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Home My WebLink About09-83551 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 49 , (?- 3 vs. CHRIS R COOK COMPLAINT IN CIVIL ACTION 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 07884764 C A Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No CHRIS R COOK 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, DISCOVER BANK is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 2. Defendant is adult individual(s) residing at the address listed below: CHRIS R COOK 29 JOHNS DR ENOLA, PA 17025 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4415 . 4. Defendant made use of said credit card and has a current balance due of $3992.61 , as of August 10, 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 29.9909.- per annum on the unpaid balance from August 10, 2009 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit 11111 and made a part hereof. v 7. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 8. Plaintiff avers that such attorneys' fees will amount to $125.00 . 9. 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 , CHRIS R COOK individually , in the amount of $3992.61 with interest at the rate of 29.99001 per annum from August 10, 2009 plus attorneys' fees of $125.00 , and costs. James a ro t,42524 WELT EINBERG & REIS CO., L.P.A. 436 Se h Avenue, Suite 1400 Pitts , PA 15219 (412) 4)3;-7955 FAX: 38-7130 0788 7 A Pit KMJ This law firm is a debt collector attem ng to collect this debt for our client and any information obtained Will be used for that purpose. New Balance DISCOVER Minimum Payment Due ? S0.00 $889.00 CARD Payment Due Date Soptember 25, 2009 t 31 SDSN6A010004109 CHRIS COOK j 29 JOHNS DR ENOLA PA 17025-2694 Account Number ending in 4415 Enter Amount Enclosed Below ) Will your payment got to us on time? Pay your bill online and your payment can be made to your account on the some day. Visit Discover.conr/payments today. PO BOX 6103 Illurllnurllnnllr?lnl CAROL STREAM IL 60197-6103 Address, e-mail or telephone change? Print change in space nul 1))Luu11111i... MAIM S ..? above, or go to Discover.com. Print your e-mail ress to receive important Account information and special offers. 000001986458030531285000000000000000088900 Discover More Card Account Summary Closing Date: August 31, 2009 page , of 1 Account number ending in 4415 Previous Balance $3,992.61 61 992 3 Payment Due Dab September 25, 2009 Payments And Credits . , 00 + 0 Minimum Payment Due $889.00 Purchases Cash Advances . + 0.00 Credit Limit $4,000.00 00 $0 Balance Transfers + 0.00 Credit Available Cash Credit Limit . $1,000.00 Fnarlcs Charges + 0.00 $0 00 Cash Credit Available $0.00 New Balance . Cashback Bonus' Opening Cashback Bonus Balance $ OW New Cashback Bonus This Period + 0.00 Cashbook Bonus Balance $ 0.00 Cashback Bonus* Anniversary Dab: November 5 1. Visit Discover.com to pay your bill for no cost, view r How Can We Help You? latest Account information, earn and redeem rewords and more It's your choice - 3 ways to help 2. Call 1.800-DISCOVER (347-2683) for fast, easy self-service options or to speak with a Customer Service Account Manager Please have your Discover Card available. 3. Write us of Discover Card, PO Box 30943, For TDD (assistance for hearing impaired) see reverse side Sal Lake City, UT 84130 Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans. Post Dale Dale Payments and Credits Aug 31 Aug 31 INTERNAL CHARGE-OFF $ -3,992.61 Finance Charge Summary Nominal Transaction Average Dail Daily Periodic ANNUAL PERCENTAGE ANNUAL PERCENTAGE Periodic FINANCE Fee FINANCE R%5 y Balances Rates - RATES RATES CHARGES L CHA current billing period: 26 days Purchases $0 0.08216% 08216% 29.99% F 99% F 29 29.99% 29.99% $0 $0 $0 $0 Cash Advances $0 0. . The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. Impertarrt Intes"wiloa. If there is more than one page to this billing statement see the back of each page for additional important information. Ea yar Cardrrsrnber Agraamait. Your Cardmember Agreement contains all the terms of your Account N E 2 Report immediately! Last or la cardit. Call 14100-34 1113. 7-- z g? you you bI ?t a you e? p rdr n of Errors or Ouestions U our wdl to o whlnicch1 he a or or tv.. ?T Kapp a-information ao?ephone ? 8 o a Se sheet r p your 11, ent t r a n ' A o rt t bi ou i sent f l a E P? $ 'a r m a n? f rg ye uarj 60 day?S o o s foil s na dd Accou num i^i m L :s n a air namE • he dollar amount of the $usReeted error em you are unsure i t • dbe the error and expial If you can, why you believe there is an error. If you need more Information, describe the N y o u V?OODUdO n have to any "amount In question while we a n oatlno. lo`t loo are still o gora to eav the pa margin udiuestion. are not in I to WhHe we InVesugare you question, we cannot report you d§ deirn u t or take an acu collect th! a yo q estion N . qu Epegal RrEe ?? Crd fh/tlases: It have aaWem with the quality of goods or services that you Durchased with a credit card, and a nt due on the spools or services. amou in fa to aorroct the pmyoo??em with a merchant you may not eve to paw the remafrRn state or with m miles v0u ^ave trled e ice was mere than S5o and the purchase Was m i M a t W n this oR only what tohoeerWaurcnase pr or o urchase^)(ercnant or if we maKed you the advertisement for the s services, all purchases ses are covered your IIInQ ms. (li 6f Uo ? ? me e n p or to ca t p Send ?IoUwvr enl and >ih t po ?ortion of this staeement the veld p{ovid . e or re r send cash sending vonuancha k rdaSc i0a0 abpye, autnonze us to use norm on on r chec W ma an c and erns s m your rat at trio n I fund transfer, pthe f ndict on yvoouur check or to s the?tt as a check trans on. If t Is processed as d raps a r f tion electronic a n I l .rr your flna o ac r check b k Y cial trans er wl I bE or Neacacouonl ai somoen as hme day we tnr ve Yaurf L a^e you vn i not receive u f rom yo withdrawn Ins}itUUOn. r sing TadlltV Aloe her d If you send each, dence or other Items with st received on or after 11 r ent K uacedtl ihoUe en The processinp Of Vour ent m be delaye an othe? S If an en ot than th INOVVOI p av you thi gh ri?or on a endeor4Wnak dirlRa?nlwll fx?p to mtolL 6019 -6103. s leassee alleoww 7-1t?nday sfdr delivery. tIf yourppayme is rctuem m ^ us by one at 1-300-341-Zee] a man a me •wwaa ..? be less than Wu on each mdn I statement when yyopuur ent will be made and how much will be. Vou autom c en amou may indicated on the mdhthly statement ba3ed redits or payments applied during the billing cycle. Reaarlflr VYe m information about vouraa?cccoeupnotrtto credit bureaus. Late ents, missed paymunt ents, or other odoerffarlulltsaaonnvour mpmrlthntl{riva?y ppea-leaclmeadtnWr crWitiroporturate or inwrtt?le[4,wesvte usdat the folla?ignaddness? DiLSCb Card, PD Bdx 15316, Wllcmefngton DE t9A50-5316. Rease Inc ude ur nis n ame, acacddress, home t ePn a num rand Account number. Grace parkd awr p?Afaea (fit Iaaa12E ?. We begin to impose Periodic Finance Charges on all transactions from the Transaction Date to the transacUOn as shopwendonn your WIIin9 stat?dm??nai, unless a trensac on is posted W you A?ursM after the close of the thin Wrlat in which it ow0curs, in which case we f m Im me odic k Finance C on that ate nsaction rom 4 the a king payments err rdocoas?vin cfbditS. AHoccouYnett YK?hvocuonU?ndu two N? ance on yournucreviCOUS Iin ?staatery nt Due Date sfaonvma onthat tb mn Statement and vougva the Npuew BNancE by the pment ue Date on, Wof current Iin statement ue e -grace II np?imbose??o 9roace penaz on ?la^rxptiansteissorheashs ed ancFS first appears Sg on the current biding statement call this the m or There 8 FyFygrrce Charge. We will charge you a minimum FINANCE CHARGE of =.50 for any billing period in which Periodic Finance Charges of ?rl f.50 would otherwise be Imposes beo a Year u yo I6 rs n the statement f pour Account haswhen n u lf1 isIt will b biela?nnualnlx Idinnoitnrefn dableau^lasrsyaorfyi hotiry usrNal WUtwishoncl The your Account the } ?Fpee. I within 3D bays of the mailing or delivery date of the statement on which the fee is billed. You will receive this refund even It you use your Card during that period. pp?a Clraroos W1, sort your transactions into roues of rchases, cash advances and balance transfers and then further sort the trap nasdacUOls within OpacelS T fir thetprsAnnual Percentage ?ate. 'FOr example, Purchassees subfect to a promotional rate anrdi purchases spuu`t?eb?alances saabitl PorrglodiceFiw snipe Chsa s?fgg h Aa e0, lat the Mllfngep Oddpfoi eacons?acnsactiontedategoryAlWe se edthe idlhawbifr gn6q?oeation to npute Periodic eac FinanceCharges to each ansaction category (Average Daily Balance) times (days in billing period) times (Daily Periodic Rate). ((4ou maYY refer to the finance charge summary on your billlna statement for these amounts.) Then we add uGG the Periodic Finance Charges for each transactlbn :ategor?to set the total Periodic Finance Charaef for Your Accooutnntt Thhe Average Daily Balance i5 shown as zero if, because d the grace period, no Pert . cFInalSce Charges a ?(?orthecb l?n?a?Illlhhhh? annirrtmethoond of cflcUlaUna the balanceupon which we impose Perfodic Finance -11 Vansjctfn wf?f 6e to the dai balance as or me nrsi as ui u c uim y yo. ihei subtwd n credi oj-- 0 f and cries that arf led and. Perlodlc Finanx Charges axru on the previous der s der 1V balance; a(G pv daily a a pavm amri the balance d the nsactlon ca on that days In calculatlna ,the balance for the flat the pilling p the revleus days dotty balance" tp have beer?ur balance for each tiansaAtion wteooryteoonortvhe last day ofdEavvp?tufur?oroefvfpus dldlivnaaeriod, per we iiod. der M1 All fees clfarged io your Aaount are to the standaM o hanseon caoKCa ahd Balance Transfer TransactlonAFee Ficenance CharoesFwanich t . Finance whlclt are atlded to the and cable cash advan tra tegoN p Charges are added tgZhe 00 de balance trans transaction When the soeclfl rate expires, we move the unpaid balance of the balance err to the staAtlard purchase Vansaction categorya However, if the special rate has On Fee Finance transfer and the Transfer TlansacU peen terminated e suit Rate tion, we leave the u gold baluntil the se bixl rateIOrhave expfEraedr rice Transfer Transaction Fee '. Finance Chars in the applicable balance transf er tronsacUon eg ere call 1 800c 47-7449. c•. rep rterecrmaadcatlaa Device for Ure DeaQ aselstanee, pie VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he is James Ball (Name) Team Lead of DFS Services LLC , plaintiff herein, that (Title) (Company) he 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 knowledge, information and belief. WWR# 7884764 Chris R. Cook '6011002962314415 n TI 1?r'')'ir?fSY 2099 D_7C -J AIal I I : "6 1 g??r , 5-6) pd 4,iY e,t tr '1363 72 - ? 6qL E O ?t`H PROTM NO TARP 2011 JON 14 AM 11: 23 CUMBERLAND COUNTY PENNSYLVVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 09-8355 CHRIS R COOK Defendant(s) 14 YS INTE GATORIES IN ATTACHMENT MEMBERS I ST FCU PNC BANK SUSQUtHANNA BANK Garnishee(s) FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 7884764 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Vs. CHRIS R COOK Defendant(s) MEMBERS I ST FCU PNC BANK SUSQUEHANNA BANK Garnishee(s) Civil Action No. 09-8355 TO: MEMBERS 1 ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 PNC BANK, 105 NOBLE BLVD, CARLISLE, PA 17013 SUSQUEHANNA BANKI 196 WALNUT BOTTON RDCARLISLE, PA 17013 .?,E: CHRIS R COOK, 29 JOHNS DR, ENOLA, PA 17025 _-_- Suggested Reference No.: XXX-XX-7913 XXX-XX- IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. 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. W WR No. 7884764 INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of deposit)? no I 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 Ick. 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. n o 3.- At the time you were served or at any subsequent tirl*ldid-you hold legal`-title to any property b any nature owned solely or part by the defendant or in which defendant held or claimed any interest? n 0 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? n0 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? no 6. At any 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? n o 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. no WWR No. 7884764 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. 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. ,^ ick-, 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. n 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? r) l6?'_ 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. n I a U wa? WELTMAN, WEINBERG & REIS CO., L.P.A. By: - William T. Molczan, Esquir PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 7884764 A MEMBERS 1St FEDERAL CREDIT UNION June 10, 2011 Christopher R. Cook 29 Johns Drvie Enola, PA 17025 Account Number: XXX979 Name on Account: Savings: Checking: Payroll: Dish Network Christopher R. Cook Hilary L. Cook (Joint) $55.02 -5.00 (Membership Fee) $50.02 -50.00 (Processing Fee) $ 0.02 $1,002.00 $300.00 Statutory Exemption was not taken out. dlju;'? - Tania S. Young/ Deposit Operations A alyst. 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org VERIFICATION The undersigned does hereby verify subject to the penalties of 18 AA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is Ta n i a 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. (SIGNAT E) Chris c2. 00L ANSWERS TO INTERROGATORIES IN ATTACHMENT At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of deposit)? No. 1 a. 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 woe 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 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. 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 in which defendant held or claimed any interest? No. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? No. 5. At any time before or after you were served, did the defendant transfer or delivery 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. r CD r v c-) a' >c O z -- r" =o o 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant 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 amount of funds in each account, 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 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 Pa.C.S. § 8123? If so, identify each account. No. 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 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. 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 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. N/A VERIFICATION I, Catherine M. Bush, verify that the facts set forth in these Garnishee's Answers to Interrogatories are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. § 4904) related to unsworn falsification to authorities. Dated: June 13, 2011 Catherine M. Bush, Assistant Secretary and Legal Counsel Susquehanna Bank 26 North Cedar Street Lititz, Pa 17543 (717) 625-6273 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff c_) r-j Jody S Smith = ??,jr ?t t rr,nt rr???r? a Chief Deput y, M _ Fri ` Richard W Stewart - ^' Solicitor a Discover Bank r'j vs. I Case Number Chris R. Cook 2009-8355 SHERIFF'S RETURN OF SERVICE 06/09/2011 01:13 PM - Stephen Bender, 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, Susquehanna Bank, 1196 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to JULIE SWANGER BRANCH MANAGER, personally three true and attested copies of the Writ of Execution and made the contents there of known to her, 06/10/2011 02:58 PM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2011 at 1458 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Chris R. Cook, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Rochelle White, 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. 06/10/2011 02:40 PM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2011 at 1440 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Chris R. Cook, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Lauralee Fetter, 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 June 15, 2011 to Chris R. Cook at 29 Johns Drive, Enola, PA 17025. June 15, 2011 5: ?Z? z ! ' z - - -, tephen Bender, Deputy SO ANSWERS, RON R ANDERSON, SHERIFF Ti ack, Deputy ;Ci Co'MtYSulto ShenPf. Teiawc;tf. fi;,; WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Matthew D. Urban, Esquire Attorney for Plaintiff(s) I.D. No.90963 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 7884764 DISCOVER BANK CUMBERLAND County .. Court of Common Pleas rte , vs. CHRIS R COOK NO. 09-8355 sC r-' and Cd ='c7 ? ate` MEMBERS I ST FCU zo x, C -- CDC-, r:- PNC BANK -?-i rtia A SUSQUEHANNA BANK ` Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), MEMBERS 1 ST FCU PNC BANK SUSQUEHANNA BANK, only. Sworn to and subscribed Before me the day of JUNE, 2011 NOTARY PUBLIC WELTMAN, WEINBERG & REIS CO., L.P.A. By Matthew D. Urban, Esquire Attorney for Plaintiff COMMON M OF Nobrim s..l ANL4 Wendy L. Gault, Notary p;: City Allegheny h, 12014 Of Nob ber. , a('?.'A- %'R.00 a' Ck-47 01 oC) o-ory X?,* aJL 1 sb WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-8355 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From CHRIS R. COOK AT 29 JOHNS DRIVE. ENOLA, PA 17025 (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 MEMBERS 1sT FCU AT 1711 SPRING RD. CARLISLE, PA 17025, PNC BANK AT 105 NOBLE BLVD. CARLISLE, PA 17013, SUSQUEHANNA BANK AT 1196 WALNUT BOTTOM RD. CARLISLE, PA 17013 GARNISHEE(S) as follows: 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 $4551.54 Interest $335.94 Atty's Comm % Atty Paid $161.00 Other Costs Plaintiff Paid Date: 5/31111 (Seal) REQUESTING PARTY: L.L. $.50 Due Prothy $2.011 David uell, Proth otary By: Deputy Name WILLIAM T. MOLCZAN, 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. 47437 TRUE COPY FROM RECORD hand in Testimony whereof, i here unto set Pa. rft ?. id Court Carfislev 20 of ??prpttwnotary day . ? f' Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. Chris R. Cook SHERIFF'S OFFICE OF CUMBERLAND COUNTY IL E 1-1 - JAN 25 A 09: r ! 09F E - PEK'NSYLVf041A. Case Number 2009-8355 SHERIFF'S RETURN OF SERVICE 06/09/2011 01:13 PM - Stephen Bender, 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, Susquehanna Bank, 1196 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to JULIE SWANGER BRANCH MANAGER, personally three true and attested copies of the Writ of Execution and made the contents there of known to her. 06/10/2011 02:58 PM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2011 at 1458 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Chris R. Cook, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Rochelle White, 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. 06/10/2011 02:40 PM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2011 at 1440 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Chris R. Cook, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Lauralee Fetter, 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 June 15, 2011 to Chris R. Cook at 29 Johns Drive, Enola, PA 17025. 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: $1915.94 SO ANSWERS, January 23, 2012 RON R ANDERSON, SHERIFF v , , 7try33