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Home My WebLink About03-0817IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI, FUNDING LLC, ASSIGNEE OF COMPUCREDIT ACQUISITION FUNDING Plaintiff vs. DERECK T. JADRO Defendant No. 03 - ?1 l_:!v t C??L ?' L COMPLAINT IN CIVIL ACTION 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02648672 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI, FUNDING LLC, ASSIGNEE OF COMPUCREDIT ACQUISITION FUNDING Plaintiff VS. Civil Action No. 0 9 - C / -? DERECK T. JADRC Defendant COMPLAINT IN CIVIL ACTION 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 a1-:pearance personally or by an attorney and filing in writing with the court your defenses or objection; 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 claim--d 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 SHOUILD 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 TC FIND OUT WHERE YOU CAN GET LEGAL HELP LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ? COMPLAINT -2388• Plaintiff is a corporation with offices in P.O. Box 2388 Doraville, Georgia 30362 1 • 2. Defendant is an adult individual residing at 49 Lincoln Street, Enola, PA 17025. a credit card issued by plaintiff `s assignor bearing the 3. ?aant applied for and received Defen account number 4791`060111699137. 4. Defenw`dant made use of said credit card and has currently a balance due and owing to shown by Plaintiffs tiff as of July 2001, in the amount of $2,509.93, as f's Statement of Account plain , attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defen=dant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 6% per annum on the unpaid balance. 7. Plaints ff avers that finance charges calculated at the aforesaid rate from July 7, 2001 to October 22, 2002 amount to $194.74. 8. A1thoUgh repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the pri.,icipal balance, finance charges, attorneys' fees or any part thereof to Plaintiff. WHEREFOREE, plaintiff demands Judgment in its favor and against Defendant, Dereck T. Jad individually, in the amount of $3,119.91 with ro annum plus costs. continuing finance charges thereon at the rate of 6% er p THIS IS AN ATTEMPT TO COLLECT A DEB SHALL BE USED FOR THAT PURPOSE. T AND ANY INFORMATION OBTAINED WELTMA , WEINBERG & REIS, CO., L.P.A. 17 Wil 'am T. Molcz Esquire PA I.D. #47437 WELTMAN, W MERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#:02648672 OSI Funding, LLC LITIGATION NETWORK Post Office Box 2388 Doraville, Georgia 30362-2388 800-945-0007 JULY 31, 2002 DERECK T JADRO 20 BUCK RD DOVER, PA 17315-2066 STATEMENT OF ACCOUNT Debtor's Name: OSI Funding LLC Acct Number: Original Creditor: Original Account Number: Write Off Date (Charge Off Date): Principle Balance: Balance Due: Interest Rate: DERECK T JADRO 3952218611 COMPUCREDIT ACQUISITION FUNDING 4791060111699137 07/07/01 $2,509.93 $2509.93 33.% EXHIBIT --L--- WWW VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 14904 relating to unsworn falsifications to authorities, that he/she is f3 . )0 L GcTR-,C-' (Name) L 9Q, Fr L t:)-N 4t-VS - of OS I F? N D iN C - , plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. 0,&A-Q ? '? , "S ' of Q. (Signature) Wwr# 02648672 n 3z" O r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI, FUNDING LLC, ASSIGNEE OF COMPUCREDIT ASQUISITION FUNDING Plaintiff vs. DERECK T. JADRO Defendant No. 03-817 PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 Gerianne Hannibal PA I.D. # 66622 WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#02648672 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI, FUNDING LLC, ASSIGNEE OF COMPUCREDIT AQUISITION FUNDIING Plaintiff vs. Civil Action No. 03-817 DERECK T. JADRO Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAK)WEINIDERG & REISZO., L.P.A. BY:1 V uh; PA I.D. # 66622 William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R #02648672 C-) p?-^ ^' 4.,...-, t... - -rq 1^ L.I .., yJ ...yA .,_ .H IITT -?? . ?, f i _ f SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-00817 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND OSI FUNDING LLC VS JADRO DERECK T R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: JADRO DERECK T but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On June 26th , 2003 this office was in receipt of the attached return from YORK Sheriff's Costs: So answe Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. Thomas Kline Dep York County 23.60 Sheriff of Cumberland County .00 60.60 06/26/2003 WELTMAN WEINBERG REIS Sworn and subscribed to before me this 3n41? day of aM3 A.D. ?I Prothonotary! , YORKTOWNE BUSINESS FOMRS • (717) 225-0363 • FAX (717) 225-0367 o? COUNTY OF YORK OFFICE OF THE SHERIFF S(717t 771-9601 L 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINE 1 THRU 12 DO NOT DETACH ANY COPIES 1. PLAINTIFF/S/ F'4 M6/fn ` ?1, ? a 3 COJ1fj?lUMBE?RpJ C1V11 / 4. TYPE OF WRIT OR ?M> . D ENDANT/S/ rte`', / d rd yr d SERVE t 5 NAME OF ?? IV DUAL-,CCOMPANY CORP RATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. b, AD RE (STREET OR RFO WTH BOX ? NUMBER, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE) y AT ??1??? (- IZ rn(a t 1.t ? ?` y"O- r -* SR6 `Z 1 7. INDICATE SERVICE : ERSONAL LlPERSONINCl AI GE }OP DEPUTIZE -O CERT.L1AILd ? 1ST CLASS MAIL 7 POSTED ?OTHER NOW May 6 20 03 I, SHERIFF OF YORK COUNTY, h by deputize riff of York COUNTY to execute this W ' r to law. This deputization being made at the request and risk of the plaintiff. SHERIFF OF YORK COUNTY B. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: (-umnerLana, OUT OF COUNTY Please mail return to Cuanberland County Sheriff. CUMBERLAND ADVANCED FEE PAID BY ATTY NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATO and SIGNATU E 10. TELEPHONE NUMBER 11. DATE FILED l?:lliu v T. Oolc..zcw, a I G rs ?t . w?? '-7 AV-L f f`fS?oufgh /a)yc3y-1 5-5-0 12. E g ARV CO,pYy T9 nl rD ADDRESS BELOW: (This area must be pleted if notice is to be mailed). l,.)fUi o ? ally K6&u Qlg, V36 ? Ada PYf?,Y? IoA !fie SPACE BELOW FOR USE O HE SHERIFF- DO NOT WRITE BELOW THIS LINE 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15. Expiration/Hearing Date or complaint as indicated above. R . A H R E N S 5-9-03 LIW- 0 3 16. HOW SERVED: PERSONA RESIDENCE POSTED( ) POE( ) SHERIFF'S OFFICE ( ) OTHER( ) E REMARKS BELOW 17. ? I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. name above. (See remarks below.) NAME AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20. Trpr a of Service 151 Date Tmg ?les r . I Date Time Miles Int. I Date Time Miles Int. I Date Time Miles Int. I Dale Time Miles Int. I Date Time Miles Int. bl, 'P'4 22. REMARKS: 23. vaAd nce Costs ' 24. SServiceCosis 25. N/F 26. Mileage 27 75.00 18.00 3.60 34. Foreign County Costs 135. Advance Costs 136. Service Costs Postage 28. Sub Total 29. Pound 30. Notary 31. Surchg. 32. Tot. Costs 33. Casts Due ChegKN /? j 21.1 2.00 23.60 $51.40 I 37. Notary Can. 38. Mileage/Posted/Not Found 39. Total Costs 40. Costs Due or Refund 41. AFFIRMED and subscribed to before me this, 23rd r? ?????yy 1 44. 42. day f J`'? r40TARIAI.2DIEW43. MELISSA J. gHAFFER, NOtarYPIR M1 City of Vork, York County My ommissIon Explres 20, 2008 M1 EJ? 50. ACK OWLEDGE RECEIPT OF THE SH FF I OF AUTHORIZED ISSUING AUTHORITY AND I E 48. Signature of Foreign County Sheriff N GNATURE SO SWERS 45%3- e,3 James V. Van g/ S?h 47. DATE I M.HOSe, Sher ?//if 23/03 49. DATE 151. ATE RECEIVED 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriffs Office tt 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING, LLC, ASSIGNEE OF COMPUCREDIT ACQUISITION FUNDING Plaintiff vs. DERECK T. JADRO Defendant No. 03-817 PRAECIPE FOR DEFAULT JUDGMENT 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#02648672 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 OSI FUNDING, LLC, ASSIGNEE OF COMPUCREDIT ACQUISITION FUNDING Plaintiff vs. DERECK T. JADRO Defendant TO THE PROTHONOTARY: Civil Action No. 03-817 PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, Dereck T. Jadro, above named, in the default of an Answer, in the amount of $3,119.91 computed as follows: Amount claimed in Complaint $3,119.91 Interest from date of judgment at the contract interest rate of 6% per annum TOTAL $3,119.91 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: rr olcz William T. a n, Esq ' e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#02648672 Plaintiff's address is: c/o Waltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 4182 Elk Cout, Apt. 113, Mechanicsburg, PA 17050: York County Jail, Inmate #59671 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING LLC, ASSIGNEE OF COMPUCREDIT ACQUISTION FUNDING Plaintiff vs. DERECK T. JADRO Defendant TO: Dereck T. Jadro 4182 Elk Court, Apt 113 Mechanicsburg, PA 17050 Civil Action No. 03-817 IMPORTANT NOTICE Date of Notice: (Q / ?Q//i 3 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 NOTICE 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 County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: j vW William T. Molczan PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R #02648672 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02648672 (_ _ .J ? I ? iy.-?.. ... ?.. `' -C ? .. C , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING, LLC, ASSIGNEE OF COMPUCREDIT ACQUISITION FUNDING Plaintiff vs. DERECK T. JADRO Defendant COMMERCE BANK, Garnishee, No. 03-817 PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02648642 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING, LLC, ASSIGNEE OF COMPUCREDIT ACQUISITION FUNDING Plaintiff vs. DERECK T. JADRO Defendant COMMERCE BANK Garnishee TO THE PROTHONOTARY: Civil Action No. 03-817 PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... directed to the Sheriff of CUMBERLAND County: 2. against DERECK T. JADRO, Defendant 3, against COMMERCE BANK, Garnishee 4. Judgment Amount $3119.91 Interest from 7/14/03 Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 140.53 $3,260.44 WELTMAN, WEINB RG & REIS CO., L.P.A. By: William T. Molczan, E uire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02648642 u b z' Cl) ? o ? y 0 a? ? :.o C C C 4CCp,Cp? L? J N o P- ? r? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-817 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OSI FUNDING, LLC, ASSIGNE OF COMPUCREDIT ACQUISITION FUNDING, Plaintiff (s) From DERECK T. JADRO, 785 CANAL RD EXT, YORK, PA 17402 (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 COMMERCE BANK, 742 WERTZVILLE RD, ENOLA, PA 17025 - SERVE INTERROGATORIES GARNISHEE(S) as follows: 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 $3119.91 L.L. $30 Interest FROM 7/14/03 - $140.53 Atty's Comm % Due Prothy $1.00 Atty Paid $182.50 Other Costs Plaintiff Paid Date: JUNE 25, 2004 CURTIS R. LONG (Seal) Prothonotaa ` Bv: 6, t? C (/j/Lily? Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 SHERIFF'S RETURN - GARNISHEE CASE NO: 2003-00817 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND OSI FUNDING LLC VS JADRO DERECK T And now RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:55 Hours, on the 13th day of July , 2004, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , JADRO DERECK T hands, possession, or control of the within named Garnishee COMMERCE BANK 742 WERTZVILLE ROAD ENOLA, PA 17025 Cumberland County, Pennsylvania, by handing to MELISSA HUMER (BRANCH MGR) , in the personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: So answers: Docketing .00 Service .00 0 Affidavit .00 R. Thomas Kline' Surcharge .00 Sheriff of Cumberland County .00 00 00/00/0000 Sworn and subscribed to before me By Deputy Sheriff this 3r% day of L/C aOCy A.D. hootar?' "`?? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING, LLC assignee of COMPUCREDIT ACQUISITION FUNDING Plaintiff vs. DERECK T. JADRO Defendant and COMMERCE BANK Garnishee Civil Action No.: 03-817 TO: COMMERCE BANK Suggested Reference No.: SS# 198-66-1648 n ?? 742 WERTZVILLE ROAD ENOLA, PA 17025 iy? SYtzg- L- lJ? IMPORTANT NOTICES 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. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. 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? ba-P-CL 1?- e' -0 . ! G 2. 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. 3. 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. 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 5. 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? 6. If the answer to interrogatory 5 is in the affirmative, describe the nature, fair market value, and present location of each of said properties. 7. 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? -V 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. N I (+ 9. 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? ?Q CCQ?? ??? \ tYt c?? ?tl C-? tti i .e & y c?1?ti+ e? ?v ?, t1?l??e? tx c Ok=?c_C9? 0' C!?t i alk ? Wtt/? ? 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 11. 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? 12. If the answer to Interrogatory 11 is in the affirmative, describe the amount or nature, fair market value and present location of each of such payments and properties. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William olcz , Es ire PA I.D. #47437 WELTMAN, WEMERG & REIS CO., L.P.A. 2718 Koppers.Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#02648672 COMMERCE BANIJHARRISRURG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING, LLC assignee of COMPUCREDIT ACQUISITION FUNDING Plaintiff vs. DERECK T. JADRO Defendant and COMMERCE BANK Garnishee No. 03-817 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#02648672 n s- 9 f71F tD n C> ?. i .J N `< IN THE COURT OF COMMON PLE C VOF DIV S ERLAND COUNTY, PENNSYLVANIA OSI FUNDING,LLC., ASSIGNEE OF COMPUCRF,DIT ACQUISITION FUNDING No. 03-817 Plaintiff PRAECIPE TO SETTLE, DISCONTINUE VS. & END AS TO THE GARNISHEE COMMERCE BANK ONLY DERECK T JADRO Defendant COMMERCE BANK FILED ON BEHALF OF Garnishee Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. LD.#47437 WELTMAN, WEINBERG & RFIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02648672 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI FUNDING,LLC., ASSIGNEE OF COMPUCREDIT ACQUISITION FUNDING Plaintiff vs. Civil Action No. 03-817 DERECK T JADRO Defendant COMMERCE BANK Garnishee 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, WFINBERG & REIS CO., L.P.A. i m ? Wa:w, PA.I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#02648672: Sworn to and sub bed Before me the Day of A s,20 NOTARY P IC r t ? 1?7 Q1 T_ C? t } f 'IMT OSI Funding LLC OF THE D VS T Derek T. Jadro ZW SEP 30 AM 10: 8 Writ of Execution Docket No. 2003-817 Civil Term CLW p , R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. Sheriff's Costs: Docketing $18.00 Surcharge 20.00 Garnishee 9.00 Levy 20.00 Mileage 10.36 Poundage 1.58 Prothonotary 1.00 Law Library .50 $80.44 So Answers: R. Thomas Kline, Sheriff BY , e Sergeant ? i b? d?o g C.Q nc 7,?.2GL ?cu. d 3 / d 7/