date: -1' ok.,? Any F. Doyle ta7062 / Daniel F. Noirson psu Philip C. Warholic #66341 / 1 ;; F1:l . David R. Galloway X87326 / Tonilyn Hppi• Ronald H. Abramson #94266 / Ronald S. Canter #94 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 C ? T7 ? CT S? - rz' - c? r+ m F f . - A r ? 2 C w cj m rv 41 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, N.A. No. 06-1845 655 PAPER MILL ROAD MAIL STOP 1411 WILMINGTON DE 19884-1411 Plaintiff vs. I KAREN L KING 5020 RICHARD LANE MECHANICSBURG PA 17055 Defendant(s) PRAECIPE TO S1TTLE AND SATISFY PLEASE MARK THE ABOVE-CAPTIONED ACTION AS SETTLED, SATISFIED AND DISCONTINUED. Respectfully submitted, I /_ By: Amy F. Doyle #87062 / Daniel F. Wolfson #20 Philip C. Warholic #86341 / Andr _ David R. Galloway #87326 onilyn M. Chippie #87 Ronald M. Abramson #94266 Ronald S. Canter #94 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 cc: PAPR4/PA176A W&A FILE NO. 106897611 Z7 t:` ?"? Y r. r 'n L: ? p ..n Lme- 321 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 MBNA AMERICA BANK, N.A. IN THE COURT OF COMMON PLEAS OF 655 PAPER MILL ROAD CUMBERLAND COUNTY, PENNSYLVANIA MAIL STOP 1411 WILMINGTON DE 19884-1411 Plaintiff VS. KAREN L KING 5020 RICHARD LANE MECHANICSBURG PA 17055 Defendant (s) JUDGMENT NO. 06-1845 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary PLEASE ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania; (2) against, KAREN L KING 5020 RICHARD LANE MECHANICSBURG PA 17055 , Defendant (s) ; (3) and against, MEMBERS FIRST FCU 4 MARKET PLAZA WAY MECHANICSBURG PA 17055-565 Garnishee(s); (4) and index this writ (a) against, KAREN L. KING Defendant (s) and (b) against, MEMBERS FIRST 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) *** GARNISH ONLY *** You are directed to attach the property of the Defendant(s) not levied upon in the possession of MEMBERS FIRST FCU 4 MARKET PLAZA WAY MECHANICSBURG PA 17055-565 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 04/27/2004 At an interest rate of 6% per year Dated: (d _-I I $ 7118.54 To Be Determined Total $ 7118.54 Plus costs & interest Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson x{'94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindlp Rnad 3rd F1nnr rmTM- u411 Dn 17M 7 / 177 fi n o 4, P w c ° d CA 4 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1845 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MBNA AMERICA BANK, N.A., Plaintiff (s) From KAREN L. KING, 5020 RICHARD LANE, 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 MEMBERS FIRST FCU, 4 MARKET PLAZA WAY, MECHANICSBURG, PA 17055-565 -- ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the 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 $7118.54 L.L. $30 Interest FROM 4/27/04 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Due Prothy $1.00 Atty Paid $38.00 Other Costs Plaintiff Paid Date: AUGUST 1, 2006 CURTIS R. LONG Prothonotary (Seal) B Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 3RD FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87737 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MBNA AMERICA BANK, NA Plaintiff NO. 06-1845 VS. KAREN L KING Defendant CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, Members First Fcu, discontinued, upon payment of your costs only. Respectfully Submitted, ?p S f Dated: Amy F. D le 062 Daniel F. Wolfson #20617 Philip C. Warholic #86341 Andrew C. Spears #87737 David R. Galloway #87326 Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 (717) 303-6700 W&A File No. 106897611 944 j N? • Y_ W Y +9. ? f ` ? tr F SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-01845 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND MBNA AMERICA BANK N A VS KING KAREN L And now JASON VIORAL ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:45 Hours, on the 11th day of August 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT KING KAREN L hands, possession, or control of the within named Garnishee MEMBERS FIRST FEDERAL CREDIT UNION 4 MARKET PLAZA MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to WENDY ALBERT (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 Her . . in the true and made Sheriff's Costs: So answ Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County 00 08/14/2006 Sworn and Subscribed to before me this day of By ?-^ D uty Sheriff A . D I 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 1.78 Advertising Law Library .50 Prothonotary 1.00 Mileage 9.68 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage .78 Garnishee 9.00 TOTAL 90.74 ? Advance Costs: 150.00 Sheriff's Costs 90.74 59.26 Refunded to Atty on 03/19/07 So Answers; R. Thomas Kline, Sheriff By_ o ( aLtx av b S :Z d 8 - gnv 9001 =`_i 7-p f `yam ,,A ? ? y7g5?J /9a5gs G WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1845 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MBNA AMERICA BANK, N.A., Plaintiff (s) From KAREN L. KING, 5020 RICHARD LANE, 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 MEMBERS FIRST FCU, 4 MARKET PLAZA WAY, MECHANICSBURG, PA 17055-565 -- ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the 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 $7118.54 L.L. $.50 Interest FROM 4/27/04 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Due Prothy $1.00 Atty Paid $38.00 Other Costs Plaintiff Paid Date: AUGUST 1, 2006 CURTIS R. LONG Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 3RD FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87737