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Home My WebLink About08-2797IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KRISTINA MARIE MOORE Defendant NO: CE - r.201?7 &VJ 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 06632855 C A Pit SXA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No KRISTINA MARIE MOORE 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: KRISTINA MARIE MOORE 600 MOUNT ROCK RD CARLISLE, PA 17015 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX2228 . 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 April 14, 2008 , in the amount of $2947.57 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 , KRISTINA MARIE MOORE INDIVIDUALLY , in the amount of $2947.57 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $500.00 , and costs. Jarmbrodt,42524 WEINBERG & REIS CO., L.P.A. 4en h Avenue, Suite 1400 Prg PA 15219 (/4) 3 -7955 F -338-7130 0 5 C A Pit SXA This law firm is a debt collector at our client and any information obtai ting to collect this debt for will be used for that purpose. NIJ?r?-v?'M GR ?L,r'?i.ai ? JL,Y4LaI CARD Payment Due Date DUE IMMEDIATELY )I- 08 SDSN6A01 0005062 KRISTINA MOORE 600 MOUNT ROCK RD CARLISLE PA 17015-7427 Address, e-mail or telephone changer' Print change in space above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. tnter Amount Enclosed Below l? CT-.. ?...,.. 3 /Z/." G t..J Will your payment get to us on time8 Pay your bill online and your payment can be made to your account on the same day. Visit Discovercard.com/payments today. PO BOX 15251 1111111111111 WILMINGTON DE 19886-5251 1tn111t1u1u111Ill 11ui11111 Ill 1JJIll 111111ill 1111Ill I 000006011002895002228029475700000000294757 Discover More Card Account Summary Closing Date: February 8, 2008 page 1 of 1 Account number ending in 'Pa ment Due D t 2228 M h Previous Balance $2,947.57 y a e arc 7, 2008 Payments And Credits 000 Minimum Payment Due $2,947.57 Purchases Credit limit $2,000.00 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 + 000 m $2,947.57 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: October 8 How Can We Help You? For Account Inquiries, write to us 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 Deaq: Customer Service: 1-800-DISCOVER (1-800-347-2683 For assistance, see reverse side. Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Information For You While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment was late, we have chosen not to do so at this time. We have terminated, however or promotional rate on purchases and any special balance transfer rate, and applied the standard APR our outstanding balance of :purchases and balance transfers. However, we reserve the right to increase the APRs your ccount if you fail to pay the minimum payment due by the payment due date. See the Default Rate flan section a Cardmember Agrsement for details. Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE CHARGES FINANCE Rates RATES RATES current billing period: 8 days Balances CHARGES Purchases Past Purchases $0 $0 0.07942% 0 07942% 28.99% F 28.99% $0 none Cash Advances $0 . 0.07942% 28.99% F 28.99% F 28.99% 28.99% $0 none $0 $0 .previous billing period: 5 days Purchases $0 0.07942% 28.99% F 28.99% $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. 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 (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. Z"?? (Signature) WWR # 6632855 KRISTINA MARIE MOORE 6011002895002228 -64, CD Y-• i' i cip SHERIFF'S RETURN - REGULAR CASE NO: 2008-02797 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS MOORE KRISTINA MARIE STEVE BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE MOORE KRISTINA MARIE was served upon the DEFENDANT at 0016:30 HOURS, on the 7th day of May 2008 at 600 MOUNT ROCK RD CARLISLE, PA 17015 by handing to ERIC MOORE HUSBAND OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Postage 18.00 5.00 .00 10.00 .41 33.41 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 05/07/2008 WELTMAN WEINBERG & REIS By: Deputy Sheriff of , A. D. D • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK. Plaintiff vs. KRISTINA MARIE MOORE Defendant No. 08-2797 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#6632855 Judgment Amount $ 3,447.57 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. 08-2797 CIVIL TERM KRISTINA MARIE MOORE Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, KRISTINA MARIE MOORE above named, in the default of an Answer, in the amount of $3,447.57 computed as follows: Amount claimed in Complaint $2,947.57 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $500.00 TOTAL $3,447.57 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. Molczan, Esqu' PA I.D.947437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6632855 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7ch Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 600 MOUNT ROCK RD, CARLISLE,PA 17015 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-2797 CIVIL TERM KRISTINA MARIE MOORE 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 /0 b7 op (xx) Assumpsit Judgment in the amount of $3,447.57 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: PR HONOT DEPU Y) KRISTINA MARIE M. OORE 600 MOUNT ROCK RD CARLISLE,PA 17015 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 1-888-434-0085 t IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff KRISTINA MARIE MOORE Defendant(s) IMPORTANT NOTICE TO: KRISTINA MARIE MOORE 600 MOUNT ROCK RD CARLISLE,PA 17015 Date of Notice: OR 1 1 S (d b WWR#: 06632655 Case # OVIL TERM 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 : ,IR (nG? c Bpd U) 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 Case no: 08-2797 CIVIL TERM Plaintiff vs. KRISTINA MARIE MOORE Defendant 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. Affant further states that based upon investigation it is the affiant's belief that the Defendant, KRISTINA MARIE MOORE is not in the military service. Affant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DM. DC), which states that the Defendant, KRISTINA MARIE MOORE is not in the military service. Further Affiant sayeth naught. / W ' AFFIANT SWORN TO AND SUBSCRIBED in my presence this -?-o day of Se o3 e hp % 9m?L- wow_-, d og? ARY PUB V. e A jr leR r' f 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 SEP-29-2008 10:46:43 ' Last Name First/Middle Begin Date Active Duty Status Service/Agency MOORE KRISTINA 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. Aby 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.m_il/fact/pis/PC09SLDR.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: THAL UBEPZD https://www.dmdc.osd.mil/scra/owa/scra.prc Select 9/29/2008 O e": rQ y t. J s 1P? V.s ? J r i FILED-C)I rrICE i Ak1 g:}8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEP X*AtVV [ CIVIL DIVISION ' `" ?` DISCOVER BANK Plaintiff No. 08-2797 CIVIL TERM VS. PRAECIPE FOR WRIT OF EXECUTION AND ENTER IT IN THE JUDGMENT INDEX (BANK ATTACHMENT ONLY) KRISTINA MARIE MOORE Defendant PATRIOT FEDERAL CREDIT UNION and SOVEREIGN BANK, Garnishee, 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#0632855 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-2797 CIVIL TERM KRISTINA MARIE MOORE i,oo Fount Rock Rd Defendant CAxilaue PA 1.7015 PATRIOT FEDERAL CREDIT UNION and 800 U--x%4 le Ave, ChO?mhP.r'a?bur?, W? 17ao1 SOVEREIGN BANK,- 15 3. Mato St ,L'ha*bera6urS. PA 11aw/ Garnishee PRAECIPE TO INDEX WRIT OF EXECUTION AND ENTER IT IN THE JUDGMENT INDEX TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... I . directed to the Sheriff of FRANKLIN County: 2. against KRISTINA MARIE MOORE, Defendant 3. against PATRIOT FEDERAL CREDIT UNION and SOVEREIGN BANK, Garnishee 4. and enter this writ in the judgment index (a) against KRISTINA MARIE MOORE, defendant, and (b) against PATRIOT FEDERAL CREDIT UNION and SOVEREIGN BANK, as garnishee, as a lis pendens against real property of the defendant in the name of garnishee as follows: Any and/or all personal property belonging to the defendant(s) in possession of the garnishee(s). 5. Judgment Amount $ 3,447.57 Interest $ 393.30 Costs $ SUBTOTAL: $ 3,840.87 Costs (to be added by Prothonotary): $ S O A-" 014.50 P WELTMN, EINBERG&REIS CO., L.P.A. C 33-41 O ? By: 1 .00 .. WILLIAM T. MOLCZ , Esquire a.gp 4 PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 15a.q/ - P4 ATN 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 4.2-00 Nwe. • 5o 1.(, 04 4%063qo WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-2797 Civil CIVIL ACTION - LAW TO THE SHERIFF OF FRANKLIN COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From KRISTINA MARIE MOORE, 600 Mount Rock Rd, Carlisle, PA 17015 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PATRIOT FEDERAL CREDIT UNION, 800 Wayne Ave, Chambersburg, PA 17201 SOVEREIGN BANK, 15 S. Main Street, Chambersburg, PA 17201 Any and/or all personal property belonging to the defendant in possession of the Garnishee. 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 $3,447.57 L.L. $.50 Interest -- $393.30 Atty's Comm % Due Prothy $2.00 Atty Paid $152.91 Other Costs Plaintiff Paid Date: 9/14/10 , S, David D. uell, Protho of (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 ~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KRISTINA MARIE MOORS Defendant and PATRIOT FEDERAL CREDIT UNION and SOVEREIGN BANK Garnishee No. 08-2797 CIVIL TERM Atisw~ `Ia INTERROGATORIES IN ATTACHMENT PATRIOT FEDERAL CREDIT UNION and SOVEREIGN 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#0632855 C"7 {~ f V !~ ~ ~~ ~~ ~ Q ~ ~ ~ ~ z' r- r-~ --~ ~ r -v i.,i ~ cn ...,~ D ~- u'+ o ~ ~ r- ~ <~ -o ""~ o ~ ' ~' f'1 .3C ' Z , ~ '~ -G ~ ~ D ~ ~ 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)? ~P S 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. shctrc Sa.t1~n~~'s Q C'~occn ~ `~ J``~ ~pO / ~'{~ CS'1, arc Cl ~c ~~~s A' c~vu k~ '~ ~(o, / 2 '- ~t/e~q r ~b'~ l.~+R ~4 n Gam' 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. „ f~ 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solel~ypor part by the defendant or in which defendant held or claimed any interest? /v ~ 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? ~d 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 pursuantt too your directions or consent and if so what was the consideration thereof? l~ ~ 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 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. ~1/'d 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. ~ /'~ 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. oc,~o6« I ~, zo r'~ 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. Q~ ~p~~r, 1 ~/~ 20 ~~ 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not deposited electronically on a recurring basis and which are identil•ied as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? a / d 12. If the response to Interrogatory 11 is in the affirmative, state the amount ofnon-exempt funds on deposit in the account. N~ WELTMAN, WEINBERG & REIS CO., L.P.A. By: "~ v ~l WII,LYAM 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#0632855 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 CG 6'G ~T~L (Name) t n L . ~ctp~po,~-f` Rya (ys J ~ of Patr-`o~ ~~~/'~~ ~Pdr~ ~n~er~, 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. ~~l~ /!~ (SIGNATURE) WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Matthew D. Urban, Esquire I.D. No.90963 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 06632855 DISCOVER BANK vs. KRISTINA MAIRE MOORE and Attorney for Plaintiff(s) CUMBERLAND County Court of Common Pleas NO. 08-2797 CIVIL TERM SOVEREIGN BANK and ;'~ PATRIOT FEDERAL CREDIT UNION -~,~:` r"ri C°;3 Garnishee(s) r=' -~, =~> PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION ~~=_._ -'=' c-.a ~~ ~, ~ TO THE PROTHONOTARY: Kindly marked the above matter settled, discontinued, and ended as to Garnishee(s), SOVEREIGN BANK and PATRIOT FEDERAL CREDIT UNION, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By ~ c~ --~ ~- --a -~, s- :v ~,'~ w r;~ ~ --~ ~~ o ~ a m n rn ~ _.~ Matthew D. Urban, Esquire Attorney for Plaintiff Sworn to and subscribed Before me tlae ~ Day of OCTOBER, 2010 ~. TARY PUBLIC COMMONWF-A~TN 0~ NSYI~ Noka~ai Saai Public Sheila G. gavan, NotR~ aunty Ross~G•, Auegheny My Commission Expires N~• 15, 2010 Member. Penns+lvanla pssriciation of Notaries $$. Oo P ~ AT7~( Ct~'{~83°5a53 ~~a~51a