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.
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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
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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
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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
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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.
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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
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•
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
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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
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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
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Curti. Long ` hb
By:
Deputy
k _
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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