HomeMy WebLinkAbout10-3397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No: lp - 33q'? CIV1?-rff-p"
vs.
COMPLAINT IN CIVIL ACTION
GAIL FRANKO
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
08251335 C A Pit EMR
Qc-
fq,A.oo Pio Am
eIGfl X18831
?,?' a4ay98
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
GAIL FRANKO
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:
GAIL FRANKO
110 CLEARVIEW DR
CARLISLE, PA 17013
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX2116 .
4. Defendant made use of said credit card and has a current balance
due of $11774.84 , as of March 11, 2010 .
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
29.9900 per annum on the unpaid balance from March 11, 2010 . A copy
of Plaintiff's Statement is attached hereto, marked as Exhibit "1" 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 , GAIL FRANKO individually , in the amount of
$11774.84 with interest at the rate of 29.9900 per annum from March
11, 2010 plus attorneys' fees of $125.00 , and costs.
James C War rodt,42524
WELTMAN, EINBERG & REIS CO., L.P.A.
436 Se en h Avenue, Suite 1400
Pittsb rg , PA 15219
(412) 43 -7955
FAX: 12 338-7130
0825 33 C A Pit EMR
This law firm is a debt collector attemng to collect this debt for
our client and any information obtained ill be used for that purpose.
Payment Due Dab
DISCOVER Minimum Payment Dw Account Number ending in 2116
Math 27, 2010 $2,286.00 Enter Amount Enclosed Below
New Balance $
$0.00
28 SDSN6AOt0005466
GAIL FRANKO Go paperless and make your account
informstlon mare secure wkh pssamord-
240 N 2ND ST APT B prolectsd st?arnaks orgy you can access.
NEW FREEDOM PA 17349-9702 LeammoreAld1wover.caNpapsrlsss.
PO BOX 6103 Illashllhssshlsllhslh??nrsl
CAROL STREAM IL 60197-6103
Address, e-mail or telephone changeg ?1 rl?uuuillr?ul a nllunrllilnhn Ir ?urullnr?nl)
Go to www.Diew~&om or print change in space above. s I I 1
000001986458136437213000000000000000228600
Opening Dals: February O, 2UJU - (losing Dais:
Discover More Card Account Summary
Cwdmanbw since
Account number ending in 2116
Previous Balance $11,774.84
Payments And Credits 11,774.84
Purchases + 0.00
Balance Transfers + 0.00
Cash Advances + 0.00
rinaha Charges + 0.00
Other Fees t + 0.00
Now Balance
00
See Finance Charge Summary section folaMng transactions
for detailed APR irJormation
Credit Line $11,900.00
Credit Line Available $0:00
Cash Advance Credit Line $8,900.00
Cash Advance Credit Line Available $0.00
t See transaction detail for a description of any fees
4AMUCK C pains- Anniversary Month
July
Opening Cashboek Bonus Balance $ 0.00
New Cashbaek Bonus This Period + 0.00
Cashbadc BMWs Baance $ 0.00
To loam more, log in at www.DWoowr.com and salter Rewards
ry 28, 2010 page 1 of 1
Payment Information
New Balance $0.00
Minimum Payment Due $2,286.00
Payment Due Date March 27, 2010
Less Payment Wang: If we do not receive your minimum
payment by the date listed above, you may have to pay a late
fee of up to $39.00.
Manage, Your Account Ord-me at www.Ducover.eom
• Securely access statements and free online tools, pay bills
online and track and vow all transactions simply and easily
• Make yaw money worth moresm-find easy ways to earn
and redeem cash rewards
• NEWI Access your aeeourd securely-through your
mobile phone
3 Easy Ways to Contact Us
1. Access your account securely at www.Di&vw x m
2. Call 1.80001SCOVER (1-800.347-2683
Please have yaw Discovw* card ovaikdAe.
3. Writs to us of Discover PO Box 30943,
Salt Lake City, UT 841 !10
For TDD (Telecommunications Device for the Deal)
assistance, please call 1$00.347-7449.
Transactions
Trans. Past
Dcft DDda
Payn a is and Credits Feb 28 Feb 28 INTERNAL CHARGE-OFF $ -11,774.84
Finance Charge Summary
Nominal Other
Average Daily ANNUAL ANNUAL P???d"ic?? Fee
Doily Periodic PERCENTAGE NRCENTACM RNANGIE FINANCE
Current billing period: 23 days Jlak6c.s Rats RATES RATES CHAR(r'E5 offim
Purchases $0 0.08216% 29.99% 29.99% $0 $0
Cash Advances $0 0.08216% 29.99% 29.99% $0 $0
V - Variable Rate
EXHIBIT
i
825Side. DISCOVER
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# 8251335
Gail Franko
2116
~~f~~. -
,2010 q~UCs to Prit ~ ~S/
G_ ~~
i- _. _,
DISCOVER BANK
Plaintiff
vs.
GAIL FRANKO
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
No: 10-3397 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
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
08251335 C A Pit SGM
Judgment Amount $13173.07
~I"~ Od Pp ~Tr/
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No~kee, ~~~P
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 10-3397 CIVIL TERM
GAIL FRANKO
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendant GAIL FRANKO above named, in
the default of an Answer, in the amount of $13173.07 computed as follows:
Amount claimed in Complaint
Less payments / adjustments made
Interest on the remaining principa
$11774.84 from March 11, 2010 to
~ the interest rate of 29.9900
Attorney's fees
TOTAL
$11774.84
$o.oo
1 balance of
July 21, 2010
per annum $1273.23
$125.00
$13173.07
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. Wa ro t,
08251335 d A( Pit SGM
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400 Pittsburgh A 15219
And that the last known address of the Defendant is
GAIL FRANKO
110 CLEARVIEW DR
CARLISLE, PA 17013
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
GAIL FRANKO
Civil Action No. 10-3397 CIVIL TERM
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the f~llowing Order of Judgment
was entered against you on 8ltb ld
(xx) Assumpsit Judgment in the. amount of $13173.07 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
Prntl~nnntarv
By:
GAIL FRANKO
110 CLEARVIEW DR
CARLISLE, PA 17013
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 10-3397 CIVIL TERM
GAIL FRANKO
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 GAIL FRANKO 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.
GAIL FRANKO
110 CLEARVIEW DR
CARLISLE, PA 17013
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
Jul-26-2010 06:58:22
'. Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
FRANKO GAIL 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 html. 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.
httnc•//www r~m~r n.c~l mil/anni/ccra/nnnrP»nrt rin 7/2~/~nl n
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
GAIL FRANKO
Defendant
Case No. 10-3397 CIVIL TERM
IMPORTANT NOTICE
TO:
GAIL FRANKO
110 CLEARVIEW DR
CARLISLE, PA 17013
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 THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO
TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED
FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA. 17013
(717) 249-3166
WELTMAN, W ER & REIS CO., L.P.A.
By- ~
Matthew Urban
P,A.I.D.# 90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
8251335 A PIT T4L
r:F TH FILED-OFFICE
T,,E-
2011 MAY 26 AM to: it 2
CUMBERLAND CGUtl -Y
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
'%S.
GAIL FRANKO
Defendant(s)
Civil Action No. 10-3397 CIVIL TERM
Aigim -1-d
INTERROGATORIES IN ATTACHMENT
MEMBERS 1 ST FCU
F?.M TRUST BANK
SuV EREIGN BANK
Garnishee(s)
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W WR No. 825133 5
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
GAIL FRANKO
Defendant(s)
MEMBERS 1 ST FCU
F&M TRUST BANK
SOVEREIGN BANK
Garnishee(s)
Civil Action No. 10-3397 CIVIL TERM
TO: MEMBERS 1 ST FCU, 1711 SPRING RD, CARLISLE, PA 17013
F&M TRUST BANK, 14 N HANOVER ST, CARLISLE, PA 17013
SOVEREIGN BANK17 W HIGH STCARLISLE, PA 17013
RE. GAIL FRANKO, 110 CLEARVIEW DR, CARLISLE, PA 17013
Suggested Reference No.: XXX-XX-3812
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. 8251335
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. The dfS1WdAWt AdS NO+ NVG 4IC(0WIt'S Wi+I l F?MTV-IAS+.
Ia. 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 AA-
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 U ,
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? 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? N 0 ,
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?
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 17'?-
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. N17N-
WWR No. 8251335
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. N /74N-
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution. 041 N 0 41(a U Ni'S.
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 IA-, S f 4_-I t d o tJ May 2 3, 2 011
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 fiords that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law? p41 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 b k
WELTMAN, WEINBERG & REIS CO., L.P.A.
By;
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 8251335
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 RaniNboW }Ao??L NS
?t41 MI N 1 SAYAt? J ?." (Name)
ASS S'rD1?I?• of FA TRM Si C 0 • , garnishee 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.
(SIGNXTUI f -- -
W" No. 8251335
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ITMILcO-OFTICE
+'trnt a?robrj'j OF THE PRCTI-{ONOV4,R','
Jody S Smith
Chief Deputy
MAY 3! AM 9: 02
Richard W Stewart
Solicitor OFFICE OFT44ES?ERIFF CUMBERLAND OOUNT`'
PENNSYLVANIA
Discover Bank
Case Number
vs.
Gail Franko 2010-3397
SHERIFF'S RETURN OF SERVICE
05/19/2011 09:35 AM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on May 19,
2011 at 0930 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Gail Franko, in the hands, possession, or control of the within
named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013,
by handing to Julie Myers, 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.
05/23/2011 03:03 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on May 23,
2011 at 1452 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Gail Franko, 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 Nurdinah Williams 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 May 25, 2011 to Gaiil Franko at 110
Clearview Drive, Carlisle, PA 17013.
05/23/2011 02:26 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on May 23,
2011 at 1415 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Gail Franko, in the hands, possession, or control of the within
named garnishee, F & M Trust, 14 N Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013,
by handing to Donna K. McNaughton, Certified 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.
SO ANSWERS,
May 25, 2011 RON R ANDERSON, SHERIFF
Ronald Hoover, Deputy Ro rt Bitner, Deputy
(c) CountySuite Sheriff, Teleosoft . Inc.
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 # 8251335
DISCOVER BANK
vs.
GAIL FRANKO
and
Attorney for Plaintiff(s)
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CUMBERLAND County ?r-
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Court of Common Pleas r-?
NO. 10-3397 CIVIL TERM
.cam- A
F&M TRUST BANK, SOVEREIGN BANK and MEMBERS 1 IT FCU
Garnishee(s)
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THI; PROTHONOTARY:
Kindly marked the above matter discontinued and ended as to Garnishee(s), F&M TRUST
BANK, SOVEREIGN BANK and MEMBERS 1ST FCU, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Sworn to and subscribed
Before e the day of JUNE, 2011
NCO RY PU IC
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal _
Wendy L. Gault, Notary Public
City of Pittsburgh, Allegheny County
My Commission Expires July 15, W14
Member. PennsNvania Assodi#1<m c^r ttotarll- .
G'w?t $ g O0 ('?
C,?t saa ?7?
??a1oo53?
Lt -U- ICE
WELTMAN, WEINBERG & REIS CO., L.P.A. 11 1 ' `" PROT
BY: Sarah F. Ehasz, Esquire Attorney for Plai"f fs) 5
I.D. No.864(9 ,
436 Seventh Avenue, Suite 1400 ? ?BERLAND C0UNT`?
Pittsburgh, PA 15219 PENNSYLVANIA
Phone: 412.?34.7955
Fax: 412.431.79:)9
File # 8251335 I"'IT
DISCOVER BANK
Plaintiff
CUMBERLAND County
Court of Common Pleas
vs.
NO. 10-3397 CIVIL TERM
GAIL FRA`:KO
Defe.idant(s)
PRAECIPE FOR SATISFACTION OF JUDGMENT
TO THE PRGTHONOTARY:
Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the
Court and mark the cost paid.
WELTMAN, WEINBERG & REI O., L.P.A.
By
Sarah E. Ehasz, El?r
Attorney for Plaintiff
Sworn to ana subscribed
Before me the_ day
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NOT Y Pt
2011
CC hiONWEAI`fH OF PEANSS:; LJAf YA. -
Notarial a
Wayne A. Janes, Notaa'` PulAk-
City Of Pittsburgh, AIIF-iheny County
My Commission expires June 29, 2014
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