Loading...
HomeMy WebLinkAbout10-5684r 4 ? RLED-O7FIC E OF HE M,TH' OTAR1 J SEP -2 AM 9: 15 cumBE,R,xz COUNTY PENNNSYLVANA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: Jp- 5(o£3y 01iVtt-F a vs. JENNIFER M DUNCAN 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 08546969 C A Pit CXC 0 49$.oo QQ A-mf al 47qto,746 0 ay7&j?, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No JENNIFER M DUNCAN 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: JENNIFER M DUNCAN 923 PETERSBURG RD CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX9263 . 4. Defendant made use of said credit card and has a current balance due of $13581.16 , as of July 08, 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 25.990% per annum on the unpaid balance from July 08, 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 , JENNIFER M DUNCAN individually , in the amount of $13581.16 with interest at the rate of 25.990% per annum from July 08, 2010 plus attorneys' fees of $125.00 , and costs. games Warmbro 42524 WELT WEINBERG t, & REIS CO., L.P.A. 436 S e th Avenue, Suite 1400 Pitts ur h, PA 15219 (412) 43 -7955 FAX: 41 -338-7130 0854 9 C A Pit CXC This law firm is a debt collector attem /ng to collect this debt for our client and any information obtaine ll be used for that purpose. New Balance e?n Account Number ending in 9263 DISCOVER $0.00 Eller Amount Enclosed Below July 25, 2010 30 SDSN6A01 0006524 JENNIFER DUNCAN 923 PETERSBURG RD CARLISLE PA 17015-9211 Go Paperless and make your account information more secure with password- protected statements only you can access. Learn more at discavercon*aperless. PO BOX 6103 lllnslli.uslirllrirlBill Address, e-mail or telephone CAROL STREAM IL 60197-6103 .com or print ch IniluiiuuuliirlnlnrLllnunllllnlnlirllnnniiulul? Go to www.Diseover.et>rn or print change in space above. 000001986618198450228000000000000000248500 Discover More Card Account Summary Account number ending in 9263 Previous Balance $13,581.16 Payments And Credits 13,581.16 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Interest Charged + 0.00 Fees Charged + 0.00 New Bae $0 .00 See Interest Charge Calculation section following transactions for detailed APR information Credit Line $12,300.00 Credit Line Available $0.00 Cash Advance Credit Line $6,300.00 Cash Advance Credit Line Available $0.00 --- --?-- Anniversary Month December Opening Cashbock Bonus Balance $ 0,00 New Cashback Bonus This Period + 0.00 Ca"-di: Bonus Balance $ 0.00 To learn more, log in at www.Disco~.mnn and select Rewards ), 2010 Payment Information New Balance $0.00 Minimum Payment Due $2,485.00 Payment Due Date July 25, 2010 Lute Payment Warning: 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 Online at www.Diswvw.com Securely access nline and track amend view all transact online simply amid bills • o • Make your money worth moreW-find easy ways to earn and redeem cash rewards • NEWT Access your account securely through your mobile phone 3 Easy Ways to Contact Us 1. Access your account securely at www.Discovin.com 2. Call 1-8004DISCOVER (1-800.347-2683) Please have your Discover® card available 3. Write to us at Discover, PO Box 30943, Sak take City, UT 84130 For TDD (Telecommunications Device for the Deal) assistance, please call 1-800.347-7449. Transactions Trans. s. Post a Date Po rnetsrs d C dR y an n s Jun 30 Jun 30 INTERNAL CHARGE-OFF 0 reef $-13,581.16 TOTAL FEES FOR THIS PERIOD $ 0 0 Interest Charged TOTAL INTEREST FOR THIS PERIOD . 0 $ 0.00 t '2010 T l Y o a s ear-to-Date TOTAL FEES CHARGED IN 2010 $ 234 00 TOTAL INTEREST CHARGED IN 2010 . 1,636.42 ' ACharge Calculation Your Annual Percentage Rate (APR) is the annual i nterest rate on your account. Current Bung Period: 10 days ANNU(AAL PERCENTAGE BALANCE SUBIECT TO RJTEREST RATE INTEREST CHARGE PuM*a"S 25.99% Cash Advances $0 27.99% $0 V - Variable Rate Additional knPorla * W.Bat r. Imporlant Information. I them is more than one page to this billing stmament, we die lack of each page for additanal importoM inrannadan Continued on reverse side. DISCOVER See your Cardmember Agreement. Your Carderember Agreement contains all the terms of your Account hod or stoles cards. Report immediately Call 1-800-347-2683. What To Do 9You Think You Find A Mistake On Yom Stationso t g you think there is an error on your statement, write to us at Discover, PO Box 30421, Salt lake City, UT 84 1 30-042 1 In your leper, give us she Following information - • Account utlostalion.- Your name and account number • Dollar amount: The dollar amount of dx suspected error • Description of Problem: t you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake You must contact us within 60 days after the error appeared on your statement You musl nobly us of any potentml errors tin wring You may call us, but t you do "are not required to inwestgoto any potential arras and your may have to pay the amount in qu iston While we investigate whether or not there has been an error, the following are true We cannot try to called to amount in question, m report you as delinquent on tat amount • The char;:;r n stion may remain on your statement, and we may continue to charge you time-est on tit amount But, if we determine that we made a mistake, wit have to pay the amount in uestion or an interest t l f d * q y or o her ees re ate .o t, ria amount • Whit you do not have to pay the amount in question, you are responu-late for the remainder of your bolome We can apply any unpaid amount against your credit lent Your Rights If You Are Dissatisfied With Your Credit Card Purchases If you we dissatisfied with the goods or services that you have purchased with your credo card, and you have wind in good faith to corned the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase To use this right, all of the following must be hue I The purchase must have been made in yaw hone slate or within 100 miles of your current mailing address , and The purchase price must have been more tern $50 (Notes: Neither of these are necessar t aw urchas b d d y y p e was ase on an a vertisement we mailed to you. or t we own the company that sold you the goods or services ) 2 You must have used your credit co:d for the. purchase i urchases made wills cash advances I am en ATM m with a check tat accesses your credit card account do not qualify 3 You must not yet have Fully pod fur the purchase if all of the crilena above are met and you are still dissatisfied with the purchase, contact us in wrdmg at Discover PO Box 30945 , , Salt lake City, UT 641300945 While we investigate, the same rubs apply to the disputed amount as discussed above Aber we Finish our investigation, we will tell you our decision At dhai point, Own think you owe an amount and you do nor pay we may report you as delinquent 0 fill z Payments. Send only your payment and the top portion oFthis statement in the envelope provided Do not send cash By sending your checkers described above, you authorize us to use information on your check to make an electronic Fund t f f o rans er rom your mount at the financal institution indicated on check or to process the pa nt as a check transaction If payment his processed as an electronic fund transfer, ter transfer will be fur the amount of thecheck. When we use informatics ham your check to make an electronic Fund transfer funds may be withdrawn horn our acco t " d °o , y un as soon as some ay 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 ar other items with your paynarh1 9 you send the payment to any other address or of you use an envelope other than the one provided Payments received in p. form at our processing focikty b 5PM local pat d ll V ^t y e many ay wi 6e credited to your Account as of that day Poymenrs received ai our processing Facikry after 5PM local time will be credited to your Account as of the next day B you have misplaced your envelope, send your payment to Discover, PO Box 6103 Card Stream IL 60197-6103 Pl ll 7 10 d En , , ease a ow . ays for delivery IF your payment is returned unpaid, we reserve the right to resubmit it as on electronc debit You can pay your minimum payment or a greater amount over the telephone, and you can set up automatic payments Call us a I-806 3 47-2683 You will need this statement and your bank account information You must ensure that sufficient Funds are available in your bank account, and all tramsocrhons must l i h l comp y w t U 5 aw You will be asked to provide dro First 5 digits of your account statement ZIP code By entering Ihose numbers as your electrorhhc sigralurc, you wig be agreeing to this authorisation to allow us and your bank to deduct each pa nt you authorize From your bank account and to initi te , a debit or cradle entries to your bank account, as applicable, b correct an error in the processing of such pay?rsenl You must tell us the amount f h o eac payment or you can select on amount such as the Minimum Payment Due or the New Balance on each statement You can cancel a perymenT; however we must receive notice ar least three business days m adwnca of dse scheduled payment You may notify us by phone al "OD347-2683 or by inch ar the address Lied in th e Previous paragraph If your payments vary in amount, we will tell you on each monthly statement when your payment will be made and haw mach it will be Your auomatc payment amount ma be less than i di t d Th hl b y n an ca e e mont y siolemenl ased on credits or payments applied during the 611kg cycle Credit Reporting. We may report information about your Account to credit bureaus lase payments, hissed payments, or other defaults on your Account mmaoyy be reflected in your credo report We normally report the status and payment history of your Account to credit re ortin a encies e h th IF p g g ac mon you believe that our report is inaccurate or incomplete, ?m write us of the following address Dixover PO Box F 5316 Wilmm ron DE 1985Q5316 Pl , , g , ease hrhdica t your name, address, fame telephone number ad Account number Paying Interest: We begin to impose Interest Charges on oil transactions From the Transaction Date For the transacion shown. an your billag satement, unless a hansactron is posted a yyao r Account after the close of the billing period in which it occurs, in which case we in to impose mierest charges on tat t f t fi d ransaction rom he rst ay of the billing period in which it is posted to your Account We continue ta i pose InterestCharges unnl the dateyou pay your en ere New Balance shown an your billing statement by making payments or receiving credits 0 you pond Inn New Balance on your previous filling sesteatent by tse Payment Der Dole shown on Ih>of billing statement we wh11 not im ose Interest Char es n h t , p g o new purc ases, hat is, purchases first appwri on the urc current billing statement, c any portion of a new phase, pod by the Payment Due Dole on your current bit ling statement We call this Ihe'g me period' it i t l th 25 d Th s no ess an ays ere is no grace period I balance transfers or cash advances As more fully cl scribed in the section of your Cardmember Agreement Oled'F1ow We Apply Payments; we generally apply payments to yyoo r Account based on the APR applicable ro the balance of each transaction category This means tat gym do not pay the New Balance m the current b1kng statement by rise Payment Due Dora shown on that billing staleatent tan , , depending on the amount of your payment and Ihr APRs on other balances, you may not gel a grace period an new, purchases Minimum Interest Charges, We will charge you a minimum Interest Charge of $ 50 for any billing period in which Interest Charges of less don $ 50 would otherwise be imposed Asrtual Fee. IF yaw Account has an annual fee, it wig be killed at the 6e inning of each onniversury year your Account is open The amount of the fee appears on the statement when the Feels billed The annual fee is not r fu d ble le f e n a un ss you noti y us tat you wish to close your Account within 30 days of" moiling or delivery date of the statement m which "lee is billed You will receive this refund even it you use your Card during that period period How W To Calculate Intered Charges - Daily Balance Method (including current transactions): We Figure Interest Charges for each telling do this • We calculate your Interest Charges separately for each balance subject to different terms (for example, standard purchases, standard cash advances and each purchase, balance transfer and cash advance balance subject to ormsofional terms) We refer to these balances as transaction categories • We figure the "doily balancw+ for each transaction category To gel the 'daly balance` we xshm the begm- N balance for each day, add any new transactions and fees and any Interest Chat lei accrued on the revious d ' d 4 b la W p ay s o y a nce e then subtract any credits and payments and make odor adjustments In calculating "daily balance for the first day of the blfing period, we consider the -previous day's daily balance' to have been your balance on the Fast day of your previous telling period This ives us iM dail b l f h g y a ance or eac transaction category • We figure the Interest Charges on your Account by multiplying the daily balance for each transaction category by els dail eriodic role f h y p , or eac - day in the tilling period • The Intel Interest Charges for the billing period are the sum of the doily Interest Charges for each transaction category for each day during tai killing period When we calculate daily baances, we add a new tronsocom as of the Transaction Date shown on our 1 gin statement, unless the nonsoctim is posted to Cut Account after the dose of the biBhng pent m which it occurs, in which case the transaction will be added to the daily balance as al to first day of the Di d h ng perio in w ich if 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 Fees which are added to the applicable cash advance transaction category and Balance Transfer fees which are added to th e applicable balance transfer transaction category For TOD (Telecommunications Devices for the Deaf) aasfdonce, pleat call T -800-347-7449. Dies- and/or record telephone calls between you and Discover representatives for quality assurance purposes The Discovermcord his issued by Discover Bank, Member FDIC O ITBK 171 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 Team Leader (Name) of DFS Services LLC (Title) plaintiff herein, that (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# 8546969 Jennifer M. Duncan 6011298777999263 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4aetty of Cumbr1,1414 OFFICE OF TAE ?;-ERtFF i 4' Bryn l_ i a0TAR, Jody S Smith Chief Deputy Richard W Stewart solicitor 4Q: 3 nr Discover Bank Case Number vs.fer M. Duncan 2010-5684 Jenni SHERIFF'S RETURN OF SERVICE 09/21/2010 08:08 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 21, 2010 at 2008 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jennifer M. Duncan, by making known unto Scott Duncan, Husband of defendant at 923 Petersburg Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $33.40 September 22, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) GountySuite Sheriff. Teleosoft, Inc. "I? T4' gmil_ _ ..r } eF'?tl??ry kW t.11 ?. -? DISCOVER BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff No: 10-5684 CIVIL TERM vs JENNIFER M DUNCAN PRAECIPE FOR DEFAULT JUDGMENT 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 08546969 C A Pit ALL Judgment Amount $14862.60 1??• 4?yt??? C1?`?? ? y ?3?q IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-5684 CIVIL TERM JENNIFER M DUNCAN PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant JENNIFER M DUNCAN above named, in the default of an Answer, in the amount of $14862.60 computed as follows: Amount claimed in Complaint $13581.16 Less payments / adjustments made $0.00 Interest on the remaining principal balance of $13581.16 from July 08, 2010 to November 05, 2010 @ the interest rate of 25.990% per annum $1156.44 Attorney's fees $125.00 TOTAL $14862.60 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 08546969 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh And that the last known address of the JENNIFER M DUNCAN 923 PETERSBURG RD CARLISLE, PA 17015 W brodt,42524 Pit ALL 15219 endant is IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff v5. JENNIFER M DUNCAN Defendant TO: JENNIFER M DUNCAN 923 PETERSBURG RD CARLISLE, PA 17015 Date of Notice: YOU Case No. 10-5684 CIVIL TERM IMPORTANT NOTICE 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, Vy."BERG & REIS CO., L.P.A. rsy: - 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 8546969 A PIT T4S IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 10-5684 CIVIL TERM JENNIFER M DUNCAN NON-MILITARY AFFIDAVIT The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant 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 , JENNIFER M DUNCAN is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the DMDC does not possess any information indicating that the below individual is in the military service: JENNIFER M DUNCAN 923 PETERSBURG RD CARLISLE, PA 17015 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsification to authorities. Request for Military Status Department of Defense Manpower Data Center 10 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Nov-08-2010 08:44:07 N Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency DUNCAN JENNIFER Based on the information you have furnished, the DMDC does not possess M 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). 14. A01 101 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/fag/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. https://www.dmdc.osd.mil/appj/scra/popreport.do 11/8/2010 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:34FQOPPS62 https://www.dmdc.osd.mil/appj/scra/popreport.do 11/8/2010 DISCOVER BANK Plaintiff VS. JENNIFER M DUNCAN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 10-5684 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 (xx) Assumpsit Judgment in the amount of $14862.60 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 Prothonotary By: JENNIFER M DUNCAN 923 PETERSBURG RD CARLISLE, PA 17015 Plaintiff's address is: (OR DEPUTY) c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5684 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From JENNIFER M DUNCAN AT 923 PETERSBURG 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 M&T BANK AT 1 W. HIGH STREET CARLISLE, PA 17013 SOVEREIGN BANK AT 17 W HIGH STREET CARLISLE, PA 17013 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $14,862.60 L.L.$.50 Interest $254.09 Atty's Comm % Due Prothy $2.00 Atty Paid $166.40 Other Costs Plaintiff Paid Dale: 3/11A I David rothonota (Seal) By: Deputy REQUESTING PARTY: Name MATTHEW D. URBAN, 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. 90963 R. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. JENNIFER M DUNCAN Defendant(s) M&TBANK SOVEREIGN BANK Garnishee(s) ??. If-dtI-s& 1?? L{?ir1 --- !'4 ?y 0. " lultt-lb oa'-? 141 w G?) `zau e?? No. 10-5684 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) c 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 ere 56's t0&k S-6 li' zC WWR No. 8546969 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-5684 CIVIL, TERM JENNIFER M DUNCAN Defendant(s) M & T BANK SOVEREIGN BANK Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... I . directed to the Sheriff of CUMBERLAND County: 2. against JENNIFER M DUNCAN , Defendant 3. against M & T BANK, SOVEREIGN BANK,, Garnishee 4. Judgment Amount $ $14,862.60 Interest $ $254.09 Costs SUBTOTAL: Costs (to be added by Prothonotary): $ $15,116.69 WELTMAN, WEINBERG & REIS CO., L.P.A. B _. 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. 8546969 SHERIFF'S O Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ICE OF CUMBERLAND COUNTY '601r of curubgpr4 are 'ice .??: OFFICEOFT?.?S!`- RIFF G C ? m z? F -vm .?D cn 7 Q -fc 2 C:) CaseN YM urrie ? t r -< 2010- 5684 Discover Bank vs. Jennifer M. Duncan SH 03/18/2011 10:05 AM - Tim Black, Deputy 2011 at 1005 hours, attached a of the within named defendant, within named garnishee, Sover 17013, by handing to Denise B interrogatories together with thi there of known to her. FF'S RETURN OF SERVICE eriff, who being duly sworn according to law, states that on March 18, herein commanded all goods, chattels, rights, debts, credits, and monies wit: Jennifer M. Duncan, in the hands, possession, or control of the 3n Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania ;cher, Customer Service Representative, personally three copies of true and attested copies of the writ of execution and made the contents The writ of execution and notice?o defendant was mailed on March 22, 2011 to Jennifer M. Duncan at 922 Petersburg Road, Carlisle, PA 1 015. 03/18/2011 10:00 AM - Tim Black, Deputy S 2011 at 1000 hours, attached w of the within named defendant, t within named garnishee, M & T 1 17013, by handing to Donna Egl interrogatories together with thre there of, known to her. March 22, 2011 ieriff, who being duly sworn according to law, states that on March 18, herein commanded all goods, chattels, rights, debts, credits, and monies wit: Jennifer M. Duncan, in the hands, possession, or control of the Sank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania )If, Customer Service Representative, personally three copies of e true and attested copies of the writ of execution and made the contents SO ANSWERS, RON R ANDERSON, SHERIFF Ti ack, Deputy (C) CCUntySuite Shenff. Teleosofl. In-c. i ' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff e s. JENNIFER M DUNCAN Defendant(s) M&"f BANK SOVEREIGN BANK Garnishee(s) TO: M &'r BANK, I WEST ILIGH ST, CARLISLE, PA 17013 SOVEREIGN BANK, 17 W HIGH ST, CARLISLE, PA 17013 RE: JENNIFER M DUNCAN, 923 PETERSBURG RD, CARLISLE, PA 17015 Suggested Reference No.: XXX-XX-6031 XXX-XX- AwC!%VS fC) IMPORTANT NOTICES TO GARNISHEE! t . Y3 7G ` ? u? .D 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. 13. Herein, the word "defendant" means any one or more of the defendants against whom the writ of I"xecution 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. ra ,,, , CS c ?r N WWR No. 8546969 Civil Action No. 10-5684 CIVIL TERM 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)? 4 _S 1 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. Bal;=lncr o Pr vidod -VI I qo y. YC' ryry May nor Req hect +J"Wste.d '? c= r,? ?` (?"l 13 t t l `a cat^r r+y. or i control of defendant. At the time you were served or at any subsequent time was there in your possession, custO4 or yourself and one or more other persons any property of any nature owned solely or in part by the PA 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? \q 1. 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? 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? Q`\h 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'? k AA 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 fiends 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. ?,) A WWR No. 8546969 8. Ifyou 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. Q0 9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. 00 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate ofdeposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. 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 binds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? '' nn U11 12. If the response to Interrogatory 1 I is in the affirmative, state the amount of non-exempt funds on deposit in the account. P`iA WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & RE IS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8546969 WIZIFICATION 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 (Narhe) ? --- of J?n , -T- , 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. (SIGNATURE) r f W W R No. 8.546969 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-5684 CIVIL TERN rT', JENNIFER M DUNCAN Defendant =? - M&,T BANK ter- SOVEREIGN BANK' Garnishee PRAE JPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, M&T BANK, in the amount of $1088.86, which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG & REIS CO., L.P.A. By: MATTHEW D URBAN, ESQUIRE PA I.D.490963 Weltman, Weinberg & Reis Co.. L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#8546969 1 hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: P.O. Box 844, Buffalo NY 14240 aY aft 9c?7310 ?-? as8e aS .. © M&TBank March 29, 2011 Wellman, Weinberg & Reis 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 Legal Document Proce Phone # 716-635-771 '1 Fax # 716-635-772 Re: Garnishment Summons on Garnishee received by Manufacturers and Traders Trust Company Discover Bank vs. Jennifer M. Duncan Case # 10-5684 Civil Term Pursuant to the above Garnishment Summons. 11 anulacturers and "Traders Trust Company has searched its rcr,,identified the following open accounts with balances due its customer (s). ,cct No. 9849713111 Balance $1,088.86 Acct No. 13al?u?r? If the Writ of Garnishment and Interrogatories also sought to restrain access to sate deposit boxes. then any >?il" ''": ?? 1 h.) identified at am- of our branches are listed below. fe Deposit Box Numbcr one VVith respect to all safe deposit boxes, an order directing the drilling of the box must first be obtained and Traders Trust Cornpany must he reimbursed for the cost of drilling and replacing the lock on the box Pa.R.C'.1, i). I? Pa.C.S.A. Sincerely. Cathy S. Fisher €_eaal Document Analyst 1716)63-5-7711 Enclosure: Responses to Interrogatories Manufacturers and Traders Trust Company P.O. Boa: #844, Buffalo, New I ork 1-i s -, 11 'N T1IE CO(jR h OF COMMON 1'1,1?AS CUMBERLAND COUNTY, PENNSYLVANIA CIVII. DIVISION 1)1SC'OVER BANK Plaintiff, vs. Civil Action No. 10-5684 CIVIL TERM JENNIFER M DUNCAN Delendant(s) M&TBANK SOVEREIGN BANK Garnishee(s) 1,0: N1 & T BANK, I WES"f 1-IIGf I ST, CARLISLE, PA 17013 SOVEREIC;N BANK, 17 W I11GH ST, CARLISLE, PA 17013 RF: JF,NNIFLR M DUNCAN, 923 PETERSBURG RD, CARLISLE, PA 17015 Suggested Reference No.: XXX-XX-603 I XXX-XX- IMPORTANT NOTICES TO GARNISHEE! A. You are required to rile answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. I lerein, the word "defendant" means any one or more ofthe defendants against whom the writ of FXCCution 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. 8546969 t INTERROGATORIES IN ATTACIINIEN'r I . At the time you were served or at any subsequent time did you owe the defendant any money or %%ere you liable to him on any ne(otflit) le of, other written instrun-ient. or did he claim that you owed him any money ur ??ere Iiabte to him for any reason (including, I*un(ls on deposit Ior checl i' ur sav deposit). ings accounts and certificates of .y I a. I f the answer to Interrogatory I is in the affirmative, state the following: the amount ol' 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 amotmts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. .a t l -? 0 L tt.? '_. At the time you were served or at any subsequent time was there in your possession, custody or control ol' yourself and one or more other persons any property of any nature owned solely or in part by the defendant. t 3. At the time you were served or at any subsequent time did you hold le-al title to any property of anv nature owned solely or part by the defendant or in which defendant held or claimed any interest? 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? V 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? o? 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'? 7. I1'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. W WR No. 3546969 ?. If?ou are a bank or other financial institution, at the time you were served or at any subsequent lime did the delcndant have funds on deposit in an account in which the I.unds on deposit, not including _ anv otherwise exempt fiends, did not exceed the amount of the general nionetarv exemption under 42 Pa.C.S. ti I?3? II so, identify cash account. 9, If the answer to hiterrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. I U. 1 f the answer to Interrogatory I is in the affirmative, state the date the written instrument, checking or savings account, certificate ofdeposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. 11. 1fthe 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 Ilinds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? I ?. If' the response to Interrogatory I 1 is i deposit in the account n the af-Firmative, state the amount of non-exempt funds on . WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. 990963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8546969 VURIFICATIUN H IC Undersigned does hereby verify subject to the penalties of 18 l A. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is (NA e)' --- L---- i -- of j-': `, " ?]-- ,., ,,. k' ,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. (SIG 'ATURE) WWR No. 8546969 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5684 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From JENNIFER M DUNCAN, 923 Petersburg 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: M&T BANK, 1 West High Street, 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 $13,773.74 L.L. Interest -- $587.10 Atty's Comm % Due Prothy $2.00 Atty Paid $218.40 Other Costs Plaintiff Paid Date: 8/12/11 Dav . Buell, P thonotary (Seal) By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN WEINBERG & REIS CO LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. JENNIFER M DUNCAN Defendant(s? M&TBANK Garnishee(s) No. 10-5684 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT 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. 8546969 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-5684 CIVIL TE -- °'' . JENNIFER M DUNCAN U3 P64emburq ej ? m c? ? rn r=-- M Defendant(s) (! VI(SW, PA 1706 > N C D M& T BANK I f h s'f' I Garnishee(s) SIe PA 170113 PRAECIPE FOR WRIT OF EXECUTION c_. a TO TI'M PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... I . directed to the Sheriff of CUMBERLAND County: 1 2. against JENNIFER M DUNCAN , Defendant 3. against M & T BANK... Garnishee 4. Judgment kmount $ 14862.6 Less Payments/credits received $ 1088.86 Interest $ 587.1 Costs $ SUBTO'T'AL: $ 14360.84 Costs (to be added by Prothonotary): O *a4.60 PO AYCy 33.40 rAw 9a. 00 •' 14.00 " 61{.50 " 14.00 " 8-00, 8.00 d18• µo - W3 A'trF WELTMAN, WEINBERG & REIS CO., L.P.A. By: -/4? William T. Molczan, Es9fire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 -sa.00 nue Cc ?? I oofoo 071 alo3 /817 06+4 So," WWR No. 8546969 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy FILED-OFHi c OF THE PR0TNC¢.,C I 2011 AUG 19 AM 8: 3 Q Richard W Stewart Solicitor OFF :- CF "-E RIFF CUMBERLAND COUNTY PENNSYLVANIA Discover Bank vs. Jennifer M. Duncan Case Number 2010-5684 SHERIFF'S RETURN OF SERVICE 08/18/2011 09:40 AM - Stephen Bender, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, M&T Bank at 1 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Donna Egolf, Customer 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 August 18, 2011 to Jennifer M. Duncan at 923 Petersburg Road, Carlisle, PA 17015. SO ANSWERS, August 18, 2011 RON R ANDERSON, SHERIFF Step en Bender, Deputy (Ci Goun!ySoite ShenfP. Teieosofl i?,?. SHERIFF'S OFFICE OF CUMBERLAND COUNTY .onny R Anderson Sheriff F F Jody S Smith Chief Deputy '012 MAR z ? PM ?? Richard W Stewart Solicitor :,pct.. ` UMSBLA W) 38 ?" µ '6 PENNSYLVANIA Discover Bank . Case Number vs. Jennifer M. Duncan 2010-5684 SHERIFF'S RETURN OF SERVICE 03/18/2011 10:05 AM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on March 18, 2011 at 1005 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Jennifer M. Duncan, 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 Denise Beecher, Customer Service Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 22, 2011 to Jennifer M. Duncan at 922 Petersburg Road, Carlisle, PA 17015. 03/18/2011 10:00 AM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on March 18, 2011 at 1000 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Jennifer M. Duncan, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Donna Egolf, 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. 03/22/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $143.77 SO ANSWERS, March 22, 2012 RON R ANDERSON, SHERIFF 'So I t. ,t ek0 57-&o?© ? 1-) 7-y 9,_ ?3 County Suite Sher,.ff. I el ecs:>ft. In::. SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Anderson [ _ LJ k' e 1 t ,ody S Smith 2012 MAR 23 PM 2: 3 8 Chief Deputy Richard W Stewart 'UUMBERLAND 000" Solicitor PENNSYLVANIA Case Number Discover Bank 2010-5684 VS. Jennifer M. Duncan SHERIFF'S RETURN OF SERVICE who being duly sworn 08/18/2011 09:40 an -ded all Stephen goods, Benchattels, der, Depu ght , debts, credits, and monies of the Defe dant attached commanded the hands, possession, or control of f the the within named garnishee, M&T Bank at 1 W High Street, Carlisle B eso nall Carlisle, PA 17013, Cumberland County, by handing to Donna Egolf, Customer Service Rep., p y three copies of interrogatories together o e with three tru6 and attested copies of the Writ of Execution and made the contents there of know The writ of execution and notice to defendant was mailed on August 18, 2011 to Jennifer M. Duncan at 923 Petersburg Road, Carlisle, PA 17015. rn accord 03/22/2012 Ronny R. Anderson, Sheriff, who being duly hoover 6 oin hso law, states this writ of execution is on writ . returned as ABANDONED. No action SO ANSWERS, SHERIFF COST: $86.70 4RON ANDERSON, SHERIFF March 22, 2012 "'d .C' 0 . ?ty) pf ???I7)?- tp; Gnu^'ySuite Shenft Teleosoit_ Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK VS. JENNIFER M DUNCAN NO. 2010-5684 TO THE PROTHONOTARY: Please enter my appearance for in the above case. Date: December 18, 2014 PRAECIPE FOR APPEARANCE DISCOVER BANK Eltman, Eltman & Cooper, PC Firm 140 Broadway, 26th Fl Address New York, NY 10005