HomeMy WebLinkAbout09-2443
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No 600) Ctv?l ?e r.,
vs.
COMPLAINT IN CIVIL ACTION
KRISTINA DIANE CHESNE
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
07305989 C A Pit ABR
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
KRISTINA DIANE CHESNE
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 DIANE CHESNE
808 COOLIDGE ST
NEW CUMBERLND, PA 1.7070
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number XXXXXXXXXXXX9662 . 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 March 18, 2009 , in the amount of
$5882.63 .
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 $1000.00
8. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and/or refused to pay the balance due to Plaintiff.
P
Wherefore, the Plaintiff prays for Judgment in its favor and
against Defendant , KRISTINA DIANE CHESNE INDIVIDUALLY , in the
amount of $5882.63 with interest at the legal rate of 6.000% per annum
from date of judgment plus attorneys' fees of $1000.00 , and costs.
James Warmbrodt,42524
WEL WEINBERG & REIS CO., L.P.A.
436 S v nth Avenue, Suite 1400
Pitt u gh, PA 15219
(41 4-7955
FAX 2-338-7130
07 0 889
C A Pit ABR
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.
$5,882.63
CARD
15 SDSNEP01 0004719
KRISTINA CHESNE
908 COOLIDGE ST
YEW CJ14BERLND PA 17070-1427
$5,882.63 j Enter Amount Enclosed Below
Payment Due Date'-1 $
February 14, 2009 Please make check payable to Discover Card.
Minimum payment due includes a past due
amount of 833.00.
Add-ess, e-mail or telephone change? Print change in space
ubove•, or go to Discover.eom. Print your e-mail address to
i ecerve imporont 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
Discover.com/payments today.
PO BOX 6103 111n1 11 11111
CAROL STREAM IL 60197-6103
dIIoil1111111II1
[)0000:1986458404982676058826300000000588263
Discover More Card Account Summary
Closing Date: January 15, 2009 page 1 of 1
A,ccoint numbar ending in 9662 Previous Balance $5,882.63
Payment Due Date February 14, 2009 Payments And Credits 0.00
Minimum Payment Due $5,882.63 Purchases + 0.00
Credit Limit $7,200.00 Cash Advances + 0.00
Credit Avoilable $0.00 Balance Transfers + 0.00
Cash Credit Limit $0.00 Finance Charges + 0.00
Cash Credit Available $0.00 New Balance = $5,882.63
; Cashback Bonuse Opening Cashback Bonus Balance $ 00:00
New Cashback Bonus Earned
:'Cashback Bonus Artniversa - - - - - - _. - . - - - - Cashback Bonus Balance $ 0100
-Available to .Redeem------------ _ - - - - .. .. _ ... _ Q.OS) _ .. _
Date: April 15
Help You?
How Can We He 1. Visit Discovencom to pay your 6911 for no cost, view our
latest Account information, earn and redeem rewards and more
Wes your choice - 3 ways to help
Please have your Discover Card available.
For TDD (assistance for hearing impaired) see reverse side 2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service
options or to speak with a Customer Service Account Manager
3. Write us at Discover Card, PO Box 30943,
Salt Lake City, UT 8,4130
Finance Charge Summary
Nominal Transaction
Average Daily ANNUAL ANNUAL Periodic Fee
Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE
Balance Rates RATES RATES CHARGES CHARGES
current billing period: 15 days
Purchases $0
Cash Advances $0
previous billing period: 13 days
Purchases $0
0.063671/a 23.24% V 23.24% $0
0.06367% 23.24% V 23.24% $0
0.00271% 0.99% F 0.99% $0
none
$0
none
EXHIBIT
- - A
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above.
lmport id Information. If there is more than one page to this billing statement see the back of each page for additional important information.
See year Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account co
Lost or stolen cards. Report immediatetyl Call 1400-947-2003. °Z'
di
111400 In Case of Errors or Questions About Your Bill If you think your bill is wrong, or it you need more information about a o
transaction on your bill write us an a separate sheet of paper at Discover Moresm; PO Box 30421, Salt Lalte City,11T 84130-0421, as soon as possible.
We must hear Trom you no later than BO days after we sent you the first bill on which the error or problem appeared. You can telephone us, but $
doing name not preserve your rights. In your letter, give us the following information: Accou number
•The dollar amount of the suspected error. m
*Describe the error and explain, it you can, why you believe there is an error. If you need more information, describe the item you are unsure
o
about
You do not have to pay any amount in question while we are investigating, but you are still obligated to pay the parts of your bill that are not in
question. While we investigate your question, we cannot report you as delinquent or take any action to collect the amount you question.
Epochal Ride for Credit Card Purchases: if you have a problem with the quality of goods or services that you purchased with a credit card, and
you,have tried in good faith to correct the problem with the merchant you tttay not have to pay the remaining amount due on the goads or
services. You have this protection only when the purchase price was. mare "loan i50 and the purchase was made in your home state or within 100
miles of your mailing address. (if we own or operate the merchant, or if we mailed you the advertisement for the goods or services, all purchases are
covered regardless of the amount or location of purchase.)
Payments. Send only your payment and the top portion of this statement in the envelope provided. Do not send cash. By sending your check as
described above, you authorize us to use information on your check to make an electronic fund transfer from yyoour account at the financial institution
indicated on your check or to process the payment as a check transaction. If payment is processed as an electronic fund transfer, the transfer will
be for the amount of the check. When we use information from your check to make an electronic fund transfer, funds may be withdrawn from your
account as soon as the same day we receive your payment and you will not receive your check back from your financial institution.
The processing of your payment may be delayed if you send cash, correspondence or other deems with Parr payment if you send the payment to
any other address or K you use an envelope other than the one provided. Payments received on or after t PIN Monday through Friday or on a
eleeKend a, Dank ncxa,r will be posted to yourAccountas-otthe-mt business day. !; you have mispfaced-your enveio,^ee ";e yourpayment to
Discover Bank, PO Box 6903, Carol Stream, IL 60197.6103. Please allow 7.10 days for delivery. If your payment is returned unpaid, we reserve the
right to resubmit it as an electronic debit
You can pay your minimum payment or a greater amount over the telephone, and you can set up automatic payymments. Call us at 1-800-347.2683.
You will need this statement and your bank account information. You must ensure that sufficient funds are ava8able in your bank account and all
transactions must comply , with U.S. law. You will be asked to provide the first 5 digits of your account statement zip code. By entering those
numbers as your eleciron+c signature, you will be agreeing to this authorization to allow us and your bank to deduct each payment you authorize
from your bank account, and to initiate debit or credit entries to your bank account as applicable to correct an error in the pro;essing of such
payment You must tell us the amount of each payment or you can select an amount such as the Minimum Payment Due or the New Balance on
each statement You can cancel a payymment, however we must receive notice at least three business days in advance of the scheduled payment You
may notify us by phone at 1-600.347 -683 or by mail at address listed in the previous paragraph. If your payments may vary in amount we will tell
you on each monthly, statement when your payment will be made and how much it will be. Your Automatic payment amount may be less than
indicated on the monthly statement based on credits or payments applied during the billing cycle.
Credit Reporting. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your
account may be reflected in your credit report We normally report the status and payment history of your Account to credit reeporting agencies each
month. If you believe that our report is inaccurate or incomplete, please write us at the following address: Discover Mores Card, P? Box 15316,
Wilmington DE 19650-5316. Please include your name, address, home telephone number and Account number.
Perbdk Fiance Comes Except as provided below, we will impose Periodic Finance Chat ges on purchases, cash advances and balance transfers
beginning with the date the transaction occurs until the date of repayment and on Old Balances until the date of repayment Old Balances are
Comprised of either purchases and cash advances made on or prior to the last day of your billing period ending during" February 1993 or Reserve
Line balances.
You can avoid payment of Periodic Finance Charges on new purchases if you pay the New Balance shown on the billing statement on which the
purchase first appears by the Payment Due Date, and the Payments and Credits on that statement equal or exceed your Previous Balance. We call
this the "grace period". You do not have a grace ppeeriod on balance transfers or cash advances. Periodic Finance Charges are imposed on new
balance transfers and cash advances beginning with the date the transaction occurs.
Periodic Finance Charges are imposed on all transactions and Old Balances until the date of repayment Re yrrienl means pa moot of your entire
New Balance. However, if you pay the New Balance shown on this billing statement by the Payment Due Oat no the Payments and Credits shown
on this statement equal or exceed the Previous Balance we will not impose Periodic Finance Charges on new purchases, that is, purchases first
appearing on this statement It your Account was closed as of September 271999, )pu can avoid payment of Periodic Finance Charges A YDU Pay
the NawBalarce shown an this S%lement-by-the Payment-Due-Date-act-the ?3yr iE, b :ad Credits-an-this al:iement-equal or exceeG you, revious
Balance. Otherwise, you will receive a billing statement next month that includes Periodic Finance Charges imposed until the date of repayment
We compute Periodic Finance Charges, cacti day for purchases, cash advances, balance transfers and Old Balances (which we refer to as transaction
Categories) by using the following equation: Average Dairy Balance x number of days in the billing Triod x WIN?y Periodic Rate. (Refer to the finance
charge summary on the front of your statement for these amounts.) Then we add all the Periodic Finance Charges for each transaction category to
gel the total Periodic Finance Charges for your Account The Average Daily Balance is shown as 0 if no Periodic Finance Charges apply to the
Vile use the" two-cycle iverage daily balance (including new transactions) method of calculating the balance upon which we impose Periodic
Finance Charges This means if ybu did not pa the New Balance shown on the billing statement you received during the previous billing period by
the Payment-Due Date, we will impose Periodid Finance Charges on new purchases that first appeared on that billing statement, as well as new
purchases that first appear on this billing statement unless we already imposed Periodic Finance Charges on the purchases on your previous trilling
statement We compute the average daily balance for each transaction category, by adding up all the daily balances in a billing period for a
transaction category and divtdin? the total by the number of days in the billing cycle. We compute the daily balance for each transaction category
on each day by Tirsdl adding the ol11e2 to the previous days daily balance: transactions made that day, fees charged that day and Periodic Finance
Charges accrued on the previous days dail1yy balance; and by then subtracting any credits and payments that are applied against the balance of the
transaction category on that dayy. Incalcufating the daily balance for the previous billing period, we consider the previous day's dairy balance" to
have been 0 on a first day of the billing perioodd
Old Balances are excluded from the balance of the purchase and cash advance transaction categories. Special rate balance transfers and Balance
Transfer Transaction Fee Finance Charges are included in the daily balance transfer transaction category. Balance transfers that were subject to an
initial special rate that has been terminated due to a late payment or because you exceeded your Account credit limit are also included in the
cate? until the initial special rate otherwise would have expired. In calculating the daily balance of the balance transfer transaction category on
the itoNday of the billing period, we subtract the unpaid balance of those Balan a Transfer Transaction Fee Finance Charges and balance transfers
that become purchase rate balance transfers on that day and we add that unpaid balance to the balance of the purchase transaction category.
All fees charged to your Account are added twthe purchase transaction cattecggoory with the exception of Cash Advance Transaction Fee Finance
Charges which are added to the cash advance tr coon category and Balanc'le ransfer Transaction Fee Finance Charges which are added to the
balance transfer transaction category.. If, a transa n made in a .previous 01O nq_ period is itemized on this statement we consider the transaction
For TOO (Tekeommunlcations Device for the Deaf} assistance, please call 1-900-347-7449.
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to
unworn falsifications to authorities, that she is Beth Bohac
(Name)
Accounts Manager of DFS Services I.LC , plaintiff herein, that
(Title) (Company)
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 her knowledge, information and belief.
(Signature)
WWR# 7305989
Kristina D. Chesne
'6011002380759662
Q
OF PP 7MY
2039 APR l I PH 2' 31
.*,18. So po AT Y
cv.-0 - tA 9.1 as
Sheriffs Office of Cumberland County
R Thomas Kline ty of crunbrr/ Edward L Schorpp
Sheri Solicitor
1,j'
Ronny R Anderson Jody S Smith
Chief Deputy 0FffCE nF THE S-ER'FF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/21/2009 08:20 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on April 21,
2009 at 2020 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Kristina Diane Chesne, by making known unto herself personally, defendant at 808
Coolidge Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same
time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $42.40
SO A S RS,
April 22, 2009
2009-2443
Discover Bank
VS
Kristina Diane Chesne
R THOMAS KLINE, SHERIFF
By •0 -
Deputy Sheriff
FILED-Oh FT
OF THE P?,'^ t w-A'nTARY
2609 APR 27 Art 11 35
r,
FILED
r, r .
T r li;?.
HE PP,0Tff0ND1;::'.
2011 JUL 20 PH 2: 33
'UMSERLA 'd CGt r .
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
No. 09-2443 CIVIL TERM
vs.
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
KRISTINA DIANE CHESNE
Defendant(s)Is bury ?? ' i13'3?
ME I RO BANK
Garnishee(s)
o PA
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molezan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
c. </. SO P A a-H7
J_ A 16 t, C, 16 7
7?-,J 6
a. S'() a
l
i b1. go pJ4 y
W W R No. 7305989
$ d-Ca tie Co,
I
IN THE COUNT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 09-2443 CIVIL TERM
KRISTINA DIANE CHESNE
Defendant(s)
METRO BANK
Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue - Writ of Execution in the above matter...
I . directed to the Sheriff of CUMBERLAND County:
2. against K.USTINA DIANE CHESNE , Defendant
3. against METRO BANK... Garnishee
4. Judgment Amount $ 6382.63
Less Payments/credits received $ 2750.00 f
1
Interest $ 593.22
Costs $
SUBTOTAL: $ 4225.85
Costs (to be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: v" ??
William T. Molczan, Es re
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 7305989
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-2443 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From KRISTINA DIANE CHESNE, 10 ZINN DR., LEWISBERRY, PA 17339
(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:
METRO BANK, 20 NOBLE BLVD., 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$3632.63 L.L.$.50
Interest $593.22
Atty's Comm % Due Prothy $2.00
Atty Paid $161.90 Other Costs
Plaintiff Paid
Date: 7/20/11
David D Buell, Protho a
(Seal) By.
Deputy
REQUESTING PARTY:
Name WILLIAM T. MOLCZAN, ESQ.
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. 47437
1 1" 1 L
('OTIONO TA';
2011 J!JL 29 PIN 2: 14
tUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
KRISTINA DIANE CHE',NE
Defendant(s)
METRO BANK
Garnishee(s)
Civil Action No. 09-2443 CIVIL TERM
INTERROGATORIES IN ATTACHMENT
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 No. 7305989
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 09-2443 CIVIL TERM
KRISTINA DIANE CHESNE
Defendant(s)
METRO BANK
Garnishee(s.
TO: METRO BAi IK, 20 NOBLE BLVD, CARLISLE, PA 17013
RE: KRISTINA IIIA'?E CHESNE, 10 ZINN DR, LEWISBERRY, PA 17339
Suggested Reference \1c,.: XXX-XX-9490
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. Fai?ure 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':: pos ession 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. 7305989
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)?
No Accounts
1 a. If the answer to Interrogatory 1 is in the affinnative, state the following: the amount
of money you owe ar owed to defendant, and, if such money is in the form of a fund, the present location thereof;
the terns, 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.
no
2. At t,,e time you were served or at any subsequent time was there in your possession, custody or
control of yourself and c-ne or more other persons any property of any nature owned solely or in part by the
defendant.
no
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 ti •ie after you were served did you pay, transfer, or deliver any money or property to the
defendant or to anV person or place pursuant to his direction or otherwise discharge any claim of the defendant
against you?
no
7. If yai are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendan 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 depositi:ig those funds on a recurring basis.
no
WWR No. 7305989
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 Ibnds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each acco;ant.
no
9. If the ans%./er to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
no
10. If tine 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.
no
11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account
which are not deposR,-d 2lectronicaliy 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 I 1 is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
no
WELTMAN, WEINBERG & REIS CO.. L.P.A.
f
By:
William T. Molczan,squire
PA I.D. 447437
WELTMAN, WEINBERG & REIS CO.. L.P.A
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 7305989
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 Jennifer Hilbish
(Name)
Levy Specialist _ of Metro Bank, garnishee herein,
(Title) (Company)
that he/she 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.
(SIGN TURE)
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Michael J. Dougherty, Esquire Attorney for Plaintiff(s)
I. D. No. 76046 G o ''?
325 Chestnut Street, Suite 501 -0:X v
Philadelphia, PA 19106
Zs + ?
c
r
Phone: 215.599.1500 =r te
Fax: 215.599.1505
File # 07305989 Eco -?, :
n
DISCOVER BANK
CUMBERLAND County
Court of Common Pleas
vs.
KRISTINA DIANE CHESNE
NO. 09-2443
PRAECIPE TO SATISFY JUDGMENT AS TO KRISTINA DIANE CHESNE
TO THE PROTHONOTARY:
Kindly mark the judgment entered against Defendant, KRISTINA DIANE CHESNE,
as SATISFIED.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
$2.oo Pty R1 ry
C*lt09l/& 17
& a6 39sy
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
1= ILED-UFEICE
101F THE PROTHONOTAR'-f
jy S Smith
,hief Deputy
Richard W Stewart
Solicitor
at wlrlnjr"jj
-.. __ I?ERIFF
2012 FEB 17 PM 2: 23
CUMBERLAND COUNT)
`
PENNSYLVANIA
Discover Bank
vs.
Kristina Diane Chesne
Case Number
2009-2443
SHERIFF'S RETURN OF SERVICE
07/26/2011 02:42 PM - Ryan Burgett, Deputy, who being duly sworn according to law, attached as herein commandec
all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or
control of the within named garnishee, Metro Bank at 65 Ashland Avenue, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to Karen Larson, Weekend Superviser, personally three copies of
interrogatories together with three true and attested copies of the Writ of Execution and made the content:
there of known to her.
The writ of execution and notice to defendant was mailed on July 26, 2011 to Kristina Diane Chesne at 10
Zinn Drive, Lewisberry, PA 17339.
02/16/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $88.12
February 16, 2012
SO ANSWERS,
RON R 'ANDERSON, SHERIFF
C
'e;ffl. Telecsoft. Inc