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HomeMy WebLinkAbout07-4231 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant 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 06005444 C A Pit WLG + ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No MELANIE R JOHNSON 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: MELANIE R JOHNSON 107 N PITT ST CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011298656036591 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 July 05, 2007 in the amount of $4511.07 . 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 MELANIE R JOHNSON ,INDIVIDUALLY in the amount of $4511.07 with interest at the legal rate of 6.000 per annum from date of judgment plus attorneys' fees of $500.00 and costs. Jame C. armbrodt,42524 WEL EINBERG & REIS CO., L.P.A. 436 Seve th Avenue, Suite 2718 Pi tsbur h, PA 15219 ( 2) 4 4-7955 F 4 2-338-7130 6005 44 C A Pit WLG This law firm is a debt collector at e ting to collect this debt for our client and any information obta' d will be used for that purpose. M ~21t 2007 ~ ~ !, ~J ~,; r{: I~J.~-~~ r,,., I i;._,,-~,,,,... ay , r Please make check payable to Discover Platinum Card. Minimum payment due includes a past due amount of $900.00. 22 SDSN6A01 0010867 MELANIE JOHNSON 107 N PITT ST CARLISLE PA 17013-2334 Save time and a stamp this month by paying your bill online. To find out about our free and flexible online payment features, visit Discovercard.com/pay PO BOX 15251 ~~~nrr~~nrnnn~n~u~n~r~~u~ Address, email or telephone changed Print change in sppaace WILMINGTON DE 19886-5251 above, or go to Discovercard.com.Printyoure-mailaddressto ~ur~~~r~n~n~r~u~n~~ur~r~ur~r~r~r~uu~~r~r~rnr~~~r~u~ receive important Account information and special offers. 000006011298656036591045110700000000451107 Discover More Card Account Summary Closing Dote: ;Account Number Payment Due Date Minimum Payment Due Credit Limit Credit Available 'Cash Credit Limit Cash Credit Avaiable April 22, 2007 page 1 of 1 6011 2986 5603 6591 Previous Balance $4 511 07 May 21, 2007 Payments And Credits , . 0 00 $4,511.07 Purchases . ~~~•~ Cash Advances + 0.00 $0•~ Balance Transfers + 0.00 $0.00 Finance Char s + 0.00 $0•~ ew Balance + 0.00 ~ ~ ~' 54,511.07 1~ ] /r ~:ashback Bonus® Opening Cashback Bonus Balance $ 0,00 New Cashback Bonus Eamed + 0.00 Cashback Bonus Balance $ 0.00 Coshback8onus~Amriversary-----------------------AYailable_t~Redaetn__- -------____--s_______4,00_- Dote: November 22 !How Can We Help You? F~ A««~t iryuiries, writ. to ~, ah. ;Please hove your Discover Card available. Discover More Card, PO Box 30943 Sak Lake City, UT 84130 Manage your amount online at Discovercard.com TDD (Felecommunicalions Device for the Dsa fl: Customer service: 1-800-DISCOVER (1-800.347-2683) For assistance, see reverse side. Transactions $0 Fraud Liability Guarantee Use year Discover Cord with confidence. ;Information For You While we ore Permitted under fhe Cardmember Agreement to increase the APRs on your Account because your payment was kite, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on purchases aid any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of purchases and balance hnnsfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the minimum payment due by the payment due date. See the Defauh Rate Plan section of the Cardmember Agreement for `details. ;Finance Charge Summary . ' Nominal Transaction Average Daily ANNUAL ANNUAL Periodic fee Daily Periodic PERCENTAGE PERCENTAGE Fes- F~~S b ces Rates RATES RATES current biAing period: 31 days Purchases $0 Cash Advances $p previous biAing period: 22 days Purchases $0 The rates Nnart apply to your Accour 0.06367% 23.24% V 23.24% $0 none 0.06299% 22.99% F 22.99% $0 $0 0.06367% 23.24% V 23.24% $0 none rt are either fixed (F) or they may vary (V) as noted above. 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 _ s~~~ ts~ /~ K~a.~ (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 # 6005444 MELANIE R JOHNSON 6011298656036591 ~ ~ \` _ I C~ N - n ,_~ r_ `~ `~ 1 rA v ~ --~ ~ r ~..1 ~ .«~ : l ~ {_ V ~~ ° L ~ rn "::, r,~ ~rl .,~ --C SHERIFF'S RETURN - REGULAR CASE NO: 2007-04231 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS JOHNSON MELANIE R KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JOHNSON MELANIE R the DEFENDANT at 1612:00 HOURS, on the 24th day of July 2007 at 107 N PITT STREET CARLISLE, PA 17013 MELANIE JOHNSON by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 .00 bj~4/01 ~ 32.80 Sworn and Subscibed to before me this day of , So Answers: .~~ R. Tho as Kline 07/25/2007 WELTMAN WEINBERG REIS By: p ty riff A.D. f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant No. 07-4231-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#06005444 Judgment Amount $ 501 l .07 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK. Plaintiff vs. Civil Action No. 07-4231-C1VIL TERM MELAN IE R JOHNSON Defendant TO THE PROTHONO'fAKY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, MELANIE R JOHNSON above named, in the default of an Answer, in the amount of $501 1.07 computed as follows: Amount claimed in Complaint $451 I.07 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $500.00 TOTAL $501 1.07 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: ~Olo WILLIAM T. MOL AN, ESQUIRE PA I.D.#47437 weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 W W R#06005444 Plaintiff s address is: c/o Weltman, 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: 107 N PITT ST CARLISLE,PA 17013 ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff MELANIE R JOHNSON Defendant(s) IMPORTANT NOTICE TO: MELANIE R JOHNSON 107 N PITT ST CARLISLE,PA 17013 ('~ Date of Notice : Z~ v' WWR#: 06005444 Case # CJ / ~~~1 ~r~ ) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY : ~~~ G~C~~ G~CCfi~%J r-~.G+~-- 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. MELANIE R JOHNSON Defendant Case no: 07-4231-CIVIL TERM NON-MILITARY AFFIDAVIT 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, MELANIE R JOHNSON 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, MELANIE R JOHNSON is not in the military service. Further Affiant sayeth naught. I/7/^//J,(j/ J"I /" II _ AFFIANT SWORN TO AND SUBSCRIBED in my presence this ~ day ,~ ,~ ~...o -` NOT RY PUBLIC ~~ dial" -~---- "4ec~~ eG F . -~s tissn.,;r; y. ~ .~ , r ecec This law firm is a debt collector attempting to collect this debt for our client an~any information obtained ~wiCi ~e 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 SEP-04-2007 06:06:18 Last Name First/Middle Begin Date Active Duty Status Service/Agency JOHNSON MELANIE 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. ~+~ ~y- 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. §§ 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: http//www.defenselink.mil/faq/pis/_PC09SLDR.html_ WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 9/4/2007 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: lCGOOPYFRU https://www.dmdc.osd.mil/scraJowa/scra.prc_Select 9/4/2007 i9Z ~--. r~~ _ ~ _~ 7 _ 1 E .- -~.. . r., , ~ -. ~ f. "~ 8 ~ ~ _ o~j0 p ~~' ~ _ ' ~ < r.; f 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK. Plaintiff vs. Civil Action No. 07-4231-CIVIL TERM MELANIE R JOHNSON Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Jud ment was entered against you on 9 O'll0 0'7 (xx) Assumpsit Judgment in the amount of $501.1.07 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: . ~ D PR T ONOTARY (OR DEPU ) 1VIELANIE R JOHNSON 107 N PITT ST CARLISLE,PA 17013 Plaintiff s address is: c!o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsbw~gh, PA 152]9 1-888-434-0085 .- _. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 07-4231-CIVIL TERM vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY MELANIE R JOHNSON Defendant MEMBERS 1ST FEDERAL CREDIT UNION, Garnishee, 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#06005444 f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-4231-CIVIL TERM MELANIE R JOHNSON , I~'7 N Pitt S+ '(,u,r lisle P A 17013 Defendant MEMBERS 1ST FEDERAL CREDIT UNION, 500 ~+se Dr I~Aecl, , P w ~ cos S Garnishee PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2, against MELANIE R JOHNSON, Defendant 3. against MEMBERS 1sT FEDERAL CREDIT UNION, Garnishee 4. Judgment Amount $ Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): 5011.07 $ 122.74 $ 5133.81 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William . Molcz squire PA I.D. #47437 WELTMAN, WE ERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06005444 ~`* ~- sti ~ ~ $ 9- ~ ~ c`~~ 04 ~ „~ ~ ~ , Q tJ1 . ~ ~ ~ ,~,, oca 9~ :~" t.. ~ ~ .~ Q' ~ o oQ ,.. ~ ~ ~~ b o ~ O ~ x 4 c~ ~ , .~ --~ ~ 't[ ~y ~' ~ rv `a E 1 ;.a ~ =~ -G WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4231 CIVIL TERM CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From MELANIE R. JOHNSON, 107 N. Pitt Street, Carlisle, PA 17013 (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: MEMBERS 1sT FEDERAL CREDIT UNION, 5000 Louise Drive, Mechanicsburg, PA 17055 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 $5,011.07 Interest -- $122.74 Atty's Comm Atty Paid $152.30 Plaintiff Paid Date: 3/10/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs f~ Curtis R. ong, Ptot~onota By: REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, Pa 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Deputy Supreme Court ID No. 47437 SHERIFF'S RETURN - GARNISHEE CASE N0: 2007-04231 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS JOHNSON MELANIE R And now NOAH CLINE ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:45 Hours, on the 17th day of March 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named GARNISHEE , MEMBERS 1ST FEDERAL CREDIT UNION in the hands, possession, or control of the within named Garnishee 1166 WALNUT BOTTOM RD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to LINDA HARTLEY (TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . Sh 'ff' C _ true and made eri s osts : So ansv~~~~~ :~ Docketing .00 ,/,.~r+~" ~~~~ Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .0000 ~ 3/i8/o~ 03/18/2008 Sworn and Subscribed to before me this day of By l~ ~,~~(~, Deputy Sheriff A.D RECEIVED MAR 18 2008 WWR#06005444 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant and No. 07-4231-CIVIL TERM INTERROGATORIES IN ATTACHMENT MEMBERS 1sT FEDERAL CREDIT UNION MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee 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#06005444 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant and MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee Civil Action No.: 07-4231-CIVIL TERM TO: MEMBERS 1sT FEDERAL CREDIT UNION Suggested Reference No.: XXX-XX-2407 5000 LOUISE DRIVE, MECHANICSBURG , PA 17055 RE: MELANIE R JOHNSON 107 N PITT ST CARLISLE,PA 17013 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 properly 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 ATTAC)EIl1~NT 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? n c~ 1 a. If the answer to Inten•ogatory 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. no 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. ~ O 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 I 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? nU 7. If you are a bank or other fmancial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 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. ~~ ~~ I~ U ~(~•YP S~vir~~~CU ~CKi rr~ ~ I 13 ~1 WELTMAN, WEINBERG & REIS CO., L.P.A. By; - ~~~ William olczan, quire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06005444 VERIFICATION The undersigned does hereby verify subject to t-h-e~penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is I (.I {~ ~~,(,_. , ~ ~ n ~' (Name) ` of Menf~s ~St Fed61~1 Credit Uhion ~5~f ~~iS garnishee herein, (Title) (Company) 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. ~ ,f U IG URE) ~ ~- r.a ~::~ ~-~ d -n ~~ ~ .-~ y ~~ n~ -r;iT' ~ r r ~ ~ -, ~` ;:. ~ ~°~~ ~ :~ c~ 4~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant No. 07-4231-CNIL TERM PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE MEMBERS 1ST FEDERAL CREDIT UNION ONLY MEMBERS 1ST FEDERAL CREDIT UNION Garnishee FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T MOLCZAN PA LD #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh. Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06005444 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant MEMBERS 1ST FEDERAL CREDIT UNION Garnishee Civil Action No. 07-4231-CIVIL TERM PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE .MEMBERS 1ST FEDERAL CREDIT UNION, ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, MEMBERS 1ST FEDERAL CREDIT UNION, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. Sworn to and subscribed Before me the ~_ Day of APRIL, 200 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer M. Borowski, Notary Public City !~f Pittsine~p~ +~ilegneny County My Comams~a+ Exlxres Feb. 22, 2012 Member, Pennsylvania Association of Notaries By: / WIL IA T M ZAN PA I.D #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06005444 ~ ~ ("'~ c.~ C_.. C':l C ~3 tl (x~ . r`'~ V' ~ ~ ~~ C; ., .'f M , 7.~_1 , U i _ ~..`-) O R. Thomas Kline, Sheriff, who being duly sworn according to law, states Q this writ is returned STAYED. ~~ ~a Sheriff's Costs: Advance Costs: 150.00 Sheriff' s Costs: 85.99 `ti- Docketing 18.00 64.01 Poundage 1.69 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 07/01/08 Mileage 4.80 Surcharge 30.00 Levy 20.00 Certified Mail Post Pone Sale Garnishee _ 9.00 Postage TOTAL $ 55.99 '~ ~lbp~j((~~~' So Answers; %"_" ••- ~ ~'.~~ R. Thomas Kline, Sheriff y Claudia A. Brewbaker zfi ~~ ~ z i ~~w 8~a1 ,,,{~ ~. ~1~ ~~ ~t4~~U .iF' t ~'lv V~ ~„' ~ ~y?~v a ~,aS`~ ~' J W WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4231 CIVIL TERM CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From MELANIE R. JOHNSON, 107 N. Pitt Street, Carlisle, PA 17013 (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: MEMBERS 1sT FEDERAL CRIIDIT UNION, 5000 Louise Drive, Mechanicsburg, PA 17055 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 $5,011.07 Interest -- $122.74 Atty's Comm Atty Paid $152.30 Plaintiff Paid Date: 3/10/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs Curtis .Long, Pr notary By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, Pa 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 ~~~~~ 1010 MAR -1 PM 4~ 25 r E.; d;~iSYL~1~"~I;~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant and No. 07-4231-CIVIL TERM ~us cJSz.r INTERROGATORIES IN ATTACHMENT M&T BANK and MEMBERS 1ST FEDERAL CREDIT UNION M&T BANK and MEMBERS 1ST FEDERAL CREDIT UN ON Garnishee 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 1.5219 (41.2) 434-7955 WWR#6005444 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant and M&T BANK and MEMBERS I ST FEDERAL CREDIT UNION Garnishee Civil Action No.: 07-4231-CIVIL TERM TO: M&T BANK Suggested Reference No.: XXX-XX-2407 960 WALNUT BOTTOM ROAD CARLISLE, PA 1.7013 MEMBERS 1sT FEDERAL CREDIT UNION 1 l 66 WALNUT BOTTOM ROAD CARLISLE, PA 17013 RE: MELANIE R JOHNSON 51 SARASOTA CIR CARLISLE, PA 17015 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? ~© 1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such- negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. ~~~ 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? N~ 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? ~Q 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. ~~ 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 an_y otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. ~ J~ fie.-mod. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ~it/A' William T. IVlolczan,~quire PA I.D. #47437 ~~// WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#6005444 1 St MEMBERS 1ST FEDERAL CREDIT UNION February 25, 2010 Name: Melanie R Johnson Address: 107 North Pitt Street Carlisle Pa 17013 Account Number: XXX688 Name on Account: Melanie R Johnson Savings: $00.00 Checking: $113.27 $(50.00) processing fee $300.00 Statutory Exemption was not taken out. d o~~~. od Burkholder De osit Operations Analyst 5000 Louise Drive P.O. Box 40 Mechanicsburg, Pennsylvania 17055 (800) 283-2328 wwwmemberslst.org 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 Jody L. Burkholder (Name) Deposit Operations Analyst ofMembers 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (S NATURE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson H ( [ l~1~~~+~1~-E;~t-ri~y~ y(~/}'{~~/ Sheriff r ~~~' ~~~tl~ll 4~. ~~tit~~7ppr.7 ~ f~! i 1 `L. ~..~t~{l~4 {I w ~ Jody S Smith ~ Chief Deputy ."~' ~_- -'~ , 2~~ ~ ~~~ ' $ Aid $~ fYt ~~s Edward L Schorpp ~ ` Solicitor oFt=~~E °~ T- r.~~st~F CEJIt~~ ',' ti~1T1" Discover Bank Case Number vs. 2007-4231 Melanie R Johnson SHERIFF'S RETURN OF SERVICE 02/25/2010 10:06 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 25, 2010 at 0957 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Melanie R. Johnson, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Brian Peters, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to him. The writ of execution and notice to defendant was mailed on March 8, 2010 to Melanie Johnson, 51 Sarasota Circle, Carlisle, PA 17015. 02/25/2010 10:20 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 25, 2010 at 1008 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Melanie R. Johnson, in the hands, possession, or control of the within named garnishee, M & T Bank, 960 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Angela Hetrick, Teller, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. SO ANSWERS, ~ ~~~ March 05, 2010 RON RAND SON, SHERIFF By ~!^--- William CLine, Deputy (c; CountSuite She:~i~t. Telex=_oft, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY; PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant and M&T BANK and MEMBERS 1ST FEDERAL CREDIT UNION Garnishee No. 07-4231-CIVIL TERM ~~,~ ws~.,s `7'a INTERROGATORIES IN ATTACHMENT M&T BANK and MEMBERS 1sT FEDERAL CREDIT UNION c~ q ` ~ n <~.= ~ ^7 ~ ~ ~";' ~.; r - m _' •_ `~' `o v ~ ~ FLED ON BEHALF OF: c } ` ~ Plaintiff ~,~ ~ <~~ ~ ,,. ~: _` ~ rn COUNSEL OF RECORD OF :~ w TINS PARTY: ~' `C William T. Molczan, Esquire PA LD. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsbw~gh, PA 15219 (412)434-7955 WWR#6005444 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL Df.VISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant and M&T BANK and MEMBERS 1ST FEDERAL CREDIT UN10N Garnishee Civil Action No.: 07-4231-CIVIL TERM TO: M&T BANK Suggested Reference Nn.: XXX-XX-2407 960 WALNUT BOTTOM ROAD CARLISLE, PA ] 7013 MEMBERS 1sT FEDERAL CREDIT UNION 1 166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 RE: MELANIE R JOHNSON 51 SARASOTA CIR CARLISLE, PA 17015 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 propeiTy 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 Ga-7~ishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's accowit, 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. ~~~~C~ ~~~~ iV~)~° ~~~~~,~ L~~~PA~~~'`~,~,q~C„~tlRl~ INTERROGATORIES IN ATTACHMENT 1. At the time you were seined 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? I~~~~-- l a. if the answer to inten-ogatory 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 te~-~ns, 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 an_y subsequent time was there in your possession, custody or control of yourself and one or mor other persons any property of any nature owned solely or in part by the defendant. y%1~~,~ 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? ~~~~ ~-~. 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? i~~~~'L.. 5. At any time before or after you were served, did the defendant transfer or deliver any propeiTy to you or to any person or place pursuant to our directions or consent and if so what was the consideration thereof? ~~LL. 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? 1f so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. ~~:'~ ~~~ ~~~~.~ I~~~~ ~yy~+r~ww~.``~}{~~~g/~p~ ~y~r'p ~p~~ry»v.~ ~ phr~p(y~~`~' ~ (y~~~ ~aeT. g yg} C...Otl49~Ea.tr? C ~~AM91 J~ A n~I1 +N~~s'~~ b~ 8. 1f 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 fiu~ds on deposit, not including an_y otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. ~ 8123? (f so, identify each account. ~,~-~- , ~~ <`' ~~~ i\Aelissa fVl. Peters ~ll~~'F.3ank },,~, k`~~ G` ;~...J ` LIAR °- 4 ~A1~ WELTMAN, WEINBERG &REIS CO., L.P.A. ;. y: `/ u' William T. Molczan, quire PA I.D. #47437 ,/~ WELTMAN, WEINBERG &REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 16219 (412)434-7955 WWR#6006444 VERIFICATION Tlie undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to t~nsworn falsifications to authorities, that he/she is (Title) of (Name) (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 knnowledge, infoi~nation and belief. (SIGNATURE) WTLTMAN, WEINBERG & REIS CO., L.P.A. BY: Matthew D. Urban, Esquire t.Q. No.90963 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 06005444 DISCOVER BANK vs. MELANIE R JOHNSON and M&T BANK anD MEMBERS 1ST FCU Garnishee(s) C'1 c=- 0 s: Attorney for Plaintiff(s~' ~~'` 4 ~ ~ , f - ~ ~ `: ~ : ~~ ~~ -:~' c5 ?~ -,u -c CUMBERLAND County Court af.~ommon Pleas NO: 07-4231-CIVIL TERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TC7 THE PROTHONOTARY: Kindly marked the above matter settled, discontinued, and ended as to Garnishee(s), M&T.BANK anD MEMBERS 1ST FCU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Matthew D. Urban, Esquire Attorney for Plaintiff Sworn to and subscribed B~#~~re me the ~ Day of MARCH, 2010 ~~~ COMMONWEALTH OF PENNSYLVRIV 4 q~ ~6,~C Notarial Seai 5nena G.3evan, Notary t'ut;lic City t~f Pittsburgh, Allegheny Gounty My Commission Expires Nav.15, 2010 Nerr~te.~, i'ennsyh«nia Assaci~tian of Notaries ~ 8. oo P~ f4T~N e~-~ ~~~t ~ ash Rx~`aa9 rya s ~ • a ~w i Z~(0 FES ! ~ ~t.~ 2~ S6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION DISCOVER BANK Plaintiff ci~~Fj ova. 1~0 vs. ~,,ras P P 5~ `~~e , MELANIE R JOHNSON Defendant .~t7oj ~ M&T BANK and _qlu~ ~n'(~1j5~ PA MEMBERS 1sT FEDERAL CREDIT UNION, ~1 ~~ I~uAn ut .~of'folrt Garnishee, ~.~ 1sk~ /~ A 17013 No. 07-4231-CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLI~ FILED ON BEHALF OF Plaintiff O ~a~.so po A~ 3a. go CBF 85. qq ., 78. 5p I~ • 00 '' a~. so -- g,oo ~~ ~ a08. aq - Po Arry ~ a. oo k~t,~ (-0 ~k#~5(OOl B ~r'rf- _ n a~ ~1" COUNSF,L OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA LD. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#6005444 .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNII, DIVISION DISCOVER BANK Plaintiff vs. MELANIE R JOHNSON Defendant M&T BANK and MEMBERS 1ST FEDERAL CREDIT UNION, Garnishee TO THE PROTHONOTARY: Civil Action No. 07-4231-CIVIL TERM 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 MELANIE R JOHNSON, Defendant 3. against M&T BANK anD MEMBERS 1sT FEDERAL CREDIT UNION, Garnishee 4. Judgment Amount $ 5,011.07 Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 705.12 $ 5,809.98 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan squire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh. Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#6005444 ..~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4231 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From MELANIE R. JOHNSON, 51 Sarasota Circle, Carlisle, PA 17013 (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: M&T BANK, 960 Walnut Bottom Road, Carlisle, PA 17013 MEMBERS 1sT FEDERAL CREDIT UNION, 1166 Walnut Bottom Road, 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 $5,011.07 L.L. Interest -- $705.12 Atty's Comm % Due Prothy $2.00 Atty Paid $268.29 Other Costs Plaintiff Paid Date: 2/16/10 David D. Buell, Prothonota (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: 412-434-7955 Supreme Court ID No. 47437