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Home My WebLink About97-06065 ~ J / t. ,~ ~ J Ji L.() .3 o ..:J JOEL STEINMAN, ESQUIRE Attorney 1.0. #62042 MELVYN S MANTZ & ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS VS Defendant NO. C/7-606S" Ciud~ DONNA L. SAYERS NOT I C E 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 other claims 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. Court Administrator Pourth Ploor, C\~erland County Courthouse Carlisle, PA 17013 (717) 240-6200 JOEL STEINMAN, ESQUIRE Attorney 1.0. #62042 MELVYN S MANTZ & ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS VS Defendant NO. t17- 6~6 S" u;.:.IT~ DONNA L. SAYERS CIVIL ACTION 1. The Plaintiff is providian National Bank f/k/a First Deposit National Credit Card Bank, a national bank with a place of business located at 53 Regional Drive, Concord, NH. 2. The Defendant is Donna L. place of residence located at 970 17324. Sayers, an individual with a Myerstown Road, Gardners, PA 3. At the request of the Defen~ant, Plaintiff issued to Defendant a VISA credit card, account number 4428231771607493 and at all times relevant hereto, Defendant was the holder of said card issued through Plaintiff's credit facilities. A true and correct copy of Defendant's application is attached hereto, made a part hereof and marked Exhibit "A". 4. Defendant, upon acceptance of Plaintiff's credit card, agreed to be bound by the terms and conditions of Plaintiff's revolving credit plan agreement. A true and correct copy of said agreement is attached hereto, made a part hereof and marked Exhibit "B". 5. The Defendant subsequently received a cash advance from Plaintiff and incurred additional obligations in the sum of $8,325.88, no part of which has been paid since 18 JUN 1997 although duly demanded. 6. Notwithstanding the frequent demands by Plaintiff for payment of the amount due, there has been a failure and refusal by the Defendant to pay the same or any part thereof. 7. In accordance with the terms of Exhibit liB", Defendant agreed to pay the Plaintiff a finance charge on all sums due at an annual percentage rate of 23.90% and Plaintiff is entitled to additional finance charges from 19 JUN 1997. 8. In accordance with the terms of Exhibit liB", Defendant agreed to pay to Plaintiff a reasonable attorney's fee if the account was referred to an attorney for collection, and Plaintiff will incur an attorney's fee in the amount of $1,665.00. WHEREFORE, in the sum of attorney's fees of this action. Plaintiff demands judgment against the $8,325.88 plus interest from 19 JUN of $1,665.00 for a total of $9,990.88 Defendant 1997 plus and costs PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. FROM Mf~TZ ~ RSSOC. TEL: 215 348 4015 OCT. 7. 1~7 9:10 AM P 6 ST1,TB OF CALIPOKNIA COUNTY OP ALAMEDA DarIa Antone, states that she is the De.ignated Agent ot Providian National Bank and is authori~ed to take this affidavit on ita behalf and that the facts set forth in the foregoing complaint are true and correct to the best of her information, knowledge and belief; that t~ere is now due and owing from Donna L. Sayar. the .um of f8,]25.B8 plus interest and attorney fees; and that. there are no deductions or offsets of any kind, except as are therein specified and credited. She further understands that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. iD~Jh {lJ-v/th'\.f DARLA ANtONB, DESIGNATED AGBNT 44282]1771607493 till v.f.Cf.\~f.O ~ 7.? \~~l \1-" ",r-~.fZ. "'tt~~~C\p..1~& (3; . \. 1 ~ ~ e. .~ ~ ~ I-Q *' -. 1k , " \n t::- ~ '\:t-. 00 t'.,\n ~ i ~ ~ . L . "," -, .. .:~,\ ",,~ ; t>, ...:.;. . 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JOEL STEINMAN, ESQUIRE Attorney 1.0. #62042 MELVYN S MANTZ & ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE TRUE & CORRECT ADDRESS IS: PLAINTIFF: 4940 Johnson Drive Pleasanton, CA 94588 DEFENDANT: 970 Myerstown Road Gardners, PA 17324 PROVIDIAN NATIONAL BANK plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS DONNA L. SAYERS Defendant NO. 97-6065 PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Please enter Judgment in favor of the Plaintiff Defendant for failure to plead or otherwise respond assess the damages as follows: and against the said to the Complaint and AMOUNT OF CLAIM PLUS ATTORNEYS FEES LESS - Amount paid on account PLUS - Interest from 06/18/97 to 12/31/97 $8,325.88 $1,665.00 $.00 $1,063.09 $11,053.97 PLUS COSTS TOTAL 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. I certify that written notice of the was mailed or delivered to the party entered and to the attorney of record, if intention to file this Praecipe against whom judgment is to be any, after the default occurred to the date of the filing of this the notice pursuant to Pennsylvania .tt;S::~~:~to~ mo,k.d Exhibit J~EL~ ESQUIRE , ATTORNEY FOR THE PLAINTIFF NOW, -r tl1,L.tL ~ V i (1, / t1 ~ X , Judgment is entered favor of the p~intiff andl against thJ ITefendant by Default for want of an Answer and damages assessed at the sum of $11,053.97 as per above certification. and at least ten (10) days prior Praecipe. A true and correct copy of Rule of Civil Procedure No. 237.1 is "A". AND t2 ~~I () PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. /t ( ~ V1..'{U PROTHONOTARY -, JOEL STEINMAN, ESQUIRE Attorney I.D. ~62042 MEL'IYN S MANTZ & ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, P~ 18901 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK Plaint if f ;1 CUMBERLAND COUNTY COURT OF COMMON PLEAS VS DONNA L. SAYERS Defendant NO. 97-6065 NOTICE or PRABCIPB rOR BNTRY or DErAULT JUDGMBNT TOI Donna L. Sayers 970 Myerstown Road Gardners, PA 17324 DATE OP NOTICE I 12-18-97 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTT.CE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service CUmberland CQunty Court Administrator 4th Ploor - CUmberland County Courthouse Courthouse Square Carlisle, PA 17013 (717) 240-6200 MEL~' . A~IATES. BY :~---......._. JOEL STEINMAN, ESQUIRE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. P.C. \ JOEL STEINMAN, ESQUIRE Attorney I.D. #62042 MELVYN S MANTZ & ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY plaintiff COURT OF COMMON PLEAS VS DONNA L. SAYERS Defendant NO. 97-6065 VERIPICATION OP NON-MILITARY SERVICE Joel Steinman, Esquire, being duly sworn according to law, deposes and says that he will make this affidavit on behalf of the within Plaintiff, being fully authorized to do so, and that to the best of his knowledge, he believes and therefore avers, that Donna L. Sayers, Defendant, is over 21 years of age; that his/her place of residence is located at 970 Myerstown Road Gardners, PA 17324, and that he/she is employed and that he/she is not in the Military of Naval Service of the United States or its Allies or otherwise with in the provisions of the Soldiers and Sailor Civil Relief Act of Congress of 1940 and its amendments. Joel Steinman, Esquire, further understands that false statements made herein are subject to the penaltie 9 18 Pa.C.S., Section 4904, relating to unsworn falsification to aut 'rli~' , ( JOEL STEINMAN, EIRE ATTORNEY FOR PLAINTIFF PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IT IS REQUIRED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. JOEL STEINMAN, ESQUIRE Attorney 1.0. #62042 MELVYN S MANTZ & ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS VS DONNA L. SAYERS Defendant NO. 97-6065 NOTICB Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: ( X ) ( ) ( ) ( ) ( ) ( ) ( ) Judgment by Default Money Judgment Judgment in Replevin Judgment in Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Melvyn S Mantz.. Associates. P.C. at this telephone number: (215) 348-5200. PROTHONOTARY: _ _ /! LL'L (LJ. _ _ i2_ L..b'1l-~-- PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT. IT IS REQU"ED THAT WE STATE THE FOLLOWING TO YOU: THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ." .~ \...-... ro' ,. ~. [. ,,- l>C / ... .. ('.~ , .. 1---. r I" ( , h~ ~ _ 4 C, r-.l (. li_, ; d LL' :: ; . , " r. u L- V' ~ ~ j ~ '" --.J I' .' ~ I -l , I '- "" N ,>.. lL 0 ~~ ,...... I..> '1.- ......... '\ ',j rn" ~""" .......... "-' ~; JOEL STEINMAN, ESQUIRE Attorney 1.0. #62042 MELVYN S MANTZ & ASSOCIATES, P.C. 25 East State Street Doylestown, PA 18901 215/348-5200 ATTORNEY FOR PLAINTIFF r~1 ''':> ,U) " , providian National Bank Plaintiff I " CUMBERLAND COUNTY, COURT OF COMMON FLEAS " VS "-d Defendant NO. 97-6065 , , I.'. J ., DONNA L. SAYERS ORDER AND NOW, this ~ day of ~, 1998, upon consideration of the Plaintiff's Motion to Compel Answers to Discovery in Aid of Execution, pursuant to Pennsylvania Rule of Civil Procedure No. 4019, it is ORDERED that Donna L. Sayers serve upon Plaintiff full and complete answers to Plaintiff's Interrogatories in Aid of Execution and Plaintiff's Request for production of Documents in Aid of Execution within twenty (20) days of the date of service of this Order. BY THE J. iJ I I f~ I I I I .~ l>o . ~~ ... '1 \;;' 1 4 F it JOEL STEIt~, ESQUIRE Attorney 1.0. #62042 MELVYN S MANTZ & ASSOCIATES, 25 East State Street Doylestown, PA 18901 215/348-5200 ATTORNEY FOR PLAINTIFF P.C. providian National Bank Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS VS DONNA L. SAYERS Defendant NO. 97-6065 MOTION TO COMPBL ANSWERS TO DISCOVERY IN AID OP BXECUTION The plaintiff by its attorneys, Melvyn S Mantz & Associates, P.C. hereby moves this Court to enter an Order pursuant to Pennsylvania Rule of civil Procedure No. 4019 directing Donna L. Sayers to serve upon Plaintiff full and complete Answers to Plaintiff's Interrogatories For Discovery of Assets in Aid of Execution and Plaintiff's Request for production of Documents in Aid of Execution, as more particularly set forth in the attached Order or suffer such further sanctions as the Court may enter and in support thereof avers as follows: 1. That on or about 01-12-98, a Judgment was entered against the Defendant, Donna L. Sayers, and damages were assessed in the sum of $11,053.97, plus interest from December 31, 1997 and costs. 2. That on March 9, 1998, Donna L. Sayers was served with an original and requisite copies of Plaintiff's Interrogatories for Discovery of Assets in Aid of Execution. A true and correct copy of the Interrogatories are attached hereto, made a part hereof and marked Exhibit "A". 3. More than thirty (30) days have elapsed since service of Plaintiff's Request for Interrogatories and Defendant, Donna L. , JOEL STEINMAN, ESQUIRE Attorney I.D. ij62042 MELVYN S MANTZ' ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK Plaintiff " CUMBERLAND COUNTY COURT OF COMMON PLEAS VS DONNA L. SAYERS Defendant NO. 97-6065 INTERROGATORIBS FOR DISCOVERY OF ASSETS IN AID OP BXBCUTION TO: Donna L. Sayers 970 Myerstown Road Gardners, PA 17324 Because you have failed to pay the full amount of the Judgment previously entered against you, the Judgment Creditor, to whom you are indebted, has a right to attempt to enforce the Judgment by a Judicial Sale (Sheriff's Sale) of your assets and has a right to inquire concerning the existence and location of those assets. Therefore, pursuant to the applicable Rules of Court, you are required to make full and complete Answers to the questions set forth in the following pages. These Answers ~ust be made in writing, under oath, within thirty (30) days after service upon you. You are warned that, should you fail to do so, the Court may make an Order imposing punishment for Contempt of Court. If you have an interest in any property which would refer to any question set forth below and that interest is owned (and/or enjoyed) by you with another, you are required to answer the specific question noting the interest of the other person including that person's name, address and telephone number. Please, if you do not understand questions, you should consult a lawyer. If lawyer, then you should go to or telephone to find out where you can get legal help. your duty you do not the office to answer these have or know a set forth below tawyer R9ferral Service CImlerland county Bar Association 2 Uberty Avenue G1rUs1e, Pennsylvania l7013 (717) 24l}-3l66 f 1. REAL ESTATBI Does the Defendant have an ownership or interest in any real estate anywhere in the United States? If so, set forth a brief description thereof, include the structure and lot size and type of construction; the location, including the state, county, and municipality; the volume and page number of the official record thereoE; and state further whether the Defendant owns it solely or together with any other person or persons and give their full names and addresses. Supply the current value of the properties and the basis for the valuation (estimate, tax assessment, appraisal, etc.). If any of the above properties are mortgaged, supply the names and addresses of lenders, the date and amount of the mortgage, where it is recorded, the monthly payments and the balance now due. Also, supply the purchase date, purchase price and the name of the party from whom the property was purchased. 2. TRANSPERS OP REAL ESTATEI In the six years preceding to the date of these Interrogatories has the Defendant trausferred any real property either by sale, gift, exchange, or otherwise? If so, please give a description of the property so transferred, the method or manner of transfer, the name of the peI'son, firm or other entity to whom transferred, the consideration or amount received by the Defendant and the time of the transf.er. ' 3. TRANSFERRED ASSETS AND GIFTSI If, in the preceding six years, the Defendant has transferred any assets (real property, personal property, chose in action), not covered by the immediate preceding interrogatory, to any person, and/or, if the Defendant has given any gift valued at more than $250.00, of any asset, including money, to any person, set forth, in detail, a description of the property, the type of transaction, and the name and address of the transferee or recipient. 4. AGREEMENTS: State whether the Defendant has any agreements involving the purchase oE any real estate anywhere in the United States. IE so, state with whom this agreement is made, and state whether or not any persons are joined with the Defendant in the agreement. Supply full names and addresses of all If the said agreement is recorded, provide the recordation, with volume and page numbers. parties concerned. state and county of 5. ACCOUNTS RECEIVABLE, DEBTS, NOTES & JUDGMENTSI State the names and addresses of any and all persons whom the Defendant believes owes the Defendant money and set forth in detail the amount of money owed, the terms of payment and whether or not the Defendant has written evidence of this indebtedness, and if so, the location thereof. Also state if the matter is in litigation, and if so give full details. If the Defendant holds Mortgages or Judgments as security for any of these debts, state where and when such was recorded or entered; and the County, Book, Page number and term where recorded. If the Defendant holds this Judgment or Mortgage jointly with any other person or persons, give their name and addresses. 6. INSURANCEs State whether or not the Defendant is the owner of any life insurance contracts. If so, state the persons whose lives are insured, the serial or policy number or numbers of said contracts, the face amount, the exact name and address of the insurance companies, the named beneficiary or beneficiaries and their present address. If the Defendant owns this insurance jointly with any other person or persons, give their name and address. State whether such policies are term, whole life or some other type of policy. State also whether such policies have any cash value and whether there exists any loans against such policies and, if so state all amounts. 7. GOVERNMENT, MUNICIPAL OR CORPORATE BONDSs State whether or not the Defendant owns individually or jointly any corporate or governmental bonds. If so, include the face amount, serial numbers and maturity dates and state the present location thereof. If the Defendant owns any of these Bonds jointly with any other person or persons, give their name and address. i 8. SHARES OR INTERBST: State whether or not the Defendant owns any stocks, shares or interest in any corporation, or unincorporated association or partnership interest, limited or general and state the location thereof. Include the names and addresses of the organizations and the serial numbers of the shar~s or stocks. If the Defendant owns any of the stocks, shares or interest jointly with any other person or persons, give their name and address. 9. DEPOSITORY ACCOUNTS: State whether or not the Defendant maintains any checking, savings, or other deposit accounts. If so, state the name and location of the deposit institution and the branch or branches thereof, the identification numbers of those accounts, and the amount or amounts the Defendant has in each account. If the Defendant maintains any of these jointly with another person, give their name and address. 10. SAFETY DEPOSIT BOXES, State whether or not the Defendant maintains any safety deposit box or boxes. If so, include the name of the institution, branch or branches, and 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 maintains any of these jointly with another person, give their full name and address. 11. PERSONAL PROPERTY, State whether or not the Defendant owns personal property. Include a full description of all machinery, equipment, inventory, furniture, fixtures, furnishings and any other items of personal property with full description, giving full value and present location. State also whether or not there are any encumbrances or liens on that property and if so, the name and address of the encumbrance or lien holder, the present balance owing on that encumbrance and the transaction which gave rise to the existence of the encumbrance. State where and when the encumbrance or lien was recorded. If the Defendant owns any personal property jointly with any other person or persons, give their name and address. 12. RENTED PROPERTY, Is any of the prope~ty of the Defendant rented to, leased to or otherwise in possession of a third person? If so, state full description of the property; the name and address of the person, firm or other entity who has possession of the property; the circumstances and reason why the property is in possession of the third person; the consideration or payment received by the Defendant; the name and address of the person who receives the rents or other consideration on behalf of the Defendant. 13. MOTOR VEHICHLESI State whether or not the Defendant owns or has any rights in motor vehicles. Include a full description of each such motor vehicle, including color, model, title number, serial number and registration plate number. Also show the name or names in which each motor vehicle is registered, the present value of each motor vehicle and their present location and place of regular storage garaging or parking. State whether or not there are any encumbrances on those motor vehicles and if so, the name and address of the encumbrance holder, the date of the encumbrance, the original amount of that encumbrance, the present balance of the encumbrance, and the transaction which gave rise to the existence of the encumbrance. If not owned, state the extent of the Defendant's rights in and to such vehicles. 14. ACCOUNTS PAYABLE, LOANS PAYABLE, DEBTS, NOTES WHICH THE DEFENDANT OWES TO SOMEONE ELSEI State the names and address of any and all persons who claim that the Defendant owes them money for any reason. Set forth in detail the amount claimed and, if there are any suits, actions, or legal proceedings of any kind against the Defendant pending and undetermined, that the full particulars as to each. However. it is not necessary to duplicate the Mortgage information given in response to Interrogatory n1 (REAL ESTATE) and/or the encu~brance information required by Interrogatory n1l (PERSONAL PROPERTY) or Interrogatory ~13 (MOTOR VEHICHLE) . 15, Are there any Judgments on record against the Defendant? a. What amount and where? b. Have payments been made on account thereof by the Defendant or by third party for the Defendant? c. By what person? d. Was satisfaction recorded? e. If answer to item d. is "In the negative", explain why. 16. Are supplementary proceedings in aid of execution now pending on any of these Judgments? 17. Has any Judgment creditor's execution (enforcement) action been commenced? 18. Where does the Defendant live? a. How long has the Defendant lived there? b. How much does the Defendant pay for rent, board, services, etc.? 19. Is the Defendant a member of any club? a. What are the dues? b. Are they paid? 20. What salary or income has the Defendant? 21. What is the occupation of the Defendant? 22. Is the Defendant married? a. Has the Defendant a family? b. How large? c. How many are dependent on the Defendant? d. With whom does the Defendant live? 23. What money has the Defendant received within the last sixty days from any source, and what has the Defendant done with it? 24. Does the Defendant have a bank account? a. When did the Defendant have a bank account? b. When did the Defendant last draw a check? 25. Has the Defendant anything in pawn? If so, give all details. 26. Has the Defendant made a Will? a. When? b. Describe all property devised in that Will. 27. OTHER ASSETS: If the Defendant has any assets which was not disclosed in the preceding Interrogatories, including but not limited to rights and copy rights, patents and confidential and secret processes, please set forth all details concerning those assets including all recorded filings and proofs of ownership. 28. Have you in the past two (2) years submitted to institution/stock broker/banking institution either a confidential statement? a financial personal or a. If the answer is in the affirmative for each personal/confidential financial statement submitted, state: 1. To whom was it submitted. 2. The date it was submitted. 3. Attach a copy of said personal/financial statement. .~ ~9. Are you either the owner or beneficiary of any life insurance policy? If so, for each life insurance policy state: a. The name of the insurance company which issued the policy. b. The date the policy was issued. c. Whether you are either an owner or beneficiary of the insurance policy. d. Attach a copy of the declaration page of the policy. 30. Do you hold as the mortgagee either individually or jointly with others, a mortgage on any real estate? If so, as to each mortgage state: a. The description of the real estate: b. The date on which j'ou acquired the mortgage: c. The original principle amount of the mortgage: d. The account outstanding balance due on the mortgage: e. The name and address of each mortgagor: f. The mortgage book and page number in the Office of the Recorder of Deeds or the Office of the Deed Registry in the County and State where the mortgage is recorded. g. The name and addresses of each person/entity including yourself listed as a mortgagee: h. Attach a copy of the mortgage: 31. Have you made any claim under any policy of insurance within the last three years? If so, as to each claim, state: a. The name and addresses of the insurer: b. The policy number: c. The facts giving rise to such claim: d. Whether or not such claim has been paid: e. If you are represented by anyone, whether it be claims adjuster and/or an attorney, state the name, address and telephone number of that representative. MELVYN S MANTZ & ASSOCIATES, P.C. BY: JOEL STEINMAN, ESQUIRE DEFENDANT PURSUANT TO THE REQUIRED THAT WE STATE COLLECT A DEBT. ANY PURPOSE. FAIR DEBT COLLECTION THE FOLLOWING TO YOU: INFORMATION OBTAINED PRACTICES ACT, IT IS THIS IS AN ATTEMPT TO WILL BE USED FOR THAT .~. JOEL STEINMAN, ESQUIRE Attorney 1.0. #62042 MELVYN S MANTZ & ASSOCIATES, 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK Plaintiff P.C. CUMBERLAND COUNTY COURT OF COMMON PLEAS VS DONNA L. SAYERS Defendant NO. 97-6065 PLAINTIPP'S REQUEST POR PRODUCTION OP DOCUMENTS IN AID OP EXECUTION TO: Donna L. Sayers 970 Myerstown Road Gardners, PA 17324 Pursuant to Pennsylvania Rules of Civil Procedure 4009 and 3117, you are hereby requested to produce below the listed documents and/or items for the purpose of discovery of assets in aid of execution. This material will be examined and/or photocopied. The documents/tangible things are to be produced at the Law Offices of Melvyn S Mantz & Associates, P.C., Suite 101, 25 East State Street, Doylestown, PA 18901 not more than thirty (30) days from receipt thereof. These requests are not directed merely to the person or party whose name appears above, but are meant to include that person/s or party's agents, servants, insurers, employers, employees. investigators, attorneys, and other similarly situated to the person named. In addition although the request seeks these documents within the nex~ thirty (30) days, the request should also be deemed continuing, in that if there are further materials which come under the purview of any of these requests which are obtained after the time of their production presently, the materials should also be furnished in accordance with this request. The items to be produced for inspection and photocopying are: 1. Any and all documents, records, evidence and everything which you reviewed or referred to in answering the Interrogatories in Aid of Execution which accompanied the Request for Production of Documents. 2. Deeds of all real estate owned by you either solely or jointly with others. 3. Documents of title for all automobiles owned by you either solely or jointly with others. 4. Your United States and Pennsylvania Tax Returns which you filed solely or with spouse including all W-2 Forms issued to you and IRS 1099 Forms issued to you either jointly or with others for the following years: 1993, 1994, 1995 and 1996. 5. Bank statements covering all demand deposit accounts in which you have an ownership interest of any kind. 6. Balance sheets and statements for the last two (2) years showing all during the said periods as well as operations during said period. of profits or assets owned the results losses by you of the 7. A schedule of all of notes receivable. Such list address of each debtor, the terms of payment. your accounts receivable and shall include the name and amount of the debt, and the 8. A schedule showing in detail all items of inventory held by you, such schedule shall include a description of the type of inventory, the cost of the inventory, its present location and its present value. 9. A list of all safe deposit boxes which is held either in your name or jointly with others. Such lists shall include the name of the box, exact total, the number of the box ar.d the name and address of the institution in which it is located. ,..- 10. A list of all of your assets pledged as collateral for loans or other obligations owned by you, either solely or jointly with others. Such list shall include a description of the collateral, its value, the name and address of the institution or person with whom such collateral is pledged, and the amount of the obligations secured by said obligation. 11. A list of all ~quipment owned or possessed by you either solely or jointly with others. such lists shall include a description of each item of equipment, its present location, its cost, and its present value. 12. ^ list of all your liabilities, whether trade debt or otherwise, including the name and address of the party to whom such debt is owed, the amount of such debt, and the terms of payment. 13. A list of all of your assets owned either solely or jointly with others, other than inventory, transferred by you within one (1) year from the date hereof including a description of such assets, its cost, its value, and the name and address of the party who received such assets, and the consideration received by you for such transfer. 14. Copies of financial statements institution within the which you were served Documents. all confidential/personal/corporate issued by you to any financial last three (3) years of the date from with this Request for production of 15. complete copies of all insurance policies issued to you either as a homeowner, tenant, or business including but not limited to life insurance policies, policies for automobile insurance, homeowners/fire insurance policies for the past two (2) years from the date you were served with the Request for production of Documents. 16. A copy of all agreements reflecting ownership in any business entity including but not limited to stockholder agreements, partnership agreements, limited partnership agreements and joint venture agreements. COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS Joel Steinman, Esquire, being duly sworn according to law deposes and says that he is the attorney for the Plaintiff in the fox'egoing matter; that he is authorized to take this affidavit on its behalf; and that the facts contained in the foregoing Petition are true and correct to the best of his knowledge, information and belief. Joel Steinman, Esquire further understands that false statements made herein are subject to the penalties of 18 Pa.C.S., Section 4904, relating to unsworn falsification to authorities. '\ _ .__--__~ J~~~QUIRE i 0."'=; ;.. tu~~ ( " I, ' II'" l j" , , ".1 , . r" ('. 1; ,1.;.. . ""',: <'. i" j . ., G: , 4- C' . - - 'I . ,',j.", (1" (J" -; u ~~~~ ~'~ J~ ...:;l :l(j ~ -. -< ^' = , _-10 en ~. a~ ~cC:J ~J~ ,S ....... IIl.1o' ~::s ] ja & ~ 'IlJi s.\\. ::;;: W ~ ~Q . "4. t' t, 11 ,"'d' / l/'", .I(~L:ll~J X\.\T' / ~ -/J I' . \"11111 IAtrll @ MAY 2 6 1998 o ! ., ~ ' . '7;. ''71 '''' r, ,., -":' -J .. ~::; 1/ ,,~ ,'-."71 :'. - .. I~':; ~ tl) ; ;i] ...:if"':; ;.' :J ~~~ - . - '- ". -< '\., t':;t 1;; .-., >- lr, t: ,.:-; .. ....j~; tJ..C' - '2: , ". ~.J ~,~ f;: :( ii:.' .:-.. u.. "-:j Ie, 0"1 ... '>- GIJ :-;.1) u:; '. I ,i?; ~L. -. j iJ !1J u:. .:1 ~ ' 'u.. t ~ 13 OJ O'l U JOEL STEINMAN, ESQUIRE Attorney I.D. '62042 MELVYN S MANTZ , ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF PROVIDIAN NATIONAL BANK CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS VS DONNA L. SAYERS Defendant NO. 97-6065 PRAlCIPB rOR WITHDRAWAL or APPIARANCI AND INTRY or APPBARANCB TO THE PROTHONOTARY: Kindly withdraw my appearance Plaintiff, Providian National Bank. on behalf of the SSOCIATES, P.C. Kindly enter my appearance on providian National Bank. behalf of the Plaintiff, VALE~' ESQUIRE COLLECTION PRACTICES ACT, IT FOLLOWING TO YOU: THIS IS AN INFORMATION OBTAINED WILL BE PURSUANT TO THE FAIR DEBT IS REQUIRED THAT WE STATE THE ATTEMPT TO COLLECT A DEBT. ANY USED FOR THAT PURPOSE. ~ ~, ff " .~ I" I ,." C ',' '" . . ).,-' I' (. , .' , ...., L; , " 0.,1- I' .: , ~. (".'1 ~.~ ,.' C) "