HomeMy WebLinkAbout11-0074i
FILED-i~FFICE
i~9°r' Tr¢~ PRDT~DhOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
LISA M MCLAIN
Defendant
N~: aan-~Y Crh~ Te~~u
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
08694248 C A Pit CXC
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
LISA M MCLAIN
Defendant
Civil Action No ~~--~~ ~(~~ ~GY~
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:
LISA M MCLAIN
116 ViIYNNWOOD AVE
CARLISLE, PA 17013
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX3819 .
4. Defendant made use of said credit card and has a current balance
due of $6433.78 as of September 03, 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
15.990% per annum on the unpaid balance from September 03, 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 LISA M MCLAIN ,individually in the amount of
$6433.78 with interest at the rate of 15.990 per annum from September
03, 2010 plus attorneys' fees of $125.00 and costs.
games c.
WELTMAN,
436 Seve
Pittsbu
(412) 4
FAX: 4 c
086942 8
This law firm is a debt collector attempt
our client and any information obtained w
ro t,42524
~INBERG & REIS CO., L.P.A.
. Avenue, Suite 1400
PA 15219
955
8-7130
A Pit CXC
o collect this debt for
e used for that purpose.
D'J~pVER New Balance Minimum Payment Due
$6,433.78 56,433.78
Payment Due Date
DUE YNMEDIATELT
08 SDSN6A01 0005587
LISA MCLAIN
llb k1YNNM00D AVE
CARLISLE PA 17013-1168
Address, a~rnaH or telephone change9
Go b www.Disemsrcem ar pnnt change in space above:
Account Number ending in 3819
Enter Amount Enclosed Bekrv
$~
Go paperlesa and make your accaxd
infomwtlor- mare segue with panrwrd-
proteded statements oMy you sere access.
cam moro at d(swvercomfpaparless.
PO BOX 6103 (~~ur~~nr~itu~uiur~r~~
CAROL STREAM IL 60197-6103
~ri~uiiuuni~~riuinrir~~nnriiiiuur~i~iiuur~in~ni~
000001986458256943537064337800000000643378
vpetttng oae: August 1, TO10 - Glaring Dale: augur
D'llsct~nsr Moro Card Account Summary
Aeeounf number ending in 3819
Previous tlokrnce 56,433.78
Paymenh And Credih 0.00
Purchosa + 0.00
Babnce Transfers + 0.00
Cash Advances + 0.00
InMresf Charged + 0.00
Fees Charged + 0.00
New Balance 33.78
Sw IrOerest Charge Cakukstion section Fdbwing
hansocfions for detailed APR informaMon
credit Lin. Ss,soo.oo
CriditLineAvalfabfe - ". 50:00-
Cash Advance Credit Line 50.00
Cash Advance Credit Line Available 50.00
Cas c BOnuse
Anniversary Month
Noverrrbsr
Opening Cashback Bonus Baksnee S 000
New Caahback Bonus This Period + 0.00
teslrberk flernrs eelarre~ 5 O.oo
To Iwm mon,109 in ar www. WsOOtier.wm
3 Easy Ways to Contact Us
1. Access your accarrrf seeuroly aF www.Daeowrcom
2. CaN 1-80401SCOVER (1-800347.2683
Pkrose haw your Diseovwecard avoikb~.
3. Write b us of Discover PO Box 30943,
Soh lake Ciy, UT 841 r30
FocTDII jfskrcommuoicalionsl2evice_kxtf»D~ssQ_ ___
assistance, pkros. call 1-800347-7449.
~ 8, 2010
page of 2
Payment Information
Nw+ ~bnce 56,433.78
Minimum Payment Dus* 56,433 78
Payment Due Date DUE IMMEDIATELY
*Ineludss past due amount of 51,283.00
leas Paynrerd Warning: IF rw do rest roceiw your minimum
payment by the date listed above, you may haw b pay a krte
fee of up b 539.00 and your purchase APRs for new
traosaciions maybe increased up b the Pendly APR of
20 99% variabk+.
Minirwm Payrrrerrf Wonrisg: If you make only the minimum
payment each period, you will pay moro in interest and if will
tab you kxrger b pay off your baksnce. For example:
13p _. ..
~at~ . ~~ MIII~Q~r:,
arler±Ay~<. ,
Only the minimum g ypn 56,434
payment
If you would hb information about endk counseling services,
call 1.800347-1 1 2 1.
AAattage Your Account Online at www.Diswvar.oont
• Access free online toils like Paydown Planner b ereaN a plop
b down your bakrnce, securely access slalsmerds, Pay
bills online and.wily track aN hansaetions
• Mob your money warih moron-find easy ways b earn
and redeem cash rewards
~- - NEW E Access yorrraeeunl securely Ilrrougir~rour - - - - - - - - - -
mobile phone
Transactions
o ~` ~.
F~fi94248 ToT~u f~FS FOR TflS Peffoo s o.oo
Interest lyrarged TgTAI NTEREST fOR TffIS F~ERIOD 5 0.00
2010 Totals Ycar`to-Date
TOTAL FEES CHARGED IN 2010
TOTAL INTEREST CHARGED IN 2010
ac
S 312.00
634.3b
~.ommuea on reverse sloe.
`~
Paperless sbtements mean less clutter, more convenience
Easily access up to 24 months of downloadabk, password protected statements.
• See your statement as soon as it's available rather than wait for it to arrive in your mailbox.
• Get helpful payment reminders through e-mail or text messages on your mobile phone.
• Print a paper copy of your statement anytime.
• Sign up today at Discovercom/papsrkss
5.2010 Dixover Bonk, Member FDIC PAPER.0310
8694248
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questions? visit wvVw.Dixowr.oom or DI$C~VEt~
call 1-800-DISCOVER {1-800-347-2683.
DISCOVER
It pop a USA MCLAIN
Account number ending in 3819
page 2 of 2
interest Charge Calculation
Your Annual Percentage Rah (APR) is the annual irtferat rate on your account.
Crrmerd bilirg Period: 8 days R~ATNEU(~ ~M~ (~ ~~SI EJECT TO INTEREST CHARGE
Pwdlews 15.99% SO SO
Past Pwdrews 18.99% SO SO
Cash Adrenas 23.99X V SO SO
V = Variabb Rah
Addiierral 6+porfard Information
ImposissM Infonnafion. d dren h man dart oro paps b Ihls billing slohnrnt, see dr back d soh pegs fa additiond impotent irrF«mation
Sw your Cardnsetesber AgrwmeM. Your Cardmsmber Agreemere cewrtoins all tb Mme d yaw Account
toed a Bolen cards. Report knmedbhlyl Call 1-800-3i7-26BS.
Mllssr Ye De KYw ytstnk Yw PAssl A Mhralre Ow Yew flaNnnM
IF you drink than Is an swot on yaw slahnrerrl, came b us at aaeowr, fro Box 30121, Sall lab City, UT 811 3 044 2 1.
In your MRer, giro us dre Fonovvirg idorrrralion
Account xdornrolron Yaw name aed account number
Donor omowrh The doper amount d the wspeehd err«
• Dsscrrptan of Problen; d you dsMk Brae is on ar« on your bpi, ebscrpse what you belisw is wrong and why you bslNw k Is a misab
You roue contact us wtthfn 60 days afM dr esr« appeared an r sahmsnt
You must notify us d arty porntlol arras m wrNmg. Yau may call ur, but 0 you do ors an trot required a Imreuigots arty pobnfid srron and you may haw to
paydaamountircefwstRm -~-- - ...-~-- - -
WhRe we lnwsNgtste whedra anal Brae has been on err«, dr Fanovvirp an kue
We canna try b eonM the amount In qualbn, « repel you as dennquem on Bred amaum.
Tha charge fn may rerrrob on your shhmsnt, and we may eonNrpse b charge you lnhreY on drat amount But, p vee derrmhr Bert ors mods o
misab, yorr will nil haw a pay dr amount In qusstisn « any kdwsd «odrsr fees nlaNd a that omoum
Whps you do rr« haw b pay dr omamt in question, You an nsponsibb hx the remairrder d yaw babrrn
• Ws can apply ary unpaid omoum agabst your eredR limn
Yew RfBMs MYw An Wsr~led 1NIIIs YwrCre/N Gerd Pserdeesee
If you ere dis»RsRed wAh the goods or services dot you haw purchased wkh yaw eredR cord. aril you hove tried N good bNh b eared drs
problem with dr merchant, you may haw d» right nil b pay the romdmng amount due rm the pweha».
To u» Ihh right, aN d the FOYON'l^B must be 1rw
1 The prweha» must haw been made b yaw home saN «wWrln }O0 ropes d your ewnM malprg address, and dre purchase prtw must haw
been more Bran f50 (Nate: NsYres d these an neseuary Y your pweha» was based ern on advarYssmem we moiled b you , «IF ors own
the comparry drat sob you dr goods or servkn )
2 You must haw used your ersdR card F« the pureha» Pureho»s nwds wBh cash adwness hart an ATM « cant a check dwt acees»s your
crsdR card aexoum do na gwliFy
3 You must nil yet haw Puny paid For the purcho»
IF all d the criMb above an mN and you aro soil dtasaNdMd whh the purcho», correct us in wrRing of Oiseover, ib Box 30915,
Silt lab G'ty, UT 8 4 1 30 0 915
Whits vn krwsRgale, tM same wkrs apply a the disputed amoam n dhcussed oboes A(hr vro Bnhh ow inwsYgolion, ors wRl teN you cur
dachion N drat pokrl, S we drink you awe an amoum and you do not pay we mvy repel you m deRrrgrrem
Pesymerds. Send only Your poymem and dr aP porilorr d this sahsrrl in dr enwbps provided Do not send cash By se~ check n descried
show, you authorise w b u» inforrrraHon on your chedr a mob an sleetonk broil kanster from yaw ax:ount at the Rnanebl in irrdkrohd em yaw
chxk «b process d» poyrnerN os a cheek hansaelion n payment h prous»d n an ebcYOnic fund transfer, the eonsbr writ b. For the amaml d dr cheek
When we u» Inlomratbn from yaw check a make an deetronk broil hansFer, bads may be wWtdrawn Fran yaw xcowr w soon as du sans day we rocsiw
your payment, and you wRl not realve your cheek back ham your (barebl Indih4brr
The drp d yaw payrnwrl may ~ Y you send cosh, c«mpondenee «odra Rams wIh yaw p~wn~ d send the b otbr
- addrsstl you u» an enwbpe olKer Yee B» one prov{dd payrrisiN~ iecdfved ki peter Form of ewproc -~ng IacRMy by SpM bon «~iy day wtp
day ~ ylou l ow mlAee«mt m d drat day Flsymenb recstwd err ow Fx«essNg fxRM afNr SPM bed tkne wtN bs aedRd a yaw Aeeoum a d the next
spbced year envebpe, send yaw payment b Dhcowr, P'O a Q7, carol stream, Il 60197.6103 Please snow 7.10 Boys for delMry
If yaw payment b returned unpaid, we n»rw the right a resu6mR R n an ebce«rk debR
You e:an pay your minimum paymem «e greater amoum oves dr Nlephone and yyesou can set up asrtonralk poymerMS. Call w al 1.806317.2683 You wit
need tMs satenrerrf and bank aeeoum kdormdfen You roue ansuro drat suf&bm funds m ava8ohb b yaw bank acoum, and aN lransocNans must
canply wRh U 5 law You win b asked b provide the Rra S Bigler d yaw accoum seaheiad Zip code By errhrkg Braes nrsmbers a your ebrlronk
s'~rMun, You wip bs epreeina a Brie awh«imtbn to snow w and your bark b dsduG each ~yt~m you euiroria ham your bank aeeowM, and a tnkfaAs
debit a rndR errxbi a Your Gark accaml, os appikabk-, a e«reet an error Fn IM propsskrg aF web poynrent You must ten w dr annum d each paymerrl
«you can select an amoum such as lire MNrkrrum Plsymem Due err drs New Babnee an earls skiMrrm You can earrosl o payma; howvw we must recent
notice a bast thr« budrru days b adveeree of the xhedubd payment You may nobly w by Pharr eM F1f0634~ 2a83 « by mill a dr addrns Rshd b dre
prMous Paagroph R your paymerrh wry N amoum, we will ten you on each m«rtFiy Malerrrm when yaw paynrsnt win be mods and how much it win be
our auamotlc payment amount maybe bw Bran indkahd on the morrddy stahersN baud en cndib «paymasrts applied during der bRkrrg cycle
Ct~ Retsorfirs8. We may report kdorrration about yaw Accoum to endR hurews Late paymetxs, missed paymenh, «odw de(oub on your Account
!mtrooyy bs reReeted b your endR repeat Ws rr«mony report the stereu and paynrm hisbry d your AeeowR a ersdR nporNrg agenehs each month Yyou
believe dal our report h ktaceurah « incanplels, dpi writs us al dr FoYowirrg address. over, PO Box 15316, Wpm rrgbn, DE 198565316 Pho»
indirah your name, address, hoer Mlephorre mxnfser and Aceounr mmrber
Paying IMerrel: We bepl~ b Impo» Interest Charges an all hansaeYons ham the Tronseelton Dau F« the kansaeNon shown on yaw 68irg slehmsnt,
unba o hansaceon h pow3 to your Aeeoum aha dr eb» d dr binkg psrfod Rr whkh R oteun, to which ca» we In W knpore interal elragec on dot
nansaetlon from the first day d the WMrp period to whkh B Is posted a yaw Aeeawa We eatNnue a impae bMeY C umR dr rfde Y~ PaY Y~r
smke New Balance dawn on your billing sarmeM by mokhrg poyarnh « eredPs. 8 you pestd dr New Baksnu on your previous b~ saMmenl
by 16 nenf Due Dar drown on the bining salemaa, we wRl nil tmpo» k~ilerest~harges on new purchases, dot k pwehases Nrst oppwring~on the
current sWhmerN, «arry portion der new purdro», pdd by dr Paynrm Dw DaM on yaw current br'Wng salemem We con drh Ihe'groce period • R
is not bu den 2S days There b ra Brae period on babrw transien «eosh advaners N man is8y described b dr section d ywr Cardnrmber
AgreeneM Rtbd'How Ws Apply Paymarh,' we generapy apply paymenk a your AccouN based on dr APR oFy~BeaMe a dr balonn d ea:h hans«Ron
category this morns dot Y you do rat pay the New Bdanu on the euweM b8krg slalMnart by dr payment Due Doh shown on thW hiN atatemem, drn,
dependbg on dr omoum d yaw poynrnt and the APb on odM babnees, you may not get a Brace psdod on new pureha»s ~
- ouklatbeewi» be Chorpe. We wpl charge you a minimum Mhrea Chas. d 5.50 for arty binkrg period rn whkh Interest Charges d less Bern S. 50
InPo+ed - - - - - -
Annud Fw. R your Aeeoum has an annul Fee, it wip bs bYbd a drr IrsaGinkrg d each anniverwry yea yaw Aceoum h open iM amount d tM Fea
appean on tAe statsmem when dr Fee is billed The annul he is not ekwdob wJess you notify us Rat you wish b cb» your A«owM within 30 days d Iha
maRNg «dekvery doh d the stahmem on which drs fee h biped You wig racdw irk refund scan Y you u» yaw Cord dwkrg that pesbd
Now illle ~ ulde InNntl CharBw .Daily 8olwue Meltsod (irsdudin8 cyrrwtF traruaellomN Ws Bgure Imerest Charyps F« each M11tng
We cakubN your Interest Charges ssporasely For each bobnee wb(ect a diRerem Mme (for erampb, sandard purchases, shndard cash
adwnees a ~~ ha», babnee saufer and cwh advance babna wb(ect b pramollonal Mmr) W. n(a a du» bokncu ea
ss94~
• dr'daRy babnu' br sxh Iransoettexr eahg«y To gN tlr'da8y hoboes' w• ahe the beAlnning babnee for each dvy add «ry
new han»cXons and Fees and any Inhrmt Chagas accrued on IFie previous ddaoyys dolly babnu W~ Iherr wbhoN arty aedM and p~aynrMs and
dmobd ~ adiuskssms (ineludhrg thou a~uslmems regs;ed N dr section Nbd'Payirg hshreY') In eakubtlrg dr ddy balance for dr Bret
%lod TfrlsbR~ ~~ we eonskbr dr'previous days doiy boksnee' to haw been yaw babnes on dr bet day d your previous billirp
Per 8h'es w the deny babnes breach eansaetlon cohgory
• ~ ~ I~teCharges on your Account by muRiplying the daily bdones For e«h transxdon cargaY by Ns dally periodk rocs, Far e«h
Ths alert Interest Chages f« dre M11kg perod an Ihs sum d dr dolly bMsY Charge for each aansaetion category For each day during that
billing period
When ors cakubh Batty Lebnces, we add o new transoetton as d d» Transaelion Oar shown on your billing slalemem, udea the aonsaclion h posed po
yyoouur Aeeoum ofser the e d dr bnkrg period in whkh R occurs, to whkh eau dr Iranroetion w8 hs added a the dally baknu os d tM Brst day d des
MIRng period in which R is posted a yaw Aezoum AR Fees charysed a your Aeeoum an added b dr sardord purcho» hons«tion ealegewy vvRh dr
eptbn d Cosh Advanes fees whkh aro added a dr appRee cosh advance hanseKHon caegory and Balance TransFsr Fen whkh aro added ro dr
applkabb 6abnes kanshr kansaeNon eahgewy
Continued on rowrse aide.
Foreign Currency r:M: 2% of the U S dollar amount of aoch purehase mods in o foreign currency
PenaNy A-Ra: E«h time you IaR b make a poymarA when due, we may, in accordance wish applicable law, lit NrminaN dse availability of any
inlroducbryy/promotlonol APRs on new tronsocrions, and (ii( increase your APRs for new hansacNons b variable PenoNy APRs which will bs dalermined by adding
up b an additional 5 percentage porch b the otherwise applicable APR Your Penally APR is determined based on your cradirworlhinsss and other Factors such
as your current APRs, and your account hisbry tl your APRs for new hansacfions are increased for a lore payment, the Penally APRs will apply indefinitely
For TDD (Tekerwmrnunicatioro Dwicrr (or 1M Doai) aasidanw, pbwo mll 1 •f100.347.7419.
Dixowr moy monitor and/or rscad teleplsone rolls between you and Dixover repro»nblives for qualYy assuronee purposes
The Dixoverm care! is issued by Dixover Flank, Member fDIC OITBK 172
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8694248
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to
unsworn falsifications to authorities, that she is Natasha Szczy~iel
(Name)
Account Manager of DFS Services LLC ,plaintiff herein, that
(Title) (Company)
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 her knowledge, information and belief.
WWR# 8694248
Lisa M. Mclain
6011002113743819
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
"'LE -Od !-IC, `
r , p i X.
-
20 11 J1= 12 A 0. r i
s E H 5 YL\1Pf s
Discover Bank
vs.
Lisa M. Mclain
Case Number
2011-74
SHERIFF'S RETURN OF SERVICE
01/06/2011 08:13 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January
6, 2011 at 2013 hours, he served a true copy of the within Complains: and Notice, upon the within named
defendant, to wit: Lisa M. Mclain, by making known unto Dominic Goodhart, Husband of defendant at 116
Wynnwood Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $33.40
January 07, 2011
TIM B C , DEPUTY
SO ANSWERS,
RONW R ANDERSON, SHERIFF
i :k
?:• ? ' -•?C
IN THE COURT OF COMMON CUMBER COUNTY, PENNK
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 11-74 CIVIL TERM
LISA M MCLAIN
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment ag inst the Defendant LISA M MCLAIN above named,
in the default of an Answer„ in the amount of $7026.82 computed as follows:
Amount claimed in Complaint $6433.78
Less payments / adjustments made $0.00
Interest on the remaining principal balance of
$6433.78 from September 03, 2010 to February 17, 2011
the interest rate of 15.990% per annum $468.04
Attorney's fees $125.00
TOTAL $7026.82
I hereby certify that appropriate Notices of Default, as attached have
been mailed in accordance w4h PA R.C.P. 237.1 on the dates indicated on the
Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: V %?
James C. Wq rodt,42524
08694248 C A1Pit DFO
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 14b0 Pittsburgh, /PA)15219
And that the last known address of the Deer ant is
LISA M MCLAIN V
116 WYNNWOOD AVE
CARLISLE, PA 17013
avk s 14 00 Po1 a
,tr 2:51c 1 ,?3
'nlALP I.1 A: G-A
DISCOVER BANK
Plaintiff
VS.
LISA M MCLAIN
Defendant
IN THE COURT OF C MMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Case No. 11-74 CIVIL TERM
IMPORTANT NOTICE
O:
LISA M MCLAIN
116 WYNNWOOD AVE
ARLISLE, PA 17013
C/O JOSEPH MURPHY
210 GRANT ST, SUITE 301
PITTSBURGH, PA 15219
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 E COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN EN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING ANDY U 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.
:RLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA. 17013
(717) 249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: A_--
Matthew Urban
P.A.I.DX 90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
8694248 A PIT M4Z
DISCOVER BANK
Plaintiff
vs.
LISA M MCLAIN
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
?I
Civil Action No. 11-74 CIVIL TERM
NON-MILITARY AFFIDAVIT
The undersigned is the dluly 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 Service tubers' Civil Relief Act (SCRA), 50 U.S.C. App.
521.
Affiant further states tat based upon investigation it is the affiant's
belief that the Defendant , ?,ISA M MCLAIN is not in military service.
Affiant further states t at this belief is supported by the attached
certificate from the Defense Manpower Data Center (DMDC), which states that
the DMDC does not possess an information indicating that the below
individual is in the militar service:
LISA M MCLAIN
116 WYNNWOOD AVE
CARLISLE, PA 17013
Affiant further states that the averments contained herein are true and
correct to the best of Affia is knowledge, information and belief and that
these averments are made sub'ect to the penalties of 18 Pa C.S.A. Section
4904 relating to unsworn fal ification to authorities.
Request for Military Status
Department of Defense Manpower Data Center
i
40 Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Feb-17-2011 09:33:40
. Last
Name First/Middle Begin ate Active Duty Status Active Duty End Date Service
S Agency
MCLAIN LISA M Based on the information you have furnished, the DMDC does not possess
any infor mation 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. 144*j,
y6t lot
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 r military medical care and other eligibility systems.
The DoD strongly supports the enfo ement 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 amily 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 htti)://www.defenselink.mil/fgL A/i)is/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 y u. See 50 USC App. §521(c).
If you obtain additional information bout the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your equest again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty
within the preceding 367 days. For
contact.
including date the individual was last on active duty, if it was
ical information, please contact the Service SCRA points-of-
https://www.dmdc.osd.mil/appj/scra?opreport.do 2/17/2011
Request for Military Status
.,
More information on "Active Duty,
Active duty status as reported in this
period of more than 30 consecutive c
service under a call to active service
of more than 30 consecutive days un
emergency declared by the President
members must be assigned against a
includes Navy TARS, Marine Corps
Uniformed Service member who is e
Service or the National Oceanic and
period of more than 30 consecutive <
Coverage Under the SCR.4 is i
Coverage under the SCRA is b:
duty for purposes of the SCRA
Page 2 of 2
certificate is defined in accordance with 10 USC § 101(d)(1) for a
ays. In the case of a member of the National Guard, includes
authorized by the President or the Secretary of Defense for a period
ter 32 USC § 502(f) for purposes of responding to a national
and supported by Federal funds. All Active Guard Reserve (AGR)
authorized mobilization position in the unit they support. This
ARs and Coast Guard RPAs. Active Duty status also applies to a
1 active duty commissioned officer of the U.S. Public Health
Atmospheric Administration (NOAA Commissioned Corps) for a
avs.
in Some Cases
oade? in some cases and includes some categories of persons on active
who would not be reported as on Active Duty under this certificate.
Many times orders are amended to e:
protections. Persons seeking to rely c
which SCRA protections are based h
Furthermore, some protections of the
for active duty or to be inducted, but
induction. The Last Date on Active I
extend beyond the last dates of active
Those who would rely on this c
guaranteed to Service members
WARNING: This certificate was
Providing an erroneous name or
Report ID:6747BFBRF9
https://www.dmdc.
tend the period of active duty, which would extend SCRA
i this website certification should check to make sure the orders on
ve not been amended to extend the inclusive dates of service.
SCRA may extend to persons who have received orders to report
vho have not actually begun active duty or actually reported for
uty entry is important because a number of protections of SCRA
duty.
ate are urged to seek qualified legal counsel to ensure that all rights
the SCRA are protected.
rided based on a name and SSN provided by the requester.
will cause an erroneous certificate to be provided.
2/17/2011
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-74 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From LISA M MCLAIN AT 116 Wynnwood Avenue, Carlisle, PA 17013
(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:
SOVEREIGN BANK, 17 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 $7,026.82
Interest $35.81
Atty's Comm %
Atty Paid $166.40
Plaintiff Paid
Date: 4/21/11
(Seal)
L. L..50
Due Prothy $2.00
Other Costs
David D Buell, Prothon t
By: .
Deputy
REQUESTING PARTY:
Name WILLIAM T. MOLCZAN, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219F
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.
LISA M MCLAIN
110 ?nePWO?t(
C?r1i c t of
SOVEREIGN BANK
1711VaVishee(s)
COA-bic 'Pik Q613
TO THE PROTHONOTARY:
Civil Action No. 11-74 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
?a
.? 4
,C
o C)
> ? Q-.;
:z
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against LISA M MCLAIN , Defendant
3. against SOVEREIGN BANK... Garnishee
4. Judgment Amount $
Interest $
Costs $
SUBTOTAL: $
Costs (to be added by Prothonotary): $
'rjq. 6D
33, 4 e
Cl 66 kk c c
1 t `. OQ \l K
4.!
s?\t?la.?D 1 d o??
$7,026.82
$35.81
$7,062.63
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: ?/
William T. Molczan, wire
PA I.D. #47437 l/
WELTMAN, WEINBERG & REIS CO., L.P.A
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
SO LA-
a),&i5l sL19SS
12 1?-- aspa?9
WWR No. 8694248
w(4- v ? ax Tzssutc?
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1,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No. 11-74 CIVIL TERM
VS. PRAECIPE-FOR WRIT OF EXECUTION
,
(BANK ATTACHMENT ONLY)_
LISA M MCLAIN c(o6c 11oi3
Defendants) `7
MEMBERS IyT�FCU',�` CGX�s�r t7� �p �
nil S ��
Ga ishee(�j r� c
FILED ON BEHALF OF
Plaintiff D c-) -r� °-:7
�n -� :if—
o c
COUNSEL OF RECORD OF A A
THIS PARTY: t
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
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19.00
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WWR No. 8694248
w rc� Df- slyI
i.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 11-74 CIVIL TERM
LISA M MCLAIN
Defendant(s)
MEMBERS 1 ST FCU
Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against LISA M MCLAIN ,Defendant
3. against MEMBERS 1 ST FCU, , , Garnishee
4. Judgment Amount $ $7,026.82
Less Payments/credits received $ $0.00
Interest $ $997.99
Costs $
SUBTOTAL: $ $8,024.81
Costs(to be added by Prothonotary): $
WELTMAN, WEINBERG&REIS CO., L.P.A.
By:
William T. Molczan,Esq - e
PA I.D. #47437
WELTMAN, WEINB G&REIS CO.,L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh,PA 15219
(412)434-7955
WWR No. 8694248
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DISCOVER BANK
Plaintiff
VS. Civil Action No. 11-74 CIVIL TERM
LISA M MCLAIN
Defendant(s)
MEMBERS 1 ST FCU
Garnishee(s)
WRIT OF EXECUTION
NOTICE
This paper is a"Writ of Execution". It has been issued because there is a judgment against you. It may cause your property to
be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can
advise you more specifically of these rights. If you wish to exercise your rights,you must act promptly.
The law provides that certain property cannot be taken and sold by the Sheriff to satisfy your debts. SUCH PROPERTY IS
SAID TO BE EXEMPT. No matter what you may owe,there is a DEBTOR'S EXEMPTION established by law. This means
that no matter what happens,the Sheriff must give you from the sale at least$300.00 in cash or property. There are also other
exemptions which may be applicable to you. Listed below is a summary of some of the major exemptions. You may have
other exemptions or other rights. If you have an exemption,you should do the following promptly:
(1) Complete the claim form on the opposite side and demand a
prompt hearing.
(2) Deliver the form or mail it to the Sheriffs Office at
the address noted.
You should come to court when and where you are told to appear ready to explain your exemption. IF YOU DO NOT COME
TO COURT AND PROVE YOUR EXEMPTION,YOU MAY LOSE SOME OF YOUR PROPERTY.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE,PA 17013
(717)249-3166
MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW
1. $300.00 exemptions set by law.
2. All wearing apparel used by yourself and all family members.
3. Bibles,school books,sewing machines,uniforms&equipment.
4. Tools of your trade such as carpenter's tools.
5. Most wages&unemployment benefits.
6. Social Security benefits,certain retirement funds and accounts.
7. Certain veteran&armed forces benefits.
8. Certain insurance proceeds.
9. Such other exemptions as may be provided by law.
WWR No. 8694248
a
CLAIM FOR EXEMPTION
TO THE SHERIFF:
I,the above-named defendant,claim exemption of property from levy or attachment:
(1) FROM MY PERSONAL PROPERTY IN MY POSSESSION WHICH HAS BEEN LEVIED UPON,
(a) I desire that my statutory$300.00 exemption be:
�) (1)set aside in kind(specify property,to be set aside in kind:
�) (2)paid in cash following the sale of the property levied upon;or
(b) I claim the following exemption: (specify property and basis of exemption):
(2) FROM MY PROPERTY WHICH IS IN THE POSSESSION OF A THIRD PARTY,I CLAIM THE
FOLLOWING EXEMPTIONS:
(a) my$300.00 statutory exemption: in cash in kind
(specify property):
(b) Social Security benefits on deposit in the amount of$
(c) Other(specify amount&basis for exemption):
I request a prompt court hearing to determine the exemption.
Notice of hearing should be given me at the following:
ADDRESS: TELEPHONE NUMBER:
I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are
made subject to the penalties of 18 PA.C.S. 14904 relating to unsworn falsification to authorities:
Date: Defendant:
THIS CLAIM TO BE FILED WITH:
Office of the Sheriff of Cumberland County
Courthouse
One Courthouse Square
Carlisle,PA 17013
Telephone Number: (717)240-6390
Note: Under paragraphs(1)and(2) of the Writ, a description of specific property to be levied upon or attached may be set
forth in the Writ or included in a separate direction to the Sheriff.
Under paragraph (2) of the writ, if attachment of a named garnishee is desired, his name should be set forth in the
space provided.
Under paragraph(3)of the writ, the Sheriff may, as under prior practice, add as a garnishee any person not named in
this writ who may be found in possession of property of the defendant. See Rule 311 l(a). For limitations on the power to
attach tangible personal property, see Rule 3108(a) (b). Each court shall,by local rule, designate the officer, organization or
person to be named in the notice.
WWR No. 8694248
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 11-74 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION--LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due DISCOVER BANK Plaintiff(s)
From LISA M.MCLAIN, 116 WYNNWOOD AVENUE,CARLISLE,PA 17013
(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:
MEMBERS 1sT FCU, 171.1 SPRING ROAD,CARLISLE,PA 17013
and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishce(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$7,026.82 Plaintiff Paid$
Interest$997.99
Attorney's Comm. % Law Library$
Attorney Paid$468.60 Due Prothonotary$2.25
Other Costs$
Date:08/5/2013
David D.Buell,Prothonotary
(Seat)
Deputy
REQUESTING PARTY:
Name :WILLIAM T.MOLCZAN,ESQUIRE
Address: WELTMAN,WEINBERG &REIS CO.,L.P.A.
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH,PA 15219
Attorney for:PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 47437
C-- �
SHERIFF'S OFFICE OF CUMBERLAND COUNTI I Cn j
co
Ronny R Anderson v -0 C,'
Sheriff r =1
Jody S Smith '
Chief Deputy
Richard W Stewart
Solicitor
Discover Bank
Case Number
vs,
Lisa M. Mclain 2011-74
SHERIFF'S RETURN OF SERVICE
08/0712013 11:49 AM-William Cline, Deputy,who being duly swam according to law,attached as herein commanded
all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control
of the within named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, North Middleton
Township, Carlisle, PA 17013, Cumberland County, by handing to Kathy Nissley, Sales Assistant,
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 8,VACLLIN?E,M. McLain at 116
Wynnwood Avenue, Carlisle, PA 17013.
DEPUTY-
SO ANSWERS,
6, a
August 08,2013 RbNW R ANDERSON, SHERIFF
(c)CountySuite Shenff,Teleosott,Inc.
rr
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 11-74 CIVIL TERM
LISA M MCLAIN Defendant(s) ofisw&5 ID
INTERROGATORIES IN ATTACHMENT
MEMBERS 1 ST FCU
Garnishee(s)
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan,Esquire
PA I.D. #47437
WELTMAN, WEINBERG&REIS CO.,L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412)434-7955
-ti
_ Q)`rj
C�r �
WWR No. 8694248
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 11-74 CIVIL TERM
LISA M MCLAIN
Defendant(s)
MEMBERS 1 ST FCU
Garnishee(s)
TO: MEMBERS 1 ST FCU, 1711 SPRING RD,CARLISLE, PA 17013
RE: LISA M MCLAIN , 116 WYNNWOOD AVE, CARLISLE,PA 17013
Suggested Reference No.: XXX-XX-1488
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. 8694248
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)? 1 , -y
1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof;
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe or owed to him; and the nature and amount of each of such liabilities.
SG ''-I"�s - L] X1 . 5 O C' c CIS
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. -E - R-cc. -
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? �j o
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 p
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?
M 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?
a
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. a
WWR No. 8694248
' 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. p slau"
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
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.
8 1- C13
11. If the response to Interrogatory 7 is in the affirmative,are other funds comingled in the account
which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law? , 1 / A-
12. If the response to Interrogatory 1 l is in the affirmative,state the amount of non-exempt funds on
deposit in the account.
WELTMAN, WEINBERG& REIS CO., L.P.A.
By: a"IlIeTA_ lx��
William T. Molczdn, Esq
PA I.D. #47437
WELTMAN, WEINBE G&REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh,PA 15219
(412)434-7955
WWR No. 8694248
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 k�-c C<��
(Name)
s� of c J , 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)
WWR No. 8694248
WELTMAN,WEINBERG & REIS CO.,L.P.A. 1 !'
BY: William T. Molczan, Esquire Attorney for Plaintiff(s)
I.D. No.47437 _. 13 AUG 19 WI :• 13
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219 Wl3L tLr'=.1L1J
Phone: 412.434.7955 PENNSYLVANIA
Fax: 412.434.7959
File # 08694248
DISCOVER BANK
CUMBERLAND County
Court of Common Pleas
vs.
LISA M MCLAIN
NO. 11-74-CIVIL TERM
and
MEMBERS 1ST FCU
Garnishee(s)
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly marked the above matter settled, discontinued, and ended as to Garnishee(s),
MEMBERS 1ST FCU, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
&/i(
William T. Mol an, Esquire
Attorney for P ntiff
Q. so'?cL_AO/
0_0 /i 8 /I)
R.-41 -6.294/S2.3
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Lonny R Anderson #
Sheriff �i :rarUcfifi� .
Jody S Smith
Chief Deputy 20111 MAR -it PM 2= 9
Richard W Stewart t UM ERLANU COUNTY
Solicitor PENNSYLVANIA
Discover Bank Case Number
vs.
2011-74
Lisa M. Mclain
SHERIFF'S RETURN OF SERVICE
08/07/2013 11:49 AM -William Cline, Deputy,who being duly sworn according to law, attached as herein
commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands,
possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring
Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Kathy Nissley,
Sales Assistant, 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 8, 2013 to Lisa M. McLain at 116
Wynnwood Avenue, Carlisle, PA 17013.
03/03/2014 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: $88.25 SO ANSWERS,
March 03, 2014 RONR ANDERSON, SHERIFF
toot . a_
fr 9.c21/3
,e0 30.2q73
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