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HomeMy WebLinkAbout07-7461 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: VS. ROBERT CAMPBELL COMPLAINT IN CIVIL ACTION 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 06307780 C A Pit WLG f l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No ROBERT CAMPBELL 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 f COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 New Albany Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at the address listed below: ROBERT CAMPBELL 4201 GETTYSBURG RD LOT 9 CAMP HILL, PA 17011 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002410727879 . 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 November 28, 2007 , in the amount of $2359.61 . 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 $300.00 . 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 , ROBERT CAMPBELL INDIVIDUALLY , in the amount of $2359.61 with interest at the legal rate of 6.000W per annum from date of judgment plus attorneys' fees of $300.00 , and costs. James 06 Warmbrodt,42524 436 Pitt (412 FAVO WEINBERG & REIS CO., L.P.A. h Avenue, Suite 2718 PA 15219 -7955 -338-7130 C A Pit WLG This law firm is a debt collector at m ing to collect this debt for our client and any information obtai e will be used for that purpose. D15CCIV'ER $2,359.61 $2,359.61 I Enter Amount Enclosed Below C,, R 4 I Payment Due Date Ckrobsr 21, 2007 Please make check payable to Discover Card. Minimum payment due includes a past due amount of $431.00. 2.1 S )SWA01 0007482 ROBEF T CAMPBELL Manage your budget, track your spending 4201 GETTYSBURG RD LOT 9 and avoid fees with FREE timely e-mail CAMP HILL PA 17011-6637 reminders. To find out more, visit Discovercard.com/reminders PO BOX 15251 11l, r J 1, r r I J II n II l r l l rsl Address, a- mcil or telephone change? Print change in space WILMINGTON DE 19886-5251 above, or yo to Discovercard.com. Print your o-mail address to receive important Account information and special offers. 000006011002410727879023596100000000235961 Discover More Card Account Summary Closing Data: September 22, 2007 page 1 of 1 Account numbtrr ending in P 7879 Previous Balance $2 359 61 ayment Due Cate October 21, 2007 Payments And Credits , . Minimum Payment Due $2,359.61 Purchases 0'00 Credit Limit $1,500.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $0.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance -- _ $2,359.61 Cashback Bonus® Opening Cashback Bonus Balance $ 0 00 . New Cashback Bonus Earned + 0.00 Cashback Bonus® Anniversary - Cashbock Bonus Balance $ 0.00 Available fo Redeem $ 000 Date: March 22 How Can We Help You? For Account Inquiries, write to us at.. Please have your Discover Card available Discover More Card, PO Box 30943 . Manage your account online at Diacovercard com Salt Lake City, UT 84130 . Customer Servkas: 1-800-DISCOVER (1-800-347-2683) TDD For lsee reverse tside. for dss Deaf): Igff Finance Charge Summary Average Daily D Daily Periodic Nominal ANNUAL ANNUAL PERCENTAGE PERCENTAGE Transaction Periodic Fee ' Balances Rates current billing period: 31 days RATES RATES I CHARGES ll CNA GES Purchases $0 0.06847% 24.99% F 24.99% Cash Advances $0 0.06847% 24.99% F 24.99% previous billing period: 22 days Purchases $0 0.06847% 24.99% F 24.99% The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above $0 none $0 $0 $0 none 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 Robert Adkins Accounts Manager of DFS Services LLC (Name) plaintiff herein, that (Title) (Company) he/she 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 # 6307780 ROBERT CAMPBELL 6011002410727879 C7) , : . o W 00 A? ' u SHERIFF'S RETURN - REGULAR CASE NO: 2007-07461 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS CAMPBELL ROBERT STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CAMPBELL ROBERT the DEFENDANT , at 1410:00 HOURS, on the 2nd day of January , 2008 at 4201 GETTYSBURG RD LOT 9 CAMP HILL, PA 17011 by handing to ROBERT THOMAS CAMPBELL SR, FATHER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 13.44 Affidavit .00 Surcharge 10.00 I?D9?op .00 41.44 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 01/03/2008 WELTMAN WEINBERG REIS By. beputy Sheriff A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ROBERT CAMPBELL Defendant No. 07-7461 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#06307780 Judgment Amount $ 2659.61 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-7461 CIVIL TERM ROBERT CAMPBELL Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, ROBERT CAMPBELL above named, in the default of an Answer, in the amount of $2659.61 computed as follows: Amount claimed in Complaint $2359.61 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $300.00 TOTAL $2659.61 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. Mj0LCZAN, 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#06307780 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7t" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 4201 GETTYSBURG RD LOT 9 CAMP HILL,PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case # 0-11 ?j 1vll-?eIaM ROBERT CAMPBELL Defendant(s) IMPORTANT NOTICE TO: ROBERT CAMPBELL 4201 GETTYSBURG RD LOT 9 CAMP HILL,PA 17011 Date of Notice: WWR#: 06307780 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 I'D BY: - UGtoy G?9l7Q?wt.c?? PATRICK THOMAS WOODMAN PA I.D. ##34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. ROBERT CAMPBELL Defendant Case no: 07-7461 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. Aff ant 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. Aff ant further states that based upon investigation it is the affiant's belief that the Defendant, ROBERT CAMPBELL is not in the military service. Affant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, ROBERT CAMPBELL is not in the military service. Further Affiant sayeth naught. J h W AFF.IANT SWORN TO AND SUBSCRIBED in my presence this IZ day RY PUB C lif iii J.''r try, °; szl Y Public My Commission t'_xr i c.S r Gov, ,,, ?Q9,9 Member, Pennsylvani, p:;:snci atian ?F v jaar'sw; 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. RTquest for Military Status Department of Defense Manpower Data Center t Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 FEB-12-2008 05:26:20 Last Name First/Middle Begin Date Active Duty Status Service/Agency CAMPBELL 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. 1,4.21 01 44, &?_ 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.htm1 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 2/12/2008 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: QMTZEXKANW https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 2/12/2008 4 „? 7s } CD '"T IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 07-7461 CIVIL TERM ROBERT CAMPBELL 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 $2659.61 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: i4 PROT NOTAR E TY) ROBERT CAMPBELL 4201 GETTYSBURG RD LOT 9 CAMP MLL,PA 17011 Plaintiffs 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 FILED-OF FIC! THE 'I?0THIIn ,?. 7.010 DEC 21 AM 9: 1 14 CUMBERLAND COUNT' PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 07-7461-CIVIL TERM vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) ROBERT CAMPBELL Defendant WACHOVIA BANK, Garnishee, FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Whim i-11y1 C IRP WWR46307780 -) 81 ga .> 14. 06 415?- 4y -T a-b..c 02.50 g a• dra Due Co. a so LL ??? ?l?i -7 -'? 173 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 07-7461-CIVIL TERM ROBERT CAMPBELL Defendant WACHOVIA BANK, Garnishee TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against Robert Campbell, 1367 Roundtop Rd, Middletown, PA 17057, Defendant 3. against Wachovia Bank, 604 E High St, Carlisle, PA 17013, Garnishee 4. Judgment Amount $ 2,659.61 Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 434.57 $ 3,094.18 WELTMAN, G & REIS CO., L.P.A. Matthew D. Ur n, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-7461 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From ROBERT CAMPBELL, 1367 Roundtop Road, Middletown, PA 17057 (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: WACHOVIA BANK, 604 East 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 $2,659.61 L.L. $.50 Interest -- $434.57 Atty's Comm % Atty Paid $ 146.94 Plaintiff Paid Due Prothy $2.00 Other Costs Dates 12/21110 REQUESTING 1?ARTY: Name "1M[ATTHEW D. URBAN, ESQUIRE IDI! David D. Bue , Prot onotary By: Deputy Address: WELTMAN WEINBERG & REIS CO. LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLANTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ROBERT CAMPBELL Defendant WACHOVIA BANK, Garnishee, No. 07-7461-CIVIL TERM AMENDED PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: ? O r? rT, C O C 2'_ Matthew D. Urban, Esquire -+ c' PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 1,5219 (412) 434-7955 WWR#6307780 C3 -n ?r- -vrn ?v °o c5 o -n o ?' w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-7461-CIVIL TERM ROBERT CAMPBELL Defendant WACHOVIA BANK, Garnishee AMENDED 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 Robert Campbell, 4201 Gettysburg Rd, Lot 9, Camp Hill, PA 17011, Defendant 3. against Wachovia Bank, 604 E High St, Carlisle, PA 17013, Garnishee 4. Judgment Amount $ 2,659.61 Interest $ 434.57 Costs $ SUBTOTAL: IS 3,094.18 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. rban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OFI ICE ')F 7:-F 2o It, am 19 Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. Robert Campbell Case Number 2007-7461 SHERIFF'S RETURN OF SERVICE 01/18/2011 01:28 PM - Ryan E. Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 18, 2011 at 1326 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Robert Campbell, in the hands, possession, or control of the within named garnishee, Wachovia Bank, 604 East High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Kris Darhower 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 January 19, 2011 to Robert Campbell at 4201 Gettysburg Road, Lot 9, Camp Hill, PA 17011. SO ANSWERS, January 19, 2011 RON R ANDERSON, SHERIFF Ryan E. Burgett, Deputy ;c GountySuite SFenft. Telec.=.oft. Inc SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee F ILED-OFF'11" ?NE Pf?0TRO?AFC? kn'Y 2011 JAN 31 PM 2: 08 CUMBERLAND COUNTY PENNSYLVANil A DISCOVER BANK : COURT OF COMMON PLEAS VS. COUNTY OF CUMBERLAND ROBERT CAMPBELL : NO. 07-7461 and WACHOVIA BANK, A DIVISION OF WELLS FARGO BANK N.A., GARNISHEE ANSWERS TO INTERROGATORIES IN ATTACHMENT TO: DISCOVER BANK, Plaintiff No. 2. Account titled Robert K. Campbell with a zero balance, and an account titled Robert K. Campbell with a zero balance. These accounts have been restricted pursuant to this writ. 3. - 6. No. 7. (Q) 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? (A) No. 8. (Q) 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? (A) In addition to any amounts disclosed above, if any, as of the date of the execution of the Verification to these Answer an a?ount titled Root K. Campbell contained the sum of $1.00, which is not being held because it is exempt pursuant to Section 8123 of the Judicial Code, 42 Pa.C.S. Section C. Garnishee Dated: East AV alp" CK? wril dri- Sworn dca ls?. wat 0 Lyis4Tj?,}. F4?.s?.•?-- s- ?? 1,,t } ,[1yc - ?". ?` O`t i Aso %- # Z:fi? i F1'+]lf3' Eitl(?°:i 7tGifit - _1; s! `ii?1?y _i ;n:L'??`v s..?.`C4st - A [rL wiAA1R? Ft E C2. G F r 'r lei f s'Eu ,{ice ? _ aC i E] ?y? i.?T T . •-• i ?.AA LtZ?+?iQk ` ? •? v WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 6307780 DISCOVER BANK vs. ROBERT CAMPBELL and WACHOVIA BANK Garnishee(s) Attorney for Plaintiff(s) ? s N -" =o C) Cumberland County c..n Court of Common Pleas NO. 07-7461 CIVIL TERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), WACHOVIA BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Jam Warmbrodt, Esquire Attoe for Plaintiff Sworn to and subscribed Before me the ZQ day of February, 2011 NOTARY PUBLIC CG`h?MC ?VEA! T! OF PENNSYLVANIA har:' sea! 5 ?2iic G. 6e`13r, ii0tary Public I Fcss ",,? ?,, r?sleghem C.o?srty My Co zi7; sior E: pjres Nov. I5, 2014 MciKBEL \fV?fE 4ASSO?1C0N Of [kOT.",`"Ll=S a 's' g'% ?a a 11, &tO 5oaa5f3 go asu4 -7 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFzlt.E . I -E 1111 FF RLED-OFFICE CIF THE PROTHONOTARY 2011 AUG 23 PM 3: 52 CUMBERLAND COUNTY PENNSYLVANIA Discover Bank Case Number vs. Robert Campbell 2007-7461 SHERIFF'S RETURN OF SERVICE 01/18/2011 01:28 PM - Ryan E. Burgett, Deputy Sheriff, who being duly sworn according to law, states that on Januar. 18, 2011 at 1326 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Robert Campbell, in the hands, possession, or control of the within named garnishee, Wachovia Bank, 604 East High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Kris Darhower 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 January 19, 2011 to Robert Campbell at 4201 Gettysburg Road, Lot 9, Camp Hill, PA 17011. 08/22/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.06 SO ANSWERS, August 22, 2011 RON R ANDERSON, SHERIFF ;? .00 f?t ( 0. .670 10, , G 3 7a:;Z (Cl GOU ITYSLAte Sherff. Te ecsoft, Irc ED^EJ 2013 MAR 14 pM 2; 4 S r'"OERLANQ COUNTY P"NSYLV NI'A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 07-7461 CIVIL TERM vs. PRAECIPE FOR WRIT OF EXECUTION ROBERT CAMPBELL 901 Defendant(s) \ y\ MYSCR SUSQUEHANNA VALLEY FCU 3 Vf& 34` a\e FULTON BANK 33yy 7v,ridle QJ 0ftNp ?141�?6(r( WELLS FARGO BANK(WACHOVIA BANK), U Dy r,. JA5h Gamishee(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 n �}�ojc l LID T A Pittsburgh,PA 15219 / r"1/[ CiF (412)434-7955 �-� 01,0 (t f It 4 a WWR No. 6307780 a0(? w(a ct � �l � r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-7461 CIVIL TERM ROBERT CAMPBELL Defendant(s) SUSQUEHANNA VALLEY FCU FULTON BANK WELLS FARGO BANK(WACHOVIA BANK) Garnishee(s) 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 ROBERT CAMPBELL ,Defendant 3. against SUSQUEHANNA VALLEY FCU,FULTON BANK, WELLS FARGO BANK (WACHOVIA BANK),Garnishee 4. Judgment Amount $ $2,659.61 Less Payments/credits received $ $0.00 Interest $ $792.20 Costs $ SUBTOTAL: $ $3,451.81 Costs(to be added by Prothonotary): $ 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 WWR No. 6307780 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-7461 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due DISCOVER BANK Plaintiff(s) From ROBERT CAMPBELL,901 RUPP AVENUE,APT. 1,CAMP HILL,PA 17011 (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: SUSQUEHANNA VALLEY FCU,3850 HARTZDALE DRIVE,CAMP HILL,PA 17011 FULTON BANK,3344 TRINDLE ROAD,CAMP HILL,PA 17011 WELLS FARGO BANK(WACHOVIA BANK),604 E.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$2,659.61 L.L. $ Interest $792.20 Atty's Comm % Due Prothy$2.25 Arty Paid $282.00 Other Costs Plaintiff Paid Date:MARCH 14,2013 avid D.Buell,Prothonotary (Seal) 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 WELTMAN,WEINBERG &REIS CO.,L.P.A. BY: William T Molczan,Esquire Attorney for Plaintiff(s) I.D.No.47437 x 436 Seventh Avenue, Suite 1400 -' Pittsburgh,PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File# 6307780 DISCOVER BANK Cumberland County Court of Common Pleas VS. ROBERT CAMPBELL NO. 07-7461 CIVIL TERM and SUSQUEHANNA VALLEY FCU,FULTON BANK AND WELLS FARGO BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), SUSQUEHANNA VALLEY FCU,FULTON BANK AND WELLS FARGO BANK, only. WELTMAN, WEINBERG&REIS CO., L.P.A. By William T Molcz ,Esquire Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY : - Ronny R Anderson w (- • rr' rn Sheriff M z Ot �;:a€aratrrrt,Trd Jody S Smith .;3 c {�=r= Chief Deputy t-- Richard W Stewart Z© ca , Solicitor `•" clo Discover Bank vs. Case Number Robert Campbell 2007-7461 SHERIFF'S RETURN OF SERVICE 03/25/2013 02:01 PM-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, Wells Fargo Bank, 604 E High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Paul Felton, 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 him. 04/01/2013 01:57 PM -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, , Fulton Bank, 3344 Trindle Road, Camp Hill Borough, Camp Hill, PA 17011, Cumberland County, by handing to Kathleen Yoder, Head 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. 04/01/2013 02:06 PM-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, Susquehanna Valley Federal Credit Union, 3850 Hartzdale Drive, Lower Allen Township, Camp Hill, PA 17011, Cumberland County, by handing to Eric Lundvall, 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 him. The writ of execution and notice to defendant was mailed on April 2, 2013 to Robert Campbell at 901 Rupp Ave,Apt. 1, Camp Hill, PA 17011. SHERIFF COST: $204.25 SO ANSWERS, June 17, 2013 RONNK ANDERSON, SHERIFF ..;fnaR?:pSu e Sh�rf,TE,•oso' i..,,. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson L - k+ Sheriff ��y�x,, cmuta f• x�h �? � � µr t,-r. Jody S Smith Chief Deputy s 2013 NOV -6 NI 1 53 Richard W Stewart ., solicitor '°c CUMBERLAND COUNTY "`" ��" � " �� `� PENNSYLVANIA Discover Bank vs. Case Number Robert Campbell 2007-7461 SHERIFF'S RETURN OF SERVICE 03/25/2013 02:01 PM-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, Wells Fargo Bank, 604 E High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Paul Felton,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 him. 04/01/2013 01:57 PM-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, , Fulton Bank, 3344 Trindle Road, Camp Hill Borough, Camp Hill, PA 17011, Cumberland County, by handing to Kathleen Yoder, Head 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. 04/01/2013 02:06 PM-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, Susquehanna Valley Federal Credit Union, 3850 Hartzdale Drive, Lower Allen Township, Camp Hill, PA 17011, Cumberland County, by handing to Eric Lundvall, 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 him. The writ of execution and notice to defendant was mailed on April 2, 2013 to Robert Campbell at 901 Rupp Ave,Apt. 1, Camp Hill, PA 17011. 11/04/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $208.80 SO ANSWERS, November 04, 2013 RONIV ANDERSON, SHERIFF C 1. . @YAp .GJ Y 1I;0 uFt ' Ci F:O$C 61 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK VS. ROBERT CAMPBELL PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: DISCOVER BANK Please enter my appearance for in the above case. Date: December 18, 2014 NO. 2007-7461 Stephen Selinger Print Name Eltman, Eltman & Cooper, PC Firm 140 Broadway, 26th Fl Address New York, NY 10005