HomeMy WebLinkAbout08-5359f %
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No: - 5'S.Sq C?vi ( T?rrti
VS.
COMPLAINT IN CIVIL ACTION
CHRISTINE T FEESE
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
06920156 C A Pit ABR
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
CHRISTINE T FEESE
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:
CHRISTINE T FEESE
4805 DELBROOK RD
MECHANICSBURG, PA 17050
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number XXXXXXXXXXXX1067 . 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 August 27, 2008 , in the amount of
$4298.52 .
5. Defendant is in default by failing to make payments when due.
6. Plaintiff avers that the Agreement between the parties provides
that Defendant will pay Plaintiff's attorneys' fees.
7. Plaintiff avers that such attorneys' fees will amount to $500.00 .
8. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and/or refused to pay the balance due to Plaintiff.
Wherefore, the Plaintiff prays for Judgment in its favor and
against Defendant , CHRISTINE T FEESE INDIVIDUALLY , in the amount of
$4298.52 with interest at the legal rate of 6.0001 per annum from date
of judgment plus attorneys' fees of $500.00 , and costs.
James C_ armbro?lt,42524
WELTMAN, INBERG & REIS CO., L.P.A.
436 Sev nt Avenue, Suite 1400
Pittsb rg , PA 15219
(412) 434 7955
FAX: 12 38-7130
0692 15 C A Pit ABR
This law firm is a debt collector attemAt/ng to collect this debt for
our client and any information obtained ill be used for that purpose.
I 4L"7, V tK
C:. RD
$4,298.52 , $4,298.52 yr V V Enter Amount Enclosed Below vV,
Payment Due Date $ (p 3 1) N-3
July 21, 2008 Please make check payable to Discover Card.
Minimum yment due includes a past due
amount of $888.00.
22 SDSN6A01 0003335
CHRISTINE FEESE
4805 DELBROOK RD
MECHANICSBURG PA
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.
Will your payment get to us on time? Pay
your bill online and your payment can be
made to your account on the same day. Visit
17050-3009 Discovercard.com/payments today.
PO BOX 15251 111rrr11rr1111r1sJr1r11rr1
WILMINGTON DE 19886-5251
(nr???n?n(n?n)u(n((ur)n(nn)n?r(r(un??n?n?uu?(?n(n?
000001986618027720395042985200000000429852
Discover More Card Account Summary
Closing Dade: June 22, 2008 page 1 of 1
Account number ending in 1067 Previous Balance $4,298.52
Payment Due Date July 21, 2008 Payments And Credits 0.00
Minimum Payment Due $4,298.52 Purchases + 0.00
Credit Limit $3,500.00 Cash Advances + 0.00
Credit Available $0.00 Balance Transfers + 0.00
Cash Credit Limit $0.00 Finance Charges + 0.00
Cash Credit Available 50.00 New Balance = $4,298.52
Cashback Bonus® Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus Earned + 0.00
Cashbock Bonus Balance $ 0.00
Cashback BonusS Anniversary Avafkible-to Redeem - - S- -0.00-
Date: June 22
How Can We Help YOU?
P 1. Visit Discover.com to pay your bN for no cost, view our
latest Account information, earn and redeem rewards and more
stns your choice - 3 ways to help
Will I 2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service
T
Please have your Discover Card available.
E options or to speak with a Customer Service Account Manager
3. Write us at Discover Card
PO Box 30943
For TDD (assistance for hearing impaired) see reverse side ,
,
Salt Lake City, UT 84130
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, any introductory or promotional rate on
purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of
purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the
minimum payment due by the payment due date. Soo the Default Rate Plan section of the Cardmember Agreement for
details.
Finance Charge Summary
Nominal Transaction
Average Daily ANNUAL ANNUAL Periodic Fee
Daily Periodic PERCENTAGE PERCENTAGE FNANa FINANCE
Balances Rates RATES RATES CHARGES CHARGES
current billing period: 22 days
Purchases $0 0.07942% 28.99% F 28.99% $0 none
Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0
previous billing period: 11 days
Purchases $0 0.07942% 28.99% F 28.99% $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
unsworn falsifications to authorities, that he is Robert Adkins
(Name)
Accounts Manager of DFS Services LLC , plaintiff herein, that
(Title) (Company)
he 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 knowledge, information and belief.
ig?nature)4?
WWR # 6920156
CHRISTINE T FEESE
6011298687691067
w?
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-05359 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
FEESE CHRISTINE T
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
FEESE CHRISTINE T the
DEFENDANT , at 1054:00 HOURS, on the 12th day of September, 2008
at 4805 DELBROOK ROAD
MECHANICSBURG, PA 17050 by handing to
EDWARD FEESE
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 18.00
Service 13.00
Affidavit .00
Surcharge 10.00
/0 G7 6? • 00
? 41.0 0
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
09/15/2008
WELTMAN WEINBERG REIS By: , G / x7
riff
A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
r DISCOVER BANK
i'
Plaintiff No. 08-5359-CIVIL TERM
? tvs. PRAECIPE FOR DEFAULT JUDGMENT
CHRISTINE T FEESE
Defendant
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#6920156
Judgment Amount $ 4,798.52
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
Ila'.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 08-5359-CIVIL TERM
CHRISTINE T FEESE
Defendant
TO THE PROTHONOTARY:
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, CHRISTINE T FEESE above named, in the default of an
Answer, in the amount of $4,798.52 computed as follows:
Amount claimed in Complaint $4,298.52
Interest from date of judgment
at the legal interest rate of 6.00% per annum
Attorney's fees $500.00
TOTAL $4,798.52
I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA
R.C.P. 237.1 on the dates indicated on the Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: ka
William T. Molczan, Esq],!'Ire
PA I.D.#47437 J'
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6920156
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 4805 DELBROOK RD, MECHANICSBURG,PA 17050
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
CHRISTINE T FEESE
De f endant (s)
IMPORTANT NOTICE
TO: CHRISTINE T FEESE
4805 DELBROOK RD
MECHANICSBURG,PA 17050
Date of Notice: 10 az?o$
WWR#: 06920156 -?
Case # (0-!2?0 CI V IL'INM
YOU ARE IN DEFAULT BECAUSEiYOU 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 a`bGxA..ovuwa ?0nl:?n,w
PATRICK THOMAS WOODMAN
PA I.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
DISCOVER BANK
Plaintiff
vs.
CHRISTINE T FEESE
Defendant
Case no: 08-5359-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, CHRISTINE T
FEESE 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, CHRISTINE T FEESE is not in the military service.
Further Affiant sayeth naught.
AFFIANT -'}"''
SWORN TO AND SUBSCRIBED in my presence this { day
of 0
NOON
cO[7Wn4bW of YLVA A
MW, ?Y Pubk
NO Y C au p?„y ,
Feb.22.2012
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.
, . I, , iv?. "Ir -V-? ?? ,
Request ,or Military Status
.. M
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Page 1 of 1
NOV-12-2008 10:05:44
Last Name First/Middle Begin Date Active Duty Status Service/Agency
FEESE CHRISTINE Based on the information you have furnished, the DMDC does not possess any
information indicating that the individual is currently on active duty.
I,
Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the
l', information that you provided, the above is the current status of the individual as to all branches of the Military.
AMY, fol
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
e Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the
3bifense and Eligibility Reporting System (DEERS) database which is the official source of data on
;legibility for military medical care and other eligibility systems.
he Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS
ppx. §§ 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 viii 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.
141, J 'See: http://www.defenselink.mil/faq/pis/PC09SLDR.htrn
1e
ING: This certificate was provided based on a name and Social Security number (SSN) provided by the
r,6?,quester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
1
1
?eport ID: FOULLRFDRB
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select
11/12/2008
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 08-5359-CIVIL TERM
CHRISTINE T FEESE
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 /11,40 Igs
(xx) Assumpsit Judgment in the amount
of $4,798.52 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration
will be suspended by the Department of Transportation, Bureau
of Traffic Safety, Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
By:
PRO HONOT PUTY)
CHRISTINE T FEESE
4805 DELBROOK RD
MECHANICSBURG, PA 17050
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7d' Avenue, Pittsburgh, PA 15219
1-888-434-0085
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N008-5359 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From CHRISTINE T. FEESE AT 4805 DELBROOK RD., MECHANICSBURG, PA 17050
(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 SOVEREIGN BANK AT 401 ENOLA ROAD, ENOLA, PA 17025
GARNISHEE(S) as follows:
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 $3,098.52
Interest $550.86
Atty's Comm %
Atty Paid $1V.50
Plaintiff Paid
Date: 2/18/11
L.L.$.50
Due Prothy $2.00
Other Costs
David D Buell, Prot t
(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
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2t611 FED 18
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r' -i#NSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
CHRISTINE T FEESE
Defendant
SOVEREIGN BANK,
Garnishee,
'ally t, Y'b4
ell "116
11
??l?G, .?o Per ???
x#5`5377
No. 08-5359 CIVIL TERM
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#6920156
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
C?j /.ASS pna"s.
vs. Civil Action No. 08-5359
CHRISTINE T FEESE
Defendant
SOVEREIGN BANK,
Garnishee
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against CHRISTINE T FEESE, Defendant
3. against SOVEREIGN BANK, Garnishee
4. Judgment Amount $ 4798.52
Less payments of $ 1700.00
Interest $ 550.86
Costs $
SUBTOTAL: $ 3649.38
Costs (to be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
00"O? 'I
_`.
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
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith t x
Chief Deputy
Richard W Stewart ( NAR -I P11
Solicitor`
s W !,1 ? • s, t,, .
Discover Bank
Case Number
vs.
Christine T Feese 2008-5359
SHERIFF'S RETURN OF SERVICE
02/25/2011 03:10 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on February
25, 2011 at 1510 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Christine T. Feese, in the hands, possession, or control of the
within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania
17013, by handing to Denise Beecher, Customer Service Representative, personally three copies of
interrogatories together with three true and attested copies of the writ of execution and made the contents
there of known to her.
The writ of execution and notice to defendant was mailed on February 28, 2011 to Christine T. Feese at
4805 Delbrook Road, Mechanicsburg, PA 17050.
SO ANSWERS,
February 28, 2011 RON R ANDERSON, SHERIFF
Va a ie Weary, puty
(cj Goun':,ySuft? Sheriff. Tzloosott. Inc.
V_4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
CHRISTINE T FEESE
Defendant
and
SOVEREIGN BANK
Garnishee
No. 08-5359 CIVIL TERM
INTERR G TORIES IN ATTACHMENT
SOVEREIGN BANK
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
W W R#6920156
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
CHRISTINE T FEESE
Defendant
and
SOVEREIGN BANK
Garnishee
Civil Action No.: 08-5359 CIVIL TERM
TO: SOVEREIGN BANK Suggested Reference No.: XXX-XX-9544
401 Enola Road
Enola, PA 17025
RE: CHRISTINE T FEESE
4805 DELBROOK RD
MECHANICSBURG, PA 17050
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 (including funds on deposit for checking or savings accounts and certificates of
deposit)?
YES
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.
SEE ATTACHED
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.
SEE ATTACHED
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?
NO
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?
NO
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?
NO
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?
NO
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.
NO
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 fimds 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.
YES - SEE ATTACHED
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
February 25, 2011
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. February 25, 2011
H. If the response to Interrogatory 7 is in the affirmative, are other fiends 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?
N/A
12. If the response to Interrogatory I 1 is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
N/A
WELTMAN, WEINBERG & REIS CO., L.P.A.
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
W W R#6920156
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 Camille Neuwinger
(Name)
C.O.P. Lead Specialist of
(Title)
Sovereign Bank
garnishee herein,
(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.
ANSWERS TO INTERROGATORIES
Account# 351181288
Balance: $2,656.94
After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this
account is $2,356.94
Account Holder: Edward David Feese
Christine Feese
4800 Delbrook Rd
Mechanicsburg, PA 17050-3009
Account# 421089513
Account Holder: Christine Feese
Attn: Rehab Dept
770 Poplar Church Rd
Camp Hill, PA 17011-2302
VERIFICATION
Balance: $14.00
I, Camille Neuwinger, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the
information contained in the foregoing Answers to Interrogatories in Attachment are true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094,
relating to unsworn falsification to authorities.
Sovereign Bank
By:
Camille Neuwinger \
C.O.P. Lead Specialist
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE:
DISCOVER BANK
VS.
CHRISTINE T FEESE
CERTIFICATE OF SERVICE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner
indicated below:
Service by first class mail addressed as follows:
Matthew D. Urban, Esquire
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Building 436 Seventh Avenue
Pittsburgh, PA 15219
Service by certified mail addressed as follows:
Christine T Feese
4805 Delbrook Rd
Mechanicsburg, PA 17050-3009
C.O.P. Lead Specialist
Sovereign Bank
MA1 M63-02-10
2 Morrisey Boulevard
Boston, MA 02125
March 4, 2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE:
DISCOVER BANK
VS.
CHRISTINE T FEESE
CERTIFICATE OF SERVICE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner
indicated below:
Service by first class mail addressed as follows:
Matthew D. Urban, Esquire
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Building 436 Seventh Avenue
Pittsburgh, PA 15219
Service by certified mail addressed as follows:
Christine T Feese
4805 Delbrook Rd
Mechanicsburg, PA 17050-3009
C.O.P. Lead Specialist
Sovereign Bank
MA1 M133-02-10
2 Morrisey Boulevard
Boston, MA 02125
March 4, 2011
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 # 6920156
DISCOVER BANK
vs.
CHRISTINE T FEESE
and
SOVEREIGN BANK
Garnishee(s)
Attorney for Plaintiff(s)
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CUMBERLAND County r
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Court of Common Pleas 'm
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NO. 08-5359 CIVIL TERM
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly marked the above matter discontinued and ended as to Garnishee(s), SOVEREIGN
BANK, only.
WELTMAN,
By
Sworn to and subscribed
Before me the C70 day of MARCH, 2011
NOTAR PUBL C
1°?v Seat public
Hlandy Gau14g ?oenN County
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Matthew D. Urban, Esquire
Attorney for Plaintiff
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s)
I.D. No.86469
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 6920156
DISCOVER BANK
Plaintiff
CUMBERLAND County
Court of Common Pleas
vs.
CHRISTINE T FEESE
Defendant(s)
NO. 08-5359 CIVIL TERM
PRAECIPE FOR SATISFACTION OF JUDGMENT
TO THE PROTHONOTARY:
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PENNSYLVANIA
Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the
Court and mark the cost paid.
WELTMAN, WEINBER REIS
By I
Sarah E. Ehasz, Esquire /
Attorney for Plaintiff
., L.P.A.
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