Loading...
HomeMy WebLinkAbout01-5057COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CO~BERT.,~TD 09-3-02 HELEN B. S~.tU~.ENBERGER ~d~e~: P.O. BOX 155 2~ ~. BI~ SPRING A~ua ~LLE, P~ Telephone: (717) 776-3187 17241 CITIBANK P. O. BOX 356 C/O OLIN NEIL & HALTRECHT WEST CHESTER, PA 19381-0356 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS i-CITIBANK P. O. BOX 356 C/O OLIN NEIL & HALT~ECHT ~EST CHESTER, PA 19381-0356 VS. DEFENDANT: NAME and ADDRESS CFO~iEY, MAEK A. 60 BIG SPRING AVE~u~ NEWVILLE, PA 17241 IDocket No.: CV-0000044-01 Date Filed: 3/19/01 THIS IS TO NOTIFY YOU THAT: Judgment: [] Judgment was entered for: (Name) ]Judgment was entered against: (Name) in the amount of $ FOR PT,AT~TFF 4, '7~;? _ 1 a on: (Date of Judgment) [~] Defendants are jointly and severally ~iable. ~ Damages will be assessed on: r--[This case dismissed without prejudice. ~'] Amount of Judgment Subject to Attachment/Act 5 of 1996 $ [] Levy is stayed for days or I-'-~' generally stayed, (Date & Time) Amount of Judgment $ 4. 656.6(] Judgment Costs $ 100.5(] Interest on Judgment $ .0(~ Attorney Fees $ .0¢ Total $ 4,757.10 Post Judgment Credits $. Post Judgment Costs $. Certified Judgment Total $ ~] Objection to levy has been filed and hearing will be held: Date: Place: Time: 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. 5-~ -o / Date /'~.~_~-.~ ,~.~ ~.~ ,District Justice 1 certify that this is a true and correct copy of the record of the proceedings containing the judgment. ~/,O-~//-/~"~/Date ~ I~ ~ ,Districtdustice My commission expires first Monday of January, AOPC 315-99 2006 SEAL 'COMMONWEALTH OF PENNSYLVANIA COUNTY OF: Cumberland Mag, Dist. No.: 09-3-02 DJ Name: Hon. Helen B. Sholenberger ^ad .... 27 W. Big Springs Road Newvllle, PA 17241 Telephon®: 717-776-3187 A._~ N~ DATE PAID FILING COSTS $ / I SERVING COSTS :~ Il CIVIL COMPLAINT PLAINTIFF: NAME and ADDRESS r CITIBANK (SOUTH DAKOTA) N.A. cio Olin Nell & Haltrecht LPO Box 356 West Chester, PA 19381-0356 VS. DEFENDANT: NAME and ADDRESS rMARK A. FORNEY 60 Big Spring Avenue LNeWville, PA 17241 Docket.o.: Date Filed: TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $4,656.60 together with costa upon the following claim (Civil fines must include citation of the statute or ordinance violated): For past due balance for goods and merchandise purchased and/or cash advances by defendant on a credit card issued by Plaintiff plus attorneys fees per terms and conditions of account. $3,725.28 Principal $.00 Interest $931.32 Attorneys Fees $.00 Credit $4,656.60 Balance I, Burton Nell, Esclu re, Atty for Plaintiff, verify that the facta set forth in this compl~l~t~rue and correct to the best of my knowledge, information and belief. This statement js~fiade subje, et t~ the penalties of Section 4904 of the Crimes Code (18 PA. C. S. § 4904) related to unsworn f~lsification to,~t~l~rities. //~ ..... ~ gn~rre of Plaintiff or Authorized Agent) Plaintiff's Attorney:. Burton Nell Address: PO Box 356 Telephone: 6t0-696-3030 West Chester, PA 19381-0356 IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT WILL BE ENTERED AGAINST YOU BY DEFAULT. if you have a claim against the plaintiff which is within district justice jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five (5) days before the date set for the hearing, if you have a claim against the plaintiff which is not within district justice jurisdiction, you may request information from this office as to the procedures you may follow. If you are disabled and require assistance, please contact the Magisterial District office at the address above. ,,' AOPC 308A-98 · OLIN,.NEIL & HALTRECHT By Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-3030 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. 701 E. 60~ Street N Sioux Falls, SD 57117 Plaintiff VS. MARK A. FORNEY 60 Big Spring Avenue Newville, PA 17241 Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA o,- : CIVIL ACTION - LAW Certification of Address and Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment creditor and debtor. 2. The said defendant is not in the Military Service of the United States or its Allies or otherwise within the coverage of the Soldiers' and Sailors' Relief Act of 1940, as amended, is over 18 years of age and has a civilian occupation. OL~,~N L & HALTRECHT Burton Ne~, Es~tfire Attorney for Plaintiff In making this communication, we advise that our finn is a debt collector. PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. MARK A. FORNEY Defendant(s) F&M TRUST Garnishee(s) : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-5057 : CWIL ACTION - LAW To the Prothonotary: 1. 2. 3. 4. ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER Directed to the Sheriff of Cumberland County, Pennsylvania against MARK A. FORNEY , Defendant(s) and against F&M TRUST , Garnishee(s) and index this writ (a) against Defendant(s) (b) against 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) NO LEVY-GARNISHMENT ONLY Serve interrogatories on garnishee at: 1901 Ritner Highway, Carlisle, Pa 5. Amount Due $4,757.10 Credit $ 156.00 Interest from 5/2/01 $ 178.15 Total $4,779.25* *Plus writ costs Dated: December 18, 2001 ...... Burton Neil, Esquire Attomey for Plaintiff NOTE: Under paragraph I when the writ is directed to sheriffofanother countyas authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the count in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). The firm of Olin Nell & Haltrecht is attempting to collect a debt. SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-05057 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND CITIB~kNK VS FORNEY MARK A And now DOUGLAS DONSEN Cumberland County of Pennsylvania, to law, at 0010:15 Hours, on the as herein commanded all goods, chattels, moneys of the within named DEFENDkNT FORNEY MARK A ,Sheriff or Deputy Sheriff of who being duly sworn according 2nd day of January , 2002, attached rights, debts, credits, and , in the hands, possession, or control of the within named Garnishee F & M TRUST 1901 RITNER HIGHWAY CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to DIAixrNA STOUFFER (HEAD TELLER) , personally three copies of interogatories together with 3 true and attested copies of the within JUDGMENT - DJ and made the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this '7~ day of ~ A.D. 45zWot~honotary t , , So answ s · . R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo ~eputy Sheriff BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire 'Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. MARK A. FORNEY Defendant and F&M Trust Garnishee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5057 : CIVIL ACTION - LAW Praecipe to Dissolve Attachment To the Prothonotary: Dissolve the attachment against F&M Trust, garnishee. BURT~oc~.C. BY: ~0 Burton Neil, Esquire Attorney for Plaintiff In making this communication, we advise that our firm is a debt collector. 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./43 Advertising ~ Law Library .50 Prothonotary 1.00 Mileage 3.25 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee 9.00 73.18 Advance Costs: 150.00 Sheriff's Costs: 73,18 Refunded to Atty on 7/3/02 Sworn and Subscribed to before me this ff~_~__ day of ~v~b 2002 A.D. ~~ ~ So Answers; R. Thomas Kline, Sheriff WRIT OF EXECUTION and/or A'rFACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland To satisfy Ihe debt, interest and costs due NO. COUNTY: Citibank (South Dakota) N.A. from Mark A. Forney, 60 Bi9 Spring Avenue, Newville, PA 17241 CIVIL CIVIL ACTION - LAW PLAINTIFF(S) DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and fo sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of F&M Tr~st - Serve interroqatories on .qarnishee at: 1901 Ritner Highway, Carlisle, PA 17013 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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 lo attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her t hat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,757.10 L.L. $. 50 Interest frc~ 5/2/01 $178.15 Due Prothy $1.00 Atty's Corem % Other Costs Atty Paid $32.23 Plaintiff Paid Date: December 21, 1001 Curtis R. Long REQUESTING PARTY: Name Bg~ton Neil, Esq. Address: __ 26 South Chu~_ch Street P.O.Box 356 West Chester, PA 19381-0356 Attorney for: Plaintiff Telephone: 610-696-3030 Supreme Cou~ ID No. 11348 Prothonotary, Civil Division (' Deputy