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Home My WebLink About10-7095 F rvr' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CP.~PITAL ONE BANK (USA),NA Plaintiff vs. SHU I AMBE Defendant No : ~ D ~~ ~"j 5 COMPLAINT IN CIVIL ACTION 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 0829'9247 C N Pit CXC ~~ l~ ob~~ ~~ C~'~ ~S®~ IN 'THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),, NA Plaintiff vsa Civil Action No SHU I AMBE 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 de:Eenses 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 key-the.. court without further notice for any money claimed in the complaint cr for any other claim or relief requested by the plaintiff. You may lase 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 IN:rORMATION 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) 249-3.1'66 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK (USA),NA is a corporation with offices at 15000 CAPITAL ONE DRIVE RICHMOND VA 23238 2. Defendant is adult individual(s) residing. at the address listed. below: SH~J' I AMBE 3439- HAWTHORNS DR CAMP HILL, PA 17001 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX5908 . 4. Defendant made use of said credit card and has a current balance dus: of $4998 .45 as of October 29, 2010 5.. Defendant is in default by failing to make monthly payments when dtze:. 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 28.200a per annum on the unpaid balance from October 29, 2010 A copy of Plaintiff's Statement is attached hereto, marked as Exhibit "1" and made a part hereof. 7. 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 SHU I AMBE individually in the amount of $4998.45 with continuing interest thereon at the rate of 28.200% per annum from October 29, 2010 plus costs Jame C. Warmbrodt,42524 WELT~MAN WEINBERG & REIS CO., L.P.A. 436,~Sev~nth Avenue, Suite 1400 Pittsburgh, PA 15219 (4/12) X34-7955 FAX: 412-338-7130 0~8 2 9 924 7 C N P i t CX C This law firm is a debt collector ateti.ng to collect this debt for our client and any information obtairi~d will be used for that purpose. EXHI81? ---~_` Acmunt S Previous Balance $1,779.95 Payments, Credits and Adjustments $.00 Transacfions $150.40 Finance Charges $45.60 Ncw Balance $1,975.95 Mrnimum Amount Due $112.00 Paymem Due Date October 21, 2006 'Total Credit Line $2,000 Tonal Avaitable Credit $24.05 Credo Line for Cash $2,000 Ati~ilable Credit fox Cash $24.05 At yourse~vice To,sll CUSCOmGi ReLahons or to report a lost or srula~ card: 1-800-462-0114 Sendpayments to: Send mqurres to: Attn: Rermtwnce Procasmg Capital One Sank Calxtnl.One P.O. Hax 7084 P.O. Box 30285 Charlotte, NC X272-0854 SLC, UT 84130-0.285 Important Account Information Beginning Octabes 1st, 2006, bard on your account activity you may be assessed. mole than two late, ovalirmt; or returned check fees that «nu during any billing period. PLL-1SC RLIURN POR770N l3LLOli' 1'f1H P:'~1Y DICNT 0000000 0 5178052359545908 21 1975950053000112006. 8'299247 New Balance $1,975.95 Mmimum Amount Due $112.00 Paymcat Disc Datc October 21, 2006 Total enclosed $ Account Number. 517& 0523-5954-5908 PLATINUM MASTERCARD ACCOUNT AUG 22 -SEP 21, 2006 5178-0523-5954-5908 Pagel of 1 Payments, Credits and Adjustments Your scheduled paymelix has not been received. Please remit the amoum due apprising. on this statement. If you have already made your payment, please accept our thanks. Transacfions 1 22 AUG CANALS LIQUOR- LINDEN LINDENWOLD NJ $14A1 2 23 AUG LAUREL SPRINGS GAS STA LINDENWOLD NJ 72.00 3 30 AUG SL1NX ENTERPRISES INC ROCHESTER NY 29.99 d 21 SEP CAPITAL ONE MEMBER FEE 59.00 5 21 SEP PAST DUE FEE 35.00 Your acLOtuu is one payment behmd. Remember that mal:mg your tmnitnum payments by the due date, kezps yoty account in good standing. When you miss a payment, L1te fees smart adding up. And nobody wants that So make sure you send m the mmunum antount due on your statement to keep your account is good standing and to keep from paying catras fees. NOTICE: Look for a new statement design far your Capital One credit card beguuung nett morit}L A summary of the key cltang'es will be pro~nded with your new statement You were assessed a past duefee of $35.00 nn 09/21/2006 because your minimum payment was not. xecEived by the due date of 09/21/2006. To avoid this fee m the fume, we recommend that you allow at least 7 business days for your payment to reach Capital One. Pittance Charges Please tee reverurid efor:mfortant enformtrtiors Bnl K~ot Pe„~ ~ Corre ~g ~~~~ ~ flPR . PURCHASES S1,SSL99 .0794296P 28.9996 545:60 CASH 5.00 .0794296P 28.4996 5.00 ANWAL PERCENTAGE RATE applied this period 28.999'0 Pleaupnntma~ gaddrar mrdrarrnunlrinngu let .us~rgblueorb7auE snk Strxx Apt k c!rr sm~ ZtP Home Phone Al:emaie Phone 0 EmailAddxess ~ #9026518781432838# MAIL IL NUMBER ~. Capital One Bank ~. SHU I AMHE P O $ox 70884 'r~O ~u~i~'~'n~lp" o, ~ ''-06 UNITED STATES AVE Charlotte, NC 28272-0884 N ~ LINOENWOL7 NJ 08021-2639 ~u~~~~a~~iu~r~~ut~n~r~~~ur~u~r~u~u~u~~u~u~n~~ut~~ ° ~ ~~~iu~u~~~~nnn~t~u~~~u~i~~~~un~~~~~~n~~uu~~nu~~~~ Plrare w7etcyourauount numlxren your chock or monry order madcpaya6le to Ca¢italOncBank and neail in t!x rndorcd cnzrlofk. CAPITAL ONE BANK (USDA), N.A., Plaintiff, v. SHU I AMBE Defendant(s). . VERIFICATION 'The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating Ito unsworn falsification to authorities, that he/she is an authorized agent of CAPITAL ONE BANK (USA), N.A., Plaintiff herein, and that he/she is duly authorized to make this Verification, and that the. facts set forth in the foregoing Complaint in .Civil Action are true and correct to the best of his/her knowledge, information and belief. ~. Dated: ~~'.`,~~~~~ _ ttis Cowar N00000025181001 866734882 A049 VVELTMAN, WEINBERG & REIS CO., L.P.A. SHERIFF'S OFFICE OF CUMBERLAND COUNTY ? a Ronny R Anderson Mrrn M,= Am Sheriff ;xm . ,tp of ??,tn$rr?r C7Y c-) -, r- Jody S Smith ?? , ? ??? Chief Deputy ?C C+ ]?• Richard W Stewart :z r 5 C: = ' Ica rn Solicitor - C n m.? Capital One Bank (U.S.A.) N.A. Case Nu mber vs. 2010-7 095 Shu I. Ambre SHERIFF'S RETURN OF SERVICE 11/22/2010 08:37 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on November 22, 2010 at 2037 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Shu I. Ambre, by making known unto himself personally, at 3439 Hawthorne Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. DENNIS -RY, DEPU SHERIFF COST: $41.50 November 23, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj GountySuite Sheriff_ ieieoso+.'t. Inc. FILED-OFFICE THE PpoTtlo'yqT'?py 2011 FEB - 7 Pty 19: 1 g CUMBERLAND couN-1 F NNSYL !lANI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. SHU I AMBE Defendant No. 10-7095 PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, ESQUIRE PA I.D. #42524 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR# 8299247 Judgment Amount $ 5,242.15 tWfl-l by'?l14 fl0iCr ?YIGt,(Q?,,? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. SHU I AMBE Defendant Civil Action No. 10-7095 PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, SHU I AMBE above named, in the default of an Answer, in the amount of $5,242.15 computed as follows: Amount claimed in Complaint $4,998.45 Interest from October 29, 2010 to January 26, 2011 at the interest rate of 28.200% per annum $343.70 Less Payments /Adjustments Made $-100.00 TOTAL $5,242.15 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. PA I.D. Weltma 1.400 1 436 Sdve (412) armbrodt, ESQUIRE einberg & Reis Co., L.P.A. s Building h Avenue , PA 15219 '4-7955 8299247 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 3439 HAWTHORNE DR., CAMP HILL, PA 17001 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA),NA Plaintiff VS. SHUTAMBE Defendant Case No. 10-7095 IMPORTANT NOTICE TO: SHUTAMBE 3439 HAWTHORNE DR CAMP HILL, PA 17001 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, WEINBERG & REIS CO., L.P.A. by: L 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 8299247 N PIT M4G IN THE COMMON PLEAS COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff VS. SHU I AMBE Defendant Civil Action No. 10-7095 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, SHU I AMBE is not in the 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: SHU I AMBE 3439 HAWTHORNE DR CAMP HILL, PA 17001 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. §4904 relating to unsworn falsification to authorities. Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Pagel of 2 Jan-31-2011 08:38:56 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency AMBE SHU I 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). iA .41% Akkk 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. https://www.dmdc.osd.mil/appj/scra/popreport.do 1/31/2011 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:V6A9IF85D3 https://www.dmdc.osd.mil/appj/scra/popreport.do 1/31/2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK (USA), NA Plaintiff vs. SHU I AMBE Defendant Civil Action No. 1.0-7095 NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on 20111 (xx) Assumpsit Judgment in the amount of $ 5,242.15 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 SHU I AMBE 3439 HAWTHORNE DR CAMP HILL, PA 17001 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK(USA),NA Plaintiff vs. Civil Action No. 10-7095 -c3 p 'r''; SHU I AMBE � Q k. Defendant(s) PNC BANK y0 Garnishee(s) 17% C. =� PRAECIPE FOR WRIT OF EXECUTION %%a TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against SHU I AMBE , Defendant 3. against PNC BANK, , , Garnishee 4. Judgment Amount $ $5,242.15 C Less Payments/credits received $ $3,100.00 I ! -( . ( S Interest $ $603.28 Costs $ SUBTOTAL: $ $2,745.43 Costs(to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: 61j-�� William T. Molczan, Esq ' e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building a 436 Seventh Avenue 1 ��%(. w Pittsburgh, PA 15219 Ctla ! 1 (412)434-7955 "(Ctg,ad tc 11 a t[ 144 .0D -1-7(.1:50 Faiblic 41' ). 22)(1 . SaLC- tfille-/ ..26 WWR No. 8 99247 e# ,)99sgv kA), , 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK(USA),NA Plaintiff No. 10-7095 vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) SHU I AMBE Defendant(s) PNC BANK Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR No. 8299247 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-7095 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK(USA),NA Plaintiff(s) From SHU I. AMBE,3439 HAWTHORNE DRIVE,CAMP HILL,PA 17001 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: PNC BANK, 105 NOBLE BLVD.,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; (2) 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$2,142.15 Plaintiff Paid$ Interest$603.28 Attorney's Comm. % Law Library$.50 Attorney Paid$176.50 Due Prothonotary$2.25 Other Costs$ Date: 12/30/13 Ti . David D. Buell,Prothonotary By: Deputy REQUESTING PARTY: Name : WILLIAM T.MOLCZAN,ESQUIRE Address: WELTMAN,WEINBERG&REIS CO.,L.P.A. 1400 KOOPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH,PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ' 7 Jody S Smith ' f � , 4 Chief Deputy I''# st"4,r Richard W Stewart Solicitor I- )JI iA ; ,, ?..,, f�til 4� ki Capital One Bank(U.S.A.) N.A. vs. Case Number Shu I.Ambe 2010-7095 SHERIFF'S RETURN OF SERVICE 01/08/2014 10:50 AM-Tim Black, 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Natasa Torres,Assistant Manager, 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 January 10, 2014 to Shu I. Ambe, 3439 Hawthorne Drive, Camp Hill, PA 17011. /r • T BL CK, DEPUTY SO ANSWERS, January 09, 2014 RONIW R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK(USA),NA CIVIL ACTION NO. 10-7095 Plaintiff, VS. ANSWERS TO INTERROGATORIES IN ATTACHMENT SHU I AMBE Defendant, C r a and Filed on behalf of PNC Bank, Association ' —<> C7 PNC BANK -- Garnishee W Joel B. Gold, Esquire Sr. Counsel for PNC Bank,National Association Pa. I.D. #42090 PNC Bank,National Association Firm#862 One PNC Plaza, 201h Floor 249 Fifth Avenue Pittsburgh, Pennsylvania 15222-2707 (412) 762-2801/6763 (facsimile) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK(USA),NA CIVIL ACTION NO. 10-7095 Plaintiff, VS. ANSWERS TO INTERROGATORIES IN ATTACHMENT SHU I AMBE Defendant, and PNC BANK Garnishee ANSWERS TO INTERROGATORIES IN ATTACHMENT AND NOW, PNC Bank,N.A. the Garnishee (`Bank"), files this response stating as follows: 1-la. The Bank has three accounts titled in the name of the judgment defendant. After allowance of a portion of the defendant's $300 exemption and prior to a deduction for the Bank process fee, there is an aggregate account balance of $0.00. 2. No. 3. No. 4. No. 5. No. 6. No. 7. Unknown. Two accounts identified in No. 1, no. x792 and x228, each received funds deposited on a recurring basis identified by the originator of the electronic deposits as "UCBENEFITSCOMM OF PA UCD" but the deposits were commingled with other deposits. 43 PS §863. 8. No. 9. Objected to as outside the scope of Pa.R.C.P..no. 3144. 10. Objected to as outside the scope of Pa.R.C.P. no. 3144.. 11. Unknown..See Nos. 1 & 7. 12. Unknown. See Nos. 1 & 7. WHEREFORE, PNC Bank does not admit owing a debt to the judgment defendant and does not admit holding tangible personal property of the judgment defendant. Respectfully submitted, PNC BANK, NATIONAL ASSOCIATION Joel Gold, Esq. Lit/bamishee-answers/Ambe,Shue 1222014 ----- ------- J ------ VERIFICATION The undersigned hereby verifies that I am an authorized representative of PNC Bank,N.A.;that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of my knowledge,information and belief and that these statements are made subject to the penalties of 18Pa. C.S. s4904, relating to unsworn falsification to authorities. RE Capital One Bank vs Shue I Arnbe DOCKET NO 10-7095 za Theresa A Dusch Team Lead, Garnishment Processing Position DATE: January 30,2014 Lit-233946.1 CERTIFICATE OF SERVICE PNC BANK, Garnishee, certifies that on January 31, 2014, a copy of the Answers to Interrogatories in Attachment was served via first-class U.S. mail to: the court where the Writ of Execution was filed; the plaintiff or counsel representing the plaintiff, and to the defendant(s). Date: 1/31/14 'sten Kinander Paralegal WELTMAN,WEINBERG & REIS CO.,L.P.A. BY: Matthew D Urban, Esquire Attorney for Plaintif q I.D.No. 90963 436 Seventh Avenue, Suite 1400 CUMBERLAND COUNTY Pittsburgh, PA 15219 PENNSYLVANIA Phone: 412.434.7955 Fax: 412.434.7959 File# 8299247 CAPITAL ONE BANK(USA),NA Cumberland County Court of Common Pleas vs. SHU I AMBE NO. 10-7095 and PNC BANK Garnishees) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), PNC BANK, only. WELTMAN, WEINBERG& REIS CO., L.P.A. By Matthew D Urban, Esquire Attorney for Plaintiff /907, Ctoeemz /Z5o.t 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson _.h.C-0F F , Sheriff l.1' 1 HE PRDTH0N0 AR',' Jody S Smith Chief Deputy Richard W Stewart Solicitor a ��>tr• of CAM/ (t 4..40 QFrHC:'v'FTk, ,i GRIFP 21)14 AUG 29 PH 2: 02 CUMBERLAND COUNTY PENNSYLVANIA Capital One Bank (U.S.A.) N.A. vs. Shu I. Ambe Case Number 2010-7095 SHERIFF'S RETURN OF SERVICE 01/08/2014 10:50 AM - Tim Black, 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Natasa Torres, Assistant Manager, 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 January 10, 2014 to Shu I. Ambe, 3439 Hawthorne Drive, Camp Hill, PA 17011. 08/27/2014 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: $88.76 SO ANSWERS, August 27, 2014 (c) CountySuite Sheriff, Teleesoft, Inc. r1" RON9R-R ANDERSON, SHERIFF