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HomeMy WebLinkAbout07-4607 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA //~~~~ Plaintiff No: ~7- ~(p~7 1.~~<< TP~'1'h vs. COMPLAINT IN CIVIL ACTION STEVE E WESTHAFER Defendant 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 06029483 C J Pit KXW r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No STEVE E WESTHAFER 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 r COMPLAINT 1. Plaintiff is CITIBANK (SOUTH DAKOTA) NA with place of business located at 701 East 50th Street North, Sioux Falls, South Dakota, 57117. 2. Defendant is adult individual(s) residing at the address listed below: STEVE E WESTHAFER 71 SILVER CROWN DR MECHANICSBURG, PA 17050 3. Plaintiff is a national banking association, engaged in consumer lending through the issuance of credit cards. 4. Pursuant to Defendant's request, Plaintiff furnished to the Defendant a credit card account (hereinafter account) bearing account number 5424180237811853 . 5. Plaintiff kept accurate running records of all debits and credits to the Account. 6. Plaintiff mailed to Defendant monthly statements for the account including the billing statement attached hereto as Exhibit A. The monthly statements accurately stated the previous balance, the debits and credits to the account for the prior billing period. 7. Defendant's actions as set forth above constituted an account stated between parties for the sum of $3252.46 which sum reflects the Exhibit A statement balance less credits, if any, which were applied subsequent to the date of Exhibit A. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant STEVE E WESTHAFER INDIVIDUALLY in the amount of $3252.46 with continuing interest thereon at the rate of 6.000% per annum from date of judgment plus costs. James C. Warmbrodt,42524 WELT EINBERG & REIS CO., L.P.A. 436 Seve th Avenue, Suite 2718 Pi sbur h, PA 15219 (4 2) 4 4-7955 F 2-338-7130 602 483 C J Pit KXW ~°~ S' ~g3 07/09/07 $3252.46 $48.00 SITE:KC-CL TM:CO-5000 ACID:KCB3104 #~~- -?~? zi~:a#~#_- 06/18/07 18:17:41: CITI CARDS PO BOX 183059 STEVE E WESTHAFER COLUMBUS, OH ATTNY ACCOUNT-CODE=LE14 43218-3059 , MECHANICSBURG PA 17050-1638000 Cities Driver's Edc~e~ Platinum Select Card-Charter Rbts Account Number 5424 1802 3781 1853 Customer Servke• C tl~ 1-800-967-8500 Total Credit Llne AvalWble Credk Line Cash Advance Limit Available Cash Limit New 9aianee $6100 $0 $310 $0 $3252.46 BOX 6500 SIOUX FALLS, SD Statement/ Closln Data 4 Amount Over Credit Lint Past Dua Pnrch/Adv Minimum Dua Minimum A ount Due 57117 06/14/2 07 $0.00 + 60.00 + $48.00 = 48.00 SaN Data Post Data Reference Number Activity Since Last Statement Amount Payments, Credits & Adjustments 5/21 81540063 PAYMENT THANK YOU -1,600.00 70 0000 0000 00000000000 Our records show home phone 717-697-7624 and business phone 717-697-6305. Please update coupon if incorrect. 161 Account Summary revious (+) Pure ases (-) aymen s (+) ANC (_) New Balance & Advances & Credits CHARGE Balance PURCHASES $4,852.46 0.00 $1,600.00 0.00 $3,252.46 ADVANCES $0.00 0.00 $0.00 0.00 $0.00 TOTAL $4,852.46 0.00 $1,600.00 0.00 $3,252.46 Da s This Blllin Period: 31 Rate Summary a ante u )ec o eno is Nomura Finance Charqe Rate APR PERCENTAGE RATE PURCHASES Standard Purch $0.00 0.08833%(D) 32.240% 32.240% Purch/Adv thru 09/14/2006 $0.00 0.08833%(D) 32.240% 32.240% ADVANCES Standard Adv $0.00 0.08833%(D) 32.240% 32.240% JI IL-15-2007 14 ~ 25 P.02i07 .• Verification ry •I~ ~~I'1 C~~ St~`{'h- , ~~~~ an employee of citicor Ser•vi~es Inc., (~5,4) which is b p Credrt y ~anir•F3ct the service pZ•trvidej• for pfairrtiff' ( TFI ~,~,[i~t~7'A~ ~.~'~. retair~ec.l tc~ r~cr•ft~rm services irrcu;.iirtt.; €~ut rrrrt primat•iEy 1;rni~c.s:I tip colir.czirr~r ' ~ cielincfuerZt debt. f am ~ratElc;ri::ec1 tee rnalce tlyis verifie~~titrn ors attc~r•rey-in.~f'aet for plaintiff under powers of attorney from pt~~intif'f' tc~ C'iticorp Credit Services, Inc., (LISA} i;nd tea mc. 'C'ite forc~goin; averments of fact ip the within pleading are true artd correct tU the E~est of my krrc~~vletIge, information acid belief.. Y nntierstand that the statements m~cde herein acre subject to the penalties of 1.8 P~:• C~:.S. Section 4904, reiatin;; :o trnss~vorr~ f~fsitic:ai~ion tc., the .i ui~ltorities. _3 ,. STEVE E WES7'~~4FC;It. S4z418023781fSS3 '~'dWR#GUZ9483 C' : c rv o T~ _ ~ ~ ' G i t c7 t r; i' r t ~ ~`''~ ~ ~ ~ O '~ ' ;_,r ~ L'~ ~j ~ p -c ;~ ~ .:~-Y~ -~ O ff ~ N ~ ~ { -1 -"~ a ~ -~" SHERIFF'S RETURN - REGULAR CASE NO: 2007-04607 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS WESTHAFER STEVE E RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WESTHAFER STEVE E the DEFENDANT at 0922:00 HOURS, on the 10th day of August 2007 at 120 ALLEN STREET MECHANICSBURG, PA 17050 STEVE WESTHAFER 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 Service Affidavit Surcharge ~f~~a~ C.~... So Answers: 18.0 0 ~~"~/ .~ 9 . 6 0 ~r~' .gut .ri-r~s;r~ ~~r~r/..~ .00 10.00 R. Thomas Kline 00 ~60 08/15/2007 WELTMAN WEINBERG RF~ A Sworn and Subscibed to By: before me this day of A.D. ty Sheriff r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. STEVE E WESTHAFER Defendant No. 07-460?-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 W W R#06029483 Judgment Amount $ 3,430.96 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 CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No. 07-4607-CIVIL TERM STEVE E WESTHAFER Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, STEVE E WESTHAFER above named, in the default ofi an Answer, in the amount of $3,430.96 computed as follows: Amount claimed in Complaint $3,430.96 Interest from date of judgment at the legal interest rate of 6% per annum TOTAL $3,430.96 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. ~. w~9~~~ 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 WWR#06029483 Plaintiffls 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: 71 SILVER CROWN DRIVE, MECHANICSBURG, PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff Case # - V ~~ STEVE E WESTHAFER Defendant(s) IMPORTANT NOTICE TO: STEVE E WESTHAFER 71 SILVER CROWN DR MECHANICSBURG,PA 17050 Date of Notice: WWR#: 06029483 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 : /~tU~L+aQ c~JG~' PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 1N THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. STEVE E WESTHAFER Defendant Case no: 07-4607-CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That helshe 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, STEVE E WESTHAFER 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, STEVE E WESTHAFER is not in the military service. Further Affiant sayeth naught. ~~ AFFIANT ~- SWO O AND SUBSCRIBED in my presence this ~ (~ay of~ . ~~ COMMONWEALTW OF PENNSYLVA'~!'A OTARY PUBLIC N°~"'~~~ ~ wlVs~.~!y L. QaWt, Notfl~ye r ti~~. ail `y 0~ Plt~burph, Alley;' >,ta~ ~~i ~: ~y(,~r: „u:.~eion F.xpirs:..iu3y 15~?01. ,~: '~~i~c.a`i~v,~nVaA s,:alatlt~:~~!n'^:i s 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 SEP-27-2007 05:58:27 * Last Name First/Middle Begin Date Active Duty Status Service/Agency WESTHAFER STEVE 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. ~ ~,-~- 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/fact/~is/PC09SLDR.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 9/27!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: QPNRGXR K'XQ https://www.dmdc.osd.miUscralowa/scra.prc_Select 9/27/2007 two f.~ c.-~ .=il C _ - '---' .-l C #~ -~ _,y l 4 'tC ~ ~;7'~ 'S' _ O ~' © ~ 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs, Civil Action No. 07-4607-CIV1L TERM STEVE E WESTHAFER Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order o Ju gment was entered against you on 9 (xx) Assumpsit Judgment in the amount of $3,430.96 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: s~ PROTHONOTARY (OR DEPUT STEVE E WESTHAFER 7I SILVER CROWN DRIVE MECHANICSBURG, PA 17050 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`'' Avenue, Pittsburgh, PA 15219 I-888-434-0085 . ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. STEVE E WESTHAFER Defendant GRAYSTONE BANK CITIZENS BANK INTEGRITY BANK, Garnishee, No. 07-4607-CNIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT and LEVY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412} 434-7955 WWR#6029483 ., - ! ~ «e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. STEVE E WESTHAFER Defendant GRAYSTONE BANK CITIZENS BANK INTEGRITY BANK, Civil Action No. 07-4607-CIVIL TERM Garnishee PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... ~ levy on Q,r,~ o~ Q,,l~ 1. directed to the Sheriff of CUMBERLAND County: ~'rs°~ ~ro~~' 2. against STEVE E WESTHAFER, Defendant , '? - S. Ivey Crb~on l~r, Mecb , PA hoso 5115 E. `7riKIIE ~. W1e01~ FA i7p5~ ~ 3345 Ma.~lwt s+, C'.a.+~yr Fti. a PA rto i ~ 3. against Graystone Bank, Citizens Bank & Integrity Bank, Garnishee , 4. Jud ment Amount au''~a~.s+ g Meck, PA ~~oss $ 3430.96 ~. Interest Costs SUBTOTAL: $ 4.28 $ 3435.24 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: 'W ~ `'~ William T. Molcza Esquire PA LD. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6029483 ~' ~1.., T ~ to y~ P .r~k ,,,=~~S ~ ~ ~ ~,, v ' a ~ a 4 Q , ~ .' ~.' `? t~~? ,~ 4u ~ oq ~ g s ~ Q a , _ _ ~ p ~ ,~ ~ ~: , ~,r~ :: ~~ ~- ~: --- ~~~:- - r~ ~ -~ ' ' ~, 6 ~ WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4607 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK (SOUTH DAKOTA} N.A., Plaintiff (s) From STEVE E. WESTHAFER, 71 Silvercrown Drive, Mechanicsburg, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell ~ti1l~ o~ 4.11 ~r oPer'Fy. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: GRAYSTONE BANK, 5115 E. Trindle Road, Mechanicsburg, PA 17050 CITIZENS BANK, 2 W. Main Street, Mechanicsburg, PA 17055 INTEGRITY BANK, 3345 Market Street, 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 $3,430.96 Interest $4.28 Atty's Comm Atty Paid $157.10 Plaintiff Paid Date: 10-17-07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs ~ (~c~~ ~ - Curtis R. Long, Prothonota By: k Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 2718 KOPPERS BLDG. 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 ~~ Carl D. Lundblad, Esquire Attorney I.D. No. 80059 GRAYSTONE BANK 112 Market Street Harrisburg, Pennsylvania 17101 Attomey for Graystone Bank CITIBANK (SOUTH DAKOTA) NA, Plaintiff COURT OF COMMON PLEAS ~• CUMBERLAND COUNTY, PA STEVE E WESTHAFER, Defendant NO.: 07-4607-CIVIL TERM and GRAYSTONE BANK, Garnishee ANSWERS AND NEW MATTER TO INTERROGATORIES IN ATTACHMENT ADDRESSED TO GARNISHEE, GRAYSTONE BANK Carl D. Lundblad, Esq. General Counsel Graystone Bank 112 Market Street Harrisburg, PA 17101 (717) 724-4655 Attorney for Garnishee, Graystone Bank GARNISHEE'S ANSWERS TO INTERROGATORIES 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? ANSWER: Graystone Bank (the "Bank") maintains the following account for the party indicated: Steven E Westhafer 71 Silver Crown Drive Mechanicsburg, PA 17055 Checking Account # 16100063 87 Balance as of October 26, 2007 - $ 50.00 Balance as of November 9, 2007 - $ 4,916.31 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. ANSWER: The Bank maintains the following account for the party indicated: Steven E Westhafer 71 Silver Crown Drive Mechanicsburg, PA 17055 Checking Account #1610006387 Balance as of October 26, 2007 - $ 50.00 Balance as of November 9, 2007 - $ 4,916.31 -2- 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? ANSWER: The Bank maintains the following account for the party indicated: Steven E Westhafer 71 Silver Crown Drive Mechanicsburg, PA 17055 Checking Account #1610006387 Balance as of October 26, 2007 - $ 50.00 Balance as of November 9; 2007 - $ 4,916.31 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 in part by the defendant or in which defendant held or claimed any interest? ANSWER: No. 4. At any time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? ANSWER: No. 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? ANSWER: On November 6, 2007, $4,866.31 was deposited into Checking Account #1610006387, which is titled in the name of Steven E. Westhafer. As of November 9, 2007, the balance of such account was $ 4,916.31. -3- 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? ANSWER: No. 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. ANSWER: No. NEW MATTER 1. Pursuant to the Bank's Consumer Fee Schedule relating to the account(s) referred to in the Bank's Answers to Interrogatories above, defendant is obligated to the Bank fora "Writ of Execution" fee of $250.00, plus attorney fees, relating to this matter. The Bank hereby claims its right to set-off such amounts owed by Defendants to the Bank from any amount claimed by Plaintiff. 2. The Bank has incurred and will incur attorney fees in the amount of $200.00 in preparation and investigation of the Answers to Interrogatories and in the general handling of this matter. -4- 3. Pursuant to 42 Pa. Con. Stat. Ann. §2503(3), Bank, as Garnishee, is entitled to reasonable counsel fees as a matter of law. WHEREFORE, Bank, Garnishee in this matter, prays that the Court authorize the set-off of the $250.00 writ of execution fee and assess and award reasonable counsel fees as permitted by law in the amount of $200.00 to be set-off from the amounts claimed by Plaintiff. Respectfully submitted, GRAYSTONE BANK By: Carl D. Lundblad Attorney I.D. No. 80059 112 Market Street Harrisburg, PA 17101 (717) 724-4655 Attorney for Garnishee, Graystone Bank Date: November 13. 2007 -5- VERIFICATION Howard Stein deposes and says, subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, that he is the Senior Vice President of Graystone Bank, that he makes this verification by its authority and that the facts set forth in the foregoing Answers and New Matter to Interrogatories in Attachment are true and correct to the best of his knowledge, information and belief. I(~13 07 Date: ~//~ Name: Howard Stein, Senior Vice President -6- CERTIFICATE OF SERVICE I hereby certify that on November 13, 2007, a copy of the foregoing Answers to Interrogatories in Attachment Addressed to Garnishee, Graystone Bank, was served upon the persons and in the manner listed below: Service by U. S. first class mail as follows: William T. Moczan, Esquire Weltman, Weinberg & Reis Co., LPA 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 Steven E Westhafer 71 Silver Crown Drive Mechanicsburg, PA 17055 -7- O ~ ~ "f? r,_! 1 !' ~.,,.. ~t ~ ~ , 1 ~ . r r~ ~~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. STEVE E WESTHAFER Defendant GRAYSTONE BANK Garnishee No. 07-4607 CIVIL TERM PRAECIPE FOR JUDGMENT AGAINST GARNISHEE 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. 271.8 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6029483 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No. 07-4607 CIVIL TERM STEVE E WESTHAFER Defendant GRAYSTONE BANK Garnishee PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, GRAYSTONE BANK , in the amount of $3435.24, which is the amount Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. olczan, quire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (41.2)434-7955 W WR#6029483 I hereby certify that the address of the Plaintiff 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 Garnishee is: 5115 E TRINDLE RD MECHANICSBURG PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No. 07-4607 CNIL TERM STEVE E WESTHAFER Defendant GRAYSTONE BANK Garnishee CARL D LUNDBLAD ESQ GRAYSTONE BANK ] 12 MARKET ST HARRISBURG PA 1.71.01 NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff ( )Defendant (xx) Garnishee You are hereby notified that the following Order or Judgment was entered against you on ~0~ (xx) Assumpsit Judgment in the amount of $3435.24 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 ( ) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: c~oz~y~3 Carl D. Lundblad, Esquire Attorney I.D. No. 80059 GRAYSTONE BANK 112 Market Street Harrisburg, Pennsylvania 17101 Attorney for Graystone Bank CITIBANK (SOUTH DAKOTA) NA, Plaintiff v. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA STEVE E WESTHAFER, Defendant and GRAYSTONE BANK, Garnishee NO.: 07-4607-CIVIL TERM ANSWERS AND NEW MATTER TO INTERROGATORIES IN ATTACHMENT ADDRESSED TO GARNISHEE, GRAYSTONE BANK By: Carl D. Lundblad, Esq. General Counsel Graystone Bank 112 Market Street Harrisburg, PA 17101 (717) 724-4655 Attorney for Garnishee, Graystone Bank GARNISHEE'S ANSWERS TO INTERROGATORIES 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? ANSWER: Crraystone Bank (the "Bank") maintains the following account for the party indicated: Steven E Westhafer 71 Silver Crown Drive Mechanicsburg, PA 17055 Checking Account #1610006387 Balance as of October 26, 2007 - $ 50.00 Balance as of November 9, 2007 - $ 4,916.31 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. ANSWER: The Bank maintains the following account for the party indicated: Steven. E Westhafer 71 Silver Crown Drive Mechanicsburg, PA 17055 Checking Account # 16100063 87 Balance as of October 26, 2007 - $ 50.00 Balance as of November 9, 2007 - $ 4,916.31 -2- 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? ANSWER: The Bank maintains the following account for the party indicated: Steven E Westhafer 71 Silver Crown Drive Mechanicsburg, PA 17055 Checking Account #1610006387 Balance as of October 26, 2007 - $ 50.00 Balance as of November 9; 2007 - $ 4,916.31 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 in part by the defendant or in which defendant held or claimed any interest? ANSWER: No. 4. At any time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? ANSWER: No. 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? ANSWER: On November 6, 2007, $4,866.31 was deposited into Checking Account #1610006387, which is titled in the name of Steven E. Westhafer. As of November 9, 2007, the balance of such account was $ 4,916.31. -3- 6. At any time after you were served did you pay, transferor 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? ANSWER: No. 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 attaclunent 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. ANSWER: No. NEW MATTER 1. Pursuant to the Bank's Consumer Fee Schedule relating to the account(s) referred to in the Bank's Answers to Interrogatories above, defendant is obligated to the Bank fora "Writ of Execution" fee of $250.00, plus attorney fees, relating to this matter. The Bank hereby claims its right to set-off such amounts owed by Defendants to the Bank from any amount claimed by Plaintiff. 2. The Bank has incurred and will incur attorney fees in the amount of $200.00 in preparation and investigation of the Answers to Interrogatories and in the general handling of this matter. -4- 3. Pursuant to 42 Pa. Con. Stat. Ann. §2503(3), Bank, as Garnishee, is entitled to reasonable counsel fees as a matter of law. WHEREFORE, Bank, Garnishee in this matter, prays that the Court authorize the set-off of the $250.00 writ of execution fee and assess and award reasonable counsel fees as permitted by law in the amount of $200.00 to be set-off from the amounts claimed by Plaintiff. Respectfully submitted, GRAYSTONE BANK By: Carl D. Lundblad Attorney I.D. No. 80059 112 Market Street Harrisburg, PA 17101 (717) 724-4655 Attorney for Garnishee, Graystone Bank Date: November 13, 2007 -5- VERIFICATION Howard Stein deposes and says, subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, that he is the Senior Vice President of Graystone Bank, that he makes this verification by its authority and that the facts set forth in the foregoing Answers and New Matter to Interrogatories in Attachment are true and correct to the best of his knowledge, information and belief. It~13 0~ ~~ Date. Name: Howard Stein. Senior Vice President -6- ~ ~ u CERTIFICATE QF SERVICE I hereby certify that on November 13, 2007, a copy of the foregoing Answers to Interrogatories in Attachment Addressed to Garnishee, Graystone Bank, was served upon the persons and in the manner listed below: Service by U. S. first class mail as follows: William T. Moczan, Esquire Weltman, Weinberg & Reis Co., LPA 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 Steven E Westhafer 71 Silver Crown Drive Mechanicsburg, PA 17055 -7- ~ "64~ -~ ~ ^` '~~l „'~` t L""~ {.'.. .. r~ :.a ._..a .-,y> w": CrJ .-~ L~ t':? ~,J '"~`1 -t} "~ j-{1 t~~~ ~ ~''~ ~ ~ ','1 ==-t ,..~ SHERIFF'S RETURN - GARNISHEE .,CASE N0: 2007-04607 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA} NA VS WESTHAFER STEVE E And now ROBERT BITNER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:55 Hours, on the 26th day of October 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT WESTHAFER STEVE E hands, possession, or control of the within named Garnishee GRAYSTONE BANK 3599 OLD GETTYSBURG RD CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to JULIE PULGAR (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 . in the true and made Sheriff's Costs: So answers: Docketing .00 Service .00 Affidavit .00 R. Thomas Surcharge .00 Sheriff of Cumberland County .oe 11/21/2007 Sworn and Subscribed to before me this day of By Deputy Sheriff A.D SHERIFF'S RETURN - GARNISHEE y. CASE N0: 2007-04607 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS WESTHAFER STEVE E And now WILLIAM CLINE ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:57 Hours, on the 8th day of November 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT WESTHAFER STEVE E hands, possession, or control of the within named Garnishee CITIZENS BANK 2 W MAIN ST MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to JOYCE ZEIGLER {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 in the true and made Sheriff's Costs: So answgg Docketing .00 ~+,. Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County . 0 0 ~ /z ~o D ~ . 0 0 / ,. J 11/21/2007 Sworn and Subscribed to before me this day of By Deputy Sheriff A.D SHERIFF'S RETURN - GARNISHEE SASE NO: 2007-04607 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND CITIBANK (SOUTH DAKOTA) NA VS WESTHAFER STEVE E And now WILLIAM CLINE ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:18 Hours, on the 8th day of November 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT WESTHAFER STEVE E hands, possession, or control of the within named Garnishee INTEGRITY BANK 3345 MARKET ST CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to TRISH PLACIDO (CUSTOMER SERVICE REP) 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 answers: Docketing .00 /°;i~... Service .00 ~~~~`~•~C ~ 2' Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County . 0 0 0 0 ~ /~~i~d7 11/21/2007 Sworn and Subscribed to ,, .~ ~ /' before me this day of By ~ ~G---~ Depu y Sheriff A.D / ~ .~ 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL .DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff No. 07-4607-CNIL TERM vs. PRAECIPE FOR SATISFACTION OF JUDGMENT AS TO THE GARNISHEE GRAYSTONE BANK ONLY STEVE E WESTHAFER Defendant GRAYSTONE BANK Garnishee FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 William T. Molczan, Esquire PA. LD.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#6029483 ~ . •.~ i IN THE COURT OF COMMON .PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. STEVE E WESTHAFER Defendant GRAYSTONE BANK Garnishee Civil Action No. 07-4607-CNIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT AS TO THE GARNISHEE , GRAYSTONE BANK, ONLY TO THE PROTHONOTARY: Please kindly Satisfy the Judgment of the above captioned matter upon the records of the Court and mark the cost paid as to Garnishee, GRAYSTONE BANK, only. Sworn to and subscribe Before me the Day of JANU/A~RY , 2 8 NO RY PUB WELTMAN, WEINBERG & REIS CO., L.P.A. g Iczan, Esquire 67 WEINBERG & REIS CO., L.P.A. •s Building 436 ev th Avenue Pi b gh, PA 1.5219 (1 434-7955 Y~ James C. W PA I.D #42 William .l PA. LD. 47 WELT A 2718 op e 3 COMMONWEALTH OF PENNSYLVANIA Notarial Sea! Wayne A. Janes, Notary Public City Of Pittsburgh, Aliegheny County My Comrnissi~xn ExpirYS June 5,10'90 :3m~r;r. PeruzWylvan~a?s;::~,:~acur. sr Notaries C 00 y ?~: w ,~; ~!;~ r ~ , ~, ~ rt7 ~ 6` ~ ~ ~~ ~ CT ' ~ ~"~ ~~ ~ ..O =y ~ ~._ ,~ rn ~ 1 CA C3J ~., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff No. 07-4607 CNIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE INTEGRITY BANK ONLY STEVE E WESTHAFER Defendant INTEGRITY BANK Garnishee FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA LD #42524 WELTMAN, WEINBERG & REIS CO., L.P.A.. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (41.2)434-7955 WWR#6029483 '.,~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action. No. 07-4607 CIVIL TERM STEVE E WESTHAFER Defendant INTEGRITY BANK Garnishee PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE ,INTEGRITY BANK ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned. matter as to Garnishee, INTEGRITY BANK, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. armbrodt PA [. D # 2 24 WELT A ,WEINBERG & REIS CO., L.P.A. 2718 pp s Building 436 S~vent Avenue Pittsburgh, A 15219 (412) 434 955 Vr~WR 029483 Sworn. to anal subscribed Before me the ~L=` Day of NOVEMBER. 2007 N ARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wendy L. Gault, Notary'Publio City Of Pittsburgh, Allegheny County My Commission Expires ,tuly 15, 2010 Member, Pennsylvania Association of Notaries -~- C ~ ~+. C3 (~ :' ..: _ ~ ~~ try t_ ~ ~ ~ W ... ti. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. STEVE E WESTHAFER Defendant No. 07-4607-CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I . D #42524 WELTMAN, WEINBERG 8~ REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6029483 ~. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CITIBANK (SOUTH DAKOTA) NA Plaintiff vs. Civil Action No. 07-4607-CIVIL TERM STEVE E WESTHAFER Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. Sworn to and subscribed before me this -3}~ day o uary, 09 NO Y COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer M. Borowski, Notary Public Cfty of Pitfaburgh, Allegheny County M Commission Expires Feb. 22, 2012 Member. pennaylvanla Association of Notaries WELTMAN, WEINBERG &REIS CO., L.P.A. By: James C. ar brodt PA I . D #4 524 WELTM INBERG &REIS CO., L.P.A. 1400 K pe Building 436 See Avenue Pittsbu , PA 15219 (412) 4 4 -7955 WWR #6029483 ~~ ~~ r- ~ O ..p ~ Q 95 ~ -; ~'' :~ { : ~` _ i~1 :.: ~~,! R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Docketing Poundage Law Library Prothonotary Mileage Surcharge Levy Postage Garnishee Advance Costs: 300.00 Sheriff's Costs: 260.61 18.00 39.39 5.11 .50 Refunded on 06/04/09 2.00 48.00 80.00 80.00 27.00 n So Answers, 260.61 / G l e s~ a 9 7~ '~c /, R. Thomas Kline, Shenjff ,., R. Lantz a c 'lG~'~~~ l ~ r~ 1 ~.~ ~ Y ~, G Q9~G ~~G,7`~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4607 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIBANK (SOUTH DAKOTA) N.A., Plaintiff (s) From STEVE E. WESTHAFER, 71 Silvercrown Drive, Mechanicsburg, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell A.hy or 0.11 ~srsona.l Fk`o(~~y . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession J of GARNISHEE(S) as follows: GRAYSTONE BANK, 5115 E. Trindle Road, Mechanicsburg, PA 17050 CITIZENS BANK, 2 W. Main Street, Mechanicsburg, PA 17055 INTEGRITY BANK, 3345 Market Street, 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 $3,430.96 Interest $4.28 Atty's Comm Atty Paid $157.10 Plaintiff Paid Date: 10-17-07 (Seal) L.L. $.50 Due Prothy $Z.00 Other Costs • 1C . ~s R. Long, Prothono By: PJ ~. Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 2718 KOPPERS BLDG. 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone : 412-434-7955 Supreme Court ID No. 47437