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Home My WebLink About09-4785J IN THE COURT OF COMMON PLEAS OF CUMBERLAND AMERICAN EXPRESS CENTURION BANK 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. MELISSA WALMER 360 MARKET ST LEMOYNE PA 17043 Defendant (s) Civil Complaint Filed on behalf of: COUNTY, PENNSYLVANIA NO. 04 - q7$5 0'4Vt'lTer6-1- CIVIL ACTION - LAW Plaintiff, AMERICAN EXPRESS CENTURION BANK Counsel of record for this party. Date: Qa . Gal wa /Philip C. Warholic #86341 . Ehasz##6469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 Counsel for Plaintiff Cover - General PACVR/PACVR FILE # 189450750 1741 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS CENTURION BANK NO. 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. CIVIL ACTION - LAW MELISSA WALMER . 360 MARKET ST - LEMOYNE PA 17043 _ Defendant (s) NOTICE 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 or any other claim or relief requested by the Plaintiff. You may lose money or property 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 HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle PA 17013 800-990-9108 CVRNOT/PACP7 FILE # 189450750 1745 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS CENTURION BANK NO. 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. CIVIL ACTION - LAW MELISSA WALMER 360 MARKET ST LEMOYNE PA 17043 Defendant (s) NOTICIA Le han demandado a used en la corte. Si used quarere defensas de esas demandas expuestas en las paginas, siguientes, used tiene viente (20) dias de plazo al partir de la fecha de lademanda y la notifiation. Used debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a last demandas en corta de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y psedido entrar una orden contra used sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Used puede perder dinero o sus propledades o otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITANCIA LEGAL. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle PA 17013 800-990-9108 CVRNOS/PACP7 FILE # 189450750 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS CENTURION BANK NO. Of. `/7PS 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. MELISSA WALMER 360 MARKET ST LEMOYNE PA 17043 Defendant (s) COMPLAINT CIVIL ACTION - LAW AND NOW, comes the Plaintiff, by and through its attorneys and the law firm of Mann Bracken LLP, and files this Complaint and in support avers as follows: 1. Plaintiff, AMERICAN EXPRESS CENTURION BANK located at, 200 VESEY ST NEW YORK NY 10285 2. Defendants, MELISSA WALMER is/are adult individual(s) with last known address(es) of 360 MARKET ST LEMOYNE PA 17043 COUNTY OF CUMBERLAND 3. It is averred that Defendant(s) was/were issued an open end credit card account. 4. At all relevant times material hereto, Defendant(s) has/have used said charge card for the purchase of products, goods, and/or for obtaining services. 5. Defendant(s) was/were provided with monthly statements showing all debits and credits for transactions on the Account to which there was no bona fide objection by Defendant(s). A Statement of Account summarizing the Account is attached hereto as Exhibit "A". 1 PAC1M1/PACP7 FILE # 189450750 1750 6. As of the date of this Complaint, the remaining balance due, owing and unpaid on Defendant's credit card account as a result of the charges made by said Defendant(s) and/or any authorized users in the sum of $ 3751.13. 7. Despite reasonable and repeated demands for payment, Defendant(s) has/have refused and continues to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 8. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 9. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant(s) in the amount of $ 3751.13, plus costs of this action, and any other relief as this Court deems just and reasonable. ectfully Submitted, David R. Gal??aay #873 hilip C. Warholic #86341 Sara Robert N. Polas, Jr. #201259 _ Amy F. Doyle #87062 MANN BRACKEN LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 866-253-0128 2 PAC1M2/PACP7 FILE # 189450750 1754 VERIFICATION The undersigned hereby states that he/she is the attorney for the Plaintiff who is located outside of this jurisdicition and in order to file the within document in an expedient and timely manner, he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. v' R, l ay #87 /Philip C. Warholic #86341 Sarah E. Ehasz 86469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 PAVERF/PACP7 FILE # 189450750 EXHIBIT "A" EXHA (10,08) f(]] ppyy O Y tt"' (? l1 CC t+J ? H It ro ??yN C yy A y yy yy G C ? 0 ro N N 1 I r r ,q 'q ? O mmyy T z? y x ? H I 1 1 1 1 ?. I at in y? W d 1 1 Y ? bal I PI 9 I ro 1? ro Q4 Y IC \ y 9Y D 8 N r I f+ ? W x to x i I 1 r ro 70 1 ~ ? K' % ? 1 1 1 i 1 M gl HN I ? i I O O 0 p fffCCC fl 1.. C? O '. I J O U1 ' !' ? ?' : W 1 N 01 ? ® ? 'L ro Y UI N Ib ! d O Q W ? to H m 'Y. • r y s tj NU :v yroy O ''17 p U1 O O o ° 1 o ? ? art W uJi N ? ? At H 10 ,p yl o tJn O ? ' r J ?° N N to 1"' '? O ?° b N N N N M r r r ? o b w R1 q ? fq fA d r P ! ! ! N n A ? • r x A M O Ip n ?d Hro a O StF?+d M W 10 t? O ? Z kkk4!!! t" ? O? 7t N ! rN ? y ! n C? 7My y (Yj y y MH ? H !'; °?? q y !C • i O r IWO ra H 1 j 1 ?? 1 'AA x I 1 A 1 1 I O I I I I I I 7 ? iV i X 1 N 1 CyYy. W ??JJ ?I ey7? yy I? 13? y?l H MMII r c r C I M O 1 0 N \ ?' N O ? O ? O Y ® Y ? I J v ? r y d N + ?rq I I r N 1 I 1 ra d '? Y O { i ® S Cyy'?ll r C m 1 N O . N ^ x N J W o + o r r ~ {pyro?j Z K R M H H H K N N d it O • • • da i '?" yy m ? r r + I 1 N i O O N INI r 0 20 9 OlUL 17 ICI I : 12 GL?1M _ _ .. d l y 418. So Pp AT-N cv-* 3a.? 3013 O aas(45 Sheriffs Office of Cumberland County R Thomas Kline FLED-OFFICE Sheri OF'ME FRO } ?'?, ?fOTAAY ?$ustn of ?a+nbcrf?fi? Ronny R Anderson Chief Deputy Y ,1009 JUL 22 PM 3= 11 Jody S Smith Civil Process Sergeant OFFICE OF THE SHOW b _.f LINTY PENt6YLVANIA Edward L Schorpp Solicitor American Express Centurion Bank vs. Melissa Walmer Case Number 2009-4785 SHERIFF'S RETURN OF SERVICE 07/21/2009 04:17 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 21, 2009 at 1617 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Melissa Walmer, by making known unto herself personally, defendant at 360 Market Street Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 July 22, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF I V Auty heriff 4305 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA oq - y'185 AMERICAN EXPRESS CENTURION BANK NO. 200 VESEY ST CIVIL ACTION - LAW NEW YORK NY 10285 Plaintiff VS. MELISSA WALMER Defendant(s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), MELISSA WALMER and for failure to answer the Complaint. ( X ) Amount due $ 3751.13 TOTAL $ 3751.13 , plus costs and statutory interest from the date of Judgment. ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( X ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of he intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after he default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. DATE; Signature: IIA d' David R. Galloway #87 26/ clip C. Warhol is Sarah E. Ehasz #8 469/Ro 1259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collec ion 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-1051 NOW, o 2009, JUDGMENT IS F,YERED AS ABOY. Protonotary/C evil Division By: Deputy PRAECJ/PACPDJ FILE # 189450750 REGIONAL OFFICES TEMPE. AZ AGOURA HILLS, CA CONCORD, CA GREENWOOD VILLAGE. CO WILMINGTON, DE BOCA RATON, FL ATLANTA. GA ROCKVILLE, MD Novi, MI CHAMPLIN. MN HUNTERSVILLE, NC CARSON CITY, NV ROCHESTER. NY 189450750 MELISSA WALMER 360 MARKET ST LEMOYNE PA 17043 LAW OFFICES MANN BRACKEN LLP Attorneys in the Practice of Debt Collection (A National Collection Attorney Network Firm) 4660 TRINDLE ROAD SUITE 300 CAMP HILL. PA 17011 (TOLL FREE) 1-866.375-1728 FACSIMILE (866) 281-9028 PLEASE DIRECT CORRESPONDENCE TO CAMP HILL OFFICE 08/13/09 REGIONAL OFFICES INDEPENDENCE, OH PORTLAND, OR CAMP HILL, PA PITTSBURGH, PA CLINTON, TN NASHVILLE, TN HOUSTON, TX IRVING, TX SAN ANTONIO, TX FAIRFAX, VA RICHMOND, VA VIRGINIA BEACH, VA ours of operation: a.m. 9 p.m. EST M-F 1 File No. 189450756 1 Re: AMERICAN EXPRESS vs. MELISSA WALMER Docket No. 09-4758 Dear MELISSA WALMER Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, David R. Gal Dway #87326 Ilip . Warholic Sarah E. Eh z #86469/ o SZTi-t:-?'vMg-, -jr--j Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA V Telephone: 866-253-0128 Fax: (717) 737-9051 Enclosure This is an attempt by a debt collector to collect a debt and any information obtaine( will be used for that purpose. NOT 10D/PANOTC 11 L TRIAD 1 1.1 29 "9 14 IN THE COURT OF COMMON PLEAS OF CUMBERLAND AMERICAN EXPRESS CENTURION BANK NO. 09-4758 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. MELISSA WALMER Defendant (s) TO: MELISSA WALMER 360 MARKET ST LEMOYNE PA 17043 DATE OF NOTICE: 08/13/09 COUNTY, PENNSYLVANIJ IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVII) YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS T A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle PA 17013 IMPNOT/PANOTC By 6?r L, David R. Gal oway #87326/ arholic Sarah E. Ehasz #864691 , Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 1 011 Telephone: 866-253-0128 Fax: (717) 737-9051 FILE # 189450750 9 4317 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CA-4'185 AMERICAN EXPRESS CENTURION BANK No. 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. MELISSA WALMER Defendant (s) . CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise residence of Plaintiff is: AMERICAN EXPRESS CENTURION BANK 200 VESEY ST NEW YORK NY 10285 and certify that the last known address of the within Defendant(s) is: MELISSA WALMER 1805 PINEFORD DR MIDDLETOWN PA 17057 1 David R. Gallowal #87326 clip C. Warholic X86 Sarah E. Ehasz #86469/Ro a as, r. Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 1 011 Telephone: 866-253-0128 Fax: (717) 737-9051 59 PCRES/PACPDJ FILE # 189450750 OF Tif, Y 20 9 SEP 22 AM 9: 4 3 t $14,oo Pry ATV ae 4 HUB P-P d3o8g5 No hem K4cLi.led 4309 • r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS CENTURION BANK NO. 09-4758 Plaintiff VS. CIVIL ACTION - LAW MELISSA WALMER Defendant (s) NOTICE OF JUDGMENT ( x ) Notice is hereby given that a Judgment in the above-ca tinned matter has been entered against you in the amount of $ 3751.13, on 2009, plus costs and statutory interest from the date of Judgment. ( x ) A copy of all documents filed with the Prothonotary in support f the within judgment is/are attached. By: If you have any questions regarding this Notice, please contact the filing party. David R. G'lallowayF.87326/ i ip't. Warholic Sarah E. Ehasz #86469/ r. FZU Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17 11 Telephone: 866-253-0128 Fax: (717) 737-9051 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: MELISSA WALMER 1805 PINEFORD DR MIDDLETOWN PA 17057 STNTCI/PACPDJ FILE # 189450750 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline r`! Sheriff Ronny R Anderson4 ritd l r j t Chief Deputy 1 , Jody S Smith _ Civil Process Sergeant= Edward L Schorpp Solicitor American Express Centurion Bank vs. Case Number Melissa Walmer 2009-4785 SHERIFF'S RETURN OF SERVICE 11/12/2009 12:45 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on November 12, 2009 at 1245 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Melissa Walmer, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, by handing to Tania Young, Deposit Operations Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on November 13, 2009 to Melissa Walmer at 1805 Pineford Drive, Middletown, PA 17057. So Answ R. Thomas Kline, Sheriff ?--puty Sh ri ci coumvst to Shen*f, Iel::^msofl, Inr. .JVJ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA '( A $ AMERICAN EXPRESS CENTURION BANK C ' `!7 6 RECEIVED No. NOV 12 2009 Plaintiff CIVIL ACTION - LAW VS MELISSA WALMER cc 4 r r Defendant (s) J vV t . " ; INTERROGATORIES TO GARNISHEE `. - TO: MEMBERS FIRST FCU 1000 BRYN MAWR RD CARLISLE PA 17013-1588 r.}. }_. PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS 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. The term "Defendant(s)" means the individual(s) or entity against whom the Writ Execution was issued. C. "You" means the main office and all branch offices, representatives, employees and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. X07 INTERROGATORIES TO GARNISHEE DEFENDANT (S) - MELISSA WALMER 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each account. If the Defendant(s) maintains an of these jointly with any other person, or persons, give their name and address. Ili U A(,c c -,? Lt 1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. 2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) 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. 3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds on deposit, not including any otherwise exempt funds, did not exceed the amount of general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. Ut 4. TRANSFER OF PROPERTY: 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 the defendant's direction or otherwise discharge any claim of the defendant(s) against you? (j ), r-,C62k,'? d 5. SAFE DEPOSIT BOX: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. J / J 6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not the Defendant(s) own any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumbrances or liens holders, the present balance of the encumbrance. State where and when encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. V b JT?- l?lJti LA 7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). M 0 At-?'fv' (-* 8. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). AU%L(' t 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charged by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer? If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. 44q-1:0 COPY David R. Galloway #87326/Philip C. Warholic #86341 Sarah E. Ehasz #86469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (71'7) 737-9051 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 Jody L. Burkholder (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. / ( NATURE) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I O FEI3 2~ i~~ I (: AMERICAN EXPRESS CENTURION BANK 4315 SOUTH 2700 WEST SALT LAKE CITY, UT Plaintiff vs. MELISSA WALMER 1805 PINEFORD DRIVE MIDDLETOWN, PA 17057 Defendant CIVIL ACTION -LAW ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appeazance on behalf of Plaintiff, American Express Centurion Bank, with regazd to the above matter. Amy F. Doyle, E q ' e PA Supreme Court 87062 Doyle Legal Services, LLC. 204 St. Chazles Way, Unit E#177 York, PA 17402 717-812-1672 877-202-9420 206-203-3878 (facsimile) Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS CENTURION BANK NO. 1044108 4315 SOUTH 2700 WEST . SALT LAKE CITY, UT Plaintiff vs. :CIVIL ACTION -LAW MELISSA WALMER 1805 PINEFORD DRIVE MIDDLETOWN, PA 17057 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that a copy of the foregoing Entry of Appeazance has been served upon th,,//e Defendant, by First Class Mail, Postage Pre-Paid, a copy thereof on this ~.:~~Iday of Februazy, 2010, to: MELISSA WALMER 1805 PINEFORD DRIVE DLETOW 17057 Amy F. Doyle, Esq e PA Supreme Court ID 8 062 Doyle Legal Services, LLC. 204 St. Charles Way, Unit E#177 York, PA 17402 717-812-1672 877-202-9420 206-203-3878 (facsimile) Counsel for Plaintiff •~ ~ v Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~o~t>,tr 01 ~it~nbrfi~,~~~ - .~s ~~ }+ ~' } s r, ~.- t~F~iCE ~F T'~E 5~ERIFF T~:'~ ~ ~' GARY 2010 ~~L -1 ~i°i 8:1$ CUtt~E .: .~.~, .ial l r~cr~l~~• ~~'~~1~'V t~! tsnAnq ~ ~4',~U'el/"i American Express Centurion Bank vs. Melissa Walmer Case Number 2009-4785 SHERIFF'S RETURN OF SERVICE 11/12/2009 12:45 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on November 12, 2009 at 1245 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Melissa Walmer, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 5000 Louise Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, by handing to Tania Young, Deposit Operations Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on November 13, 2009 to Melissa Walmer at 1805 Pineford Drive, Middletown, PA 17057. 06/30/2010 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: $91.62 June 30, 2010 a Od ~ . Co . • ~ (~~ 7G ~~S". SHERIFF'S OFFICE OF CUMBERLAND COUNTY (ci GountySuite Sheriff. Teleosoft. Inc. SO ANSWERS, .w RON R ANDERSON, SHERIFF