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HomeMy WebLinkAbout10-3397 2Q f Q ?`i% i' 2::> ?a Lt 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/ e~ ~F~8~7 _ ~.'~ a4~~9~ 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) (7.4 a: r? C= Y` a = rn ..._ c-- ---i -r-, M.-, CUMBERLAND County ?r- - -0 ? e? 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 4' 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 f =m ur f inn5vivan d of Sb.6 iPuh F wo:p,,P6 avh.A -V $, 00 ?a a lu ? Itba, 3Uq "_ ' q*aca a syo