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HomeMy WebLinkAbout07-1439IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KII D MORRISON Defendant No : on- 7 - )jy$ f 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 05758703 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No KII D MORRISON Defendant 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 COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 . 2. Defendant is adult individual(s) residing at the address listed below: KII D MORRISON 121 E MAIN ST FL 1 MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002620356980 . A copy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of March 02, 2007 , in the amount of $2782.80 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $500.00 8. 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 , KII D MORRISON INDIVIDUALLY , in the amount of $2782.80 with interest at the legal rate of 6.000g per annum from date of judgment plus attorneys' fees of $500.00 , and costs. James 436 Pitt (412 FAX 05 5 TI uy uL."Jt%.JUU I di 67L4 WEINBERG & REIS CO., L.P.A. h Avenue, Suite 2718 PA 15219 -7955 338-7130 C A Pit WLG This law firm is a debt collector at /will ng to collect this debt for our client and any information obtai be used for that purpose. DISCOVER CARD 24 SDSN6A01 0010139 KII MORRISON 121 E MAIN ST FL MECHANICSBURG PA New Balance Minimum Payment Due $2,782.80 $343.00 Payment Due Date January 23, 2007 1 17055-3854 Account Number 6011 0026 2035 6980 Enter Amount Enclosed Below Please make check payable to Discover Card. You are overlimit. Pay the sum of the monthly minimum payment plus the overlimit amount of . Consolidate bills quickly and securely with a Balance Transfer to your Discover Card - Call 1-877-353-0989 or visit Discovercard.com/balancetransfer TODAYI PO BOX 15251 111nr11nueInWrJrhu11 Address, e-mail or telephone change$ Print change in space WILMINGTON DE 19886-5251 above, or go to Discovercard.com.Print your e-mail address to ?nnJ?LL?(n((u?u?(nJn(un11 111111111 1111111111 ((L(nn( receive important Account information and special offers. 000006011002620356980027828000000000034300 Discover Card Account Summary Account Number Payment Due Date Minimum Payment Due Credit Limit Credit Available Cash Credit Limit Cash Credit Available 6011 0026 2035 6980 January 23, 2007 $343.00 $2,000.00 $-782.00 $1,000.00 $0.00 Closing Date: December 24, 2006 page t of 1 Previous Balance $2 691.98 Payments And Credits , Purchases 0.00 Cash Advances + 35.00 Balance Transfers + 0.00 Finance Charges + 0.00 New Balance + 55.82 - $2,782.80 You may be able to avoid Periodic Fi nance Charges see the reverse side for details. , Cashback Bonus® Opening Cashback Bonus Balance $ 0,00 New Cashback Bonus Earned + 0.00 m $ 0.00 L-ashbock Bonu30 Anniversary _ _ - - - - - - - - - -- ? e to deeBalance Date: August 24 $ - 0.00 How Can We Help You? For Acc~ Inquiries, write to us at. Please have your Discover Card avaiable. Discover Card, PO Box 30943 ?na8s your account online at Discovercard.com Salt Lake City, UT 84130 Customer Service: 1-8004DISCOVER (1-800-347-2683) For asssincceea? ??? siDid °' the D°°?° Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Date Post Other/Miscellaneous Dec 24 Dec 24 tATF FFF $ 35.00 Information For You Your Account is overlimit. While we are permitted under the Cardmember Agreement to charge you an Overlimit Fee, we have chosen not to do so at this time. We reserve the right to do so if, as of the close of a billing period, your outstanding Account balance exceeds your Account credit limit. See the Ovedimit Fee section of the Cardmember Agreement for details. ATTENTION * * * Your account is seriously past due. Payment of the amount due and arrangements for Future payments should be made immediately. Finance Charge Summary Averse Nominal Dail 9 Daily ANNUAL ANNUAL Periodic Fee saction I Daily Periodic PQCBRAGE CCENTAGE FINANCE FINANCE a nee Rates ItAiE,S current billing period: 30 days -- VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he is Robert Adkins (Name) Accounts Manager of Discover Financial Services LLC., plaintiff herein, that (Title) (Company) he is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signature) WWR # 5758703 KII D MORRISON 6011002620356980 Law Offices of Weltman, Weinberg & Reis Co., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 March 02, 2007 RE: DISCOVER BANK vs. KII D MORRISON COURT #: TO THE SHERIFF OF CUMBERLAND COUNTY: PLEASE SERVE THE DEFENDANT(S) AT THE FOLLOWING ADDRESS(ES): KII D MORRISON 121 E MAIN ST FL 1 MECHANICSBURG, PA 17055 Please confirm service by sending notice to: WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 05758703 C A Pit WLG tel. N -TI 1F N f ,-n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KII D MORRISON Defendant No. 07-1439-CIVIL TERM 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05758703 Judgment Amount $ 3282.80 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 DISCOVER BANK Plaintiff vs. Civil Action No. 07-1439-CIVIL TERM KII D MORRISON Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, KII D MORRISON above named, in the default of an Answer, in the amount of $3282.80 computed as follows: Amount claimed in Complaint $2782.80 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $500.00 TOTAL $3282.80 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. ?f By: W (((J' A 1-14 WILLIAM T. MOLCZAN, ESQU PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05758703 Plaintiffs address is: c/o 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: 121 E MAIN ST FL 1 MECHANICSBURG,PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-1439-CIVIL TERM KII D MORRISON Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order r judgment was entered against you on adG? (xx) Assumpsit Judgment in the amount of $3282.80 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, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: &ra?, I-0jue PROTHONOTARY (Oft 131E ?') KII D MORRISON 121 E MAIN ST FL 1 MECHANICSBURG,PA 17055 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff KII D MORRISON Defendant(s) IMPORTANT NOTICE TO: KII D MORRISON 121 E MAIN ST FL 1 MECHANICSBURG,PA 17055 Date of Notice: LI-)O •_ 0-1 WWR#: 05758703 Case # 0*?-/ 1(35 -Cl vrLrrRlti 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 `,r?C ??tOVito?d BY: PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KII D MORRISON Case no: 07-1439-CIVIL TERM NON-MILITARY AFFIDAVIT Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, KII D MORRISON 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, KII D MORRISON is not in the military service. Further Affiant sayeth naught. l AFFIA T SWORN TO SUBSCRIBED in my presence this day of M A a 00-1 NOTAR n v ccurlt?p 4q ASS, of Nota This law firm is a debt collector attempting 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 Page 1 of 2 APR-30-2007 06:06:52 < Last Name First/Middle Begin Date Active Duty Status Service/Agency MORRISON KII 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. Autr? 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;9167; 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 small 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 may be invoked 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: htti)://www.defenselink.mil/faq//pis/PCQ9SLDR.htm_1 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 4/30/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: RJPHKDGMIT https://www.dmde.osd.mil/scra/owa/scra.prc_Select 4/30/2007 44. w ? ?, Vl% SHERIFF'S RETURN - REGULAR CASE NO: 2007-01439 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS MORRISON KII D JESSICA HERMANSEN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MORRISON KII D the DEFENDANT at 1413:00 HOURS, on the 22nd day of March , 2007 at 121 E MAIN STREET MECHANICSBURG, PA 17055 KII MORRISON FLOOR 1 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.60 Affidavit .00 Surcharge 10.00 .00 31?y f6? ? 37.60 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 03/23/2007 WELTMAN WEINBERG REIS By: i V--5-epuy heriff A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KII D MORRISON Defendant PNC BANK, Garnishee , No. 07-1439-CIVIL TERM 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05758703 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 07-1439-CIVIL TERM KII D MORRISON Defendant PNC BANK, , Garnishee PRAECIPE FOR WRIT OF EXECUTION SUBTOTAL: Costs (to be added by Prothonotary): $ 3395.56 WELTMAN, WEINBERG & REIS CO., L.P.A. By: U - l " v- William T. Molczan, Esq e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05758703 TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against KII D MORRISON, Defendant , moo Middle rZic?e Rd, NeWPort, PA 1707L/ 3. against PNC BANK, Garnishee I'foo Ccu*.p }H 1l MouU Co rn.p ON. PA 117011 4. Judgment Amount $ 3282.80 $ 3, o2b a. 8o Less payments of 20.00 Interest $ 132.76 Costs $ 013 L ?, to :'i cn 0 ..n U OD cy a o - '1 pp _ y" O DO D d vo WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1439 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From KII D. MORRISON, 8460 Middle Ridge Road, Newport, PA 17074 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PNC BANK, 1400 Camp Hill Mall, Camp Hill, PA 17011 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 $3,262.80 Interest -- $132.76 Atty's Comm % Atty Paid $134.10 Plaintiff Paid Date: 2/12/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs C , s R. Long, Pro ary By: 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 Deputy Telephone: 412-434-7955 Supreme Court ID No. 47437 SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-01439 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS MORRISON KII D And now MARK CONKLIN ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0009:25 Hours, on the 15th day of February-, 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT MORRISON KII D hands, possession, or control of the within named Garnishee PNC BANK 105 NOBLE BLVD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to VIOLA ROELKE (ASST MANAGER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscribed to before me this , in the true and made So answers: .00 '° « r .... ;. .00 t .00 R. Thomas Kline .00 Sheriff of Cumberland County 00 02/19/2008 ?; I ??? day of By zl,?A Depu y Sheriff A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KII D MORRISON Defendant PNC BANK Garnishee No. 07-1439-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE PNC BANK ONLY FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: 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 WWR#05758703 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-1439-CIVIL TERM KII D MORRISON Defendant PNC BANK Garnishee PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE, PNC BANK, ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, PNC BANK, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: _ WILLIAM T MOLC N PA I.D #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05758703 .? oo ° cjl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KII D MORRISON Defendant PNC BANK, Garnishee, No. 07-1439-CIVIL TERM 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5758703 Y L 3,ag2.8D - a.o • oa 3a?a . 90 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, I ' CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-1439-CIVIL TERM KII D MORRISON, SK(oo Middle- P-ktf Peck , Il)ewpoJ,. PA ('1 o7q Defendant PNC BANK, ?os W66 914, 0,0A 6 , PA 1-7013 Garnishee TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against KII D MORRISON, Defendant 3. against PNC BANK, Garnishee 4. Judgment Amount $ 3,282.80 Less payments of $ 20.00 Interest $ 261.73 Costs SUBTOTAL: Costs (to be added by Prothonotary): $ $ 3,524.53 $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: ?/t/,?/? /v William T. Molcz Esquire PA I.D. #47437 IWO WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5758703 ? ? ?S W t ? -?s Viz.? , ca cra ? . ? :. " ; ' ' ?"• ? ? t7 0 0 Q Z o ? 03 to WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1439 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From KII D. MORRISON, 8460 Middle Ridge Road, Newport, PA 17074 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PNC BANK, 105 Noble Blvd, 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 $3,262.80 L.L. Interest - $261.73 Atty's Comm % Due Prothy $2.00 Atty Paid $164.10 Other Costs Plaintiff Paid Date: 9/19/08 (Seal) By: R. Long, Prothonotary Deputy 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 SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-01439 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS MORRISON KII D And now STEVE BENDER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0009:35 Hours, on the 25th day of September, 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , MORRISON KII D hands, possession, or control of the within named Garnishee PNC BANK 105 NOBLE BLVD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to KATIE STOUFFER (SALES CONSULTANT) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her , in the true and made Sheriff's Costs: So answ rs• Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 0 0? ;010,2 /0 P L?- 09/25/2008 Sworn and Subscribed to before me this day of By Deputy Sheriff A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KII D MORRISON Defendant PNC BANK Garnishee No. 07-1439-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE PNC BANK 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5758703 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-1439-CIVIL TERM KII D MORRISON Defendant PNC BANK Garnishee PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE PNC BANK ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, PNC BANK, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A By' - William . Mold n, 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#5758703 Sworn to and subscribed Before me the _1-9 DaLof OCTOBER. 2008 k -PUBLIC ON0 my t to n n - t X', ` :' "V 0 ( 0 L ' Q, 00 431 v 4-' J. y R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, WRIT IS EXPIRED. Sheriff's Costs: Docketing Poundage Law Library Prothonotary Mileage Surcharge Garnishee Levy Postage TOTAL 36.00 3.38 .50 4.00 9.60 60.00 18.00 40.00 .88 172.36 J 9/a f/0f ?Z- ;.. N) - co 11'-'- x 8E :1 d E 1 933 0001 AA183HS 3H1 ?0 131 AJO L Advance Costs: 300.00 Sheriff's Costs: 172.36 127.64 Refunded to attorney 05-20-09 c w So Answers; WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1439 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From KII D. MORRISON, 8460 Middle Ridge Road, Newport, PA 17074 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PNC BANK, 1400 Camp Hill Mall, Camp Hill, PA 17011 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 $3,262.80 L.L. $.50 Interest -- $132.76 Atty's Comm % Due Prothy $2.00 Atty Paid $134.10 Other Costs Plaintiff Paid Date: 2112/08 C Long, Pro (Seal) By: Deputy 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 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, WRIT IS EXPIRED. Sheriff s Costs: Advance Costs: 300.00 Sheriff's Costs: 172.36 Docketing 36.00 127.64 Poundage 3.38 Law Library .50 Prothonotary 4.00 Refunded to attorney 05-20-09 Mileage 9.60 Surcharge 60.00 Garnishee 18.00 Levy 40.00 Postage .88 TOTAL 172.36 So Answers; R. Thomas Kline, Sheriff B9 Y Y ?` M V nj f-- Rj WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1439 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From KH D. MORRISON, 8460 Middle Ridge Road, Newport, PA 17074 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PNC BANK, 105 Noble Blvd, 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 $3,262.80 Interest - $261.73 Atty's Comm % Atty Paid $164.10 Plaintiff Paid Date: 9/19/08 L.L. Due Prothy $2.00 Other Costs (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE By: 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 Deputy h r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KII D MORRISON Defendant FIRST NATIONAL BANK OF MIFFLINTOWN, Garnishee, No. 07-1439-CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION AND ENTER IT IN THE JUDGMENT INDEX (BANK ATTACHMENT ONLY) "- t;j tn,. r - ,? --- t-? < ' i ca FILED ON BEHALF OF Plaintiff = -. COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 ? 37- to U C'??" 3U r4 7a ft SS . S U , ILI- CMG' 9q. f 5 U c? OrNkl 8,1 A WWR#5758703 ?iZ-?8- 1/y7o--?O i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KII D MORRISON Defendant Civil Action No. 07-1439-CIVIL TERM FIRST NATIONAL BANK OF MIFFLINTOWN, Garnishee PRAECIPE TO INDEX WRIT OF EXECUTION AND ENTER IT IN THE JUDGMENT INDEX TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of JUNIATA County: 2. against KII D MORRISON, Defendant 3. against FIRST NATIONAL BANK OF MIFFLINTOWN, Garnishee 4. and enter this writ in the judgment index (a) against KII D MORRISON, defendant, and (b) against FIRST NATIONAL BANK OF MIFFLINTOWN, as garnishee, as a lis pendens against real property of the defendant in the name of garnishee as follows: Any and/or all personal Vrgper1y belonging to the defendant(s) in possession of the garnishee(s). 5. Judgment Amount $ 3282.80 Interest $ 704.78 Costs $ SUBTOTAL: $ 3987.58 Costs (to be added by Prothonotary): $ WELTMAN, WE_INBERG & REIS CO., L.P.A. Bett ' M w D . Ur n, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KII D MORRISON Defendant FIRST NATIONAL BANK OF MIFFLINTOWN Garnishee Civil Action No. 07-1439-CIVIL TERM WRIT OF EXECUTION TO THE SHERIFF OF JUNIATA COUNTY: To satisfy the judgment, interest and costs against: KII D MORRISON Defendant(s); (1) You are also directed to attach the property of the defendant not levied upon in the possession of FIRST NATIONAL BANK OF MIFFLINTOWN, as garnishee, 2 North Main St., Mifflintown, PA 17059 and to notify the garnishee that: a. An attachment has been issued; b. Except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant and from delivering any property of the defendant or otherwise disposing thereof; c. The attachment shall not include any funds in an account of the defendant with a bank or other financial institution i. In which funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law, or (i) the first $10,0000.00 of each of the account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are indentified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law ii. Each account of the defendant(s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are indentified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law iii. Any funds in an account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are indentified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law (2) If property of the defendant not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify [him] such other person that he or she has been added as a garnishee and is enjoined as above stated Amount due ..........................................$ 3987.58 Costs to be added .................................. $ Prothonotary Deputy DATED: WWR#5758703 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK Plaintiff VS. KII D MORRISON Defendant FIRST NATIONAL BANK OF MIFFLINTOWN Garnishee WRIT OF EXECUTION NOTICE No. (17-1439 CIVIL TERM This paper is a "Writ of Execution". It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that certain property cannot be taken and sold by the Sheriff to satisfy your debts. SUCH PROPERTY IS SAID TO BE EXEMPT. No matter what you may owe, there is a DEBTOR'S EXEMPTION established by law. This means that no matter what happens, the Sheriff must give you from the sale at least $300.00 in cash or property. There are also other exemptions which may be applicable to you. Listed below is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following promptly: (1) Complete the claim form on the opposite side and demand a prompt hearing. (2) Deliver the form or mail it to the Sheriffs Office at the address noted. You should come to court when and where you are told to appear ready to explain your exemption. IF YOU DO NOT COME TO COURT AND PROVE YOUR EXEMPTION, YOU MAY LOSE SOME OF YOUR PROPERTY. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 exemptions set by law. 2. All wearing apparel used by yourself and all family members. 3. Bibles, school books, sewing machines, uniforms & equipment. 4. Tools of your trade such as carpenter's tools. 5. Most wages & unemployment benefits. 6. Social Security benefits, certain retirement funds and accounts. 7. Certain veteran & armed forces benefits. 8. Certain insurance proceeds. 9. Such other exemptions as may be provided by law. CLAIM FOR EXEMPTION TO THE SHERIFF: I, the above-named defendant, claim exemption of property from levy or attachment: (1) FROM MY PERSONAL PROPERTY IN MY POSSESSION WHICH HAS BEEN LEVIED UPON, (a) I desire that my statutory $300.00 exemption be: (__) (1) set aside in kind (specify property, to be set aside in kind: (___) (2) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption: (specify property and basis of exemption): (2) FROM MY PROPERTY WHICH IS IN THE POSSESSION OF A THIRD PARTY, I CLAIM THE FOLLOWING EXEMPTIONS: (a) my $300.00 statutory exemption: in cash in kind (specify property): (b) Social Security benefits on deposit in the amount of $ (c) Other (specify amount & basis for exemption): I request a prompt court hearing to determine the exemption. Notice of hearing should be given me at the following: ADDRESS: TELEPHONE NUMBER: I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsification to authorities: Date: Defendant: THIS CLAIM TO BE FILED WITH: Office of the Sheriff of Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Telephone Number: (717) 240-6390 Note: Under paragraphs (1) and (2) of the Writ, a description of specific property to be levied upon or attached may be set forth in the Writ or included in a separate direction to the Sheriff. Under paragraph (2) of the writ, if attachment of a named garnishee is desired, his name should be set forth in the space provided. Under paragraph (3) of the writ, the Sheriff may, as under prior practice, add as a garnishee any person not named in this writ who may be found in possession of property of the defendant. See Rule 311 l (a). For limitations on the power to attach tangible personal property, see Rule 3108(a) (b). Each court shall, by local rule, designate the officer, organization or person to be named in the notice. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KII D MORRISON Defendant and No. 07-1439-CIVIL TERM INTERROGATORIES IN ATTACHMENT FIRST NATIONAL BANK OF MIFFLINTOWN FIRST NATIONAL BANK OF MIFFLINTOWN Garnishee FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5758703 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KII D MORRISON Defendant and FIRST NATIONAL BANK OF MIFFLINTOWN Garnishee Civil Action No.: 07-1439-CIVIL TERM TO: FIRST NATIONAL BANK OF MIFFLINTOWN Suggested Reference No.: XXX-XX-7078 2 North Main St. Mifflintown, PA 17059 RE: KII D MORRISON 8460 MIDDLE RIDGE RD NEWPORT, PA 17074 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 (including funds on deposit for checking or savings accounts and certificates of deposit)? I 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. 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. 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? 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? 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? 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? 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 amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 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. 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. IL . If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not 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? 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. WELTMAN, WEINBERG & REIS CO., L.P.A. By. Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5758703 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 (Name) (Title) of (Company) garnishee herein, that he/she is 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. (SIGNATURE) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-1439 Civil CIVIL ACTION - LAW TO THE SHERIFF OF man4+0'- COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From KII D MORRISON AT 121 E. MAIN STREET FL 1, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of FIRST NATIONAL BANK OF MIFFLINTOWN AT 2 NORTH MAIN STREET MIFFLINTOWN, PA 17059 GARNISHEE(S) as follows: ANY AND/OR ALL PERSONAL PROPERTY BELONGING TO THE DEFT IN POSSESSION OF THE GARNISHEE 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 $3282.80 L.L. Interest $704.78 Atty's Comm % Atty Paid $508.82 Plaintiff Paid Due Prothy $2.00 Other Costs TO BE ADDED Date. 1/18/11 (Seal) i D. Buell, Prot onotaryBy: Deputy REQUESTING PARTY: Name :MATTHEW D. URBAN, ESQ. Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 7TH AVE. PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C. Warmbrodt, Esquire Attorney for Plaintiff(s) I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 5758703 DISCOVER BANK CUMBERLAND County Court of Common Pleas vs. ' KII D MORRISON NO. 07-1439-CIVIL TERM and cD - C3 FIRST NATIONAL BANK OF MIFFLINTOWN C-n Garnishee(s) ?.-.' N -? - .- V, PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), FIRST NATIONAL BANK OF MIFFLINTOWN, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By James.?Warmbrodt, Esquire Attorn v or Plaintiff Sworn to and subscribed Before me the/( day of FEBRUARY, 2011 ", ? _ COMMONWEALTH F AN? ?? r?S`5S 3 0? - OTARY PUBLIC Notasal No %al Public shells G. Bevan, NobIN Rass Twp., AllephtnY ownty My COMM Oro Nov 15, 2014 l?n TiON Of NOTARIES MEMBER PENNSYLVANIA ASSOW