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Home My WebLink About09-5568102 IN THE COURT OF COMMON PLEAS OF CUMBERLAND AMERICAN EXPRESS BANK, FSB 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. DARRYL RYAN 110 FAIRWAY DR CARLISLE PA 17.015 Defendant (s) Civil Complaint Filed on behalf of: COUNTY, PENNSYLVANIA NO. Oq - W(Og Civil le.rM CIVIL ACTION - LAW Plaintiff, AMERICAN EXPRESS BANK, FSB Counsel of record for this party. Date: sl_ -Tr David R. Gall ay 26/Philip C. Warholic #86341 Sarah E. Ehasz # 469/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 # 192018501 111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. CIVIL ACTION - LAW DARRYL RYAN 110 FAIRWAY DR CARLISLE PA 17015 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 # 192018501 114 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. CIVIL ACTION - LAW DARRYL RYAN 110 FAIRWAY DR . CARLISLE PA 17015 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 # 192018501 117 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. Of. 5s-( ,y (.l ; 7i-to, 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. CIVIL ACTION - LAW DARRYL RYAN . 110 FAIRWAY DR CARLISLE PA 17015 Defendant(s) COMPLAINT 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 BANK, FSB located at, 200 VESEY ST NEW YORK NY 10285 2. Defendants, DARRYL RYAN is/are adult individual(s) with last known address(es) of 110 FAIRWAY DR CARLISLE PA 17015 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 # 192018501 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 $ 9098.47. 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 $ 9098.47, plus costs of this action, and any other relief as this Court deems just and reasonable. Respect?lly Submitted, David R. GalYdway 8 3T6/Philip C. Warholic #86341 Sarah E. 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 866-253-0128 2 PAC1M2/PACP7 FILE # 192018501 123 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. David R. GalloVay #8!7126/Philip C. Warholic #86341 Sarah E. Ehasz #8 69/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 # 192018501 EXHIBIT "A" EXHA (ionvros) w a P RI PK 0 a O a ' N E N d . • • q ¦ (F? ?+ F l jr t 1 pM N l U ¦ ~ O 0 IV! c4 w a N F 1 N .7 m m o f 11 x!! O r c? 0 \ 0 I i I I ; 44 C, 0, O H r- O O O O ?? 0 ? 1 ? , 1 1 O 1 1 1 1 1 1 1 1 0 a [ F a 0 w i i O fL a w i YI 0 7G " p U i e O Ll ' a H : a pq F ¦ , ? ? F F F U y c4 a? s ?i N °? e ¦ p a p a w ps I w . i U U a K th m o N H u U z In a M 01 of v In E x * i N o W * r 1 r o R ¦ a N a \ Z ? ?' a . c t+E m O O r r M 1 m o \ cv o F • N 1 a {y? OD ? ,ryy m a o o w • . o+ 4 N w .a ? N tO m rR 1 0 In o q / -1 . o N ? T?. i r o r o o r4 r-4 ? N 1 F 1 1 M r ri P: ? ? W 0.' N N If, Q U O 0 A t7? a N a i i pp f SIC W 1 fFq \ W a '1 1 p U i 1 i i ? . a W o x r T a m 0-4 x 1 ? W w 1? r1 0 : i +i N 1 •? 11 • Z v Uo F 0 *78.60 Po AT -4 00 3y8a95 234 aagolco Sheriffs Office of Cumberland County R Thomas Kline Sheri FILELI OF THE c' '^ n wY Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor American Express Bank, FSB vs. Darryl Ryan 2009 AUG 25 Al 10: 0 '1 INTY cutlkiL? pi-NJi?? ?y r N Case Number 2009-5568 SHERIFF'S RETURN OF SERVICE 08/14/2009 08:10 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on August 14, 2009 at 2010 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Darryl Ryan, by making known unto himself personally, defendant at 110 Fairway Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 August 17, 2009 SO ANSWERS, OA R THOMAS KLINE, SHERIFF By Z?, Deputy Sheriff 6163 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. 09 5568 200 VESEY ST CIVIL ACTION - LAW NEW YORK NY 10285 Plaintiff VS. DARRYL RYAN Defendant (s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), DARRYL RYAN and , for failure to answer the Complaint. ( X ) Amount due $ 9098.47 TOTAL $ 9098.47 , 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 the 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 the default occurred and at least ten days rior to the date of the filing of this praecipe and zocl? of the notice is attac d. DATE: 3 Signature: R. Gal oway 1187326/ ilip C. Warholic #86341 Sarah E. Eh z 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 NOW, ?ap`F . oZ? 2009, JUDGMENT I S TERED AS AB E . Pr onotary/ c1 ivil Division By: Deputy PRAECJ/PACPDJ FILE # 192018501 REGIONX OFFICES TEMPF. AZ AGOURA HILLS. CA OONOORO. FA GREENWOOD Vt 1AGE, CO WN.IIONGTON, OE BOCA RATON, FL ATLANTA GA ROC1KVILLtw MO NO\01' W C HAMPUN. MN HUNTERSVILLE, NC CARSON CITY, NV ROCHESTEft NY 192018501 DARRYL RYAN 110 FAIRWAY DR CARLISLE PA 17015 Re: AMERICAN EXPRESS vs. DARRYL RYAN Docket No. 09 5568 Dear DARRYL RYAN REGIONAL OFMEN INDEPENDENCE.. ON PORTLAM, OR CAMP HILL PA F"'ITT" lROH. PA CLINTON, TN NASNVUI,F- TN HOUSTON, TX IRV040, TX SAN ANTONIO, TX FAIRFAX, VA RICHMOND, VA VIRGINIA BEACH, VA Hours of OpWakin: 8 e.m. B p.m. EST M-F I File No: 192018501 Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, Enclosure CC: DARRYL RYAN 09108/09 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: (717) 737-9051 This is an attempt by a debt collector to collect a debt and any information obtained will be used for that purpose. NOT 10D/PANOTC LAW OFFICES MANN BRACKEN LLP Attomeys in the Practxv of De& C*#* vn (A National Collectaom Attorney Network Fwm) 4660 TRINDLE ROAD SUITE 300 CAMP HILT. PA 17011 (TOLL FREE) FACSIMILE (868) 281-1X128 PLEASE DIRECT CORRESPONDENCE TO CAMP HILL OFFICE LTRH01 jov-Nvo) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. 09 5568 200 VESEY ST NEW YORK NY 10285 Plaintiff VS. DARRYL RYAN Defendant(s) TO: DARRYL RYAN 110 FAIRWAY DR CARLISLE PA 17015 DATE OF NOTICE: 09/08/09 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 MAYBE 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. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle PA 17013 By _ 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: (717) 737-9051 1MPNOT/PANOTC FILE # 192018501 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB 200 VESEY ST NEW YORK NY 10285 Plaintiff No. 09 5568 CIVIL ACTION - LAW Vs. DARRYL RYAN Defendant (s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise residence of Plaintiff is: AMERICAN EXPRESS BANK, FSB 200 VESEY ST NEW YORK NY 10285 and certify that the last known address of the within Defendant(s) is: DARRYL RYAN 110 FAIRWAY DR CARLISLE PA 17015 ?? &R7326/Philip C. Warholic #86341 Sarah E. Eha #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 PCRES/PACPDJ FILE # 192018501 $14-. oo Po A`MY cr-W 4ay (cµa 0` a3la.Ds 0o*C-Al ka,"Ld 6167 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN EXPRESS BANK, FSB NO. 09 5568 Plaintiff VS. CIVIL ACTION - LAW DARRYL RYAN Defendant(s) - NOTICE OF JUDGMENT ( x ) Notice is hereby given that a Judgment in the above-captioned matter has been entered against you in the amount of $ 9098.47, on 'f o19 2009, plus costs and statutory interest from the date of Judgment. ( x ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. By: If you have any questions regarding this Notice, please contact the filing party. c_ 5svid 873A/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 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: DARRYL RYAN 110 FAIRWAY DR CARLISLE PA 17015 STNTCI/PACPDJ FILE # 192018501 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline r' Sheriff ???ti\571' of ?iltllflpp?d?j1? Ronny R Anderson , . Chief Deputy J', ! Jody S Smith Civil Process Sergeants Edward L Schorpp Solicitor American Express Bank, FSB vs. Darryl Ryan Case Number 2009-5568 SHERIFF'S RETURN OF SERVICE 11/12/2009 09:19 AM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on November 12, 2009 at 0919 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Darryl Ryan, in the hands, possession, or control of the within named garnishee, Orrstown Bank, 22 S Hanover Street, Carlisle, Cumberland County Pennsylvania 17013, by handing to Allison Marshall, Customer Service 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 Darryl Ryan at 110 Fairway Drive, Carlisle, PA 17015. So Answers, f R. eboma?s?Kline, S?eriff By puty Sheriff r; County5jiLO She M Teleosott Inc (FAX) P.0071017 1111212009 14:58 ORRSTOWN BANK IN THE COURT OF COMMON PLEAS CUMBERLAND AMERICAN EXPRESS BANK, FSB Plaintiff VS DARRYL RYAN Defendant(s) TO: ORRSTOWN BANK 22 S HANOVER ST COUNTY, PENNSYLVANIA No. 09 5568 CIVIL ACTION - LAW GARNISHEE'S ANSWERS TO INTERROGATORIES TO GARNISHEE CARLISLE PA 17013-3306 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. 1111212009 14:58 ORRSTOWN BANK (FAX) P.0081017 S. INTERROGATORIES TO GARNISHEE DEFENDANT(S) - DARRYL RYAN 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. Statement Savings xxxxxx782, joint with spouse, Victoria Ryan $452.87 Free checking xxx698, joint with spouse, Victoria Ryan $374.33 Free checking xxxx5285, joint with spouse, Victoria Ryan $184.23 Free checking xxxxx4940, $5,399.96 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. No. 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. No. 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. See joint accounts listed at No. 1. 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? No. 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 Cull name and address. No. (FAQ) P.0091017 1111212009 14:59 ORRSTOWN BANK 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. No. 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). No. 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). Yes. See accounts referenced at No. 1. 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, Yes. Processing Fee of $125.00 and attorney fees of $416.25. 4V7>?6 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: (717) 737-9051 AS TO OBJECTIONS, . i David A. Baric, Esquire O'Brien, Baric & Scherer I.D. # 44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Orrstown Bank VERIFICATION I verify that the statements made in the foregoing Garnishee Orrstown Bank's Answers To Interrogatories Directed To Garnishee are true and correct to the best of my knowledge, information and belief. This verification is signed by David A. Baric, Esquire, Attorney for Plaintiff and is based upon the statements provided by Plaintiff, as well as documents reviewed by the undersigned as attorney for Plaintiff. I undersigned that false statements herein are made subject to penalties of 18 Pa.C.S. §4904, relating to unsworn falsifications to authorities. David A. Baric, Esquire Dated: November 18, 2009 CERTIFICATE OF SERVICE I hereby certify that on November 19, 2009, I, David A. Baric, Esquire of O'Brien, Baric & Scherer, did serve a copy of Garnishee, Orrstown Bank's Answers To Interrogatories Directed To Garnishee, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Amy Doyle, Esquire Mann Bracken, LLP 4660 Trindle Road, Suite 300 Camp Hill, Pennsylvania 17011 David A. Baric, Esquire RLED-OfTCE OF THE FRCT?° W %OTARY 2099 NOV 20 AM 10: 31 C?Jhi f %' flTY ,. ,. .. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff '~~ -~~ ~~~~; ' `~L Jody S Smith r Chief Deputy ~~ .,-~ ~ ~.a 20f O JUG. - I d~~ ~: 2~ a~, . Richard W Stewart '' '" Solicitor c~~~,c~carT..~s~-E~~F~ C(jP~;d~ 1.~ ~ ~1~ American Express Bank, FSB Case Number vs. 2009-5568 Darryl Ryan SHERIFF'S RETURN OF SERVICE 11/12/2009 09:19 AM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on November 12, 2009 at 0919 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant; to wit: Darryl Ryan, in the hands, possession, or control of the within named garnishee, Orrstown Bank, 22 S Hanover Street, Carlisle, Cumberland County Pennsylvania 17013, by handing to Allison Marshall, Customer Service 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 Darryl Ryan at 110 Fairway Drive, Carlisle, PA 17015. 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: $87.50 June 30, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF B on R. Lan .s~ w pd , ~~ ~~ ~o~ ~. ~s ~.s' ;ci CountySuite Sheriff. Teleosoff. Inc.