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Home My WebLink About10-2505THE P, ) F? NOTAPY 2Qlfl APR Is PM 3= 23 OUNTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: ?b - O?SC5 aivI l (er A vs. COREY L ODONNELL 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 08022423 C A Pit EMR O *ga.oo Pd A'"Y CO g4loa833 f-* ayo5go IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No COREY L ODONNELL 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: COREY L ODONNELL 1337 PINE RD CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2500 . 4. Defendant made use of said credit card and has a current balance due of $4025.94 , as of December 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 27.240% per annum on the unpaid balance from December 10, 2009 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit 111" and made a part hereof. 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 , COREY L ODONNELL individually , in the amount of $4025.94 with interest at the rate of 27.240% per annum from December 10, 2009 plus attorneys' fees of $125.00 , and costs. James C. WELTMAN, 436 Sev Pittsb (412) 3 FAX: 12 08022 2A W INBERG & REIS CO., L.P.A. t Avenue, Suite 1400 PA 15219 -7955 338-7130 C A Pit EMR This law firm is a debt collector attempng to collect this debt for our client and any information obtained ill be used for that purpose. vw?rv; V `1% 54,025.94 I $999.00 CARD Payment Due Date DUE IMMEDIATELY 08 SDSN6A01 0003752 COREY ODONNELL 1337 PINE RD CARLISLE PA 17015-7926 Enter Amount Enclosed Below $ Will your payment get to us on time? Pay your bill online and your payment can be made to your account on the same day. Visit Discover,com/payments today. PO BOX 6103 ill rnIll Ill IIIll I Address, e-mail or telephone change? Print change in:spoce CAROL STREAM IL 60197-6103 above, or go to Discover.com. Print your e-mail address to 11111111111111 1111111111111 11111 receive important Account information and special offers. 0000019864521789336010w259400020000099900 Discover More Card Account Summar y Closing Date: December 8, 2009 page 1 of 1 Account number ending in 2500 Payment Due Date January 3 2010 Previous Balance $4,045.94 , Minimum Payment Due $999.00 Payments And Credits Purchases _ 20.00 Credit Limit $3,000.00 Credit Available $0 00 Cash Advances + 0.00 + 0 00 . Cash Credit Limit $1,500.00 Balance Transfers Finance Charges . + 0.00 Cash Credit Available $0.00 New Balance + 0.00 _ $4,025.94 Cashback Bonus® O i pen ng Cashback Bonus Balance $ 0 00 New Cashback Bonus This Period . + 0,00 y..- ----- Cashback BorivsiftAnniversar Cashback Bonus Balance $ 000 Date: April8 ------- ------ How Can We Help You? 1. Visit Discover.com to pay your bdl for no co t i ?tr5 your ChOtCe - 3 WCIyS t0 hel s , v ew your latest Account information, earn and redeem rewards and more 2 C ll 1 8 p Please have your Discover Card available. . a - 00-DISCOVER (347-2683) For fast, easy self-service options or to speak with a Customer Service Account Mana e For TDD (assistance for hearing impaired) see reverse side 3' Write us at Discover Card, PO Box 30943 g r , Salt Lake City, UT 84130 Transactions $0 Fraud Liability Guarantee U Trans. Post se your Discover Card with confidence. Date Date Payments and Credits Dec 4 Dec 4 PAYMENT - THANK YOU $ -20.00 EXHIBIT Finance Charge Summary Averse Dail g y Daily dic a Nominal ANNUAL NTAGE ANNUAL PERCENTAGE Periodic Transaction Fee Balance s tes R RATES RATES FINANCE FINANCE current billing period: 30 days CHARGE?_ CMRGES Purchases $0 Cash Advances $0 0.07463% 0 27.24% V 27.24% $0 $0 The rates that aPPIY to our Ac t 0.08216 % 29.99% V 29.99% $0 $0 y coun are eith er fixed (F) or they may vary (V) as noted above. Important Information. If there is more than one page to this billing statement, see the back o eeach page for additional important information. See your Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account. Lost or stolen cards. Report immediately' Call 1-800-347-2683. Billing Rights Summary. In Case of Errors or Questions About Your Bill: If you think your bill is wrong, or it you need more information about a transaction on your bill, write us on a separate sheet of paper at Discover MoresM; PO Box 30421, Salt lake City, UT 84130-0421, as soon as possible. We must hear from you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information: .Your name and Account number. .The dollar amount of the suspected error. .Describe the error and explain, if you can, why you believe there is an error. If you need more information, describe the item you are unsure about. You do not have to pay any amount in question while we are investigating, but you are still obligated to pay the parts of your bill that are not in question. While we investigate your question, we cannot report you as delinquent or take any action to collect the amount you question. Special Rule for Credit Card Purchases: If you have a problem with the quality of goods of services that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, you may not have to pay the remaining amount due on the goods or services. You have this protection only when the purchase price was more than $ 5Y0 and the purchase was made in your home state or within 100 miles of your mailing address. (If we own or operate the merchant, or if we mailed you the advertisement for the goods or services, all purchases are covered regardless of the amount or location of purchase.) Payments. Send only your payment and the top portion of this statement in the envelope provided. Do not send cash. By sending your check as described above, you authorize us to use information on your check to make an electronic fund transfer from your account at the financial institution indicated on your check or to process the payment as a check transaction. If payment is processed as an electronic fund transfer, the transfer will be for the amount of the check. When we use information from your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your financial institution. The processing of your payment may be delayed if you send cash, correspondence or other items with your payyment, if you send the payment to anv other address or if you use an envelope other than the one provided. Payments received on or after 1 PF1 Monday hro ggh fnda on a weekend or bank holiday will'be posted to your Account as of the next-business day It you have mrsplaced youi envelope. send your Oymfent to Discover Bank, PO Box 6103, Carol Stream, IL 60197.6103 Please allow 7-10 days for delivery. If your payment is returned unpaid, we reserve the right to resubmit it as an electronic debit. You can ay your minimum pa ment or a greater amount over the telephone, and you can set up automatic payments. Call us at 1.800-347-2663. You will need this statement and your bank account information. You must ensure that sufficient funds are available in your bank account, and all transactions must comply with U.S. law. You will be asked to provide the first 5 digits of your account statement zip code. By entering those numbers as you electronic signature, you will be agreeing to this authorization to allow us and your bank to deduct each ray ment from your bank account, and to initiate debit or credit entries to your bank account, as applicable, to correct an error in the processing of such payment You must tell us the amount of each payment, or you can select an amount such as the Minimum Payment Due or the New Balance on each statement. You can cancel a payment, however we must receive notice at least three business days in advance of the scheduled payment. You may notify us by phone at 1.800.347.2683 or by mail at address listed in the previous paragraph. If your payments may vary in amount, we will, tell you on each monthly statement when your payment will be made and how much it will be. Your Automatic payment amount may be less than indicated on the monthly statement based on credits or payments applied during the billing cycle. Credit Reporting. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report We normally report the status and payment history of your Account to credit reporting a encies each month. If you believe that our report is inaccurate or incomplete, please write us at the following address: Discover MoresM Card, P8 Box 15916, Wilmington DE 19850-5316. Please include your name, address, home telephone number and Account number. PERIODIC FINANCE CHARGES. Periodic Finance Charges are imposed on all transactions from the date the transaction is posted to until the date you pay your entire New Balance by making Fa yments or receiving credits. However, we will provide the followin "graceuperiod f you paid the New Balance on your previous billing statemenby the Payment Due Date shown on that statement, and you YY following g the Payment Due Date on this statement, we will not impose Periodic Finance Charges on new purchases, that is, urchasesafirst a pea lin Balance is statement. Otherwise, you will receive a billing statement next month that includes Periodic Finance Charges on those new purchases.Therefis no grace period on balance transfers or cash advances We sort your transactions into groups of purchases, cash advances, and balance transfers and then further sort the transactions within each group by their Annual Percentage Rate. For example purchases subject to a promotional rate and purchases subject to a standard rate would be separate groups. We refer to these groups as transaction Cate ones. Al the end of each billing period we compute balances and Periodic Finance Charges for each day of the billingg period or each transaction category We use the following equation to compute Periodic Finance Charges for each transaction category. Average DaiTy Balance x number of days in the billing period x Daily Periodic Rate (See (he finance charge summary on your statement for these amounts! Then we add up the Periodic Finance Charges for each transaction category to get the total Periodic Finance Charges for your Account. The Average Daily Balance is shown as zero if, because of the grace period, no Periodic Finance Charges apply to the balance in a transaction category. gg )) ChargestThiswmeaans ifvyougdid nlot pay the(iNewdBalanca shownconnlhe billing tatementiyou receved dunngn thecprevous billingefpeririodFby the that asywell asDnewapurcha es that fi sttappearnon the cur ent biling statemientcunlessfwe already imposed PertodrciFsinanceaCharges on theipurchases 6 your previous billing statement We compute the Average Daily Balance for each transaction categoryy by adding up all the daily balances in a billing period for a transaction Cate ory and dividing the total 6 the number of days in the billing cycle. Re compute the daily balance for each transaction category on each day bylirst adding the Tollowin to the previous day's daily balance: transactions made that da , fees charged that day and Periodic Finance Charges accrued on the previous day's saily balance; and by then subtracting any credits and payments that are applied against the balance of the transaction category on that dar. In calculating the daily balance for the previous billing period, we consider the "pprevrous day's daily balance" to have been zero on the first day o the billing period. If a transaction is posted to your Account after the close of the billing period in which it occurs, we will treat the transaction as having occurred on the first day of the billing period in which it is posted to your Account All fees charged to your Account are added to the standard purchase transaction category with the exception of Cash Advance Transaction Fee areaadded togthe applicable bale ceotransfertransactionhCategory Whenathe speeiaiffate expirels, we movefrtyhe unpaidtrbalance oina the balanceetrar offer terminated under the Default Rate Planewe lea eetheau paid balance offine balance transferoandatheoBalancewTransferlTransacUOn Fee finance Charges in the applicable transaction category until the special rate would have expired. For TOD (Telecommunications Device for the Deaf) assistance, please call 1-900-347-7449. 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# 8022423 Corey L. Odonnell '601 r'. ":, ? , "? 40 - ~' .. ~ ,h, -+-Er.C ~~ ~'.I''"i tvC ZOiQ .lE~`~i 2$ A~;12~ 4 CUF,~~.. ~~~t.~~ ;1:~1~~aTY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 10-2505 CIVIL TERM vs. COREY L ODONNELL PRAECIPE FOR DEFAULT JUDGMENT Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warn-brodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 08022423 C A Pit DIP Judgment Amount $4708.97 $~y,vo P~~ ~/~ 3 SO 31 .~~~3~y N~t~ ,~. 4, i~~ DISCOVER BANK Plaintiff vs. COREY L ODONNELL IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 10-2505 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order of Judgment was entered against you on ~ ao~6 (xx) Assumpsit Judgment in the amount of $4708.97 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 Proth no ry ,_ A By: COREY L ODONNELL 1337 PINE RD CARLISLE, PA 17015 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 DISCOVER BANK Plaintiff vs. COREY L ODONNELL TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 10-2505 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant COREY L ODONNELL above named, in the default of an Answer, in the amount of $4708.97 computed as follows: Amount claimed in Complaint $4025.94 Less payments / adjustments made $0.00 Interest on the remaining principal balance of $4025.94 from December 10, 2009 to June 14, 2010 ~ the interest rate of 27.2400 per annum $558.03 Attorney's fees $125.00 TOTAL $4708.97 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: James C. ,42524 08022423 Q' A fit DIP Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh P 15219 And that the last known address of the D~dant is COREY L ODONNELL 1337 PINE RD CARLISLE, PA 17015 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. COREY L ODONNELL Defendant Case No. 10-2505 CIVIL TERM IMPORTANT NOTICE TO: COREY L ODONNELL 1337 PINE RD CARLISLE, PA 17015 Date of 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 TMIS 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, TH15 OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMA~ERG & REtS CO., L.P.A. 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 8022423 A PiT T4L IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-2505 CIVIL TERM COREY L ODONNELL NON-MILITARY AFFIDAVIT The undersigned, who first 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 COREY L ODONNELL is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMSC), which states that the DMDC does not possess any information indicating the individual status. COREY L ODONNELL 1337 PINE RD CARLISLE, PA 17015 is not in the military service. Further Affiant sayeth naught. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jun-23-2010 08:01:37 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency ODONNELL COREY L Based on the information you have furnished, the DMDC does not possess 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.htm1. 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 6!23!2010 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:NAI4BODTNL https://www.dmdc.osd.mil/appj/scra/popreport.do 6/23/2010 4 ? - a IN THE COi iRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION D[SCO"5'ER BANK Plaintiff vs. Civil Action No. 10-2505 CIVIL TERM COREY L ODONNELL _x'331 WOA ?OQ? l:ar?lS?ft n14 l S Defendant(s) MEMBERS 1ST FCLJ Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION TO "THE PROTHOt'OT/`.RY: Kindly issue a Writ of Execution in the above matter... 1. direc,ed to the Sheriff of CUMBERLAND County: against COREY L ODONNELL , Defendant ;. aga,>>st MEMBERS 1 ST FCU,, , Garnishee i. Judg,ner,., Amount Les.: Pay,-,tents/credits received Interest Cots SUBTOTAL: Costs (to `)e added by Prothonotary): QM? sa4.sb TrA all? 33.E ? x•60 d J f? w ?Iblo.yo a ?r s3 C $ $4,708.97 $ $0.00 $ $332.86 $ $5,041.83 „? ca r rn CD -za CD e r. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, rsquire 0- WELTMAN, PA I.D. #4743 7 WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 ?oil WWR No. 8022423 C CxX 'rcaw d IN THE, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOV R BANK Plaintiff vs. COREY L ODONNELL Defendant(s i MEMBEkS I ST F("J (jarnishee(s) No. 10-2505 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACIIMENT ONLY) 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. 0"022423 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2505 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From COREY L. O'DONNELL, 1337 Pine Road, Carlisle, PA 17015 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FCU, 1711 SPRING ROAD, 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 $4,708.97 Interest $332.86 Atty's Comm % Atty Paid $166.40 Plaintiff Paid Date: SEPTEMBER 16, 2011 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff , a§1i" c t c u m b,E./,140# !,'?^ t ? ?hC 4n;FF t L). Jody S Smith Chief Deputy Richard W Stewart Solicitor 2-Ui I S P ^E? cUIMSEKAK' Discover Bank vs. Corey L. O'Donnell Case Number 2010-2505 SHERIFF'S RETURN OF SERVICE 09/22/2011 10:41 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, Members 1 st FCU at 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Melinda Williams, Members Service Rep., 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 September 23, 2011 to Corey O'Donnel at 1711 Spring Road, Carlisle, PA 17015. SO ANSWERS, September 23, 2011 RON R ANDERSON, SHERIFF 'z, Zz"4, - i11PW- Pn, Deputy ri Gow-,,Suito Sheriff. Te eo. oft. irc,. ;r; THE COl RT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C)VIL DIVISION D'SCOVER FsANK Pl:1 i!it:ff vs. ;vii woion No. i 0-2505 ?; -- ? COREY I, ODONN?FLI. ? ? Defendant MEMBERS 1ST FCl =fi=g -- _ ?RAECIPE FOR JUDGMENT AGALNST GARNISHEE i:inc'ly enter Judgmcnt a??ainst the Ciarnisnee, MEIABERS I ST FCIJ, in the amount of $1939.20, which is ?%,ss than the rirnoun, Deft ndant owes to Pialptiff az:d NN hich amount Garnishee has admitted owing to the Defendant, ii-, answers V) ??iterro rao? gas. W1:. iviAN, WEINBERG & REIS CO., L.P.A. By --- -- Ma`thew D. Urban ':squire PA I.DX90963 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers 134.1g. 436 Seventh Av;°nue Pittsbui,;h. PA 152,19 (412) 434-7955 W XR#80212423 I slcreby certify that the ad.ress of,.hQ Plair.ciff is: c'o ,Veltman,'.Vein`,_rg 8: Reis Co.. '-.P.A., ? 400 K-npe-s T3uildin, , 436 7`f' ,avenue, Pittsburgh, PA 15219 nd that.Fe ',,.;t knc,wn a?,,,tress of r .a r , ..;s',.ee is IT i c"RING RD, CARLISLE, PA 17013 011& to qj ?crke? ? FILED-OFFICE Recom y4q_ 1 HE Pk;?7HOnow SEP 2 3 2011 21111 SEP 2 ? t t0: 51 CUMBERLAND COUNT` PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Vs. Civil Action No. 10-2505 CIVIL TERM COREY L ODONNE.LL Defendant(s) MEMBERS 1 ST FCC. Garn=shee(s) INTERROGATORIES IN ATTACHMENT 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. 8022423 IN THE, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 10-2505 CIVIL TERM COREY L ODONNELL Defendant(s ) MEMBERS I ST FCU Garnishee(s) TO: ;r4 MBi:RS ! ST -CU, 1711 SPRING RD, CARLISLE, PA 17013 Ri:: ."COREY L ,)DONNELL , 1337 PINE RD, CARLISLE, PA 17015 Suggested Reference No.: XXX-XX-3071 XXX-XX- IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upoi, 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 tl?t- Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. WWR No. 8022423 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 lie 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)'? TI-1 1 If the answer to Interrogatory l 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 i lities. x??IV I I????. 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself :,nd one or more other persons any property of any nature owned solely or in part by the defendant. nd 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? no 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? nb 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? n0 b. 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'? 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. WWR No. 8022423 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. hD If the answer to Interrogator, 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. t2k 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. 11 I I 11. If thy: response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are nol 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 lc_' 12. If the response to Interrogatory I 1 is in the affirmative, state the amount of non-exempt funds on deposit in the account. & wwc" WU WELTMAN, WEINBERG & REIS CO., L.P.A. By: !n/^ 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. 8022423 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGN URE IN THE C'"iURT OF COi" IOT-i PLEAS CUNW RLAND (:O.)NTY, PENNSYLVANIA CIVIL hI'.?ISl?:iv DISCOVER BANK Plaintiff' vs. Civil Action No 10-2505 COREY L ODONNELL Defendant. MEMBERS ! ST FCC J 6arnistiee NOTICE. OF JUDGMENT OR ORDER TO: ( ) Plaintiff ( j Defendant (,, c) Garnishee Y•-:;: ,jre hk,rebv Ito ified that the fo !1, .wing Order or ; i.idgment w; s entered against yo'.i o.1 /D (xx) Assu ipsit .; udgment in the amount of $1939.20 plus costs. ( ) Trespass Judgment in the amount of $_, p'us costs. ( ) If not satisfied within sixty (60) days, your motor vehicle- operator's license and/or registration will be suspended by the Department of i ransportation, Bureau of Traffic Safety, Harrisburg. PA. (xx) Entry of Judgment of ( ) Court Order Ncn-Pros Confession D,. Iault i VCidict A rbitrat: )n Award 'ruthc notary By: P ONO Y DEPUTY) MEMBERS 1ST FCC 171 i SPRING RD, C.,:R1.ISLE, PA 17013 F?' D 0 1 Ji r E E P OTHO 'OTAk'; 2012 FEB -2 AM 11: 40- CUMBERLAND COUNTY PENNSYLVANIA FEB $ I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. COREY L ODONNELL Defendant(s) Civil Action No. 10-2505 CIVIL TERM ? i<s INTERROGATORIES IN ATTACHMENT WOODFOREST NATIONAL BANK MEMBERS 1 ST FCU 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. 8022423 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. COREY L ODONNELL Defendant(s) WOODFOREST NATIONAL BANK MEMBERS 1 ST FCU Garnishee(s) Civil Action No. 10-2505 CIVIL TERM TO: WOODFOREST NATIONAL BANK, 60 NOBLE BLVD, CARLISLE, PA 17013 MEMBERS 1 ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 RE: COREY L ODONNELL, 474 E KING ST, SHIPPENSBURG, PA 17257 Suggested Reference No.: XXX-XX-3071 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. WWR No. 8022423 INTERROGATORIES IN ATTACHMENT I . 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)? i ( 0 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. 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 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? NO 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? NO 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? N6 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 O 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. Nd WWR No. 8022423 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. * S 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. NJA 10. If the answer to Interrogatory I 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 0 H. 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? ,?j lA 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. ,U 1)4 WELTMAN, WEINBERG & REIS CO., L.P.A. By: 1 Williafn T* Molczan, E 06ire PA I.D. 447437 ?d WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8022423 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 Kelly L Hall (Name) Deposit Operations Analyst of Members 1 st 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. (SI AT RE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r Sheriff Jody S Smith Chief Deputy M: Richard W Stewart elft Solicitor OFFICE OF . RwGP.fFF PE? C !t i i ?. Discover Bank Case Number vs. Corey L. O'Donnell 2010-2505 SHERIFF'S RETURN OF SERVICE 02/01/2012 09:56 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 1, 2012 at 0958 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Corey L. O'Donnell, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Ashley Mislyan, 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. 02/01/2012 12:53 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 1, 2012 at 1255 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Corey L. O'Donnell, in the hands, possession, or control of the within named garnishee, Woodforest National Bank, 60 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Kevin Duffy, Retail Banker, 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 him. The writ of execution and notice to defendant was mailed on February 2, 2012 to Corey L. O'Donnell, 474 E King Street, Shippensburg, PA 17257. SO ANSWERS, February 02, 2012 RON R ANDERSON, SHERIFF r'illiam Cline, Deputy (c; CCUnySURG Sheriff. Te'easot I c. ??scover dank VS . Corey L . Odonnel I CC6 tac'ce> INTERROGATORIES IN ATTACHMENT 16-9-150S I . 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)? \/Q c I 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 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. one. ch e clef ng accoon-fi w I an o ve.rd ro-w n bcd-anc.-er 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. 1\1 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? C 4. At the time you were served or at any subsequent time did you hold as fiduciagMpy Wppe -in which the defendant had an interest? -. M rn 70 0V l ?1 C) ED -0 ?.' 5. At any time before or after you were served, did the defendant transfer or deliv?cuy pmer?fc' you or to any person or place pursuant to your directions or consent and if so what was the consider4n 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? Nb 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 FS 01 WWR No. 8022423 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. yes Ch-I- c k1 +n CCbU Imo' 13q'Z325? to w i+?) an 6verd yawn bal n ce. 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. on or abou+ a) o t I la 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings acc„ount, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. No hold ad u e- to 1 a b?or 's exemption 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? No 12. If the response to Interrogatory I I is in the affirmative, state the amount of non-exempt funds on deposit in the account. IV ) k WELTMAN, WEINBERG & REIS CO., L.P.A. By: William "T: Molczan, Es ire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 FEB 0S, WWR No. 8022423 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 SS 1 Ca Black (Name) lssi star it yi cc r- ?' Wooc)fore st l tlon? "a n shee herein, (Title) (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. q?)YXIA- (SIGNATURE) woodforest National Bank Legal Dept Bryan Abraham Jessica Black Cedrick Frazier 25231 Grogan Mill Rd., Suite 100 The Woodlands, TX 77380 832-375-2898 Phone 832-375-3071 Fax WWR No. 8022423 FEB 0 3 2012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Anderson t Q`*tttlt, 01 p: atarrp,r?,f / s ??? J 4trT ?`i0 yr??? fi{;r°? -...4 .?y S Smith ,hief Deputy 912 FEB 22 PM 3. 00 Richard W Stewart CUMBERLAiK COUN Solicitor PENNS YLVA M A Discover Bank Case Number vs. 2010-2505 Corey L. O'Donnell SHERIFF'S RETURN OF SERVICE 02/01/2012 09:56 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 1, 2012 at 0958 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Corey L. O'Donnell, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Ashley Mislyan, 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. 02/01/2012 12:53 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 1, 2012 at 1255 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Corey L. O'Donnell, in the hands, possession, or control of the within named garnishee, Woodforest National Bank, 60 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Kevin Duffy, Retail Banker, 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 him. The writ of execution and notice to defendant was mailed on February 2, 2012 to Corey L. O'Donnell, 474 E King Street, Shippensburg, PA 17257. 02/22/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as STAYED per request of plaintiffs attorney. SHERIFF COST: $143.97 SO ANSWERS, February 22, 2012 RON R ANDERSON, SHERIFF WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 8022423 DISCOVER BANK vs. COREY L ODONNELL and Attorney for Plaintiff(s) c.) -j M rn w MrF= rv ter, CD - C=? -- o Cumberland County Court of Common Pleas NO. 10-2505 CIVIL TERM WOODFOREST NATIONAL BANK AND MEMBERS 1 ST FCU Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), WOODFOREST NATIONAL BANK AND MEMBERS 1 ST FCU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to and Before me NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA i Notarial Seal Wendy L. Gault, Notary Public city of Pittsburgh, Allegheny County LL My Commission Expires July 15, 2014 Member, Pennsvlvanla Association of Notarle<_ 0.?} $ q. SO pd cud, of February, 2012 James armbrodt, Esquire Attornfor Plaintiff