HomeMy WebLinkAbout07-61071
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff No: toIa7 CIViI TerM
VS.
COMPLAINT IN CIVIL ACTION
JESSICA M LEHMAN
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
06089878 C A Pit KMJ
f Ift
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
JESSICA M LEHMAN
Defendant
Civil Action No
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, CAPITAL ONE BANK is a corporation with offices at 6851
JERICHO TURNPIKE #190 SYOSSET , NY 11791
2. Defendant is adult individual(s) residing at the address listed
below:
JESSICA M LEHMAN
9 BUTTONWOOD LN
CARLISLE, PA 17013
3. Defendant applied for and received a credit card bearing the
account number 4862362391515411 .
4. Defendant made use of said credit card and has a current balance
due of $1452.44 , as of September 15, 2007
5. Defendant is in default by failing to make monthly payments when
due. As such, the entire balance is immediately due and payable to
Plaintiff.
6. Plaintiff is entitled to the addition of interest at the rate of
25.9009. per annum on the unpaid balance from September 15, 2007 . A
copy of Plaintiff's Application is attached hereto, marked as Exhibit
111" and made a part hereof.
7. 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 , JESSICA M LEHMAN , individually , in the amount of
$1452.44 with continuing interest thereon at the rate of 25.90016 per
annum from September 15, 2007 plus costs.
James C. rmbrodt,42524
WELTMAN, W INBERG & REIS CO., L.P.A.
436 Sev nt Avenue, Suite 2718
Pittsb rgh PA 15219
(412) 434- 955
FAX: 412- 38-7130
0608,')878 C A Pit KMJ
This law firm is a debt collector attet' g to collect this debt for
our client and any information obtaine ill be used for that purpose.
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VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is
(NAME)
authorized agent of Capital One Bank, plaintiff herein, that he/she is duly authorized to make this
verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of
his/her knowledge, information and belief.
(SIGNA"TUltE)
W WR#
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CASE NO: 2007-06107 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK
VS
LEHMAN JESSICA M
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
LEHMAN JESSICA M the
DEFENDANT , at 2111:00 HOURS, on the 6th day of November-, 2007
at 9 BUTTONWOOD LN
CARLISLE. PA 17013
by handing to
CHRISTOPHER HEINBAUGH, HUSBAND
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
???DO
Sworn and Subscibed to
before me this
of
18.00
5.76
.00
10.00
So Answers:
R. Thomas Kline
11/07/2007
WELTMAN T.TEINBERG REIS
By.
day
A. D.
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
JESSICA M LEHMAN
Defendant
No. 07-6107 CIVIL TERM
PRAECIPE FOR. DEFAULT JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
WILLIAM T. MOLCZAN, ESQUIRE
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06089878
Judgment Amount $ 1557.56
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
CAPITAL ONE BANK
Plaintiff Case # 0-7 -(r )0"7 C'iVI L
RIM
JESSICA M LEHMAN
Defendant (s)
IMPORTANT NOTICE
TO: JESSICA M LEHMAN
9 BUTTONWOOD LN
CARLISLE,PA 17013
Date of Notice: WWR#: 06089878
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:
r1t- / IY?vvLV
PATRICK THOMAS WOODMAN
PA I.D. 434507
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 KOPPERS BLDG, 436 7TH AVE.
PITTSBURGH, PA 15219
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK.
Plaintiff
vs. Civil Action No. 07-6107 CIVIL TERM
JESSICA M LEHMAN
Defendant
TO THE PROTHONOTARY:
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, JESSICA M LE14MAN above named, in the default of an
Answer, in the amount of $1557.56 computed as follows:
Amount claimed in Complaint
$1452.44
Interest from SEPTEMBER 15, 2007 TO DECEMBER 26, 2007
at the legal interest rate of 25.900% per annum $105.12
TOTAL
$1557.56
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:
WILLIAM T. moteZAN, 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#06089878
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 9 BUTTONWOOD LN CARLISLE,PA 17013
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
JESSICA M LEHMAN
Defendant
Case no: 07-6107 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, JESSICA M
LEHMAN 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, JESSICA M LEHMAN is not in the military service.
Further Affiant sayeth naught.
(N
AFFIANT
SWORN TO AND SUBSCRIBED in my presence thisaW day
of ??CP?fY11G7 acm
COMMONWEALTH OF PENNSYLVANIA
Notari=enynty
"-YAk./
NO Y PUBLIC Wayne A. JoneCity og pittsburghL
y Commission EMember, Penrsyivanie Asscc+ation orNotaries
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
DEC-26-2007 07:14:58
,< Last Name First/Middle Begin Date Active Duty Status Service/Agency
LEHMAN 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.
01
/#I ji4i,
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: httR://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 12/26/2007
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs. Civil Action No. 07-6107 CIVIL TERM
JESSICA M LEHMAN
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Judgment was entered against you
on
(xx) Assumpsit Judgment in the amount
of $1557.56 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
ID
BY S .sdl.9_ /111
Ajd5
PRO ONOTARY (OR DEPU Y)
JESSICA M LEHMAN
9 BUTTONWOOD LN
CARLISLE,PA 17013
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219
1-888-434-0085
T, h
1! SEE 19
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
No. 07-6107 CIVIL TERM
vs. PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
JESSICA M ' ,EHMAN I Rb conewd ?zd dcjrljsJowl im lS
Def::,idant(s)
M & T B. ,NK 1 W. Ph5W 34' CA(?SI? t ?1F ?' ?3
Garnishee(s)
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
QNk `egp'l. So '?8 a
?3.1 (* Ct5F
$5o GAP
Q.s? «4
?z?ac?893
WWR No. 6089878
1/' -? 'y z?Y
IN FHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs. Civil Action No. 07-6107 CIVIL TERM
JESSICA M LEHMAN
Defendant(s)
M&TBANK
Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
10 THE PROTHON07ARY:
Kindly issu-, a Writ of Execution in the above matter...
1. direlcted to the Sheriff of CUMBERLAND County:
2. agaivi.,t.)LSSICA M LEHMAN , Defendant
3. against M & T BANK... Garnishee
'. Judgment Amount $ $1,557.56
Less Payments/credits received $ $0.00
Interest
Costs
SUBTOTAL:
Costs (to be added by Prothonotary):
$ $342.06
$ $1,899.62
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: Uj4l-
William m T. Molczan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers 13461ding
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 6089878
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-6107 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CAPITAL ONE BANK Plaintiff (s)
From JESSICA M LEHMAN, 90 Concord Road, Carlisle, PA 17015
(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, 1 WEST HIGH STREET, 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 $1,557.56
L.L. $.50
Interest $342.06
Atty's Comm %
Atty Paid $153. alf
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: SEPTEMBER 19, 2011
(Seal)
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 f'or: PLAINTIFF
Q-YI-
D. Buell, Prothonotary
By:
Deputy
Telephone: 412-434-7955
Supreme Court ID No. 47437
SHERIFF'S OFFICE OF CUMBERLA,tkQ UNTl(
Ronny R Anderson ;
Sheriff
tt p
y4ttittlp pi n+raGr? d1? ,ry; i 1 S,` i 2' 1 p 2'23
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor OFF C, ',)f TfE ERIFF.
Capital One Bank
vs.
Jessica M Lehman
SHERIFF'S RETURN OF SERVICE
Case Number
2007-6107
09/22/2011 10:54 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded
all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control
of the within named garnishee, 1 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County,
by handing to Donna Egolf, Customer Service Rep., 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.
The writ of execution and notice to defendant was mailed on September 23, 2011 to Jessica M. Lehman at
90 Conrad Road, Carlisle, PA 17015.
SO ANSWERS,
September 23, 2011 RON Y R ANDERSON, SHERIFF
"A ?12
Z
illiam Cline, Deputy
icj Ccu'It,;Suite SterIff Ieleoi:ott. If c
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs.
JESSICA M LEHMAN
uel'undant(s)
M & T BANK
Garnishee(s)
Civil Action No. 07-6107 CIVIL TERM
TO: M & T BAND, 1 WEST HIGH ST, CARLISLE, PA 17013
RE: JESSICA M LEHIv1AN, 90 CONRAD RD, CARLISLE, PA 17015
Suggested Reference No.: XXX-XX-8219
XXX-XX- ftAa0J5
IMPORTANT NOTICES TO GARNISHEE!
{ Y A2 _
cr,
CD
C)
A. You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure co 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.
W WR No. 6089878
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 hin, for any reason (including funds on deposit for checking or savings accounts and certificates of
deposit)?
I a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount
of money y'ou 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.
?g53gC71?' 5 loo `41-0
?. At the time you were served or at any subsequent time was there in your possession, custody or
control of yourself a.-Id one or more other persons any property of any nature owned solely or in part by the
defendant.
V\
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned stalely or part by the defendant or in which defendant held or claimed any interest?
nb
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?
Ob
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?
rN o
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?
? o.
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
recurrine basis and which are identified as being funds that upon deposit are exempt from execution, levy or
attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption,
the amount being withheld under each exemption and the amount of funds in each account, and the entity
electronically depositing those funds on a recurring basis.
n+>
WWR No. 6089878
S. 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.
yes ??s3?61?'s t- 115 c??I??la1.3Y3J-^I-
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
q"kkk
10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking
or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this
institution.
c1 a rYSr? ni . v r?c3? e .?eay1 i ?n
11. If tl„ response to Interrogatory 7 is in the affirmative, are other funds comingled in the account
which are not depositcul eiectronically on a recurring basis and which are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law?
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: -.?
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
W W R No. 6089878
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is (???- ?_?
(Name)
of a'rt' Aor) , 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 Interru gator t: s are true and correct to the best of his/her knowledge, information and belief.
(SIGNAtURE)
WAR No. 6089878
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WELTMAN, W EINBERG & REIS CO., 1..!'.A.
FAY: James C Warmbrodt, Esquire
I.D. No.42524
436 Seventh Aveirue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File 4 6089878
CAPITAL ONE BANK
vs.
JI?SS1CA N1 LEHMAN
ar '
M & F BANK
Garnishee(s)
re
Attorney for Plaiaft(CT 2 j PM Or2: 0 4
PE?'mc Y?_'?'?! X11 }; . .
Cumberland County
Court of Common Pleas
NO. 07-6107 CIVIL TERM
PRA Prtff: TO DISCONTINUE ATTACHMENT EXECUTION
TO THE P1:7TIiONOTARY:
Kindly n)ark,_d the above matter discontinued and ended as to Garnishee(s), M & T BANK,
only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Swot,i to arkd sv',,scribed
Bel"-)-e me tl e / 7 da-, ctober, 7,Oli
j%??) Y Pu1?-
J-me "arm4out, Esquire
Aco v r Pit?mtiFf
Y-13.6)6 'i?L"?
eta ioiti?gs!
tom- a?zs?
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
FILED`OFTiCC?
tr 1 H P-ROTHONOTARY
ZOI I NOY 21 AM 1Q ?o
CUMBERLAND COUNTY
'ENNSYLVANIA
Capital One Bank
vs.
Jessica M Lehman
Case Number
2007-6107
SHERIFF'S RETURN OF SERVICE
09/22/2011 10:54 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded
all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or
control of the within named garnishee, 1 W High Street, Carlisle Borough, Carlisle, PA 17013,
Cumberland County, by handing to Donna Egolf, Customer Service Rep., 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.
The writ of execution and notice to defendant was mailed on September 23, 2011 to Jessica M. Lehman
at 90 Conrad Road, Carlisle, PA 17015.
11/15/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned
SATISFIED.
SHERIFF COST: $117.53 SO ANSWERS,
November 16, 2011 RbNWY- R ANDERSON, SHERIFF
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