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HomeMy WebLinkAbout09-3473 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSSC BANK NEVADA, N.A. AS Plaintiff VS. X - 31173 N/Y IIAM No: COMPLAINT IN CIVIL ACTION JENNIFER L MURRAY 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 07200960 C N Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff VS. Civil Action No JENNIFER L MURRAY 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 couurt without further notice for any money claimed in the complaint or fob 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 HA E 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, HSBC BANK NEVADA, N.A. AS is a corporation with offices at 1111 TOWN CENTER DRIVE LAS VEGAS , NV 89193 . 2. Defendant is adult individual(s) residing at the address listed below: JENNIFER L MURRAY 511I2 N WALNUT ST M"T HOLLY SPR, PA 17065 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2985 . 4. Defendant made use of said credit card and has a current balance due of $5420.49 , as of may 05, 2009 . 5. Defendant is in default by failing to make monthly payments when dine. 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 6.!000W per annum on the unpaid balance from May 05, 2009 . A copy of Plaintiff's STATEMENT OF ACCO UNT 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 , JENNIFER L MURRAY , INDIVIDUALLY , in the amount of $5420.49 with continuing interest thereon at the rate of 6.000% per annum from May 05, 2009 plus costs. James C Warmbrodt,42524 WEL WEINBERG & REIS CO., L.P.A. 436 S th Avenue, Suite 1400 Pitts gh, PA 15219 (412 34-7955 FAX- 12-338-7130 072 0960 C N Pit KMJ 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. ' DIRECT MERCHANTS BANK® Ambdw& CARDMEMBER SERVICES • PO BOX 21550 TULSA OK 74121-1550 ACCOUNT NUMBER 6466 0015 2000 2966 Payments Payable To: HSBC Card Services NEW STATEMENT N!"MUM AMOUNT PAST PAYMENT MUST AMOUNT DUE BE RECEIVED BY ENCLOSED DATE BAI.AWCE P AYMENT DUE 00 0.00 05119107 i 96 04124107 4,365.16 . a Na. add- or emN1 Check box. See M.M .1de. SEND PAYMENTS TO: -50070046008000- JENNIFER L MURRAY 29197 PAYMENT CENTER 512 N WALNUT ST MT HOLLY SPGS PA 17065-1509 Il„.I,I.r..il,Ihl,ll,,,l,l,,,,,ll III III PO BOX 17313 BALTIMORE, MD 21297-1313 „I,I„II, t,l,l,,,ll„lilt,I„I...I,„Ilr,ll,,,rlirllrh„II„11,1,,,1 .r,r „. „. 545800152000298500009600004365168 Detach and insert this top portion in the enclosed envelope. Be cure the Payment Center address slows in the emebpe wlroow. - DIRECT MERCHANTS BANK° A VIEW OF YOUR RECENT CHARGES AND CREDITS P Online, 'me: WiNW.6xcoanleentralonOne.00M TRANS POST REFERENCE DATE DATE NUMBER CREDITS GES DESCRIPTION U PAYMENTS AND CREDITS 04/16 04115 854580039WZJWQP4 101. PAYMENT-THANK YOU TULSA OK PURCHASES, CASH ADVANCES R FEES 51.77 'FINANCE CHARGE' PURCHASES $45.16 CASH ADVANCE $6.61 YOUR ACCOUNT SUMMART-Artier ACCOUNT AND PAYMENT FORMATION CREW LINE orORMATION A MARY 39 $4414 7 ACCOUNT NUMBER 5458001520002965 TOTAL CREDIT LINE 600 CE S . 000 NEW BALANCE 4756.16 TOTAL AVAILABLE CREDIT 134 ' 2250 VANCES 000 - MNMUM PAYMENT DUE 96" CASH ADVANCE CREDIT LIMIT S 0.00 0,00 CASH ADVANCE AVAILABLE CREDIT 1 T AMOUNT U - 00 101 VMENTS + PAYMENT MUST T BE BE OVERLIMIT AMOUNT . 00 0 ,SAM RECEIVED BY MAY 19, 3007 'CASH ADVANCE CREDIT UNIT OTHER + FINANCE CHARGE . 51.77 PORTION OF YOUR TOTAL 16 4796 NEW BALANCE . CARDMEMBER SER 0.379-7985 ?Y#& A:' ; --CAR D PAYMENT BY P FROM OUTSIDE THE U.S. CALL COLLECT: 904-99 ING IMPAIRED-TDD CUSTOMERS CALL: 877- 902-0967 SEND PAYMENTS TO: PAYMENT BOX 17717, BALTIMORE, MAD 21297-1313 MAIL INQUIRIES TO:CARDME R S, PO Box 21650, TULSA, OK 74121-1650 NOTICE: SF?,R RS E FOR IMPORTANT INFORMATION. PaheiOnli?l : www?ecoanheMTalOnllnexam STATEMENT A TD AS FOLLOWS: A CHECK BY PHONE FEE MAY BE AS 3E UR ACCOUNT EACH TIME A PAYMENT IS MADE BY TELEP O F THE PAYMENT IS MADE BY SOMEONE OTHER THAN OF THE FEE WILL BE DISCLOSED WHEN A CHECK BY PHONE IS REQUESTED. '11-1.1 STERCARDS CORE BENEFITS INCLUDE EXTENDED WARRANTY, PU ASSURANCE COVERAGE, SATISFACTION GUARANTEE COVERAGE, M SERVICE, TRAVEL ASSISTANCE SERVICES, AND MASTERCARD GLOBAL SERVICE. FOR DETAILS, CALL 1-800-MCASSIST OR VISIT VW WJ.MASTERCARD.COM/SMARTSHOPPER. 5994 0002 XPD 2 7 17 070424 Page 1 of 2 8800 1500 8377 01OT5994 29197 •7 4? d0 5L'0 °';? d DIRECT MERCHANTS BANKO ACCOUNT NUMBER 5458 0015 2000 2955 A SUMMARY OF YOUR FINANCE CHARGES (EXCLUDING PROMOTIONAL OFFERS) NOMINAL NUMBER AVERAGE DAILY ANNUAL ANNUAL OF DAYS STATEMENT DAILY PERIODIC PERCENTAGE FINANCE PERCENTAGE IN BILLING CLOSING BALANCE RATE RATE CHARGE RATE CYCLE DATE PURCHASES 3993.57 .05900 % 14.24% 45.16 14.24% CASH ADVANCES 411.06 .055" % 20.24% 8.51 20.24% 29 0424/07 m 5994 0002 XPD 2 . 7 17 070424 Page 2 of 2 8800 1500 8377 OIBT5994 29197 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. Section 4904 relating to unworn falsification to authorities, that he/she is, VALERIE DEMARAIS, employee, of HSBC BANK NEVADA, N.A., plaintiff herein, 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. VALERIE DEMARAIS 07200960 5458001520002985 $5544.94 A049 WELTMAN, WEINBERG & REIS CO., L.P.A. d F, L T-{ f/g a ,?1?-" ??S J 3S ? Sheriffs Office of Cumberland County R Thomas Kline j'%%' Etua6rr?A Edward L Schorpp Sheri r' Solicitor Y.. Ronny R Anderson Jody S Smith Chief Deputy OFF>GE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/28/2009 08:07 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 28, 2009 at 2007 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jennifer L. Murray, by making known unto Dan Murray, husband of defendant at 512 N. Walnut Street Mount Holly Springs Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $34.30 SO ANSWERS, 00*004Gg::::M0g4r 1? May 29, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff- 2009-3473 HSBC Bank Nevada V Jennifer Murray eve ? C-7 Qj ro ,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. JENNIFER L. HURRAY Defendant No. 09-3473 CIVIL 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#7200960 Judgment Amount $ 5571.96 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. JENNIFER L. MURRAY Defendant TO THE PROTHONOTARY: Civil Action No. 09-3473 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, JENNIFER L. MURRAY above named, in the default of an Answer, in the amount of $5571.96 computed as follows: Amount claimed in Complaint $5420.49 Interest from MAY 5, 2009 TO OCTOBER 22, 2009 at the legal interest rate of 6.000% per annum $151.47 TOTAL $5571.96 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, SQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7200960 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`i' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 512 N WALNUT ST MOUNT HOLLY SPR,PA 17065 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff vs. JENNIFER L MURRAY Defendant TO: JENNIFER L MURRAY 512 N WALNUT ST MOUNT HOLLY SPR, PA 17065 Dafe of Notice: Case No. 09 -3473 CIVIL TER IMPORTANT NOTICE YOU ARE 1N DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE 1N 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 ASSOCIA71ON 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 {717) 249-3166 WELTMA WEINBERG & REIS CO., L.P.A. B Matfhew Urban P,A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 7200960 N PIT L4Q Request for Military Status Department of Defense Manpower Data Center ~~ ` Military Status Report ~ , ~-~ Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 OCT-22-2009 05:31:32 ~~. Last Name First/Middte Begin Date Active Duty Status Service/Agency MURRAY JENNIFER 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. 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: htt~//www.defenselink.mil/fact/pis/PC09SLDRhtm1 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: ZUDXCJZQZU https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/2212009 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DMSION HSBC BANK NEVADA, N.A. Plaintiff vs. JENNIFER L. HURRAY Defendant Case no: 09-3473 CIVIL NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That helshe 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), SO U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, JENNIFER L. HURRAY 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, JENNIFER L. HURRAY is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence thi~(~day Of ~~~-2009. _ AR COMMONWEALTH OF_PENNSYLVANW Notarlat Beal Wendy L. Oautt, Notary public Clty of plttaburph, ANspheny County MY CWnmisBion EXpirea JUIy 18, 2010 Member, Pennsyhranla AaaodaUon Natarle~ i `,~ 2C~~ ~~~~' -2 F~=i 3~ ~8 a,~.=.- ;;~t,Y ~I~k•oo Pp A~ cu,~ PR 19 4~8 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. Civil Action No. 09-3473 CIVIL JENNIFER L. MURRAY Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on oq (xx) Assumpsit Judgment in the amount of $5571.96 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: OTHONOTARY (OR DEPUTY) .~jy~ JENNIFER L MURRAY I 512 N WALNUT ST MOUNT HOLLY SPR,PA 1.7065 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 HSBC BANK NEVADA, N.A. Plaintiff vs. JENNIFER L. HURRAY Defendant No. 09-3473 CIVIL 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#7200960 Judgment Amount $ 5571.96 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. JENNIFER L. HURRAY Defendant TO THE PROTHONOTARY: Civil Action No. 09-3473 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, JENNIFER L. HURRAY above named, in the default of an Answer, in the amount of $5571.96 computed as follows: Amount claimed in Complaint $5420.49 Interest from MAY 5, 2009 TO OCTOBER 22, 2009 at the legal interest rate of 6.000% per annum $151.47 TOTAL $5571.96 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, SQUIRE PA I.D.#47437 weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (41.2)434-7955 WWR#7200960 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1.400 Koppers Building, 436 7`~' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 512 N WALNUT ST MOUNT HOLLY SPR,PA 17065 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff vs. JENNIFER L MURRAY Defendant TO: JENNIFER L MURRAY 512 N WALNUT ST MOUNT HOLLY SPR, PA 17065 Date of Notice: Case No. 09 -3473 CIVIL TER IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE 1N 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 AFFORb 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 WELTMA WEINBERG &REIS CO., L.P.A. B Matthew Urban P.A.I.p.# 90963 WELTMAN, WEINBERG &REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 7200960 N PIT L4Q Request for Military Status Department of Defense Manpower Data Center x.` Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 OCT-22-2009 05:31:32 Last Name FirstlMiddle Begin Date Active Duty Status Service/Agency HURRAY JENNIFER 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. +~~. ~, ~- 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/fad/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: ZUDXCJZQZU https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/22!2009 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION HSBC BANK NEVADA, N.A Plaintiff vs. JENNIFER L. HURRAY Defendant Case no: 09-3473 CIVIL 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, JENNIFER L. HURRAY 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, JENNIFER L. HURRAY is not in the military service. Further Affiant sayeth naught. . ,.-, AFFIANT SWORN TO AND SUBSCRIBED in my presence thi~~day Of ~C~-2009_ AR COMMONWEALTH OF PENPISYLVANIA NofaAel Seal City a Pitbbur~ph All~he -yuCo~untY 1 My Commfseion Expires 18, 2010 vlsrnber, Pennsylvania AeeodaUon NapAeua ZC~~~~ ~ -2 ~'~-i 3~ ~8 r n - , j 1 rrv E- ~~~, ~ ~ ~~~.oo Pp Arrf CI~~ PR ~9 4~8 ~o~~, ~.~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C1ViL DIVISION HSBC BANK NEVADA, N.A. Plaintiff vs. Civil Action No. 09-3473 CIVIL JENNIFER L. MURRAY Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on o9 (xx) Assumpsit Judgment in the amount of $5571.96 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 ay: OTHONOTARY (OR DEPUTY) JENNIFER L MURRAY 51.2 N WALNUT ST MOUNT HOLLY SPR,PA 17065 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 ~.,_' r~ ~' ~: L ao~o I~06 5 A1d l0: (!o 211 01~~, i.'~ -` ~ ~ ~~ ~ '~ i'~ ~ .. ~F ~ '. ~ti :,.,.~~ ~.. .. ~~; r~r 4 ~ k_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA Plaintiff vs. No. 09-3473 CIVIL TER PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACIiMENT ONLY) JENNIFER L HURRAY 5~d1 N. u)o-.~nt7f' $+ Mf Norry~rin9s, ~ l7O(oS Defendant MEMBERS 1sT FEDERAL CREDIT UNION, t 1(0(o icaod~ irk L•~Hom Qd , ~rt~s(e ~ PA noi3 Garnishee, Q ~a~.so P~ Arn 3'x.30 C'8F '18.60 « ~~ • 00 a a.50 " 153.80 - PO ~~N FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA LD. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#07200960 ~ a . oc Oc,eCo • So u. fit ~(d1535~1 °3 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA Plaintiff vs. JENNIFER L HURRAY Defendant MEMBERS 1ST FEDERAL CREDIT UNION, Garnishee TO THE PROTHONOTARY: Civil Action No. 09-3473 CIVIL TER 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 JENNIFER L HURRAY, Defendant 3. against MEMBERS 1sT FEDERAL CREDIT UNION, Garnishee 4. Judgment Amount $ 5,571.96 ~ 5K1.9(v Less payments of _ ~p.pp $ 260.00 Interest 5, 3 < < ' ~ $ 232.65 Costs $ SUBTOTAL: - ___. -_-_ _ - _ _ $ 5,544.61 Costs (to be added by Prothonotary): $ WELTMAN, ERG & REIS CO., L.P.A. B ... Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 43b Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-3473 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC BANK NEVADA, NA, Plaintiff (s) From JENNIFER L. MURRAY, 512 N. Walnut Street, Mt. Holly Springs, PA 17065 (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: MEMBERS 1sT FEDERAL CREDIT UNION, 1166 Walnut Bottom Rd, 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 $5,311.96 L.L. $.50 Interest -- $232.65 Atty's Comm Atty Paid $153.80 Plaintiff Paid Date: 8/5/10 Due Prothy $2.00 Other Costs I Davi rotho otary (Seal) 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 By: Deputy Supreme Court ID No. 90963 RECEIVED AUG 2 0 2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSI3C BANK NEVADA, NA Plaintiff vs. JENNIFER L MURRAY Defendant and MEMBERS I ST FEDERAL CREDIT UNION Garnishee No. 09-3473 CIVIL TER AOSU)ets TO INTERROGATORIES IN ATTACHMENT MEMBERS IsT FEDERAL CREDIT UNION C n ref' L _ + J J •? <c - . FILED ON BEHALF OF: v 3 Plaintiff r r? 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#07200960 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, NA Plaintiff vs. Civil Action No.: 09-3473 CIVIL TER JENNIFER L MURRAY Defendant and MEMBERS I ST FEDERAL CREDIT UNION Garnishee TO: MEMBERS 1 s7 FEDERAL CREDIT UNION Suggested Reference No.: XXX-XX-9394 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 RE: JENNIFER L MURRAY 512 N WALNUT ST MOUNTY HOLLY SPRINGS, PA 17065 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)? 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. 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. 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? 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? y 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? r1 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? I? V 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. ` 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. o?? ? 0cds 9. If the answer to Interrogatory I is in the affirmative, state the date: the sheriff served these interrogatories on this institution. n ? 6- 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. Ir 1 ? 1 1. If the response to Interrogatory 7 is in the affinnative, 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`? 12. If the response to Interrogatory I 1 is in the affnmative, state the amount of non-exempt funds on deposit in the account. WELTMAN, WEINBERG & REIS CO., L.P.A. 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 WWR#07200960 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 Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. 11??JVA ml (SIGNAL RE) AMMENDMENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLANIA CIVIL DIVISION HSBC BANK NEVADA, NA Plaintiff Vs JENNIFER L MURRAY Defendant And MEMBERS IST FEDERAL CREDIT UNION Garnishee RECEIVED SU' 0 2, 2019 No. 09-3473 CIVIL TER AMWE2S m INTERROGATORIES IN ATTACHMENT MEMBERS IsT FEDERAL CREDIT UNION n D -11 ' rm ' fin w; : a q FILED ON BEHALF OF: Plaintiff ; z ? -Y COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA ID 490963 WELTMAN, WEINBERG & REI S CO. L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburg, PA 15219 (412) 434-7955 W WR#07200960 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 any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? No 1 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. N/A 2. At the time you were served or at any subsequent time were 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. 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 interest? No 5. At any time before or after you were served, did the defendant transfer o 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 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 nay 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. 217800-savings $0.00 Daniel A Murray-primary 217800-checking $354.80 Jennifer L Murray joint 30911 1-savings $0.24 Faeth I Murray-primary Jennifer L Murray joint $300.00 Statutory Exemption was not taken out. 9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. N/A 10. If the answer to Interrogatory I is in 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? N/A 12. If the response to Interrogatory 1 I 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: Matthew D. Urban, Esquire PA ID #90963 WELTMAN, WEINBERG & REIS CO. L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburg, PA 15219 (412) 434-7955 WWR#07200960 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 Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. 1 (SIGNATUIj, ) i WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire Attorney for Plaintiff(s) I.D. No.47437 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 07200960 HSBC BANK NEVADA, NA vs. JENNIFER L MURRAY and MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee(s) CUMBERLAND County Court of Common Pleas NO. 09-3473 CIVIL TER PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: p l 1 vl?,, e? y Kindly marked the above matter settled, discontinued, and ended as to Garnishee(s), MEMBERS 1ST FEDERAL CREDIT UNION, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By _ William T. Molczan, E uire Attorney for Plaintiff Sworn to and subscribed Before me the Day of SEPTEMBER, 2010 *%-OoP?o PTT` T Clt 4-7(,6341 !N U' 1'A E ! P L 1 L_01,4 ?l'ONWEALJ OF PENNSYLVANIA a y8 3a7 Notarial Seal Wendy 4 Gault, NotarY Publlc Icy oP Ptetsburgh, AlleghanY County My commisalan ExPlrt+c duly 15, aola .?eribe ?ennsvlvanla ArSSOClatlon of Notaries ( _ S F11..EC('-CL! (nF1 f?I C(?E T/r? R"( 'HE P 0 1 TT H0N0 An L61{? J.a7- P 20 FM 3• 4 ", P.l R L A ND C 0 U N T Y SYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff vs. JENNIFER L MURRAY Defendant(s) No. 09 -3473 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA I.D. # 205520 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7200960 JAM t. oo Pb ATTIJ Q#y7is!5 a3 O'ags54q i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HSBC BANK NEVADA, N.A. AS Plaintiff vs. Civil Action No. 09 -3473 CIVIL TERM JENNIFER L MURRAY Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff you are directed to satisfy the above-captioned Judgment. WELTMAN, ;?6INbERG & REIS CO., L.P.A. q if By: Lyndsay E Row and, Esquire PA I.D. # 20552 WELTMAN, IN BERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR #7200960 Sworn to and subscribed before me this _/V day of September, 10 ° TARY PU_ IC CO IA woa+?? tf?re? WWI A, Jam, Nwry RUtMIC ".."O k a do M8A1 . JPNI . tiw' rts SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ti`s Sheriff _ ??? 1 Jody S Smith Chief Deputy Richard W Stewart Solicitor c "r I ? SEFF a at" .? f I? ptRC t,t HSBC Bank USA, N.A. Case Number vs. Jennifer L. Murray 2009-3473 SHERIFF'S RETURN OF SERVICE 08/20/2010 03:21 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on August 20, 2010 at 1517 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Jennifer L. Murray, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania, by handing to Ashley Hoch, 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 writ of execution and notice to defendant was mailed on August 23, 2010 to Jennifer L. Murray at 512 N. Walnut Street, Mt. Holly Springs, PA 17065. 03/11/2011 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: $87.50 SO ANSWERS, March 11, 2011 RON R ANDERSON, SHERIFF F3 Sharon R. La alf / AO a56-"-62 cl c oust"Suite She",ff. Tele osott Inr.