HomeMy WebLinkAbout08-2370OP
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs
JASON M SHOREY
Defendant
No : 08 - a370 0,64 l Tiro,
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
06466910 C N Pit TSW
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
JASON M SHOREY
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
At.
COMPLAINT
1. Plaintiff, CAPITAL ONE BANK (USA),NA is a corporation with offices
at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238
2. Defendant is adult individual(s) residing at the address listed
below:
JASON M SHOREY
20 JOHNS DR
ENOLA, PA 17025
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXXXXXX9442
4. Defendant made use of said credit card and has a current balance
due of $1628.30 , as of March 11, 2008 .
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
28.100% per annum on the unpaid balance from March 11, 2008 . A copy
of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 11111 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 , JASON M SHOREY , INDIVIDUALLY , in the amount of
$1628.30 with continuing interest thereon at the rate of 28.100% per
annum from March 11, 2008 plus costs.
James C. VJkmbro
WELTMAN, E NBERG & REIS CO., L.P.A.
436 Seve th,Avenue, Suite 1400
Pittsbu gh,/PA 15219
(412) 34-77955
FAX: 1238-7130
0646 910/ C N Pit TSW
This law firm is a debt collector atteip?Zng to collect this debt for
our client and any information obtaine(b,"wi.ll be used for that purpose.
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VERIFICATION
CAPITAL ONE BANK (USA), N.A., successor-in-interest to Capital One Bank
vs
SHOREY, JASON M
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities, that he/she is, TRACY TAYLOR, Authorized Agent, of CAPITAL ONE BANK (USA),
N.A., successor-in-interest to Capital One Bank, Plaintiff Herein, that he/she is duly authorized to make this
Declaration, 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.
TRACY TA. R
Noi?,ary Public, Dekklb County, Georgia
My Commission Expires January 19, 2009
5291072231129442
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
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CASE NO: 2008-02370 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA NA
VS
SHOREY JASON M
DAVID MCKINNEY , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SHOREY JASON M the
DEFENDANT
, at 2015:00 HOURS, on the 15th day of April , 2008
at 20 JOHNS DRIVE
ENOLA, PA 17025 by handing to
NICOLE MONAHAN, GIRLFRIEND, ADULT IN CHARGE
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 15.00
Affidavit .00
Surcharge 10.00
00
wIl"1?bP 43.00
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
04/16/2008
WELTMAN WEINBERG REIS
By:
D uty/Sheri f
A.D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
VS.
JASON M SHOREY
Defendant
No. 08-2370-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#06466910
Judgment Amount $ 1724.41
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 (USA), NA
Plaintiff
VS. Civil Action No. 08-2370-CIVIL TERM
Kindly enter Judgment against the Defendant, JASON M SHOREY above named, in the default of an
Answer, in the amount of $1724.41 computed as follows:
Amount claimed in Complaint
Interest from 03/11/08 to 06/30/08
at the legal interest rate of 28.100% per annum $96.11
JASON M SHOREY
Defendant
TO THE PROTHONOTARY:
PRAECIPE FOR DEFAULT JUDGMENT
$1,628.30
TOTAL
$1724.41
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.. 141!?
WILLIAM T. MOLCZAN, E UIRE
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06466910
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 20 JOHNS DR
ENOLA,PA 17025
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
VS. Civil Action No. 08-2370-CIVIL TERM
JASON M SHOREY
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
n
(xx) Assumpsit Judgment in the amount
of $1724.41 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
Bv:
PROTHONOTARY (@*
JASON M SHOREY
20 JOHNS DR
ENOLA,PA 17025
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
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
VS.
JASON M SHOREY
Case no: 08-2370-CIVIL TERM
NON-MILITARY AFFIDAVIT
Defendant
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, JASON M
SHOREY 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, JASON M SHOREY is not in the military service.
Further Affiant sayeth naught.
AFFIANT
SWQ?ZN TO AND SUBSCRIBED in my presence this day
of ?•
COMMONWEALTH OF PENNSYLVANIA
N ' ARY PU IC Notarial Seal
Wayne A. Jones, Notary Public
Q y Of Piftburgh, Allegheny County
My Commission Expires June 29, 2010
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.
IN THE COURT OF COM14ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
Case # M r 3L
JASON M SHOREY
Defendant(s)
IMPORTANT NOTICE
TO; JASON M SHOREY
20 JOHNS DR
ENOLA,PA 17025
Date of Notice:
WWR#: 06466910
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: rtU-VIV?{M^? ?dO
PATRICK THOMAS WOODMAN
PA I.D. #34507
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 KOPPERS BLDG, 436 7TH AVE.
PITTSBURGH, PA 15219
. Request for Military Status
Department of Def ense Manpower Data Center
Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Page 1 of 2
JUN-30-2008 07:25:09
-K Last Name First/Middle Begin Date Active Duty Status Service/Agency
SHOREY JASON M 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 befense 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
44'A?W_
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. §5 501 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.
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/30/2008
Request for Military Status
Page 2 of 2
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://wwwdefenselink.mil/faq/ps/PC095LDR.html
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:VRWCEROM56
https://www.dmdc.osd.mil/scra/owo/scra.prc_Select 6/30/2008
70
? w
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-2370 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CAPITAL ONE BANK Plaintiff (s)
From JASON M. SHOREY, 20 JOHNS DRIVE, 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:
MEMBERS 1s' FCU, 1711 SPRING ROAD, 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 $1,724.41 L.L. $.50
Interest $309.55
Atty's Comm % Due Prothy $2.00
Atty Paid $162.50 Other Costs:
Plaintiff Paid
Date: 7/26/11
;r
Da d IIAuell, Prot notary
(Seal) By:
Deputy
REQUESTING PARTY:
Name MATTHEW D. URBAN, 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. 90963
IN THE COUNT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL nIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
JASON M SHOREY
01o Jpe1? A% n-,c,>r. z lruok? Cam } IZo as
MEMBERS 1 ST FCU
Garnishee(s)
CA4k?LePW11a i3
TO THE PROYHO-` OTARY:
?r
Civil Action No. 08-2370-CIVIL TERNO:r_
C-) =9
7°
PRAECIPE FOR WRIT OF EXECUTION
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. a,gair,st J,',.SON M SHOREY , Defendant
3. against MEMBERS 1 ST FCU,, , Garnishee
4. Judgment Amount $ 1724.41
Less Payments/credits received $ 0.00
Inten,st $ 309.55
Costs $
SUBTOTAL: $ 2033.96
Coss (to'. ; added by Prothonotary):
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Car '.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
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
so GL
C?? l avi ?`?3S
WWR No. 6466910
'W?? o f 4?r - S ?4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK ('JSA),NA
Plaintiff - No. 08-2370-CIVIL TERM
vs.
JASON M SHOREN'
Defendant(s)
MEMBERS 1 ST FCU
Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
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
WWR No. 6466910
HE >ReTHONOifs; r RECEIVED
r01 ! AU - I Am 10: U , JUL 2 8 20IN
CUMBERLAND COUN ,!
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK USA),NA
Plaintiff
VS.
JASON M SHOREY
Defendant(s 1
MEMBERS 1 ST FCU
Garnishee(s)
Civil Action No. 08-2370-CIVIL TERM
AnougAg 40
INTERROGATORIES IN ATTACHMENT
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
WWR No. 6466910
IN THis \`.,OURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
JASON M SHOREY
Defendant(s)
MEMBERS 1 ST FCU
Garnishee(s)
Civil Action No. 08-2370-CIVIL TERM
TO: MEMBERS I ST FCU, 1711 SPRING RD, CARLISLE, PA 17013
RE: JASON M sHOREY, 20 JOHNS DR, ENOLA, PA 17025
Suggested Reference No.: XXX-XX-4951
XXX-XX-
IMPORTANT NOTICES TO GARNISHEE!
A. You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failurc to do so may result in Judgment against you.
B. Here:n,''ie 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 ±hen 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.
WWR No. 6466910
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 (including funds on deposit for checking or savings accounts and certificates of
deposit)?
Ia. 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 presf:?t location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe oi owed to him; and the nature and amount of each of such liabilities.
v1 ?
2. At tl;e tine you were served or at any subsequent time was there in your possession, custody or
control of yourself and c•ne or more other persons any property of any nature owned solely or in part by the
defendant.
3. At th; 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?
IVA 6
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?
r0
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?
?) U
6. At any tine 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?
100
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 amount of funds in each account, and the entity
electronically depositing those funds on a recurring basis.
r0
WWR No. 6466910
8. If y(,:i are a bank or other financial institution, at the time you were served or at any subsequent
time did the defenda»t h ve funds on deposit in an account in which the funds on deposit, not including any
otherwise exempt finds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each account.
9. If the. answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
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.
11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account
which are not depos'ted electronically on a recurring basis and which are identified as being funds that upon deposit
are exempt from ex ?.cution, levy or attachment under Pennsylvania or federal law?
r?
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on
deposit in the account. r, V
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
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
WWR No. 6466910
A
I (I@
MEMBERS 1St
FEDERAL CREDIT UNION
July 29, 2011
Jason Shorey
409 Mountain Street
Enola, PA 17075
Review Dates (60 Days): May 31, 2011-July 29, 2011
Total Writ of Execution: $2,198.96
Cumberland County Docket Number: 08-2370 Civil
File #WWR 6466910
Account Number: XXX995
Name on Account:
Savings - 0000:
Checking - 0011:
Jason Shorey
$ 0.00
-5.00 (Membership Fee)
$ 0.00
$ 1337.44
- 50.00 (Processing Fee)
$ 1287.44
Payroll: Drayer Physical/Patriot News
$300.00 Statutory Exemption was not taken out.
Kelly LMall
Deposit Operations Analyst
Rev: 06/11
5000 Louise Drive - P.O. Box 40 - Mechanicsburg, Pennsylvania 17055 - (800) 283-2328 - www.memberslst.org
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
Kelly L Hall
(Name)
Deposit Operations Analyst of Members 1st Federal Credit Union
(Title)
(Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
(SIG ATU )
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
,Uttta?
y?tr 0 C
Jody S Smith
Chief Deputy ' i L F is I
Richard W Stewart
Solicitor - 1P : - '2011 AUG -2 AM 8: b
0UMBERLAND COUN
PENNSYLVAIIIA
Capital One Bank
vs. Case Number
.
Jason M Shorey 2008-2370
SHERIFF'S RETURN OF SERVICE
07/29/2011 10:10 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 nadned garnishee, Members 1st FCU at 1711 Spring Road, North Middleton Township,
Carlisle, PA 17613, Cumberland County, by handing to KRISTAL LUCKEY, CSR, personally three true and
attested copies Hof the Writ of Execution and made the contents there of known to her.
The writ of execution and notice to defendant was mailed on August 1, 2011 to Jason M. Shorey at 20
Johns Drive, Erlola, PA 17025.
SO ANSWERS,
July 29, 2011 RON A DERSON, SHERIFF
i iam Cline, Deputy
Ir1 Cow-,IYS;1 to She, *f T e e.^, post. Ir.,
(N THE ('_OUK OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BAi?K ;USA) NA
Plaintiff
vs.
JASON M S1-;ORE1'
Def-,idant
ML,M;? ERS 1 ST FC'-)
Garnishee
No. 08-2370-CIVIL TERM
PRAECIPE FOR JUDGMENT AGAINST c c -n
GARNISHEE -pa
w
ern ?•
-
z? c? rim
D M oT
?a
C 25
FILED ON BEHALF OF -t
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I. D.#90963)
Weltman, Weinberg & Reis Co., I.,.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W W R#6466910
*.14.00 ph AV?
e#a?3ss?
IN THE CGjRT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK ('-SSA) NA
Plaintiff
vs. Civil Action No. 08-2370-CIVIL TERM
JASON r, SHOREY
Defendant
MEMBERS I ST FC('
Garnishee
PRAECIPE FOR JUDGMENT AGAINST GARNISHEE
TO 'rHI. PROTHONO ; ARY:
Kindly ente., Judgment against the Garnishee, MEMBERS 1 ST FCU , in the amount of $987.44, which less
than the aniowit Dei'.nda!,t owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in
answers to IncerrogWr ,-i. _..
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
Matthew D. Urban, Esquire
PA I.D.#90963
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6466910
I hereby certify that the ad.-iress of the Plaintiff is:
c/o Weltman, 'JVein ?c` Reis Co., L.P.A., 1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219
Y-. nd that the last known ,?ldress of the Garnishee is: 5000 Louise Drive, P.U. Box 40, Mechanicsburg, PA 17055
' 1L??0RECEIVED
? .
``'? THE f P'0 T HOPI TAcs k, t ,
JUL 2 0 201
?Ot AUG - t AMlO: Cu
CU LPENNSYCOUNT Y
y ANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK 'USA),NA
Plaintiff
vs.
Civil Action No. 08-2370-CIVIL TERM
JASON M SHOREY
Defendant(s)
MEMBERS I ST FCU
Garnishee(s)
INTERROGATORIES IN ATTACHMENT
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
WWR No. 6466910
lk
IN TH ` COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
Civil Action No. 08-2370-CIVIL TERM
JASON M SHOREY
Defendant(s)
MEMBERS I ST 1`0_1
Garnishee(s)
TO: MEMBERS 1 ST l--CU, 1711 SPRING RD, CARLISLE, PA 17013
RE: JASON M SHOREY, 20 JOHNS DR, ENOLA, PA 17025
Suggested Reference; No.: XXX-XX-4951
XXX-XX-
IMPORTANT NOTICES TO GARNISHEE!
A. You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failurc w do so may result in Judgment against you.
B. Herein, 1',ie 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.
WWR No. 6466910
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 (including funds on deposit for checking or savings accounts and certificates of
deposit)?
N)b
I 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 presF:it location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe of owed to him; and the nature and amount of each of such liabilities.
fi?
2. At tl;e time you were served or at any subsequent time was there in your possession, custody or
control of yourself and c rie or more other persons any property of any nature owned solely or in part by the
defendant. "0
3. At th 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?
Vic
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?
"Q
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 puce pursuant to your directions or consent and if so what was the consideration thereof?
YJ ?
6. At any t1ine after you were served did you pay, transfer, or deliver any money or property to the
defendant or to any p erscn 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 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 amount of funds in each account, and the entity
electronically depositing those funds on a recurring basis. N d
W WR No. 6466910
8. If yv:i 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.
M
9. If the. answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
10. If the answer to Interrogatory I 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. 0
IL If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account
which are not depos;,ed electronically on a recurring basis and which are identified as being funds that upon deposit
are exempt from ex-?cution, 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 accou;it. n IA
L?QL? WELTMAN, WEINBERG & REIS CO., L.P.A.
S? C
By:
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
WWR No. 6466910
St
MEMBERS 1St
FEDERAL CREDIT UNION
July 29, 2011
Jason Shorey
409 Mountain Street
Enola, PA 17075
Review Dates (60 Days): May 31, 2011-July 29, 2011
Total Writ of Execution: $2,198.96
Cumberland County Docket Number: 08-2370 Civil
File #WWR 6466910
Account Number: XXX995
Name on Account:
Savings - 0000:
Checking=0011:
Jason Shorey
$ 0.00
-5.00 (Membership Fee)
$ 0.00
$ 1337.44
- 50.00 (Processing Fee)
$ 1287.44
Payroll: Drayer Physical/Patriot News
$300.00 Statutory Exemption was not taken out.
Kelly L. Hall
Deposit Operations Analyst
Rev: 06/11
5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org
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 Kelly L Hall
(Name)
Deposit Operations Analyst of Members 1st Federal Credit Union
(Title)
(Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
IN THE ?'OIJRT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (i iSA) NA
Plaintiff
vs. Civil Action No. 08-2370-CIVIL TERM
JASON M SHOREY
Defendant
MEMBERS 1ST F("J
Garnishee
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
( ) Defendant
(xx) Garnishee
You are hereby notified that the
following Order or Judgment was
entered against you on F-- -1 l6 -- //
(xx) Assumpsit Judgment in the amount
of $987.44 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration will be
suspended by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
( ) Default
( ) Verdict
( ) Arbitration
Award
Prothonot
By:
DEPUTY)
MEMBERS 1 ST FC' 1
5000 LOUISE DRIVIL
P.O. BOX 40
MECHANICSBUR6, PA. 17055
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
,ay R Anderson
,ieriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
F '-ERtFF
t F THELP OTHUNC%A )"
2012 FEB 17 PM 2: 23
CUMBERLAND CCUNTy
PENNSYLVANIA
Capital One Bank
vs.
Jason M Shorey
Case Number
2008-2370
SHERIFF'S RETURN OF SERVICE
07/29/2011 10:10 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, Members 1 st FCU at 1711 Spring Road, North Middleton
Township, Carlisle, PA 17013, Cumberland County, by, handing to KRISTAL LUCKEY, CSR, personally
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 August 1, 2011 to Jason M. Shorey at 20
Johns Drive, Enola, PA 17025.
02/16/2012 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: $88.13 SO ANSWERS,
February 16, 2012 R-ONINW R ANDERSON, SHERIFF
,ssV LL
Cou i ' S-tF "t. ( leoso°t_ ?nc_