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HomeMy WebLinkAbout06-6323 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. CHRISTINE L APPLE Defendant No: COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 05467683 C A Pit KEB IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. CHRISTINE L APPLE Defendant Civil Action No Ole' - COMPLAINT AND NOTICE TO DEFEND 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 in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 w COMPLAINT 1. Plaintiff, CAPITAL ONE BANK is a corporation with offices at 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is adult individual(s) residing at the address listed below: CHRISTINE L APPLE 77 BEECHCLIFF DR CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number 5291151807304181 . 4. Defendant made use of said credit card and has a current balance due of $2775.89 , as of October 11, 2006 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 25.900% per annum on the unpaid balance from October 11, 2006 . A copy of Plaintiff's STATMENT is attached hereto, marked as Exhibit 11111 and made a part hereof. • 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , CHRISTINE L APPLE , INDIVIDUALLY , in the amount of $2775.89 with continuing interest thereon at the rate of 25.900% per annum from October 11, 2006 plus costs. Jarmbrodt,42524 WEINBERG & REIS CO., L.P.A. 4en h Avenue, Suite 2718 Pr , PA 15219 (/41) -7955 F -338-7130 0 3 C A Pit KEB This law firm is a debt collector at emfpting to collect this debt for our client and any information obtained will be used for that purpose. r? 0 r ---r C.:1 0 C3 r " -n r7l rJ t > 1 LF?f r1 SHERIFF'S RETURN - REGULAR CASE NO: 2006-06323 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS APPLE CHRISTINE L SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE APPLE CHRISTINE L was served upon the DEFENDANT , at 1447:00 HOURS, on the 6th day of November , 2006 at 77 BEECHCLIFF DRIVE CARLISLE, PA 17013 BARBARA L BAIR by handing to 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: So Answers: Docketing 18.00 Service 7.92 Affidavit .00 - Surcharge 10.00 R. Thomas Kline .00 35.92,,/ 11/07/2006 WELTMAN WEIN13ERG REIS Sworn and Subscibed to By: ; f , before me this day Deputy Sheriff -.,1,4 of A.D. _., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPI'T'AL ONE BANK, Plaintiff VS. CHRISTINI: L APPLE Defendant No.: 06-6323 PRAECIPE FOR DI;FAUI.,T JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL, OF RECORD OF THIS PARTY: WILLIAM T. M0 1,C.'_AN, ESOUIRE PA I.D.447437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R,,'05467683 Jud(-)ment Amount $ 2927.58 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL, DIVISION CAPITAL ONE BANK, Plaintiff vs. CHRISTINE L APPLE Defendant TO THE PRO"I'll ONO"fARY: Civil Action No.: 06-6323 PRAECIPE FOR DEFAULT JUDGMENT Kindiv enter Judgment against the Defendant, CHRISTINE I, APPLI! above named, in the default of an Answer. III the amount of$2927.58 computed as follows: A11101.1t claimed in Complaint $2775.89 Interest From OCTOBER 11, 2006 to DECEMBER 27, 2006 at the legal interest rate of 25.900% per annum $151.69 TOTAL, $2927.58 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ......_ WILLIAM T. MOLCI ESQUIRE., PA I.D.1147437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh. PA 15219 (412)434-7955 W WR#05467683 Plaintiff's address is: co Weltman. Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 77 BEECIICLIFF DR CARLISLE„PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff Case # Vt1? - LQ 3?3 CHRISTINE L APPLE Defendant (s) IMPORTANT NOTICE TO: CHRISTINE L APPLE 77 BEECHCLIFF DR CARLISLE,PA 17013 Date of Notice: j .l s j WWR#: 05467683 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 FOLLOWING 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 ----- (717) 249-3166-- BY: JAMES W RODT, ESQUIRE PA ID /#412524 WELT. . EINBERG & REIS CO., L.P.A. 2718 K-/GH, RS BLDG, 436 7TH AVE. PITTSBU PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL, DIVISION CAPITAL, ONE BANK, Plaintiff vs. CHRISTINE L APPLE Case no:: 06-6323 NON-MILITARY AFIF IDAVIT Defendant The undersi-ned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duty authorized agent of the Plaintiff in the within matter. Affiam further states that the within Affidavit is made pursuant to and in accordance with the Serviccmcmbers' Ci\ it Relief Act (SCRA), 50 U.S.C. App. § X21. Affiant farther states that based upon investigation it is the affiant's belief that the Defendant, CI-IRISTINE L APPLE is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, CHRISTINE L APPLE is not in the military service. Further Affiant sayeth naught. PAN A SWORN TO AND SIJBSCRIBF,D in my presence this9- -W 11 of . ens NCI) ARY PIJB .IC ' j .'-._ arty C)t p ttsWi tr '-', ounty mycommtsq!Mr- jurV29,2010 of Notaries Memhpr [-his law firm is a debt collector ?ittempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act z . Page 1 of 2 DEC-27-2006 06:16:52 Last Name First/Middle Begin Date Active Duty Status Service/Agency APPLE Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. AWJI Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a sinall error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA inay be involved against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: h tp:!i?w??.detenselin<.mil/faq/p,5!PC09SI,[R.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 12/27/2006 Request for Military Status y? Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BIFTMZDDDGZ https://www.dmdc.osd.nlil/scra/owa/scra.prc_Select 12/27/2006 Z c? M 40 44 c 0 F- I ? 4 i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL., DIVISION CAPITAL, ONE BANK, Plaintiff vs. Civil Action No.: 06-632 CHRISTINI: 1. APPLE Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order yr Judgment was entered against you on _,,J;aA->-J-,--a 0°7 (xx) Assumpsit Judgment in the amount ol'$2927.58 plus costs. ( ) Trespass Judgment in the amount of $____ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, I-larrisbur", PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: _ dva??- PIWTHONO-I ARY (' CHRIS'T'INE: L APPLE: 77 BCECI I CLIIT DR CARLISLFTA 17013 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 1-888-434-0085 qlp? 0. -- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. CHRISTINE L APPLE Defendant COMMERCE BANK, Garnishee, No. 06-6323 PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT and LEVY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5467683 1w 0 --, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. 06-6323 CHRISTINE L APPLE Defendant COMMERCE BANK, Garnishee PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: A de?? o Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against CHRISTINE. L APPLE, Defendant ,17 Uscheli ff br' 0AH,sle PA 17b(3 3. against COMMERCE BANK, Garnishee, b5 "b4d Ave 4. Judgment Amount Belisle, PA $ 2927.58 17013 Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 299.34 $ 3327.34 WELTMAN, WEINBERG & REIS CO., L.P.A. By: Wj (q)4? William T. Molczan, Es ire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5467683 (?1 O Q p .- l p Odd DO D ? 0 c?. t rya -•c W G flip, . r-. r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6323 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK, Plaintiff (s) From CHRISTINE L. APPLE, 77 Beechcliff Drive, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all of defendant's personal property. (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, 65 Ashland Avenue, Carlisle, PA 17013 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 $2,927.58 L.L. $.50 Interest - $299.34 Atty's Comm % Atty Paid $127.42 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 11/03108 (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone : 412434-7955 Supreme Court ID No. 47437 Curtis R. Lo , r onot By: Deputy WWR#5467683 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. CHRISTINE L APPLE Defendant and COMMERCE BANK Garnishee No. 06-6323 y?v'lid - INTERROGATORIES IN ATTACHMENT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5467683 INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? Defendant had account 537402893 held individually with a balance of $144.78. Defendant had account 626929350 held individually with a balance of $4.04. Defendant did not receive $300 exemption. 1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. See answer to question 1 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. See answer to question 1 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? No 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? No 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? No 6. 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 his direction or otherwise discharge any claim of the defendant against you? No 7. 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. Not to the knowledge of Commerce bank. 8. 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. See answer to question 1] WELTMAN, WEINBERG & REIS CO., L.P.A. By. -J William T. Molczan, Es re PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5467683 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist of Commerce Bank/Harrisburg N.A., garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. _ , ?, ? } _..> t? '"?Z ' `t" ? .; t.. ..._. a• t _.,. _r-? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. CHRISTINE L APPLE Defendant COMMERCE BANK Garnishee No. 06-6323 PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE COMMERCE BANK ONLY FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5467683 w • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. CHRISTINE L APPLE Defendant COMMERCE BANK Garnishee Civil Action No. 06-6323 PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE, COMMERCE BANK, ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, COMMERCE BANK, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: _ -AF James C. Wa odt PA I.D #42514 WELTMA , INBERG & REIS CO., L.P.A. 1400 Kop ers ilding 436 Seve th enue Pittsbur , P 15219 5 (412) 4p4;795 WWR#5467683 Sworn to and subscrib d Before me the. Day of DECEMBER COMMONWEALTH OF PENNSYLVANIA Notarial Seal 3200 JennNar M. Borowski, Notary Public city or Pnaburoh, Aftheny CAUL • My commission Expires Feb. 22, 2012 Member. Pennsylvania AssociaW of Notaries N TRY PUBLIC go C,3 04- 1.3a,3 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned SATISFIED. Sheriff s Costs: Docketing 18.00 Poundage 58.55 Advertising Law Library .50 Prothonotary 2.00 Mileage 10.00 Misc. Surcharge 40.00 Levy 40.00 Post Pone Sale Garnishee 9.00 Bad Check Charge Postage / ll TOTAL $ 178.05 ,?:r? Pd by Defendant So Answers; R. Thomas Kline, S eriff i ti- By, Claudia A. Brewbaker 10 :C V 9 - AON 9001 JJ183HS 3H1 jo X014 it ?o -%.2.06 f. ro CK4 4,7399 2 .2146Q? 9 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6323 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK, Plaintiff (s) From CHRISTINE L. APPLE, 77 Beechcliff Drive, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all of defendant's personal property . (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, 65 Ashland Avenue, Carlisle, PA 17013 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 $2,927.58 Interest -- $299.34 Atty's Comm % Atty Paid $127.42 Plaintiff Paid Date: 11/03/08 (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 L.L. $.50 Due Prothy $2.00 Other Costs r c.? Curti. Long ` hb By: Deputy k _ _j ?t? DISTRIBUTION ATTY FOR PLTFF: William Molczan WRIT NO. 2006-6323 Civil Capital One Bank -vs- Christine L. Apple Real Debt $ 2927.58 Interest 299.34 Attorney's Comm. Writ Costs, Atty 127.42 Writ Costs, Pltff. Miscellaneous Attorneys Fees $ 3354.34 Sheriff's Costs: Docketing $ 18.00 Poundage 58.55 Posting Sale Bills Law Library .50 Prothonotary 2.00 Service 10.00 Postage Advertising Postpone Sale Bad Check Charge Surcharge 40.00 Garnishee 9.00 Levy 40.00 TOTAL $ 178.05 Defendant Paid to Sheriff $ 3532.39 Advance Costs 300.00 Total Collected $ 3832.39 DISTRIBUTION Pd. To Pltff. $ 3354.34 Refund of Adv. Costs 300.00 Pd. To Prothonotary 2.50 rs: . R. Thomas Kline, Sherif By ' a"ju IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. CHRISTINE L APPLE Defendant No. 06-6323 PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C Warmbrodt, Esquire PA L D D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05467683 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. CHRISTINE L APPLE Defendant Civil Action No. 06-6323 PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C W brodt, Esquire PA 1. D #4 ?%24 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05467683 Sworn to and sus i e before me this day of wary, 09 NOTARY PVSLIC c0lwoM?TH of PEWSYLVAMA Noland seal da WAK M. S OWSki, Notwy PubNc con,nwN w gVn Feb. 22, 2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. CHRISTINE L APPLE Defendant No. 06-6323 PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C Warmbrodt, Esquire PA I. D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05467683 ., .., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. CHRISTINE L APPLE Defendant Civil Action No. 06-6323 PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C W rnbrodt, Esquire PA I . D #4 4 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05467683 Sworn to and sus i e before me this day of).a§?uary, 09 f1 NOT,4RY PUBLIC cowwoNWMTH OF PENNSYLVANIA Notarial S" Jennifer M. Norowski, Notary Public Car of Plaeburgh. Alia enr count cony dww Feb. A 2072 Member. Pennsylvania A"ocMW of Not0ft R a