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HomeMy WebLinkAbout08-7249f % IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. ROBIN L BOECKEL Defendant No: 08 -,I& i7 0,wit l?`^ 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 06858518 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No ROBIN L BOECKEL 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: ROBIN L BOECKEL 221 W DAUPHIN ST ENOLA, PA 17025 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX4497 . 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 November 19, 2008 , in the amount of $5329.72 . 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 , ROBIN L BOECKEL INDIVIDUALLY , in the amount of $5329.72 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $500.00 , and costs. James C. r ro t,42524 WELTMAN, E NB ERG & REIS CO., L.P.A. v 436 Sev th enue, Suite 1400 Pittsbu gh, A 15219 (412) 34-7 5 FAX: 4 2-33 -7130 06858 18 A Pit ABR This law firm is a debt collector attempt'n to collect this debt for our client and any information obtained A 1 be used for that purpose. - • e. R'L $6,389.72 CARD 02 SDSN6A01 0001729 ROBIN BOECKEL 221 W DAUPHIN ST ENOLA PA 17025-2210 I "'?umoerenaing in 44Y/ $1,188.00 Enter Amount Enclosed Below Payment Due Date !. C' ' ?` July 1, 2008 ` '' i 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 Discovercard.com/payments today. PO BOX 15251 IIInJ1nrIll n111ll„1,I Address, e-mail or telephone change? Print change in s ace WILMINGTON DE 19886-5251 above, or go to Discovercard.com. Print your e-mail address to (rir(r)r)r)iii r((i(r(rrri Illi Iir? receive important Account information and special offers. 000001986459695545321063897200100000118800 Discover More Card Account Summary Closing Date: Account number ending in 4497 Payment Due Date July 1, 2008 Minimum Payment Due $1,188.00 Credit Limit $6,400.00 Credit Available $0.00 Cash Credit Limit $3,300.00 Cash Credit Available $0,00 June 2, 2008 page 1 of 1 Previous Balance Payments And Credits $6,.72 Purchases 100 100.00 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 New Balance + 000 _ $6,389.72 Cashback Bonus® O pening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback -Bonus® Anniversary - - - - - - - - - $ 0.00 - - - - _ - _ - _ _?0 v lable t8o Red eBalance m Date: August 2 - - - - _ - -- $ - ----0.00- How Can We Help You? 1 • Visit Discover.com to pay your bill for n It's your choice - 3 ways to help o cost, view your ore 2. Call tl 800-DISCOVERt'(347.2683) f f f Please have your Discover Card available. For TDD (assistance for hearing impaired) see re or ast, easy sel service options or to speak with a Customer Service Account Manager 3. Write us at Discover Card PO B d 30 v , erse si ox e 943, Salt Lake City, UT 8,4130 Transactions $0 Fraud Liability Guarantee U Trans. Post se your Discover Card with confidence. Date Date Payments and Credits May 7 May 7 PAYMENT- THANK YOU $ -100.00 ,Finance Charge Summary Average DailY Daily Periodic Nominal ANNUAL PERCENTAGE ANNUAL Periodic Transaction Fee Balances current billing period: 31 days Rate, s__ RATES PERCENTAGE RATES FINANCE CHARGES FINANCE CHARGES Purchases $0 Cash Advances $0 0.07942% 28.99% F 28.9 $0 The rates that apply to your Acc t 0.07942% 28.99% F 28.99% $0 none $0 oun are either fixed (F) or the may vary Y Y N) as noted above. EXHIBIT VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unworn falsifications to authorities, that he/she is Robert Adkins (Name) Accounts Manager of DFS Services LLC , plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signature) WWR # 6858518 ROBIN L BOECKEL 6011003870644497 0?. C? rv 0 0 ? C7 0 C= S2? W O - 04 -_ c 7 n? C7 _U of f L? IF SHERIFF'S RETURN - REGULAR CASE NO: 2008-07249 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BOECKEL ROBIN L SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BOECKEL ROBIN L the DEFENDANT , at 0020:00 HOURS, on the 17th day of December-, 2008 at 221 W DAUPHIN STREET ENOLA, PA 17025 ROBIN BOECKEL by handing to DEFENDANT a true and attested copy of COMPLAINT & NOTICE So Answers: 001 R. Thomas Kline 12/18/2008 WELTMAN WEINBERA RE/0 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge /n? /z/,Zy/o7 `, 18.00 13.50 .00 10.00 .00 41.50 Sworn and Subscibed to before me this day of , By: A. D. .I., • A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ROBIN L BOECKEL Defendant No. 08-7249 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#6858518 Judgment Amount $ 5,829.72 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1 ? r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 08-7249 CIVIL TERM ROBIN L BOECKEL Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, ROBIN L BOECKEL above named, in the default of an Answer, in the amount of $5,829.72 computed as follows: Amount claimed in Complaint $5,329.72 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $500.00 TOTAL $5,829.72 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, Esquire Q PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6858518 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: 221 W DAUPHIN ST, ENOLA,PA 17025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ROBIN L BOECKEL Defendant TO: ROBIN L BOECKEL 221 W DAUPHIN ST ENOLA, PA 17025 Date of Notice: COQ ?j? 0`? Case No. 08-7249 CIVIL TERM IMPORTANT NOTICE 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: c'k.' . woiit W4,-- Patrick Woodman P.A.1.D.# 34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 6858518 A PIT T4S IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Case no: 08-7249 CIVIL TERM Plaintiff vs. ROBIN L BOECKEL 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. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, ROBIN L BOECKEL 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, ROBIN L BOECKEL is not in the military service. Further Affiant sayeth naught. - ?JZ411 _r_.01? AFFIA T SWORN TO AND SUBSCRIBED in my presence this day of Y1 COMMONWEALTH OF PENNSYL~ Noted sea! NO Y P IC dennftr M. eOM", Notary Putfic CRY or Pnteax?n, aµep??r?y county My Cann ninkm eb. 22.2012 Man-,. or Nowft 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 or Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 JAN-27-2009 06:04:55 Last Name First/Middle Begin Date Active Duty Status Service/Agency BOECKEL ROBIN 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 1^ . 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.mil/faq/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: BB VYWIJZKEL https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 1/27/2009 L4* o ?o 10, ll i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-7249 CIVIL TERM ROBIN L BOECKEL 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 $5,829.72 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 HONO R D UTY) ROBIN L BOECKEL 221 W DAUPHIN ST ENOLA,PA 17025 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ROBIN L BOECKEL Defendant(s) SANTANDER BANK, N.A. Garnishee(s) TO THE PROTHONOTARY: Civil Action No. 08-7249 CIVIL TERM-0 PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against ROBIN L BOECKEL , Defendant 3. against SANTANDER BANK, N.A., , Garnishee 4. Judgment Amount L-f u Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): A a 0 $ $ $5,829.72 g 1 $2,700.00 --1Y $1,476.74 $4,606.46 WELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. V ecko, Esquire PA I.D. #79 96 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 ica.,SDLL_ CA-it WI 0 WWR No. 6858518 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ROBIN L BOECKEL Defendant(s) SANTANDER BANK, N.A. Garnishee(s) No. 08 -7249 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434 -7955 WWR No. 6858518 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-7249 Civil COUNTY OF CUMBERLAND) CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From ROBIN L. BOECKEL, 221 WEST DAUPHIN STREET, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: SANTANDER BANK, N.A., 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; (2) 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 $3,129.72 Interest $1,476.74 Attorney's Comm. % Attorney Paid $163.00 Other Costs $ Date: MARCH 10, 2014 (Seal) Plaintiff Paid $ Law Library $.50 Due Prothonotary $2.25 David D. Buell, Prothonotary REQUESTING PARTY: Name : JAMES P. VALECKO, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7TH AVENUE, SUITE 1400 PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 79596 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F—\�� ,. ` A� RO�HO�0��x� �"°^' . \ / ''� ` onn^~ ~'-~°n<�^' _ . � 70\b�NR 17 PM 2: 31 �"` ...' �l� ��� CUMBERLAND �UU.`'/ �n�orn�w��p y[��0�\�\ `�"..._ Discover Bank vs. Robin Boeckel Case Number 2008-7249 SHERIFFS RETURN OF SERVICE 03/14/2014 02:40 PM - 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, Santander Bank,17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Julie Myers, Teller, 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 wri of execution and notice to defendant was mailed on March 17, 2014 n Boeckel at 221 W Dauphin Street, Enola, PA 17025. March 17, 2014 eaunlySuitc- Sheriff, Toicosoft. inc. LIAM CLINE, DEPUTY SO ANSWERS, RONNYR ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION vs. Civil Action No. 08-7249 CIVIL TERM DISCO \TER BANK Plaintiff ROBIN L BOECKEL Defendant(s) SANTANDER BANK, N.A. Garnishee(s) TO: SANTANDER BANK, N.A., 17 W. HIGH ST, CARLISE, PA 17013 : ROBIN L BOECKEL , 221 W DAUPHIN ST, ENOLA, PA 17025 Suggested Reference No.: XXX-XX-9100 xxx-xx- 4rsLceLo IMPORTANT NOTICES TO GARNISHEE! 'sr< 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. W1ATR No. 6858518 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) ?` ._. See attached la. 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. 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. Yes 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. Yes - see.` attached WWR No. 6858518 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. See attached 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. 3/17/2014 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. n/a 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? No 12. If the response to Interrogatory 11 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. By: James P. V cko, Esquire PA I.D. #79 96 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 6858518 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 C.O.P. Lead Specialist (Title) (Name) of Santander Ban1�, N.A. , 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. WWR No. 6858518 Account # ANSWERS TO INTERROGATORIES 0921712634 Balance: $1,399.07 It has been determined that this account is exempt from attachment under Pennsylvania Rule 3111.1 Account Holder: Timothy C Boeckell Robin L Boeckell 221 W Dauphin St Eno la, PA 17025-2210 VERIFICATION I, Camille Neuwinger, C.O.P. Lead Specialist of Santander, 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. Santander By: Camille Neuwinger C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Discover Bank vs. Robin L Boeckell 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: James P. Valecko, Esq Weltman, Weinberg & Reis Co., L.P.A. 436 7th Ave Suite 1400 Pittsburgh, PA 15219 Service by certified mail addressed as follows: Robin L Boeckell 221 W Dauphin St Eno la, PA 17025-2210 01A Camille Neu i ger C.O.P. Lead Specialist Santander MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 March 26, 2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Discover Bank vs. Robin L Boeckell 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: James P. Valecko, Esq Weltman, Weinberg & Reis Co., L.P.A. 436 7th Ave Suite 1400 Pittsburgh, PA 15219 Service by certified mail addressed as follows: Robin L Boeckell 221 W Dauphin St Eno la, PA 17025-2210 Camille Net.? ger C.O.P. Lead Specialist Santander MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 March 26, 2014 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James P Valecko, Esquire Attorney for Plaintiff(s) 1.D. No. 79596 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 6858518 - i. FICL THE PROTHON0TAR ZURAPR-8 8: 24 CUM-BERLAND COUNTY PENNSYLVANIA DISCOVER BANK Cumberland County Court of Common Pleas vs. ROBIN L BOECKEL NO. 08-7249 CIVIL TERM and SANTANDER BANK N.A. Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), SANTANDER BANK N.A., only. WELTMAN, WEINBERG & REIS CO., L.P.A. By James 1 Valecko Esquire Attorney for Plaintiff 0.1)1 atm U st.1 1;(5-in8 �%������0��o�� OFFICE OF CUMBERLAND COUNTY SHERIFF'S ~~ Ronny RAndersono:;1 I citlif;tp OF THE PRO THONCITARY FLEOOFFIr' Sheriff OF HE ro TH�NTMy Jody S Smith Chief Deputy Richard W Stewart Solicitor OPnCE OF THE SHERIFF 2914 OCT — .~",,'�� CUMBERLANDCOUNTY` ������ Discover Bank vn. Robin Boeckel Case Number 2008-7249 SHERIFF'S RETURN OF SERVICE 03/14/2014 02:40 PM - WijIiam CUne, Deputy, who being duy sworn according to Iaw, 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, Santander Bank, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handinto J\ieK8yers.TeUar.pereonaUythnoe copies of interrogatories together with three true and attested copies of the Writ of Executon and made the contents there of known to her. The wrof execution and notice to defendant was mailed on March 17, 2014 to Robin L. Boeckel at 221 W Dauphin Street, Enola, PA 17025. 10/07/2014 Ronny R. Anderson, Shenif, who being duly sworn according to Iaw, states this writofexecution io returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $88.76 SO ANSWERS, October 07, 2014 RONR ANDERSON, SHERIFF (c) CountySuile Sheriff, Teffeosoff, Inc.