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Home My WebLink About08-17816 - .-1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: -Fcn, vs. COMPLAINT IN CIVIL ACTION KIMBERLY L WOLF 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06497908 C A Pit SXA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No KIMBERLY L WOLF 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: KIMBERLY L WOLF 110 LOCUST WAY CARLISLE, PA 17015 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX2980 . 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 29, 2008 , in the amount of $6998.07 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $1000.00 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 , KIMBERLY L WOLF INDIVIDUALLY in the amount of $6998.07 with interest at the legal rate of 6.000W per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. James C Narmbrodt,42524 WELT INBERG & REIS CO., L.P.A. 436 S?Ventjh Avenue, Suite 1400 Pitt urg , PA 15219 (41 434 7955 FAX 412 338-7130 06 97 90 C A Pit SXA This law firm is a debt collector attnp?Ang to collect this debt for our client and any information obtain d will be used for that purpose. 'V tK $6,998.07 I $6,998.07 CARD ?-- - Payment Due Date January 21, 2008 22 SDSN8A01 0004843 ?.. KIMBERLY WOLF 110 LOCUST WAY CARLISLE PA 17015-8808 Address, e-mail or telephone change$ Print change in space above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. Enter Amount Enclosed Below L- Please make check payable to Discover Card. Minimum yment due includes a past due amount of $1,294.00. Make payments on your schedule, in advanoe or on the same day as your due date. Vlsh Dlsooveroard.oom/payments to make an online payment today. PO BOX 15251 1111111111111111111 11111111 WILMINGTON DE 19886-5251 000006011002560772980069980700000000699807 Discover More Card Account Summary Closing Date: December 22, 2007 page 1 of 1 Account number ending in 2980 Previous Balance $6,998.07 Payment Due Date January 21, 2008 Payments And Credits 0,00 Minimum Payment Due $6,998.07 Purchases + 0.00 Credit Limit $5,000.00 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 $6,998.07 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonu3OAnniversary ..Available to Redeem. $ ..0.00_ Date: August 22 How Can We Help You? For Account Inquiries, write to pis at: Please have your Discover Card available. Discover More Card, PO Box 30943 Salt Lake City, UT 84130 Manage your account online at Discovercard.com TDD [Telecommunications Device for the Deafl: Customer Service: 1-800-DISCOVER (1-800.347.2683) For assistance, see reverse side. ;Finance Charge Summary Average Daily Nominal ANNUAL ANNUAL Periodic Transaction Fee Daily Balance s Periodic Rates PERCENTAGE RATES PERCENTAGE RATES FMS FMS current billing period: 22 days Purchases $0 0.06847% 24.99% F 24.99% $0 none Cash Advances $0 0.06847% 24.99% F 24.99% $0 $0 previous billing period: 6 days Purchases $0 0.06847% 24.99% F 24.99% $0 none The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unworn 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 # 6497908 KIMBERLY L WOLF 6011002560772980 W ? D ? t ~ CIO OV. SHERIFF'S RETURN - REGULAR CASE NO: 2008-01781 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS WOLF KIMBERLY L NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WOLF KIMBERLY L the DEFENDANT , at 2105:00 HOURS, on the 20th day of March 2008 at 110 LOCUST WAY CARLISLE, PA 17015 KIMBERLY L WOLF by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 4.80 _`°?' ws Postage ,58 Surcharge 10.00 R. Thomas Kline .00 33.38 `03/26/2008 WELTMAN WEINBERG REIS 31281-08 ?:Zrrt Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KIMBERLY L WOLF Defendant No. 08-1781-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. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6497908 Judgment Amount $ 7,998.07 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. 08-1781-CIVIL TERM KIMBERLY L WOLF Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, KIMBERLY L WOLF above named, in the default of an Answer, in the amount of $7,998.07 computed as follows: Amount claimed in Complaint $6,998.07 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $1,000.00 TOTAL $7,998.07 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. MolczW, Esgwre PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6497908 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7d' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 110 LOCUST WAY, CARLISLE,PA 17015 r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case # OV- IN 1 CIVIL ! eX I'VL,- KIMBERLY L WOLF Defendant(s) IMPORTANT NOTICE TO: KIMBERLY L WOLF 110 LOCUST WAY CARLISLE,PA 17015 Date of Notice: ( j WWR#: 06497908 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: PA RICK 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. KIMBERLY L WOLF Defendant Case no: 08-1781-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, KIMBERLY L WOLF 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, KIMBERLY L WOLF is not in the military service. Further Affiant sayeth naught. AFFIANT ?Ji4, SWORN TO AND SUBSCRIBED in my presence this 1 day of a U T J TH &ZV?Mft NO P JNNr M. NM6dc?F?,Kp,, AIW" 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 1 AUG-13-2008 08:55:06 -< Last Name First/Middle Begin Date Active Duty Status Service/Agency WOLF KIMBERLY 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. )6t lot. 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: htt.p://www.defenselink.mil/faq-/pis/PC09SLDR.httnl WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:PXHBUELHWH https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 8/13/2008 r--31 ?11 A' V !l ; -dC IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 08-1781-CIVIL TERM KIMBERLY L WOLF 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 $7,998.07 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( } Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary Bya-5PR NOTARY (OR DEPUT ) Otd KIMBERLY L WOLF 110 LOCUST WAY CARLISLE,PA 17015 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 76' Avenue, Pittsburgh, PA 15219 1-888-434-0085 SHERIFF'S RETURN - REGULAR CASE NO: 2008-01781 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS WOLF KIMBERLY L NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WOLF KIMBERLY L the DEFENDANT , at 2105:00 HOURS, on the 20th day of March 2008 at 110 LOCUST WAY CARLISLE, PA 17015 KIMBERLY L WOLF by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Postage .58 Surcharge 10.00 .00 ?Uaro¢?''" 33.38 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 03/26/2008 WELTMAN WEINBERG REIS By. Deputy Sheriff A. D. i- ,,` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KIMBERLY L WOLF Defendant FULTON BANK, Garnishee, No. 08-1781-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#6497908 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-1781-CIVIL TERM KIMBERLY L WOLF, 1515 Oe2S a P-tMEPZ ,-APrl- e.LvL 1, PA 1'7 0 6LG Defendant FULTON BANK, 3100 Curnbs-rland Pkw4 . " PA 1-1055 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 KIMBERLY L WOLF, Defendant 3. against FULTON BANK, Garnishee 4. Judgment Amount $ 7,998.07 Interest $ 188.02 Costs $ SUBTOTAL: $ 8,186.09 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: C 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#6497908 5i JW- era 88OLsa R ?? 08 b_' f Ul D ?' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1781 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From KIMBERLY L. WOLF, 1515 Orrs Bridge Rd., Apt 1, Enola, PA 17025 (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: FULTON BANK, 360 Cumberland Pkwy, 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 $7,998.07 L.L. $.50 Interest -- $188.02 Atty's Comm % Due Prothy $2.00 Atty Paid $152.88 Other Costs Plaintiff Paid Date: 2/03/09 Ag4 ? is R. Long, o onotary (Seal) By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 SHERIFF'S RETURN - GARNISHEE CASE NO: 2008-01781 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS WOLF KIMBERLY L And now KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:59 Hours, on the 9th day of February-, 2009, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , WOLF KIMBERLY L in the hands, possession, or control of the within named Garnishee FULTON BANK 1423 S MARKET ST MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to ADRIENNE BLACK (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 . true and made Sheriff's Costs: So answers: Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County U NJ 02/09/2 Sworn and Subscribed to before me this day of By , A.D c?v EL ? ] **?-r R?M « w4t CL j' .a1 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KIMBERLY L WOLF Defendant and FULTON BANK Garnishee No. 08-1781-CIVIL TERM AA-Wlw362.r `7O INTERROGATORIES IN ATTACHMENT FULTON 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#6497908 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KIMBERLY L WOLF Defendant and FULTON BANK Garnishee Civil Action No.: 08-1781-CIVIL TERM TO: FULTON BANK Suggested Reference No.: XXX-XX-6537 360 Cumberland Pky Mechanicsburg, PA 17055 RE: KIMBERLY L WOLF 1515 ORRS BRIDGE RD APT I ENOLA, PA 17025 IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? 46 1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? W 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 thereor n/6 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? / l/" 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including 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. C}? A-lb WELTMAN, WEINBERG & REIS CO., L.P.A. ?- By: any 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#6497908 A . VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/ he i (? is (Name) of ka=?k' , garnishee herein, (Title) (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. -2j"- (SIGNATURE) C "s c? -TI 7" Fri IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KIMBERLY L WOLF Defendant FULTON BANK Garnishee No. 08-1781-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE FULTON BANK ONLY 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6497908 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-1781-CIVIL TERM KIMBERLY L WOLF Defendant FULTON BANK Garnishee PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE, FULTON BANK, ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, FULTON BANK, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Esqu' PA I.D #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#6497908 Sworn to and subscribed Before me the 2 ? Day_DkFEBRUARY, 2009 RY Notarial Seal Jennifer M. Borowski, Notary Public City of Pittsburgh, A%gheny County ComrMlldit Expires Feb. 2Z 2012 00 y? 4 8 -? m Discover Bank VS Kimberly Wolf Writ of Execution Docket No. 2008-1781 Civil Term OF THE i A&K NOTAW 2004 OCT -2 AM 8: 39 CUMRI . SL-, Z iJOUNTY PENNSYLVANIA R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. No action has been taken in the last six months. Sheriff s Costs: Docketing $18.00 Surcharge 30.00 Garnishee 9.00 Levy 20.00 Mileage 12.00 Prothonotary 2.00 Law Library .50 Poundage 1.83 $93.33 So Answers: R. Thomas Kline, Sheriff BY Zf) 0 Sergeant ? ro/s/a Q 4'-- Co- 21 t ?' ?? ,j 3135S? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1781 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From KIMBERLY L. WOLF, 1515 Orrs Bridge Rd., Apt 1, Enola, PA 17025 (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: FULTON BANK, 360 Cumberland Pkwy, 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 $7,998.07 Interest -- $188.02 Atty's Comm % Atty Paid $152.88 Plaintiff Paid Date: 2/03/09 L.L. $.50 Due Prothy $2.00 Other Costs Cu is R. Lon onota (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 By: Deputy Supreme Court ID No. 47437