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HomeMy WebLinkAbout99-04103 tl', i s? V V v VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS WESLEY BRETZ CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. q _0'e11W 010"C-F" Defendant N O T 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 r VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 East State Street (215) 348-5200 Doylestown, PA 18901 ATTORNEY FOR PLAINTIFF CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS WESLEY BRETZ Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. q 9 - yios? Tom` CIVIL ACTION 1. The Plaintiff is Citibank (South Dakota) N.A., a nationally charted banking institution with a place of business located at 3940 Olympic Blvd., Erlanger, KY 41018. 2. The Defendant is WESLEY BRETZ, with a place of residence located at 905A Bosler Avenue, Lemoyne, PA 17043-1759. 3. At the request of the Defendant, Plaintiff issued to Defendant a CITIBANK PREFERRED MASTERCARD credit card, account # 5410654528852913; and at all times relevant hereto, Defendant was the holder of said card issued through the Plaintiff's credit facilities. 4. Defendant, upon acceptance and use of the Plaintiff's credit card, agreed to be bound by the terms and conditions of Plaintiff's revolving credit plan. A true and correct copy of said Agreement is attached hereto, made a part hereof and marked Exhibit "A". 5. The Defendant subsequently used the said credit card. As of 05-15-99, the Defendant had incurred charges in the sum of 6,961.24, no part of which has been paid although duly demanded. 1 ' . --- . 6. In accordance with the terms of Exhibit "A", the Defendant agreed to pay the Plaintiff a finance/service charge on all sums due at an annual percentage rate 19.80 and the Plaintiff is entitled to additional finance/service charges from 05-15-99. 7. In accordance with the terms of Exhibit "A", Defendant agreed to pay 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 1,740.31. WHEREFORE, Plaintiff demands judgment against the defendant in the sum of 6,961.24 plus attorney's fees of 1,740.31 plus interest from 05-15-99 at the contract rate and cost of this action. Respectfully submitted: PARK LAW AS IATES, P.C. BY: VAL IE ROSENBLUTH PARK, ESQ. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1 AFFIDAVIT STATE OF MISSOURI COUNTY OF PLATTE, TO-WIT: On this ) `I day of aforementioned, MAY JEANETTE M. BROWN JEANETTE M. BROWN who, after being duly sworn, deposes as follows: hereby certify that I am a Manager of Citicorp Credit Services, Inc.; that I authorize to execute this Affidavit on behalf of Citibank (South Dakota), N.A.; that 1 make this affidavit of my own personal knowledge and am competent to testify to all matters contained herein; that 1 am personally familiar with Account No. 5410654528852913 that the defendant signed an Application for Credit Card which forms the basis for this account; that Wesley Bretz used or authorized use of said credit card for the purchase of goods and/or services and cash advances; that the existing balance of the account is S 6961.24 that demand has been made upon Wesley Bretz for payment of this amount; that Wesley Bretz was sent a copy of the Disclosure Statement with the credit card; that payment has not been made pursuant to the agreement between the parties and that said amount, plus continuing interest and attorney's fees is due and owing to Citibank (South Dakota). N.A.; that 1 have made diligent search and inquiry to determine whether the defendant, Wesley Bretz , is in the military service of the United States of America; and, as a result of such search and inquiry, have determined and ascertained that the said defendant hereto is not in the military services of the United States and is not entitled to any of the rights and privileges as prescribed under the Soldiers and Sailors Civil Relief Act of 1940, as amended. 1 certify the above to be true and correct to the best of my knowledge and belief. CITICORP CREDIT SERVICES, INC. B tl MANAGER under limited power of attorney for CITIBANK (SOUTH DAKOTA), N.A STATE OF MISSOURI COUNTY OF PLATTE, TO-WIT: The foregoing Affidavit was acknowledged before me this /`? day of MAY 1999, by JEANETTE M. BROWN , whose title is MANAGER on behalf of Citibank (South Dakota), N.A., a South Dakota corporation, on behalf of the corporation. Given under my hand this /q day of MAY , 1998 My commission expires: .•• . LP'1 Nntart ius c S+al 5• •e (V ARY PUBLIC 1999, came before me, a Notary Public in the jurisdiction .11 r (' 9FMK V L? Ei ????i.g.{? j$-€ ? a_be2a S ra -Fp"u??L nPc ?9 C?+'g? L, n, _sugF Wis. tp >e_a€o? E.a _ Ecsso83 ^?a qge it U. g csa ag bez E E " Ei??" E UE;?«'g2 gait is .9. M cz =E °- _ '? o5so s"re ?? ass ..fie ^g ? ?gag?'a8 u`€s ' S. u`2 sgE `'€S ? $ ???yCS o? Ord =B'- = k3i gl_g =$ a e? pE.EL C a _F ;-`g^ m=" U r EE "P o? b 8- C R 9,9_27 ° 2 E.8 Y.a?s JLY U YS? US€`c?8°.a Q?:F Q?p m3 Ev.. .21zc" .-. i3 OWA II S _E ?s?- gee L SEE ...=LZ?FeQ Eat-€?x 3'Ee `s ?$ 3 5 S Fr° 3ta-o? 5. SS.?v L 8 8- o L- ? Y-85 E i e 9, gi °aEqq S e gfg d ?` E ?te e E i32 Fa K € iB F « 68 Fit €= .. _t_syy? g`gE =5' _ v__?"s 9 F ;fig' a "Sep a"g s Qy=:9 Fa vxaF yEc.. oai "? L zY. = QkSX9 6 y??°..g- y52? .5.2 Fe a -tf°?J'q? E "g lip _ 0 t °F W#° wB 6.a 8S 3'.I?C?2P E? 1s PART"°" uIR?i".tit av__?R -. 3F.: SS' a Sins i S$ a?`?rz E!m ?' r??$?g=o? e?LFEx?ae€€_z LO?i??.aL g m ? > eE°o'-g?c o ?a y ?-E" FCE _ Z14 ?S . F _gy _?•€OS ez ,c,S?E§Xa HIS 5' xc -22 .& •S f'$ b -16 'g Nur n: 1 i'5 - RUM -- _°; LG'pFpFFaEp n9E R e Esc, =g _€ . ._ Y F.t. ff _- E= mob RLI€" .•R gy cYS " ? Z. CES - pad _?;??€?o:?a° •qe ??°??? ?Y?'Fsgfaa °' ° .. ? ? L??BECEo^?a U? ???8 ?i=?8 o° crd Fs aFe° ps _ o?? ?3' as o Y P c,- E II C?`e-L+f 3 3 5.9247-a sn, s V c C? a}°a` 17F ; ,g C 3 F F 2" C 2.? 5 ,. E_ t4o is ur E ZY 3s- E pe z z: g 3 pg ooaE `o€?€e2g>Fgg `nFe? k3 Eyp IDQ P3 oJ$3 Ff?$"?# ?? -30 RRR'?r ay__r Ka•??t t?BS +? o?Y1"€ dIIF'SY Yx9' $II Cv ti."15 c?? s J5 ?? a g ?s gig aE R , ass ` $x - flap. 3 3 R a C l IM 2i a 6F.1 ? `? .• $ggg Sa ~E `o Eby ?'qa I CCC .F 333 E niza, 1 •. 4 1. ZB p?E? g .3 as o?-a Q g s s a 2 zz- 1G s"a•az-aa a?gEg 3R1'N.?s ?s .$B.?•as$a 9? _ ggae°?5 nSa G? 0vsc Ada $: E va en -t _?IE___v o3 vsel 0ia ??a ?X?' s? ??rr?.. r=?a g¢E¢$36ee o1 a 3a n a?"= ?3 3 -g, =2 cY?g.s' qas ^?a? 2?"e ^.??o's o Y9" ?- U1? as `a FZ-, 12 ?'Fg?g?y=' e?#ue3 ?fita S' = 6 gg° ? F 1 fia8 . Eat= a' sa •x?rs n ? N SHERIFF'S RETURN - REGULAR CASE NO: 1999-04103 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS. BRETZ WESLEY CPL. TIMOTHY REETZ , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND CIVIL ACTION was served upon BRETZ WESLEY the defendant, at 15:33 HOURS, on the 22nd day of July 1999 at 905 A BOSLER AVE LEMOYNE, PA 17043 CUMBERLAND County, Pennsylvania, by handing to WESLEY BRETZ a true and attested copy of the NOTICE AND CIVIL ACTION and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answe Docketing 18.00 r Service 9.92 Affidavit .00 Surcharge 8.00 A -Tnomas I ine, $35. 92 K 14AW PA ASSOCIATES 7 023/19 99 by -7-,,.Z Sworn and subscribed to before me this day of 19A.D. . r/l? c_ t _? 7 VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. STATE ST. P.O.Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE ADDRESSES OF THE PARTIES ARE: PTF: 7920 NW 110th Street Kansas City, MO 64153 DEF: 905A Bosler Avenue Lemoyne, PA 17043-1759 CITIBANK (SOUTH DAKOTA) : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff VS. WESLEY BRETZ Defendant NO. 99-4103 PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Please enter Judgment in favor of the Plaintiff and against the said Defendant for failure to plead or otherwise respond to the Complaint and assess the damages as follows: AMOUNT OF CLAIM $6,961.24 PLUS- Attorneys Fees $1,740.31 LESS-Amount paid on account $ .00 PLUS-Interest from 05-15-99 To 08-23-99 $ 381.40 TOTAL $ 9,092.95 plus costs 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 intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. A true and correct copy of the notice pursuant to Pennsylvania Rule of Civil Procedure No. 237.1 is attached hereto and marked Exhibit "A". VAL IE ROSENBLUTH PARK, ESQUIRE Attorney for the Plaintiff AND NOW, Judgment is entered in favor of the Plaintiff and agai s the Defendant by Default for want of an Answer and dams es assessed at the sum of $9,092.95 plus costs as per the above ertification. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. VALERIE ROSENBLUTH PARK, Esquire Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street P.O. Box 1779 Doylestown, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CITIBANK (SOUTH DAKOTA) N.A. CUMBERLAND COUNTY . COURT OF COMMON PLEAS Plaintiff VS. WESLEY BRETZ Defendant NO. 99-4103 AFFIDAVIT NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUCKS Valerie Rosenbluth Park, Esquire, being duly sworn according to law, deposes and says that she will make this affidavit on behalf of the within Plaintiff, being authorized to do so, and that she knows of her own personal knowledge and therefore avers, that WESLEY BRETZ, Defendant, is not in the Military or Naval Service of the United States or its Allies or otherwise within the provisions of the Soldiers and Sailor Civil Relief Act of Congress of 1940 and its amendments. Valerie Rosenbluth Park, 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. zz l l' VALERIE ROSENBLUTH PARK, ESQUIRE 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. VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF CITIBANK (SOUTH DAKOTA) N.A. : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff VS. WESLEY BRETZ Defendant NO. 99-4103 N O T I C E 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: PARK LAW ASSOCIATES, P.C. at is telephone umbe (215) 348-5200. PROTHONOTARY. THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION Q13TAINM WILL BE USED FOR THAT PURPOSE. VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF CITIBANK (SOUTH DAKTOA) N.A. : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Plaintiff VS. WESLEY BRETZ Defendant NO. 99-4103 NOTICE OF PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO: WESLEY BRETZ 905A BOSLER AVENUE LEMOYNE, PA 17043-1759 DATE OF NOTICE:08-17-99 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 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 Reference Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 PARK W ASSOCIATES, P.C. BY VA IE RO NBLUTH PARK, ESQUIRE THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT I r-? CL - La V; C U C Cr ? (2?6 IN THE COURT OF CONMN PLhAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ( ) Confessed Judgment Citibank (South Dakota) N.A. () Other C/0 25 East State Street X Execution-Garnishment Doylestown, PA, 18901 File No. 99-4103 VS. Wesley Bretz 2151 Queens Drive, Apt B2, Harrisburg, PA, 17111 Commerce Bank, garnishee 100 Senate Avenue, Camp Hill, PA, 17011 TO THE PROTHONOTARY OF THE SAID COURT: Amount Due $9,092.95 Interest arem 09 _09-9Q Atty's Comn Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate or?.ginal proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of County, for debt, interest and costs upon the following described property of the defendant(s) PRAECIPE FOR ATTACHfi12C EXIT MON Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Levy upon all savings accounts, checking accounts, certificates of deposit and obligations owed to the Defendant, Wesley Bretz 188-68-2250 at commerce Bank, garnishee. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis s against real estate of the defendant(s) described in the attached exbit. DATE: Signature: V V Print Name: Vale,- FoSP-Ibluth Park Address: P 0 Box 1779, 25 East State Street Doylestown, PA, 18901 ._•.-ccy for: ;tibank (South Dakota) N_A, 215-348-5200 ;f N 724 l a t4 p lTam 41rM adToassd alesedas 9TT3 '4TaM spur oy 1sTT 30 s9rdoo.Tno3 ITddns '1srT AITeuossad Ay16u9T 3I '(6ZTE 'oN 'd'J'Ned) dryssauMO 30 3rnepr33e 3o Cdoo pup Teur6r.xo ue pue sluauranoxdirr 6urpnTour uoTldTSOSap 30 sardoo xrs CTddns IA4.Tadosd Teat 91 :sa4ON SHERIFF'S RETURN - GARNISHEE CASE NO: 1999-04103 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS BRETZ WESLEY And now RICHARD SMITH ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 1044:00 Hours, on the 6th day of April , 2000, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT BRETZ WESLEY , in the hands, possession, or control of the within named Garnishee COMMERCE BANK 100 SENATE AVE. CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to DEB WILSON, PRESIDENT'S ASSISTANT & ADULT IN CHARGE personally three copies of interogatories together with THREE true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her Sheriff's Costs: Docketing 100 Service .00 Affidavit .00 Surcharge .00 .00 .00 So a R.R. Thomas Kline Sheriff of Cumberland County 00/00/0C Sworn and subscribed to before me this day of /? U'A.? By /oz•v A.D. P o honotary VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P. C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF CITIBANK (SOUTH DAKOTA) N.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff VS. WESLEY BRETZ Defendant COMMERCE BANK Garnishee NO. 99-4103 PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of the Plaintiff and against the Garnishee, Commerce Bank, in the amount of $459.35, admitted in the Answer to Interrogatories to be in garnishee's possession. PARK LAW A,, SOCIATES VALERIE ROSENBLUTH PARK, ESQUIRE Attorney for Plaintiff AND NOW, to wit, thisAL?_day of l 2000, judgment is entered in favor of the Plaintiff and against the garnishee aforesaid in the amoun of $459.35. PROTHONOTARY VALERIE ROSENBLUTH PARK, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES, P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF CITIBANK (SOUTH DAKOTA) N.A VS. WESLEY BRETZ COMMERCE BANK Pursuant to Rule 236 of the Supreme Court you are hereby notified that a Judgment has been you in the above proceeding as indicated below: Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS Defendant Garnishee NO. 99-4103 N 0 T I C E Judgment by Default X Money Judgment Judgment in Replevin Judgment in Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings of Pennsylvania, entered against IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: PARK LAW ASSOCIATES, P.C. at this telephone number: (215) 348-5200. PROTHONOTARY: THIS IS AN ATTEMPT TO COLLECT WILL BE USED FOR THAT PURPOSE. A DEBT. ANY INFORMA ON OS?AINED t VALERIE ROSENBLUTH PARK ATTORNEY I.D. # 72094 PARK LAW ASSOCIATES, P. C. 25 EAST STATE STREET, P.O. BOX 1779 DOYLESTOWN, PA 18901 (215) 348-5200 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CITIBANK (SOUTH DAKOTA) N.A.' PLAINTIFF VS WESLEY BRETZ DEFENDANT COMMERCE BANK GARNISHEE NO. 99-4103 Am6oc ne INTERROGATORIES TO GARNISHEE TO: COMMERCE BANK 100 SENATE AVENUE CAMP HILL, PA 17011 i? c_ 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 a Judgment against you. 1. Did the garnishee ever have an account of any type with the Defendant? If so, please identify the account number and the balance of said accounts. C-6ck v.n OCco,.., + 403:?e5334I0 \«.\a",( e W 95-q. 35 2. If the answer to the preceding interrogatory is in the affirmative, state with regard to each account: (a) Identify all documents that were given to the Bank or signed for the bank establishing the account. PIA (b) State the bank's understanding of the legal composition of its customer and identify all documents the bank has that show the legal composition (ie: individual, corporation, partnership, sole proprietorship)f I TN A?Ji ?v0.I (c) State all addresses given for the bank's customer and all addresses to which the account statements were to be sent. '{S5 5 PvJt.) PO 1-70 L s (d) Identify whether the defendant holds any accounts jointly with any other entities. If so, please provide the name of said entity, account number and balance. No (d) State how title is held on all accounts. 3. At the time you were served or at any subsequent time, did the Defendant have a safe deposit box at your bank or at any branch of your bank? If your answer is in the affirmative, please provide the box number and location. CIO . 4. At the time you were served or at any time subsequent, did you owe the defendant any money or were you liable to him/her/it on any negotiable or written instrument, or did you claim that you owed it/him/her any money or were liable to him/her/it for any reason: PJ O a) State with specificity the amount owed by you for each obligation you owed to the defendant; 01A b) Attach a copy of all documents; Nlt? 5. At the time you were served or at any subsequent time, did you hold as fiduciary any property in which the Defendant has an interest? If your answer is in the affirmative, describe the nature and value of said property. 00• 6. At any time or after you were served, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent; and what was the consideration therefor? N0- 7. At any time after you were served, did you pay, transfer, or delivery any money or property to the Defendant or to any person or place pursuant to its direction or otherwise is in the affirmative, set forth dates and amounts specifically. 00. 8. If the answer to the preceding interrogatory is in the affirmative, state with regard to each account: (a) Identify all documents that were given to the Bank or signed for the bank establishing the account. 01 F- (b) State your understanding of the legal composition of its customer and identify all documents the bank has that show the legal composition, ?Ih" (c) State all addresses given for the bank's customer and all addresses to which the account statements were to be sent. Park Law Associates P.C. By: _ Valerie Ro Park, Esquire \. n. ?ci '-7 i J _ n " f ?F??i ? ? ? .i Mi ? .ti .S '?4 I U L -..5. Valerie Rosenbluth Park, ESQUIRE Attorney I.D. #72094 PARK LAW ASSOCIATES,P.C. 25 E. State Street Doylestown, PA 18901 (215 348-5200 ATTORNEY FOR PLAINTIFF CITIBANK (SOUTH DAKOTA) N.A VS. WESLEY BRETZ COMMERCE BANK Plaintiff Defendant Garnishee : CUMBERLAND COUNTY : COURT OF COMMON PLEAS NO. 99-4103 ORDER TO MARK JUDGMENT SATISFIED AGAINST GARNISHEE ONLY TO THE PROTHONOTARY: Kindly mark the Judgment in the above captioned matter satisfied as to, COMMERCE BANK, Garnishee ONLY upon payment of your costs. PARK LAW ASSOCIATES, P.C. BY: I VALERIE ROSENBLUTH PARK, ESQUIRE ?- _ > , ? ??; ;? ';?? . _ ,_. r ? r' Y.7 ::. -- i?_ ?? ? ? Q CJ `?p ,? av ", ?' ? l1 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. No action has been taken in the last six months. Sheriff's Costs: Docketing 618.00 Poundage 1.36 Law Library .50 Prothonotary 1.00 Service 9.30 Garnishee 9.00 Surcharge 10.00 Levy 20.00 $69.16 Sworn and subscribed to before me Advance Costs: 6150.00 Sheriff's Costs: 69.16 $ 80.84 So Answer: R. Thomas Kline, Sheriff This /,¢- da of 2QA.D.?-)Uyc._ Cc, YNc¢Px - ti?nZr p"'.ASS Prothonotary is By aIn P 1 ?Jai,( k J epu y Sheriff 9 t 0 15? i:12.3o3i1 ?„ /D 33L WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 99-4103 CIVIL tW CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Citibank (South Dakota) N.A. C/O 25 East State Street Doylestown, PA 18901 PLAINTIFF(S) from Wesley Bretz 2151 Queens Drive, Apt B2 Harriahnrg PA 17111 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Levy upon all savings accounts, checking accounts, certificates of deposit and obligations owed to the Defendant, Wesley Bretz 188-68-2250 at Commerce Bank. garnishee, GARNISHEE(S) as follows: Commerce Hank, garnishee 100 Senate Avenue, Camp Hill, PA 17011 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $9,092.95 L L $.50 Interest cnm 09-09_99 Due Prolhy 81.00 Arty's Comm % Other Costs Ally Paid $108.42 Plaintiff Paid Date: - April 4, 2000 REOUESTING PARTY: Curtis R. Long Prothonotary, Civil Division by: Deputy Name Valerie Rosenbluth Park, Esq. Address: P.O. Box 1779, 25 East State Street DoViestown, PA 18901 Attorneyfor: Citibank (South Dakota) N.A. Telephone: 215-348-5200 Supreme Court ID No.