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Home My WebLink About09-4405IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No: (q _ gg05 CtVt?-Fem, vs. COMPLAINT IN CIVIL ACTION LISA KING 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 07384626 C N Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. Civil Action No LISA KING Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA),NA is a corporation with offices at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238 . 2. Defendant is adult individual(s) residing at the address listed below: LISA KING 549 MEADOW CROFT CIR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX5923 . 4. Defendant made use of said credit card and has a current balance due of $4237.52 , as of June 23, 2009 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 25.900% per annum on the unpaid balance from June 23, 2009 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit 11111 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 , LISA KING , individually , in the amount of $4237.52 with continuing interest thereon at the rate of 25.9006 per annum from June 23, 2009 plus costs. James C WELTMAN 436 Se Pittsb (412) 4 FAX: 0738 W INBERG & REIS CO., L.P.A. en Avenue, Suite 1400 r PA 15219 4-7955 -338-7130 6 C N Pit KMJ This law firm is a debt collector attemAing to collect this debt for our client and any information obtained will be used for that purpose. FINANCE Previous Balance Payments & Credits CHARGE Transactions New Balance Minimum Payment Due Date $4,9 06 6 -l $0.00 + $112.64 $39.00 $5,1-12.3 $1,112.31 Mar. 17, 2008\' Jan. 22, 2008 - Feb. 21, 2008 Page 1 of 1 ^ TA5[ MV AT Itl, " -MAW "m MasterCard Platinum Account 51784523$2484823 Your Account Information TOTAL CREDIT LINE $4,000.00 TOTAL AVAILABLE CREDIT $0.00 CREDIT LINE FOR CASH $4,000.00 AVAILABLE CREDIT FOR CASH $0.00 Finance Charges (Please we reverse for important Information) Balance rate periodic Corresponding FINANCE applied to rate APR CHARGE Purchases 54,89472 0072339/6D 2540% 510975 Cash S12897 0 07233'/, D 2640% 12W ANNUAL PER(?71TAGE RATE applied this period: 2l'a40% Q At YourServkz 1-800.8033637 To cal CLsirxre- ReWe rx 4r rarz,rt n tst a sWbl cod ® Send payments to: Cagtel One Be* • P D 9m 708(4 • Cha6rte, NO 25272,7684 Your aWxlnt is su payments behrnd. If we charge off your account d o to late payments, we will report the charged-off status to several national credit bureaus, and the Purchase APR as reflected on this statement will be allied to all your outstanding balancers Act now to prevent this from happening Plane ray the amount due on your statement or give us a oall at 1 800 955 6600 WA work with you so you can take centol of your account and start rebuilding your aedit with Capital One ^'Important Notice" Urrckar the terms we previously disclosed to you, your account is now elglNe for an increase in Annual Percentage Rates (APRs) effective immediately However, Cq)bl Orle has elected rat to rare your APRs at this title Please be ad.Ased that it you fad to keep your account in guar standing, Capital Ore reserves the right to raise your APRs in the future Pqments Credits & Miustments_ Transactions 1 15 FED PAST DUE FEE $33,00 You were assessed a past clue fee because your minimum payment was not received by the due date To avoid this fee in the future, we recommend that you allow at least 7 business days for your minimum payment to reach Caotal One A Sencl Inquiries to; Canal One- P 0 9cz 902%- Sat Lda City, Uf 841300255 rAnioll Q Have a question about a charge on your statement? Please refer to the Billing Rights Summary on the back of your statermenl or visit www-oapilalone.can/disputes I PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ONTO WWW CAPrrALONE.COM TO MAKE YOUR PAYMENT ONLINE a apital0rle` wh.1 in ymu -1101 New Balance Minimum Payment Due Date $5,112.31 ( $1,112.31 Mar. 17, 2008 PLEASE PAY AT LEAST THISAMOUNT Amount Enclosed ) 0 5178052382495923 21 5112310100001112312 Capital One Bank P•O• Box 76884 ?Ilnl?lrn?nr??nr?? Charlotte, NC 28272-0884 7384626 irririirrinrirurrrirrirnirrrinirirlirrirriirrirrirri?rrrn Account Number. 5178-0523-8249-5923 Please print address or phone number dTanges below using blue or black ink 7yome Phone A7remate Phone #90053969110815500 MAIL ID NUMBER LISA KING 549 MEADOW CROFT CIR IIECHA4ICSBURG, PA 17055-5863 Please write your account number on your check or money order made payable to Capital One Bank and mail wRh this coupon in the enclosed envelope. PROTHONOTARY CUMBERLAND CO CAPITAL ONE BANK (USA), N.A., Plaintiff, V. LISA KING Defendant(s). VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that he/she is an authorized agent of CAPITAL ONE BANK (USA), N.A., Plaintiff herein, and that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief Dated: J CJ Ottis Coward A049 WELTMAN, WEINBERG & REIS CO., L.P.A. Q R C', OF THE 20G9 JE 1 -1 PVi`i 1 ? L B CUM" t C? : VQ. LvAll"iI+4! 419.5o p o AT'N CIC-* µ[o5[oal8 p? aati4 ? o Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy ' Jody S Smith Civil Process Sergeant OFFICE '>,1RIFF Edward L Schorpp Solicitor Capital One Bank (U.S.A.) N.A. Case Number vs. 2009-4405 Lisa A. King SHERIFF'S RETURN OF SERVICE 07/11/2009 09:44 AM - Timothy Reitz, Corporal, who being duly sworn according to law, states that on July 11, 2009 at 0944 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lisa A. King, by making known unto herself personally, defendant at 549 Meadowcroft Circle Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 July 13, 2009 SO ANSWERS, R THOMAS KLINE. S RIFF L De uty S erif FILE. f-O'rF!CE OF THE t Fa' ION fO ARY 2009 JUL 21 A,ti 1 i ' 8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. LISA KING Defendant No. 09-4405-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#7384626 Judgment Amount $ 4505.89 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. LISA KING Defendant TO THE PROTHONOTARY: Civil Action No. 09-4405-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, LISA KING above named, in the default of an Answer, in the amount of $4505.89 computed as follows: Amount claimed in Complaint $4237.52 Interest from JUNE 23, 2009 TO OCTOBER 27, 2009 at the legal interest rate of 25.900% per annum $268.37 TOTAL $4505.89 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. MOL ZAN, FA - QUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7384626 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 70` Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 549 MEADOW CROFT CIR, MECHANICSBURG, PA 17055 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Case no: 09-4405-CIVIL TERM Plaintiff VS. LISA KING 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, LISA KING 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, LISA KING is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence this M day O?009. INOTAR?YPUBLIC L S4i9ila G. davdr, 'dofary tub€;'- City Of Nuts uwu -h' k Olt -.y C trr, My Commissior. Expire Nov. '; 5, 20 0-__j Member, Pennsylvania Association of Notaries IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. LISA KING Defendant Case No. 09-4405 CIVIL TERM IMPORTANT NOTICE TO: LISA KING 549 MEADOW CROFT CIR MECHANICSBURG, PA 170 5 Date of Notice: in c C) 9 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: / Matthew 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 7384626 N PIT L4Q Recuest rorMilitary Status Department of I;?efense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Oct-29-2009 08:12:43 A?. Last First/Middle Begin Date Active Duty Status Active Duty End Date Service A enc Name g y Based on the information you have furnished, the DMDC does not possess KING LISA any information indicating the individual status. 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 Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). 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 DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as 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 status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.htral. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional 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 active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 10/29/2009 20' 9 'v;` i 0 ii L: 414. pD Pb Al" aX,P 4 3657`73 W* aaaaa&l NohcF- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. LISA KING Defendant Civil Action No. 09-4405-CIVIL TERM 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 $4505.89 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: OTHONO? D UTY) LISA KING 549 MEADOW CROFT CIR MECHANICSBURG, PA 17055 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 76 Avenue, Pittsburgh, PA 15219 1-888-434-0085 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-4405 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK, Plaintiff (s) From LISA KING, 549 Meadow Croft Circle, Mechanicsburg, PA 17055 (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: PNC BANK, 105 NOBLE BLVD., CARLISLE, PA 17013 CITIZENS BANK, 665 NORTH EAST STREET, CARLISLE, PA 17013 SOVERIGN BANK, 17 WEST HIGH STREET, CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,505.89 L.L. $.50 Interest $422.20 Atty's Comm % Due Prothy $2.00 Atty Paid $156.50 Other Costs Plaintiff Paid Date: 6/17/11 L Buell, rothonotary (Seal) By: Deputy REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff vs. LISA KING dr ? Cj tle S4A Defendant(s) rAe'A.IPA I'los5 PNC BANK CITIZENS BANK SOVERIGN BANK Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... Civil Action No. 09-4405 CIVIL TERM n C= N p C:) 3 ma) M n ? c(nr- -O = {D _„j 6 o , r-;z -4c3 v C-) Vi=a c=; rti, 1. directed to the Sheriff of CUMBERLAND County: 2. against LISA KING , Defendant h g . ('b W gad Sk _ 1-7 W • 9 ? 3. against PNC BANK, CITIZENS BANK, SOVERIGN BANK, Garnishee 105 luoble Qlvd. C??l?sle, fop 1Z613 4. Judgment Amount $ $4,505.89 Less Payments/credits received $ $0.00 Interest $ $422.20 Costs $ SUBTOTAL: $ $4,928.09 Costs (to be added by Prothonotary): $ l=/ a "'A 3? . oo 4.40 1( << a. So s?s?. SO f d a WELTMAN, W ERG & 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 4D buQdi, s sv ?? C IL 1* -7 WWR No. 7384626 Wn 1 dG ek 7-?sLted IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff No. 09-4405 CIVIL TERM vs. LISA KING Defendant(s) PNC BANK CITIZENS BANK SOVERIGN BANK, Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 7384626 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ???rtu' at ?rtffiIirr(??i 4 f l? J t AN 7 14 Richard W Stewart Solicitor OF'€a.E'r '-E r--4 JVF rE.NNSYLVAHIA Capital One Bank (U.S.A.) N.A. vs. Lisa A. King Case Number 2009-4405 SHERIFF'S RETURN OF SERVICE 06/22/2011 10:03 AM - 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, RNC Bank at 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013 Cumberland County, by handing to SHERI GUTTSHALL, BRANCH MRG, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 23, 2011 to Lisa A. King at 549 Meadow Croft Circle, Mechanicsburg, Pennsylvania, 17055. 06/22/2011 10:29 AM - 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, C_tizens Bank at 665 North East Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to JESSICA WEBB, TELLER MRG, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 23, 2011 to Lisa A. King at 549 Meadow Croft Circle, Mechanicsburg, Pennsylvania, 17055. 06/22/2011 10:20 AM - 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, kverign Bank at 17 West High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to JULIE MYERS, BRANCH OPS MRG, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 23, 2011 to Lisa A. King at 549 Meadow Croft Circle, Mechanicsburg, Pennsylvania, 17055. SHERIFF COST: $285.62 June 23, 2011 SO ANSWERS, 21 dRON R NDERSON, SHERIFF v illiam Cline, Deputy Sheriff fcj GountySulke She!iff TF; eoS1ft Inc. SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee CAPITAL ONE BANK (USA), NA vs. LISA KING and C c z rn -n r- ? _ C ? 3> . .._. C) ?CD o? ?o :)C,3 C) to f COURT OF COMMON PLEAS COUNTY OF CUMBERLAND NO. 09-4405 PNC BANK, NATIONAL ASSOCIATION, GARNISHEE ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of PT the above-captioned matter. Date: shee, in IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION DISCOVER BANK Plaintiff(s), VS. LISA KING Defendant(s), VS. Citizens Bank of Pennsylvania, Garnishee. r NO.: 09-4405 CIVIL TE1? _-7 Answers to Interrogatorie-1 Tc? CJ Code: 200 Execution 5:c= i" C r ` C'n Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Parry: Nicholas Deenis, Esquire PA I.D. No. 62378 Stradley, Ronon, Stevens & Young Great Valley Corporate Center 30 Valley Stream Parkway Malvern, PA 19355-1481 (484) 323-1351 (610) 640-1965 fax ndeenis@stradley.com www.stradley.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION DISCOVER BANK Plaintiff(s), VS. LISA KING Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. NO.: 09-4405 CIVIL TERM ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1-12) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of PA, states that with the information provided it maintains no deposit accounts in the name of the Defendant, LISA KING. Therefore, no funds are being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF ALLEGHENY ) NO.: 09-4405 CIVIL TERM Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Christina Graham who being duly sworn according to the law deposes and says that she is an Operations Clerk, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Christina Graham Sworn and subscribed before me this l5 day of 2011. No blic COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY NO.: 09-4405 CIVIL TERM Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Christina Graham who being duly sworn according to the law deposes and says that she is an Operations Clerk, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Q l) Christina Graham Sworn and subscribed before me this 15 day of ?, 2011. vVELTMAN, A'FINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Av .nue, Suite 1400 Pittsburgh, f`A ',5219 Phone: 412.434.7955 Fax: 412.434.799 File # 73$4626 CAPITAL ONE BANK (USA),NA vs. Attorney for Plaintiff(s) Cumberland County Court of Common Pleas = rY p Cl - xv .. ) rr v? .. ,e p LISA KINC NO. 09-4405 CIVIL TERM anC PNC BANY SOVEREIGN BANK & CITIZENS BANK Gan;;sh:???(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), PNC BANK SOVEREIGN BANK & CITIZENS BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to and sur.°::cribed Before m e day of August, 2011 r sue. ? NOTAR4YNj B-iCy Q%'?A} 'k 8`.00 (A wkj C1c web a(0 SIR -? al.aaR.s WELTMAN, WEINBERG & REIS CO., L.P.A. fIONO TA BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s)rg i - 29 , 11: 3,5 I.D. No.86469 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 7384626 CAPITAL ONE BANK (USA) NA CtjiPENNS YLD?F?Ut?7'?' /? CUMBERLAND County Court of Common Pleas vs. LISA, KING NO. 09-4405-CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROTHONOTARY: Please kindle Satisfy the Judgment of the above-captioned matter upon the records of the C)urt and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. FBy Sarah E. Ehasz, Esquire Attorney for Plaintiff Sworn to and subscribed Befor me tie Z day of August, 2011 OTA PUBLIC" COMMONWEALTH EALTH OF PENNSYLVANIA Notarial Seal Sheila G. Bevan, Notary Public Ross Twp., Allegheny County M Commission Expires Nov. 15, 2014 ^tEMdEk PENNSYLVANIA ASSOCIATION OF NOTARIES !?.W' to f;. 4 0- 1? C04 16tooomo eA -;7( sat oz WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-4405 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK, Plaintiff (s) From LISA KING, 549 Meadow Croft Circle, Mechanicsburg, PA 17055 (l) 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: PNC BANK, 105 NOBLE BLVD., CARLISLE, PA 17013 CITIZENS BANK, 665 NORTH EAST STREET, CARLISLE, PA 17013 SOVERIGN BANK, 17 WEST HIGH STREET, CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,505.89 L.L. $.50 Interest $422.20 Atty's Comm % Due Prothy $2.00 Atty Paid $156.50 Other Costs Plaintiff Paid Date: 6/17;11 D . Bue , P othonotary (Seal) By: Deputy REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. TRUE COPY FROM RECORD In Testimony whereof, l here unto set my hand 1400 KOPPERS BUILDING and the seal of said at Carlisle, Pa. 436 SEVENTH AVENUE This n day of?.20 1 L Prothonotary PITTSBURGH, PA 15219 1r10W 16L 6 ? ) Attorney for: PLAINTIFF v_ ?_Qy Telephone: 412-434-7955 Supreme Court ID No. 90963 a Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 4itrtT ct t:iartGfifrr z. Jf 2 5 #w? a 1 p CUMBER! A& 1 Capital One Bank (U.S.A.) N.A. vs. Lisa A. King Case Number 2009-4405 SHERIFF'S RETURN OF SERVICE 06/22/2011 10:03 AM - 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, PNC Bank at 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013 Cumberland County, by handing to SHERI GUTTSHALL, BRANCH MRG, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 23, 2011 to Lisa A. King at 549 Meadow Croft Circle, Mechanicsburg, Pennsylvania, 17055. 06/22/2011 10:29 AM - 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, Citizens Bank at 665 North East Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to JESSICA WEBB, TELLER MRG, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 23, 2011 to Lisa A. King at 549 Meadow Croft Circle, Mechanicsburg, Pennsylvania, 17055. 06/22/2011 10:20 AM - 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, Soverign Bank at 17 West High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to JULIE MYERS, BRANCH OPS MRG, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 23, 2011 to Lisa A. King at 549 Meadow Croft Circle, Mechanicsburg, Pennsylvania, 17055. 01/23/2012 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: $196.38 SO ANSWERS, January 23, 2012 RON R ANDERSON, SHERIFF G?? "9P` ,'s ?a r5