HomeMy WebLinkAbout08-5353IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff No: 08 _ 5333 0.1yll lers,
vs.
COMPLAINT IN CIVIL ACTION
JOHN A FARROW
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
06788608 C N Pit IAS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), N.
Plaintiff
VS. Civil Action No
JOHN A FARROW
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, CAPITAL ONE BANK (USA), Nq 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:
JOHN A FARROW
140 LANCASTER BLVD
MECHANICSBURG, PA 17055
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXXXXXX7536 .
4. Defendant made use of said credit card and has a current balance
due of $7392.42 , as of July 29, 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
27.6005 per annum on the unpaid balance from July 29, 2008 . A copy of
Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" 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 , JOHN A FARROW , INDIVIDUALLY , in the amount of
$7392.42 with continuing interest thereon at the rate of 27.600W per
annum from July 29, 2008 plus costs.
-"> -
James C. armbrodt,42524
WELTMAN, W INBERG & REIS CO., L.P.A.
436 Sev nt Avenue, suite 1400
Pittsb rgh PA 15219
(412) 34- 955
FAX: 12- 38-7130
0678 608 C N Pit IAS
This law firm is a debt collector attemitig to collect this debt for
our client and any information obtaine w 11 be used for that purpose.
FINANCE
Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date
$5,742 82 - $0 00 + $13911 + $39 00 = $5,920 93 $1,11700 Oct 16, 2007
Aug 22, 2007 - Sep 21, 2007 Page 1 of 1
Visa Platinum Account
4003.4426.3355.7536 (After
Your Account Information REWARDS
TOTAL CREDIT LINE $5,00000
TOTAL AVAILABLE CREDIT $000
CREDIT LINE FOR CASH $2.50000
AVAILABLE CREDIT FOR CASH $000
Flnance Charges (Please see reverse for i pontant information)
Balance rate applied to Parodic APR dint CH RGE
Purchases $5,81856 007712%D 2815% $13911
Cash $0 00 0 07712% D 2815% $000
ANNUAL PERCENTAGE RATE applied this period. 28.1574
Your account is six payments behind If we charge off your accourd due to late payments, we will report the
charged-off status to several national credit bureaus, and the Purchase APR as reflected on this statement will
be applied to all your oulstmdug balances Act now 10 prevent this from happening Please pay the amount due
on your statement or give us a cell at 1800 955, 6800 Well work with you so you can take cmbol of your
account and start rebuilding your credit with Capital One
"Important Notice" Under the terms we previously disclosed to you, your account is now eligible for an increase
in Annual Percentage Rates (APRs) effective immediately However, Capital One has defied not to rage your
APRs at tes lime Please be advised that it you fad to keep your account in good standing, Capital One reserves
the nght to rase your APRs in the future
Rewards Summa
Previous available balance $6576
Earned this period $000
(reflects transactions Posted during the bldg qcb)
Available Balance $6576
ATh At Your Service t-80045&7070 Payments, Credits & Adfustments
To cal CEstxna Relatiois our to report a lost or down card
® Send payments to. Transactions
Capita One Bark P 0 Box 70884 Chado te. NC 28272.0884 1 15 SEP PAST DUE FEE $39 OD
A Send ingnUrros to.
C 1PeU One P 0 BeK 30285 Salt Lake City, UT 84130-0285
Q For more information on your Rewards.
Viiiet. www capitelonecmJcaeheaeNs
Cal 1.800.22i,T001
® Have refer r question to the Billing a charge an your statement?
Please e ref
ng Rights Summary on the bed of
You were assessed a past due fee because your minimum payment was not received by the due date. To avoid
your statement or visit ties fee in the future, we recommend that you allow at least 7 business days for your minimum
payment to reach
Capital One
6056 506 1 07 21 070921 PAGE 1 of 1
O1DM6056
PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ON TO W W W CAPITALLONE COM TO MAKE YOUR PAYMENT ONLINE
• al I what's in your wallet?"
New Balance Minimum Payment Due Date
F$5,92093 $1,11700 Oct 16, oar
4003442633557536 21 5920930293001117006
PLEASE PAY AT LEAST
THIS AMOUNT
Amount Enclosed
Capital One Bank
P.6. Box 70884
Charlotte, NC 28272-0884
Account Number. 4003-4426-3355-7536
Please print address or phone number changes below using blue or black ink
Address
Home Phone Al-.- Phone
E-mail! address Q
#9026563399793486# MAIL ID NUMBER
JOHN A FARROW
470 BROOK CIR
nECHANICSBURG, PA 17050-4622
6788608 Please write your account number on your check or money order made payable to Capital One Bank and mail with this coupon in the enclosed envelope
CAPITAL ONE BANK (USA), N.A.,
Plaintiff,
V.
JOHN A FARROW
Defendant(s).
VERIFICATION
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 an authorized agent of Capital One Services,
Inc., an affiliate of and service provider to CAPITAL ONE BANK (USA), N.A., Plaintiff
herein, and that 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.
Dated: -1- ?- 2-0,0 Q
Anthony ti
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
M.
W
b
C`? rv
c ?m
r'F-
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-05353 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA N A
VS
FARROW JOHN A
NOAH CLINE , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
FARROW JOHN A
was served upon
the
DEFENDANT
, at 1000:00 HOURS, on the 13th day of September, 2008
at 140 LANCASTER BLVD
MECHANICSBURG, PA 17055
LORI PONDER, GIRLFRIEND
by handing to
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 14.00
Affidavit .00
Surcharge 10.00
/o/07/0 F .00
42.00
Sworn and Subscibed to
before me this day
of
So Answers:
R. Thomas Kline
09/15/2008
WELTMAN WEINBERG REIS
By: Deputy Sheriff
A. D.
A
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
JOHN A FARROW
Defendant
No. 08-5353 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#06788608
Judgment Amount $ 8000.14
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. 08-5353 CIVIL TERM
JOHN A FARROW
Defendant
TO THE PROTHONOTARY:
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, JOHN A FARROW above named, in the default of an
Answer, in the amount of $8000.14 computed as follows:
Amount claimed in Complaint
$7392.42
Interest from July 29, 2008 to December 9, 2008
at the legal interest rate of 27.6% per annum $607.72
TOTAL
$8000.14
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: 11-4
WILLIAM T. MOl/CZAN, 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#06788608
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: 140 Lancaster Blvd, Mechanicsburg, PA 17055
l
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
JOHN A FARROW
Defendant(s)
IMPORTANT NOTICE
TO: JOHN A FARROW
140 LANCASTER BLVD
MECHANICSBURG, PA 170055 ?^?
Date of Notice: to G! -V 7
WWR#: 06788608
Case #
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: t _ rw?cti LbVad?v ,- -
PATRI THOMAS WOODMAN
PA T.D. #34507
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 KOPPERS BLDG, 436 7TH AVE.
PITTSBURGH, PA 15219
(412) 434-7955
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
JOHN A FARROW
Defendant
Case no: 08-5353 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, JOHN A
FARROW 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, JOHN A FARROW is not in the military service.
Further Affiant sayeth naught.
AFFIANT
SWORN TO AND SUBSCRIBED in my presence this day
f ec? - "aOp
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
C?6ARY PUB
Held J. Kelly, Notary Public
CKY
My Corms Ntnr 4,2006
- " Membaf. Pannsylvanle Assoclatlon of hlotarlas
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
40 Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Page I of 1
DEC-09-2008 12:47:00
-K Last Name First/Middle Begin Date Active Duty Status Service/Agency
FARROW JOHN 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.
14.
fit
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: hq://www.defenselink.mil/faq/p is/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: BZZCOQQBCLX
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 12/9/2008
04 V
Lo °°
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS. Civil Action No. 08-5353 CIVIL TERM
JOHN A FARROW
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Jud ent was entered against you
on
(xx) Assumpsit Judgment in the amount
of $8000.14 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 ONOT D UTY)
JOHN A FARROW
140 LANCASTER BLVD
MECHANICSBURG, PA 17055
Plaintiff's 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
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-5353 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CAPITAL ONE BANK (USA) NA Plaintiff (s)
From JOHN A. FARROW, 1300 BIGELOW DRIVE, APT. 35, HARRISBURG, PA 17103
(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, 1 WEST HIGH STREET, CARLISLE, PA 17013
PNC BANK, 105 NOBLE BLVD., CARLISLE, PA 17013
SOVEREIGN BANK, 17 WEST HIGH STREET, CARLISLE, PA 17013
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due$8,000.14 L.L. $.50
Interest $1,177.62
Atty's Comm % Due Prothy $2.00
Atty Paid $161.50
Other Costs
Plaintiff Paid
Date: 6/27/11
David D. Buell, Prothonotary
(Seal) gy;
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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS. Civil Action No. 08-5353 CIVIL TERM
JOHN AFARROW --13bb r?:; e14W -IDr ,
t
Defendant(s) p? i
, 0
M & T BANK -1 UJ. [tW? -e. ASk j `] OI 3 M3
rrncu
-
PNC BANK - 1US No We Wd, CQr VS zrn rri
SOVEREIGN BANK jt'?;te, PP 1`701- ?
Garnishee(s) r--x --?
PRAECIPE FOR WRIT OF EXECUTIO N C)
TO THE PROTHONOTARY: C
C)rrl
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against JOHN A FARROW , Defendant
3. against M & T BANK, PNC BANK, SOVEREIGN BANK, Garnishee
4. Judgment Amount $ $8,000.14
Less Payments/credits received $ 0
Interest $ $1,177.62
Costs $
SUBTOTAL: $ $9,177.76
Costs (to be added by Prothonotary): $
Q+(1?t+ ?' • So a
?. ob C6
`1?.SaKtI
114.po??tt
D. sa
WELTMAN, WEINBERG & REIS CO., L.P.A. I I I. - - ' ? ?
y.
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
o.. 5p L, L
Cam- saF&y 9
?? ?io$S
WWR No. 6788608
U) T C5 ? Ex.
zz' "
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
No. 08-5353 CIVIL TERM
vs.
JOHN A FARROW
Defendant(s)
M & T BANK
PNC BANK
SOVEREIGN BANK,
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. 6788608
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson C
Sheriff r{
,
Jody S Smith ?'
Zrn C
tz
Chief Deputy
Richard W Stewart
r--
Solicitor QFFI Z' --r
Q -F3
5, C,
Capital One Bank (U.S.A.) N.A. Case Number
vs.
2008-5353
John A Farrow
SHERIFF'S RETURN OF SERVICE
07/01/2011 02:57 PM - Dennis Fry, 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, Sovereign Bank at 17 W High Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to ALLISA PECK TELLER, 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 July 5, 2011 to John A. Farrow at 1300
Bigelow Drive, Apt. 35, Harrisburg, Pennsylvania, 17013.
07/01/2011 03:51 PM - Dennis Fry, 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, PCN Bank at 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013
Cumberland County, by handing to BETH ANN EPPLEY BRANCH MANAGER, 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 July 5, 2011 to John A. Farrow at 1300
Bigelow Drive, Apt. 35, Harrisburg, Pennsylvania, 17013.
07/01/2011 02:56 PM - Dennis Fry, 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, M&T Bank at 1 W High Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to DONNA EGOLF TELLER, 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 July 5, 2011 to John A. Farrow at 1300
Bigelow Drive, Apt. 35, Harrisburg, Pennsylvania, 17013.
SHERIFF COST: $355.50
July 05, 2011
SO ANSWERS,
( '?Z' Y, - z2/
RbNINW R ANDERSON, SHERIFF
Den s Fry, u y Sheriff
!C; C0L0TyS1Aito Snenff. Te eoso?l. Inc.
` IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs. Civil Action No. 08-5353 CIVIL TERM ca , c-:?
,
y
JOHN A FARROW
?
MMIX C- =-n
Defendant(s) ;r M
;:v
r-
i==
? --
M & T BANK ?
-
PNC BANK
SOVEREIGN BANK = F3
Garnishee(s)
r? 4a dzr) `5
TO: M & T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013
PNC BANK, 105 NOBLE BLVD, CARLISLE, PA 17013
SOVEREIGN BANK 17 W HIGH STCARLISLE, PA 17013
RE: JOHN A FARROW, 1300 BIGELOW DR APT 35, HARRISBURG, PA 17103
Suggested Reference No.: XXX-XX-3049
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. 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.
WWR No. 6788608
j / 50t /'3 `L0
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)?
i a. If the answer to Interrogatory I 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.
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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?
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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?
V-1 13
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?
PU
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.
00
WWR No. 6788608
8. lf'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.
--,1-?;1\\
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 finds were fi-ozen, 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 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?
12. If the response to Interrogatory I 1 is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
WELTMAN, WEINBERG & REIS CO., L.P.A.
Matthew D. Urban, Esquire
PA I.D. 490963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 6788608
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 C-
me)
of va:?N •s-`T- , '?Qr)-C'? , 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.
(SIGURE)
4 Zo»
WWR No. 6788608
WELTMA"4, WEINBERG & REIS CO., L.P.A.
BY: Jame,: C Warmbrodt, Esquire
I.D. No.42524
436 Seventh Avenue, Suite 1400
''ittsburgh, PA .5219
Phone: 412.,434."955
Fax: 412.434.7959
File # 6788608
CAPITAL ONE BANK (USA),NA
vs.
JOHN A FARROW
and
PNC BANK, SOVEREIGN BANK, M & T BANK
Ga. nisfi--:,(s)
Attorney for Plaintiff(s)
Cumberland County
Court of Common Pleas
NO. 08-5353 CIVIL TERM
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
. O THE PK•D'I'HJNOTARY:
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Kindly r.:ark,.,d the above matter discontinued and ended as to Garnishee(s), PNC BANK,
SOVEREIGN BANK, M & T BANK, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Sworn to aiid subscribed
Before me the . day of August, 2011
i
NOTARY PUBLIC
Jam AC Warmbrodt, Esquire
Attn ev for Plaintiff
COMM- M (1t I° wiYANIA
Notarial Sol
Shelia G. Bevan, Notary Public
Ross Tvrp., Allegheny County
My Commir n m Nov. 15, 2014
MEMBER PENNSYLVANIA ASSOCIATION OF NOTARIES
*$,Co Pb AYE
&-J&3185
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
y R Anderson
'riff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
20112 MAR 22 Ali 10: 4
CUMBERLAND COUNTY'
PENNSYLVANIA
Capital One Bank (U.S.A.) N.A.
vs.
John A Farrow
Case Number
2008-5353
SHERIFF'S RETURN OF SERVICE
07/01/2011 02:57 PM - Dennis Fry, 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, Sovereign Bank at 17 W High Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to ALLISA PECK TELLER, 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 July 5, 2011 to John A. Farrow at 1300
Bigelow Drive, Apt. 35, Harrisburg, Pennsylvania, 17013.
07/01/2011 03:51 PM - Dennis Fry, 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, PCN Bank at 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013
Cumberland County, by handing to BETH ANN EPPLEY BRANCH MANAGER, 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 July 5, 2011 to John A. Farrow at 1300
Bigelow Drive, Apt. 35, Harrisburg, Pennsylvania, 17013.
07/01/2011 02:56 PM - Dennis Fry, 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, M&T Bank at 1 W High Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to DONNA EGOLF TELLER, 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 July 5, 2011 to John A. Farrow at 1300
Bigelow Drive, Apt. 35, Harrisburg, Pennsylvania, 17013.
03/21/2012 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: $199.87
March 21, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
!c1 Coiin,ySuite Sheriff. Teleasoft Inc,