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Home My WebLink About08-1359 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. GEORGE LEWIS MASESE Defendant No : d L u't L COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06414708 C A Pit SXA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 4 CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No GEORGE LEWIS MASESE Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 New Albany Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at the address listed below: GEORGE LEWIS MASESE 863 CARLWYNNE MNR APT 10 CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX5653 . 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 February 08, 2008 , in the amount of $3371.52 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $500.00 . 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , GEORGE LEWIS MASESE INDIVIDUALLY , in the amount of $3371.52 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $500.00 , and costs. James WELTM 436 S Pitt (41 FAX 06 14 This law firm is a debt collector att our client and any information obtain armoroar,4ZbZ4 EINBERG & REIS CO., L.P.A. n h Avenue, Suite 1400 PA 15219 -7955 -338-7130 C A Pit SXA ng to collect this debt for 11 be used for that purpose. New Balance Minimum Payment Due DISCOVER $3,371.52 $3,371.52 CARD Payment Due Date December 14, 2007 15 SDSN6A01 0007665 GEORGE MASESE 863 CARLWYNNE MNR APT 108 ??}} CARLISLE PA 17013-153Q V Account Number ending in 5653 Enter Amount Enclosed Below Please make check payable to Discover Card. Minimum payment due includes a past due amount of $891.00. Make payments on your schedule, in advance or on the same day as your due date. Visit DisooveroarcLoomJpeyments to make an online payment today. PO BOX 15251 11111111111111111 1r 1rr 1rr 11 WILMINGTON DE 19886-5251 Address, e-mail or telephone change? Print change in space „111 1 1i11i11111i1111i?11111111i111111i111111i11i111i11i1 above, or go to Discovercard.com. Print your e-mail address to 1 receive important Account information and special offers. 000006011007460275653033715200000000337152 Discover More Card Account Summary Closing Date: November 15, 2007 page 1 of 1 Account number ending in 5653 Previous Balance $3,371.52 Payment Due Date December 14, 2007 Payments And Credits 0.00 Minimum Payment Due $3,371.52 Purchases + 0.00 Credit Limit $2,800.00 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 $3,371.52 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary - - - - - - Available to Redeem.. $ 0.00. - Date: May 15 How Can We Help You? For Account Inquiries, write to us at. Please have your Discover Card avaiabls. Discover More Card, PO Box 30943 Salt Lake City, UT 84130 Manage your account online at Discovercard.com MD (Telecommunications Device for the Deaf): Customer Service: 1-800-DISCOVER (1-800-347-2683) For assistance, see reverse side. Transactions $0 Fraud Liability Guarantee iseyoi;c_lard with confidence. Information For You ¦ While we are permitted under the Cardmember Agreement to increo APRs, n o eveffbecause your payment was late, we have chosen not to do so at this time. WefiCpinated, however, any introductory or promotional rate on purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for details. Finance Charge Summary Average Daily Nominal ANNUAL ANNUAL Periodic Transaction Fee Daily Balance s Periodic Rates PERCENTAGE RATES PERCENTAGE RATES FINANCE FINANCE CHARGES CHARGES current billing period: 31 days Purchases $0 0.07942% 28.99% F 28.99% $0 none r -.k &A-.--. !n n n'7n Ane nn .,..a ? .., . , ... .. 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 (Name) Accounts Manager of DFS Services. LLC , 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 # 6414708 GEORGE LEWIS MASESE 6011007460275653 O w a ? M v( ?a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. GEORGE LEWIS MASESE Defendant No. 08-1359 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WARMBRODT, ESQUIRE PA I.D.#42524 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06414708 Judgment Amount $ 3871.52 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. 08-1359 CIVIL TERM GEORGE LEWIS MASESE Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, GEORGE LEWIS MASESE above named, in the default of an Answer, in the amount of $3871.52 computed as follows: Amount claimed in Complaint $3371.52 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $500.00 TOTAL $3871.52 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 JAMES C A MBRODT, ESQUIRE PA I.D.# 2524 Weltm , Wei berg & Reis Co., L.P.A. 2718 oppers ldg. 436 venth enue Pitt urgh, A 15219 (41 ) 434- 955 14708 Plaintiff's 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: 863 CARLWYNNE MNR APT 10 CARLISLE,PA 17013 i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case # 06 -135a c wig I Rm GEORGE LEWIS MASESE Defendant(s) IMPORTANT NOTICE TO: GEORGE LEWIS MASESE 863 CARLWYNNE MNR APT 10 CARLISLE,PA 17013 t Date of Notice : ()y t to WWR#: 06414708 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 PATRICK THOMAS WOODMAN PA T.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 t IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. GEORGE LEWIS MASESE Defendant Case no: 08-1359 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, GEORGE LEWIS MASESE 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, GEORGE LEWIS MASESE is not in the military service. Further Affiant sayeth naught. AFFIANT SSWORN O AND SUBCRIBJED in my presence this ?3 day COMMONWEALTH OF PENNSYLVANIA L Notarial Seal Jennifer M. Borowski, Notary Public City of Pittsburgh, Allegheny County My Commission Expires Feb. 22, 2012 Member, Pennsylvania Association of Notaries 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. Aquest for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 APR-22-2008 06:54:20 < Last Name First/Middle Begin Date Active Duty Status Service/Agency MASESE 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 Atut 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.htrnl 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 4/22/2008 Tj O TK • O OD ?1 y _,. +• fro LL? -C ltquest 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: DZPHODYPIM https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 4/22/2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-1359 CIVIL TERM GEORGE LEWIS MASESE 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 30 (xx) Assumpsit Judgment in the amount of $3871.52 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: PRO ONOT ( R QIPPUTY) GEORGE LEWIS MASESE 863 CARLWYNNE MNR APT 10 CARLISLE,PA 17013 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 of . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. GEORGE LEWIS MASESE Defendant M&T BANK, Garnishee, No. 08-1359 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6414708 I 's r . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. GEORGE LEWIS MASESE Defendant M&T BANK, Garnishee Civil Action No. 08-1359 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... I . directed to the Sheriff of CUMBERLAND County: 2. against GEORGE LEWIS MASESE, Defendants,aoaq sw4rr Run Rol, 6W.&s4u , PA 17&0 3. against M&T BANK, Garnishees GaI9 SipKpson Ferry eJ, MeA, PA i7ow 4. Judgment Amount $ 3,871.52 Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 244.39 $ 4,115.91 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, EsgWre PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6414708 O HLED--OFFF" OF THE PPO HOWTARY 2009 JUG! -5 PEE 2: 59 PENNSYlUVANA 04.50 Pp ATTY 33.38 C&F T9.60 14-00 p''Y 1-5a .88 - Pb 4 .oo ovo Co • 5o u. ae yp699(os e aa.?.,Naq s. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1359 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From GEORGE LEWIS MASESE, 2059 Swarr Run Rd, Lancaster, PA 17601 (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, 5219 Simpson Ferry Rd, Mechanicsburg, PA 17055 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3,871.52 Interest -- $244.39 Atty's Comm % Atty Paid $152.88 Plaintiff Paid Date: 6105/09 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs 066s R. Lon o By: REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15213 Attorney for: PLAINTIFF Deputy Telephone: 412434-7955 Supreme Court ID No. 47437 Sheriffs Office of Cumberland County R Thomas Kline ?mA%v of Cut"a,.,'fi Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 06/11/2009 11:20 AM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2009 at 1120 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: George Lewis Masese, in the hands, possession, or control of the within named garnishee, M & T Bank, 6560 Carlisle Pike, Ste 500, Mechanicsburg, Cumberland County, Pennsylvania, 17070 by handing to Anita Long, Branch Manager, pe sonally 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 June 12, 2009 to George Lewis Masese, 2059 Swarr Run Road, Lancaster, PA 17601. Disco 2008-1359 So Answ rs .J? Discover Bank vs George Lewis Masese R. T omas Kline, Sheriff By Deputy Sheiff N d aura `r7 '- \ : q } t (S D? 1 ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. GEORGE LEWIS MASESE Defendant and M&T BANK Garnishee No. 08-1359 CIVIL TERM INTERROGATORIES IN ATTACHMENT M&T BANK FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6414708 W IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. GEORGE LEWIS MASESE Defendant and M&T BANK Garnishee Civil Action No.: 08-1359 CIVIL TERM TO: M&T BANK Suggested Reference No.: XXX-XX-2229 5219 Simpson Ferry Road Mechanicsburg, PA 17055 RE: GEORGE LEWIS MASESE 2059 SWARR RUN RD LANCASTER, PA 17601 IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. >? eANDgND?O P ?cFEp EkF Op S N D INTERROGATORIES IN ATTACHMENT MpT144561V7. 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? (-I-e? -? &k-C _ X114,14 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. l l? (? 6 . 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? r-0 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have fonds 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. ?r 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. Az + (""Uu,'", WELTMAN, WEINBERG & REIS CO., L.P.A. By: ?? William T. Molczan, Esyre PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6414708 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 13A. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is of Mj`T BANK garnishee herein, (Title) (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/hA knowlpfte, information and belief. IGNATURE) OF THE PF O T P,"" )TARY 2009 JUN 29 A IU* ! J PENNSYI. /A CIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. GEORGE LEWIS MASESE Defendant M & T BANK Garnishee No. 08-1359 CIVIL "TERM PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE M & T BANK ONLY 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 WWR406414708 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. GEORGE LEWIS MASESE Defendant M&TBANK Garnishee Civil Action No. 08-1359 CIVIL TERM PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE, M & T BANK, ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, M &T BANK, only, upon the records of the Court and mark the cost paid. Sworn to and subscribed Before me the / Day of JULY 1 2009 OT R Y PUBLI ?? " WELTMAN, WEINBERG & REIS CO., L.P.A. By: ?./ WILLIAM T. MOLL AN, 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#06414708 4.. - 4 t '] ALED-, --'FiC;E i OF THE PRO" ONOT,ARY 1009 JUL 20 Pty 2.4 PEN ViJYLvA to $8.oe> pCp Al" T'-4 C&4U-75(p 3 e aasa ao 11 ol" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff V"', "A 7 Jody S Smith Chief Deputy i Edward L Schorpp Solicitor Discover Bank Case Number vs. 2008-1359 George Lewis Masese SHERIFF'S RETURN OF SERVICE 06/11/2009 11:20 AM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2009 at 1120 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: George Lewis Masese, in the hands, possession, or control of the within named garnishee, M & T Bank, 6560 Carlisle Pike, Ste 500, Mechanicsburg, Cumberland County, Pennsylvania, 17070 by handing to Anita Long, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 12, 2009 to George Lewis Masese, 2059 Swarr Run Road, Lancaster, PA 17601. 04/08/2010 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: $80.97 April 08, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF F.3 y haron R. Lanz s - /; CK-? 7 5 ?,?8 ? .? Vo.2 0 f r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1359 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From GEORGE LEWIS MASESE, 2059 Swarr Run Rd, Lancaster, PA 17601 (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, 5219 Simpson Ferry Rd, Mechanicsburg, PA 17055 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3,871.52 Interest -- $244.39 Atty's Comm % Atty Paid $152.88 Plaintiff Paid Date: 6/05/09 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs C is R. Long, Pr o ar By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15213 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437