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Home My WebLink About06-5296i r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY No. SUCCESSOR TO HNB BANK 1410 COULTER DRIVE ROANOKE VA 24012- Plaintiff VS CIVIL ACTION - LAW STEPHANIE SECHRIST 1505 ENGLISH DR MECHANICSBURG PA 17055 Defendant(s) Filed on behalf of: Plaintiff, BRANCH BANKING & TRUST COMPANY Counsel of record for this party: Date: $ 3/ 6 Amy F. Doyle # 062 / Daniel F. Wolfson #20617 Philip C. Warhol c #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #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, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 147447330 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY :No. SUCCESSOR TO HNB BANK Plaintiff VS :CIVIL ACTION - LAW STEPHANIE SECHRIST Defendant(s) 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 an 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 judgment may be entered against you by the Court without further notice for any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property 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 HELP. 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 South Bedford Street Carlisle, PA 17013- 717-249-3166 CCP Notice to Defend W&A File No. 147447330 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY :No. SUCCESSOR TO HNB BANK Plaintiff VS STEPHANIE SECHRIST Defendant(s) CIVIL ACTION - LAW NOTICIA USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o objeciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013- 717-249-3166 CCP Notice to Defend W&A File No. 147447330 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY SUCCESSOR TO HNB BANK Plaintiff VS STEPHANIE SECHRIST Defendant(s) COMPLAINT :No. D G - .Z 94 :CIVIL ACTION - LAW AND NOW, comes the Plaintiff, by and through its attorneys and the law firm of Wolpoff & Abramson, LLP, and files this Complaint and in support avers as follows: 1. Plaintiff is BRANCH BANKING & TRUST COMPANY SUCCESSOR TO HNB BANK , 1410 Coulter Drive Roanoke, VA 24012-. 2. Defendant, STEPHANIE SECHRIST, is an adult individual with a last known address of 1505 English Dr Mechanicsburg, Cumberland County, PA 17055. 3. An installment loan was issued to the Defendant(s). 4. The Defendant(s) agreed to be responsible for payment of interest, reasonable attorney's fees, and all court and collection costs incurred by Plaintiff in the event of default. 5. That the Defendant(s) defaulted under the terms of the loan. 6. As of the date of this Complaint, the remaining balance due, owing, and unpaid on Defendant's loan balance with Plaintiff is the sum of $12,667.63. A true and correct copy of a Statement of Account identifying the balance due and owing to Plaintiff is attached hereto, incorporated herein, and marked as Exhibit "A". CCP Cmplt - Loan 4 W&A File No. 147447330 7. Pursuant to the applicable Pennsylvania law, any unpaid or delinquent balance on said account shall continue to bear interest at the rate of 6 %. See Exhibit "A" as previously identified and incorporated herein. 8. As of the date of the filing of this Complaint, the amount of interest which has accrued is the sum of $451.87. 9. Despite reasonable and repeated demands for payment, Defendant(s) has/have refused and continue to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 10. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. CCP Cmplt - Loan 5 W&A File No. 147447330 WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant(s) in the amount of $12,667.63, interest in the amount of $451.87, plus costs of this action and any other relief as this Court deems just and reasonable. Respectfully Submitted, Date: 3 0 6 Z'v Amy F. Doyle #870 /Daniel F. Wolfson #20617 Philip C. Warholic 6341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #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, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff CCP Cmplt - Loan 6 W&A File No. 147447330 VERIFICATION The undersigned hereby states that they are the attorney for the Plaintiff who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, they are authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Pleading are true and correct to the best of their knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: _A17/4 Amy F. Doyle #870 / Daniel F. Wolfson #206 Philip C. Warholic 6341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #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, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff CCP Cmplt - Loan W&A File No. 147447330 Exhibit "A" H w a a U H ? 0 H ? ? a lp H VW m \ co >+ o z o a ? a ?o U S4 E N V? R a Ea 7 F Cl z p G O W 0z o O H O U z ry FC ? N m •• U O x N o w o U ur E U W a El a Q Q ° u O C!) H N W H q a H z a a H a s " w z M w u) .. O Q ? H q O H f w W U W M ? x Q o m a N a x a W ° E z x .. c O H W W ?4 x ao P4 v z Q a a E g Q z 7 U z Q ? o u 5 w w m zti ? z 'i 'd H W W H VI N F H y E H q .. £ U x H a u O U El o u0 N H a u a E W x -? W L U U E a o -/H< maC7 x M o a Q a U) M O a 7 E W o x E E w m w C o W U UI ? U) V) d' H H H U ?/] N r . a a a H N <1' U U x U z H u) .. H U a a Q O H H W H x azhq ••rnmU p .. Sr O W C W .. .. z q .. .. W O1 U w .. .. 04 .. N E >+ q H t/) •• U a E CL R W V) W W >E F H •• W E Q H >+ W E a FC w W F z z .. V) CO CL Q q z E C7 zi 5 x a H ?C W H r.? H a z u FE>.Qcn olCw w uQ za H E+ z\ F z W ' U E> U) F E cr) p a1 a s H Z. H W a a) U (D a s C7 H C7 H W Q< a E W q W z z r.? H H U Q Q E H So4HzwQ WU)cl) aaoo Qua w auawwQ am U) 0 ouu ID<0 lk ? d -cl OW SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-05296 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRANCH BANKING & TRUST COMPANY VS SECHRIST STEPHANIE R. THOMAS KLINE Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SECHRIST STEPHANIE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT , SECHRIST STEPHANIE 1505 ENGLISH DRIVE MECHANICSBURG, PA 17055 DEFENDANT DOES NOT LIVE AT 1505 ENGLISH DRIVE. Sheriff's Costs: So ans ,- Docketing 18.00 Service 17.60 Not Found 5.00 R. Tho s._Kline Surcharge 10.00 Sheriff of Cumberland County Postage .39 50.99, WOLPOFF & ABRAMSON 11101.1b& 4, 10/11/2006 Sworn and Subscribed to before me this day of , A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, BRANCH BANKING & TRUST COMPANY No. 06-5296 F/K/A FIRST VIRGINIA CREDIT SERVICES,INC. Plaintiff VS CIVIL ACTION - LAW STEPHANIE SECHRIST Defendant(s) To the Prothonotary: PRAECIPE TO REINSTATE Kindly reinstate the complaint in the above-referenced matter. Respectfully Submitted, Date: i Z- 0 Amy F. Doyle #872 / Daniel F. Wolfson #2061 Philip C. Warholic 86341 /?? Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson 4266 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 VANIA W&A File No. 147447330 Q V G ? ?? c? n ? _ ?, ?'`? - "i?? ' "'? ? 1 r'-` ate ?. SHERIFF'S RETURN - REGULAR .? CEASE NO: 2006-05296 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BRANCH BANKING & TRUST COMPANY VS SECHRIST STEPHANIE JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SECHRIST STEPHAINE the DEFENDANT at HIGHMARK at 1118:00 HOURS, on the 31st day of May 2007 300 CORPORATE CENTER DRIVE CAMP HILL, PA 17011 by handing to STEPHANIE SECHRIST 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 6.00 Service 14.40 Affidavit .00 Surcharge 10.00 .00 GJ13f0? ?,.. ? 30.40 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 06/01/2007 WOLPOFF & ABRAMSON By: A. D. SHERIFF'S RETURN - NOT FOUND • CASE NO: 2006-05296 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRANCH BANKING & TRUST COMPANY VS SECHRIST STEPHANIE R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SECHRIST STEPHANIE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT SECHRIST STEPHANIE 1781 AUTUMNWOOD DRIVE MECHANICSBURG, PA 17055 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: Docketing 18.00 Service 13.44 Not Found 5.00 Surcharge 10.00 Postage 41 4 6. 8 5 So R. Thomas Kline Sh riff of Cumberland County WOLPOFF & ABRAMSON 06/01/2007 Sworn and Subscribed to before me this day of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY F/K/A FIRST VIRGINIA CREDIT SERVICES,INC. Plaintiff No. 06-5296 VS CIVIL ACTION - LAW STEPHANIE SECHRIST Defendant(s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), STEPHANIE SECHRIST , for failure to answer the Complaint. (X) Amount due $13,119.50 TOTAL $13,119.50, 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; 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 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. Doy 87062 / aniel F. Wolfson #20617 Philip C. W olic #86S41 / David R. Galloway #87326 Tonilyn M. Chippie #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, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff NOW, 20QZ, JUDGMENT IS ENTERED AS ABOVE. s PrIthonotary/Clerk, Civil Div' on By: Deputy W&A File No. 147447330 a ? 04 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY F/K/A FIRST VIRGINIA CREDIT SERVICES,INC. No. 06-5296 Plaintiff vs. CIVIL ACTION - LAW STEPHANIE SECHRIST Defendant(s) NOTICE OF JUDGMENT ( x ) Notice is hereby given that a Judgment in the above-captioned matter has been entered against you in the amount of $13,119.50, plus interest, on a5 -,20-01--. ( x ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. By. If you have any questions regarding this Notice, please contact the filing party. Date: oZ- Amy F. Do a #87062 Daniel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #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, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: Stephanie Sechrist 1781 Autumnwood Dr Mechanicsburg PA 17055 W&A File No. 147447330 4u ? a VR p O 8 MAIN OFFICE TWO IRVINGTON CENTRE 702 KING FARM BLID, ROCKVILLE, MD 20850 REGIONAL OFFICES JUDICIAL 10606 G. A-5, FAIRFAX, VA 22030 17 WEST CARY STREET, RICHMOND, VA 23220 5122 GREENWICH RD., VIRGINIA BEACH, VA 23462 919 N. MARKET ST., STE. 1300, WILMINGTON, DE 19899 1 VALLEY BANK BLDG., BOX 1226, CLARKSBURG, WV 26302 4660 TRINDLE ROAD, 3RD FLOOR, CAMP HILL, PA 17011 301 GRANT ST., STE. 4300, PITTSBURGH, PA 15219 28632 ROADSIDE DR., STE. 265, AGOURA HILLS, CA 91301 39500 HIGH POINTE BLVD., STE. 250, NOVI, MI 48375 300 CANAL VIEW BLVD., ROCHESTER, NY 14623 5215 N. O'CONNOP. BLVD., STE. 1060, IRVING, TX 75039 3200 SOUTHWEST FREEWAY, STE. 3300, HOUSTON, TX 77027 111 SOLEDAD ST., STE. 300, SAN ANTONIO, TX 78205 1201 PEACHTREE STREET, STE. 1717, ATLANTA, GA 30361 301 CARLSON PKWY., STE. 303, MINNETONKA, MN 55305 4643 S. ULSTER ST., STE. 800, DENVER, CO 80237 5355 TOWN CENTER RD, STE. 1002, BOCA RATON, FL 33486 LAW OFFICES NATIONAL COLLECTION ATTORNEY NETWORK WOLPOFF & ABRAMSON, L•L•P LLP • OFFICES OFWOLPOFF&ABRAMSON 1' Attorneys in the Practice of Debt Collection BIRMINGHAM, ALABAMA . . FARGO, NORTH DAKOTA (A National Collection Attorney Network Firm) ANCHORAGE, ALASKA CLEVELAND, OHIO 4660 TRINDLE ROAD PHOENIX, ARIZONA OKLAHOMA CITY, OKLAHOMA SUITE 300 LITTLE ROCK, ARKANSAS EUGENE, OREGON CAMP HILL, PA 17011 EAST HARFORD, CONNECTICUT HONOLULU, HAWAII PROVIDENCE, RHODE ISLAM[ COLUMBIA, SOUTH CAROLINj BOISE, IDAHO KNOXVILLE, TENNESSEE (TOLL FREE) CHICAGO, ILLINOIS SANDY, UTAH (800) 830-2793 MERRILLVILLE, INDIANA MILWAUKEE, WISCONSIN KANSAS CITY, KANSAS RAWLINS, WYOMING FACSIMILE (666) 281-9028 LEXINGTON, KENTUCKY METAIRIE, LOUISIANA SEATTLE, WASHINGTON WORCESTER, MASSACHUSETTS PLEASE DIRECT ALL INQUIRIES TO THE CAMP HILL OFFICE ST. LOUIS, MISSOURI GREAT FALLS, MONTANA The National Collection OMAHA, NEBRASKA Attorney Network M an LAS VEGAS, NEVADA affiliation of separate law flan: MANCHESTER, NEW HAMPSHIRE CEDAR KNOLLS, NEW JERSEY W&A Hours of Operation: June 22, 2007 RALEIGH, NORTH CAROLINA 8 a.m. - 6 p.m. M-F STEPHANIE SECHRIST I,? 1781 AUTUMNWOOD DR /? MECHANICSBURG, PA 17055 W&A File No. 147447330 RE: BRANCH BANKING & TRUST COMPANY F/K/A FIRST VIRGINIA CREDIT SERVICES,INC. vs. STEPHANIE SECHRIST Dear Stephanie Sechrist: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, h L/Z?J/- Amy F. Doyle 87062 / Daniel F. Wolfson #20617 Philip C. War olic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #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, Wolpoff & Abramson, L.L.P. Camp Hill, PA 17011 Telephone: (800) 830-2793 Counsel for Plaintiff Enclosure cc: This is an attempt by a debt collector to collect a debt and any information obtained will be used for that purpose IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY F/K/A FIRST VIRGINIA CREDIT SERVICES,INC. Plaintiff vs. NO. 06-5296 CIVIL ACTION - LAW STEPHANIE SECHRIST Defendant(s) TO: STEPHANIE SECHRIST 1781 AUTUMNWOOD DR MECHANICSBURG PA 17055 DATE OF NOTICE: June 22, 2007 IMPORTANT NOTICE Q YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 L/4 Amy F. Doyl ' 4187062 40aniel F. Wolfson #26617 Philip C. Warholic #86Y41 / David R. Galloway #87326 Tonilyn M. Chippie #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, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 147447330 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY F/K/A FIRST VIRGINIA CREDIT SERVICES,INC. No. 06-5296 Plaintiff VS. CIVIL ACTION - LAW STEPHANIE SECHRIST Defendant(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise address of Plaintiff is: Branch Banking & Trust Company 1410 Coulter Drive Roanoke VA 24012 and certify that the last known address of the within Defendant(s) is: Stephanie Sechrist 1781 Autumnwood Dr Mechanicsburg PA 17055 Date: dx'6'4? Amy F. oyle #87 / Dance F. Wolfson Philip C. Warholic 86341 / David R. Galloway #87326 Tonilyn M. Chippie #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, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 147447330 `?a "?) ?i rt1 a a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY F/K/A FIRST VIRGINIA CREDIT SERVICES,INC. Plaintiff No. 06-5296 vs. CIVIL ACTION - LAW STEPHANIE SECHRIST 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, Stephanie Sechrist> above-named, is over 21 years of age; is last known to reside at 1781 Autumnwood Dr, Mechanicsburg, 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: I (" Amy F. Doyle #8062 / D iel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 COMMONWEALTH PENNSYLVANIA Wolpoff & Abramson, L.L.P. Notarial l Seal Amy R. Wise, Notary Public Attorneys in the Practice of Debt Collection Hampden Twp., Cumberland County 4660 Trindle Road, Suite 300 L My Commission Expires Nov. 30, 2010 Camp Hill, PA 17011 Member, Pennsylvania ?.ssociation of Notaries Telephone: (717) 303-6700 Counsel for Plaintiff ??`?Y? SWORN and SUBSCRIBED to before me this day of 20y . -A _k C? /YN% Notary blic W&A File No. 147447330 ??? $..??5,? ? ? 'r1 +"?7 'v '?° ? ?Q C?! r L A PRAECWE FOR WRIT of EXECUTION (MONEY JUDGMENT) P.R.C.P. 31-01 to 3149 BRANCH BANKING & TRUST COMPANY F/K/A FIRST VIRGINIA CREDIT SERVIrCES,INC Plaintiff VS. STEPHANIE SECHRIST Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 06-5296 PRAECIPE FOR WRIT OF EXECUTION .(MONEY JUDGMENT) To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $13,119.50. (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against,STEPHANIE SECHRIST located at 804 DARLA RD, MECHANICSBURG, PA 17055, Defendant(s) (3) and against, COMMERCE BK located at 20 NOBLE BLVD, CARLISLE, PA 17013, Garnishee(s); (4) and index this writ (a) against, STEPHANIE SECHRIST , Defendant(s) and (b) against, COMMERCE BK, 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 COMMERCE BK located at 20 NOBLE BLVD, CARLISLE, PA 17013, 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 $13,119:50 Interest from 07/25/2007 To Be Determined At an interest rate of 6% per year Total $13,119.50 Plus costs & interest Date: f l D i A 4,444 Amy F. D oyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #'87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Ronald S. Canter #94000 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. 147447330 XXX-XX-6402 .? $ y d "' 6 ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5296 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BRANCH BANKING & TRUST COMPANY f/k/a FIRST VIRGINIA CREDIT SERVICES, INC., Plaintiff (s) From STEPHANIE SECHRIST, 804 Darla Rd., 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 GARNISHEE(S) as follows: COMMERCE BANK, 20 Noble Blvd, Carlisle, PA 17013 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 $13,119.50 L.L. $.50 Interest FROM 7/25/07 AT AN INTEREST RATE OF 6% PER YEAR - TO BE DETERMINED Atty's Comm % Atty Paid $234.74 Plaintiff Paid Date: 10/15/07 (Seal) REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone : 717-303-6700 Supreme Court ID No. 87062 Due Prothy $2.00 Other Costs C rtis R. Long, Prothono ry By: ??M A.'o It Deputy SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-05296 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BRANCH BANKING & TRUST COMPANY VS SECHRIST STEPHANIE And now WILLIAM CLINE ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:19 Hours, on the 19th day of October , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT L11r, SnTOM 0MVnTJTATTV hands, possession, or control of the within named Garnishee COMMERCE BANK 20 NOBLE BLVD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to SHILO MAGARO (CUSTOMER SVC REP) 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 ansv'=° r? Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .Dodo 1/ 10131,10 10/22/2007 Sworn and Subscribed to before me this day of By Deputy Sheriff A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY F/K/A FIRST VIRGINIA CREDIT'SERVICES,INC. Plaintiff VS STEPHANIE SECHRIST Defendant(s) TO: COMMERCE BK 20 NOBLE BLVD CARLISLE, PA 17013 No. 06-5296 CIVIL ACTION - LAW PA--)SLA.)eA5 -6 INTERROGATORIES TO GARNISHEE PURSUANT TO RULE 3253 OF THE RULES OF CIVEL 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 SAT4SFY 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. issued. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was 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. 147447330 XXX-XX-6402 r. INTERROGATORIES TO GARNISHEE DEFENDANT S) - STEPHANIE SECHRIST 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 ineach account. If the Defendant(s) maintains any of these jointly with any other person, or persons, give their name and address. No 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. No 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. No 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. No 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 person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? No 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. No W&A File No. 1 474 47 3 30 XXX-XX-6402 Y 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. No 8. PROPERTY HELD AS A FIDUCIARY: At the time you wore 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. No Date: (D 1go y F. Doyle #8706 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 /Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Ronald S. Canter #94000 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. 1.47447330 XXX-XX-6402 VERIFICATION 1-he und(v igncd does hereby venfy subject to the penalties of 1$ PA GS_ 4904 relating to unswom falsifications to authorities. that he/she is Mindi L Sprout (Name) Levy Specialist (T)tle} --- - of Commerce Bank/Harrisburg NA (Company) garnishee herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoine Answers to Intenogatories are true and correct to the best of his/ber knowledge. information and belief (.l ;ATURE) r Ir b WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5296 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BRANCH BANKING & TRUST COMPANY f/k/a FIRST VIRGINIA CREDIT SERVICES, INC., Plaintiff (s) From STEPHANIE SECHRIST, 804 Darla Rd., 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 GARNISHEE(S) as follows: COMMERCE BANK, 20 Noble Blvd, Carlisle, PA 17013 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 $13,119.50 L.L. $.50 Interest FROM 7/25/07 AT AN INTEREST RATE OF 6% PER YEAR - TO BE DETERMINED Atty's Comm % Atty Paid $234.74 Plaintiff Paid Date: 10/15/07 (Seal) REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87062 Due Prothy $2.00 Other Costs MIJIrtis R. Long, Prothonota By: Deputy R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Advance Costs: 150.00 ; Sheriff's Costs 96.19 }?=t1 Docketing 18.00 53.81 Poundage 1.89 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 04/30/08 Mileage 4.80 Misc. Surcharge 40.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 96.19 ? SoiMA?e P"T -W R. Thom Kline, Sheriff By ?t?t9 ,),K l ? h _.15V ?a.f: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING & TRUST COMPANY F/K/A FIRST VIRGINIA CREDIT SERVICES,INC. No. 06-5296 Plaintiff VS CIVIL ACTION - LAW STEPHANIE SECHRIST Defendant(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, COMMERCE BK, discontinued, upon payment of your costs only Respectfully Submitted, Date: a& Amy F. Doyle #87 2 / Daniel F. Philip C. Warholic 8634 Davi R. Gallo #87` Tonilyn M. Chippie # 52 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 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. 14744733+0 J Co cer T 1 r1?1' ncz ^{ -r