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HomeMy WebLinkAbout11-2029 F ILL* ' F 1 C iJ t I F[_ ta' I C"r' PENS, `'L 't_,'.',. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK 0/ Plaintiff No: VS. KEITH D MARTIN 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 08909686 C A Pit CXC ra ,d 4553 3 v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No KEITH D MARTIN 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 r ' 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: KEITH D MARTIN 612 WOODLAND AVE MT HOLLY SPGS, PA 17065 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8720 . 4. Defendant made use of said credit card and has a current balance due of $2863.53 , as of December 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 29.990% per annum on the unpaid balance from December 03, 2010 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit 111" 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 , KEITH D MARTIN individually , in the amount of $2863.53 with interest at the rate of 29.990% per annum from December 03, 2010 plus attorneys' fees of $125.00 , and costs. ames 436 Pitt (412 FAX 089 This law firm is a debt collector att our client and any information obtain warmbr9-,42524 WEINBERG & REIS CO., L.P.A. nth Avenue, Suite 1400 gh, PA 15219 4-7955 -338-7130 C A Pit CXC ng to collect this debt for 11 be used for that purpose. New Balance Minimum Payment Due Account Number ending in 8720 DISCOVER $0.00 $629.00 Enter Amount Enclosed Below Payment Due Date r ?'1 Decwnber 28, 2010 L 30 SDSN6A01 0004562 KEITH MARTIN 612 WOODLAND AVE MT HOLLY SPGS PA 17065-1927 Address, e-mail or telephone change? Go to www.Discover.com or print change in space above. Go paperless and make your account information more secure with password- protected statements only you can access. Learn more at discover cornlpapedess. PO BOX 6103 Illnrllnmllnllrnlnrll CAROL STREAM IL 60197-6103 ),li,r)I,u„ 000001986457625419153000000000000000062900 upenmg Late: November I/, zu Iu - closing uate: N Discover More Card Account Summary Account number ending in 8720 Previous Balance $2,863.53 Payments And Credits 2,863.53 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Interest Charged + 0.00 Fees Charged + 0.00 New Balance - See Interest Charge Calculation section following transactions for detailed APR information Credit Line $2,200.00 Credit Line Available $0.00 Cash Advance Credit Line $0.00 Cash Advance Credit Line Available $0.00 Cashbock Bonue Anniversary Month August Opening Cashbock Bonus Baksnce $ 0.00 New Cashbock Bonus This Period + 0.00 Cashbock Bwws Balance $ 0.00 To learn more, log in of www.Disco~.com ovember 30, 2010 page 1 of 1 Payment Information New Balance $0,00 Minimum Payment Due $629,00 Payment Due Date December 28, 2010 Late 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 $35.00 and your purchase and balance transfer APRs For new transactions may be increased up ?o the Penalty APR of 29.99% variable. Manage Your Account Online at www.Discovw.com • Securely access statements and free online tools, pay bills online and track and view all transactions simply and easily • Make your money worth moroSM -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.Disc~ corn tx IF 2. Call 1-8004DISCOVER (1-800.347-2683) Please have your Discover® cord available. 3. Write to us at Discover, PO Box 30943, Salt Lake City, UT 84130 For TDD (Telecommunications Device for the Deal) assistance, please call 1-800.347-7449. Transactions Trans. Post Date Dabs Payments and Credits Nov 30 Nov 30 INTERNAL CHARGE-OFF 5 -2,863.53 Fees TOTAL FEES FOR THIS PERIOD $ 0.00 interest awrw TOTALANTEREST FOR THIS PERIOD - - - - - - $ 0.00 2010 Totals Year-to-Date TOTAL FEES CHARGED IN 2010 $ 354.00 TOTAL INTEREST CHARGED IN 2010 647.85 WKWharge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. BALANCE C word BRng Period: 14 days RATE (M PERCENTAGE NT EST RATE ECT TO INTEREST CHARGE Purchases* 07/06/2010 and after 29.99% V $0 $0 07/05/2010 and prior 28.99% $0 $0 Cash Advances 28.99% $0 $0 V - Variable Rate * Dates apply to non-promotional purchases and to expired promotions with start dates within the specified date range Continued on reverse side. DR 46VCIF Add'Aional Itl"dant Mornwtion Important Information. IF there is more than am page to this billing statement, see the bock of each page for additional important information. See your Cordmember Agnemersl. Your Cardmember Agreement contains all the terms of your Account. Lost or stolen cards. Report immediately! Call 1-800-347-2683. What To De If You Think You Find A Mistake On Your Statement If you drink there is on error on your statement, write to us al: Discover, PO Box 30421, Sall Lake City, UT 84130-0421. In your letter, give us the following information: Account information: Your name and account number. Dollar amount: The dolor amount of to suspected error. Description of Problem: 9 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 ohm Flow error appeared on your statement. You must notify us of any potential errors in writing. You may call us, but il you do we are act required to investigate any potential errors and you may have to pay the amount in question. While we investigate whether or nos there has been an error, the fallowing are true: We cannot try to collect the amount in question, or report you as delinquent on 'hat amount. The charge in question may remain on your statement, and we may continue to charge you interest on thal amount. But, ii we determine that we made a mistake, you will not have to pay the amount in question or any interest or other fees related to that amount. While you do tar hove to pay the amount in question, you are responsible for the remainder of your balance. We can apply any unpaid amount against your credit limit Yaw Rights N Yore Are Dissatisfied t1YRh Yew Credit Card Purchases if you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not b pay the remaining amount due on the purchase. To use this right all of the Following must be true- I. The purchase must have been mode in your home state or within 100 miles of your current mailing address, and the purchase price must have been more than $50. (Note: Neither of these ore necessary if your purchase was based on an advertisement we mailed to you or if we own the company that said you the goods or services. ) 2. You must have used your credo) card for the purchase. Purchases made with cash advances from an ATM or with a check that accesses your (n O credit card account do not qualify. ED 3. You must not yet have Fully paid for the purchase. s 9 all of Flow criteria above ore met and you are still dissatisfied with the purchase, contact us in writing at: Discover, PO Box 30945, o Salt Lake City, UT 841300945 While we investigate, the some rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our 0 o decision. At that point, ilwe think you owe an amount and you do not pay we may report you as delinquent. A Payments. Send only your payment and "lop portion of this statement in the envelope provided. Do notsend cash. By sending your checkers described ou authorize us b use infrxmhOtfen on your check to make an electronic fund transfer from your account at the linamiol institution indicated on your above Of, N , y check or to process the payment as a check transaction. IF payment is processed as an electronic fund transfer, the transfer will be for the amount of the check. When we use information from your check to make an electronic fund transfer, funds maybe withdrawn from your account as soon as the some day we receive X ro your payment, and you will not receive your check back from your financial institution. The processing of yaur payment may be delayed if you send cash, correspondence or odw items with your payment, it you send the payment to any other will 5PM local time on an da facli b t o r rocessin f d m i d d y y y y P g orm a u ve pr r . Payments rece e address or l you use an envelope other than the one provi our Account as of the next 5PM local area will be credited to f ilit ft d y y a er at our process ac be credited to your Account as aF dal day. Payments receive Please allow 7-10 days for delivery. It 601975103 Card Stream PO 6103 Di l d . , scover, ox , your payment to ope, sen day. 9 you have misplaced your enve l your payment is returned unpaid, we reserve the right b resubmit it as an electronic debit. You can pay your minimum payment or a grealer amount over the telephone, and you can set up automatic payments. Call us at 1.800347.2683. You will need this statement and your bank account information. You must ensure that sufficient funds are available in your bank account, and all transactions must rovide the first 5 digits of your account statement ZIP code. By entering those numbers as your electronic You will be asked to it U S la l p h . . w. comp y w signature, you will be agreeing b* this authorization to chow us and your bank to deduct each Forem you authorize from your bank account, and to initiate debt or credit entries to your bank account as applicable, to correct an error in the processing of such payment. You must fell us the amount of each payment or you can select on amount such as the Minimum Payment Due or the New Balance on each statement. You can cancel a payment; however we must receive notice at least three business days in advance of the scheduled paymml. You may notify us by phone at 1-800347.2683 or by mail at the address listed in the previous paragraph. 9 your Payments, in amount, we will tell you on each monthly statement when your payment will be mode and how much it will be. l ll b i ing cyc e. Your aubmatic payment amount may e less than indicated on the monthly statement based on credits or payments applied during the Credit Reporting. We may report information about your Account to credit bureaus. Late payments, missed polmenls, or other defaults on your Account maybe reflected in your credit report. We rhorm oly report the status and payment history of your Account to credit reporting agencies each month. ff you DE 198505316 Please Wil PO B 15316 t D dd . ming on, iscover, ox , ress: believe that our report is inaccurate or incomplete, ease write us of the following a indicate your name, address, home telephone number and Account number. Paying Interest: We begin to impose Interest Charges on dl ransactions from the Transaction Date for the transaction shown on your 611'sg satcmenl, es on that in b im ose interest char h e be hi hi h i i d i f f b ll l h g case w g p n w c c occurs, i ing per o n w I ose o t e unless a transaction is posted 1 -your Account offer to c osted b your Account. We continue to'repose Interrst Charges until the date you pay your eriod in which it is of the billin t da ti f th fi t p g p y on rom e rs ransac entire New Balance shown on yaw billing statement by malu ?ymeno or receiving credits. If you paid the New Balance on your previous billing statement in on the fi t th t i h h Ch g s, purc ases rs ases, a appear arges on new purc by dhow Payment Due Date shown on that billing statement, we wi I not impose Interest eriod It statement We toll this Iha' race urrent billin t h D D id b P h . . g p g a e an your c y t ayment ue ase, pa e current billing statement, or any portion of a new purc k not less Flan 25 days. There is no grace period on balance transfers or cash advances. As more fully described in the section of your Cardmember Agreement filled 'Flow We Apply Payments,' we generally apply payments to yyoouur Account based on the APR applicable to the balance of each transaction then ment Due Date shown on that billing statement statement b the Pa ent bi Ill in B l th d h N t l , , y y g e curr a ance on you o not pay t e ew hat category. This means depending on the amount of your payment and the APRs on other balances, you may not get a grace period on new purchases. Minimum Interest Charge. We will charge you a minimum Interest Charge of $.50 for any billing period in which Interest Charges of less than $.50 would otherwise be imposed. Annual Fee. If your Account has an annual fee, it will be billed Of the beginning of each anniversary year your Account is open. The amount of the fee our Account within 30 days of the ou wish to close us that nless ou notif t f d bl d Th l f i i bill h h F y y y y s no re un a e u . e annua ee e en t e ee s appears on the slole ent w mailing or delivery date of door statement on which the Fee is billed. You wig receive this refund even il you use your Card during that period. How We Calculate Interest Charges Daily Balance Method (including current tronsadions): We figure interest Charges far each billing period. To 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 b promotional terms). We refer a these balances as transaction cakgorles. We figure The doily balance' Far each transaction category. To get the 'daily lsalance' we take the beginning balance For each day, add any new transactions and Fees and any Interest Charges accrued on the previous clays daily balance. We en subtract any credits and poyrnents and f l h f ' irst ance or t e Paying Interest) In calculating the daily ba make other adjusnnenh (including those adjustments required in the section filled day of the billing period, we consider the'previousday's daily balance' to have been your balance .,,he last day of your previous billing period. This gives us the daily balance for each transaction category We figure the Interest Charges on your Account by multiplying the daily lsulance for each transaction category by its doily periodic rate, for each cloy in the baying period. The total Interest Charges for the billing period are to sum of the daily interest Charges for much transaction category for each day during that billing period. When we calculate daily balances, we add a new transaction as of the Transaction Date shown on your billrg statement, unless the transaction is posted to of the balance as of the first da ill be added b the dail n tion hi h th i t d hi h o) h b ll l f y y occurs, n w c case e ra sac w in w ing perio c yor e c ose o t e i biN wh it is posted to your Account. Al Fees charged to your Account are added to de 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 the applicable balance transfer transaction category. Foreign Currency Fee: 2% of the U.S. dollar amount of each purchase mode in a foreign currency. Penalty APRs: Each time you fail to make a payment when due, we may, in accordance with opplicable low, (t) terminate the availability of any introductory/promotional APRs on new transactions, and (ii) increase your APRs for new transactions to variable Penalty APRs which will be determined by adding up to an additional 5 percentage points to the otherwise applicable APR. Your Penally APR is determined based on your creditworthiness and Other Factors such as your current APRs, and your account his". IF your APRs For new, transactions are increased For a late payment, the Penalty APRs will apply indefinitely. For TDD Joilecommunicafions Device for the Deaf) assistance, please call 1.800-347-7449. Discover may monitor and/or record Idephone cols between you and Discover representatives for quality cuutcusce purposes. The Disc-4111 card is issued by Discover Bonk, Member FDIC O 1TBK 172 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 Szczygiel, Legal Placement Account Manager (Name) (Title) of DB Servicing Corporation successor to DFS Services LLC, servicing agent for Discover Bank, (Company) plaintiff herein, that 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# 8909686 Keith D. Martin 6011001700238720 DISCOVER BANK Plaintiff vs. -71TH D MARTIN TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 1 = rn 11-2029-CIVI nj PRAECIPE FOR DEFAULT JUDGMENT - : k7 J rv XI" Z-W c.? X.- r -? r-t; Kindly enter Judgment against the Defendant KEITH D MARTIN above named, in the default of an Answer, in the amount of $3281.75 computed as follows: Amount claimed in Complaint $2863.53 Less payments / adjustments made $0.00 Interest on the remaining principal balance of $2863.53 from December 03, 2010 to April 07, 2011 @ the interest rate of 29.990% per annum $293.22 Attorney's fees $125.00 TOTAL $3281.75 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. Blames C. W\? rodt,42524 08909686 Pit DFO Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, 15219 And that the last known address of the Def ndant is KEITH D MARTIN 612 WOODLAND AVE MT HOLLY SPGS, PA 17065 }$14.oo pd a c? S14641 (DO 19 477 7 NpkiCe "?`t?o?le? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KEITH D MARTIN Defendant Case No. 11-2029-CIVIL IMPORTANT NOTICE TO: KEITH D MARTIN 612 WOODLAND AVE MT HOLLY SPGS, PA 17065 Date of Notice: at 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: Ma rba -------- 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 8909686 A PIT M4Z IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KEITH D MARTIN Civil Action No. 11-2029-CIVIL 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 , KEITH D MARTIN 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: KEITH D MARTIN 612 WOODLAND AVE MT HOLLY SPGS, PA 17065 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 Page 1 of 2 Department of Defense Manpower Data Center Apr-14-201108:37:05 40 Military Status Report Pursuant to the Service Members Civil Relief Act rC Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency MARTIN KEITH D 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). 14 In. 4W*i._ * y6t 44*_ 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/faqlpis/PC09SLDR.htinl. 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). https://www.dmdc.osd.mil/appj/sera/popreport.do 4/14/2011 Request for Military Status Page 2 of 2 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. 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:AS8ATE86KN https://www.dmdc.osd.mil/appj/scra/popreport.do 4/14/2011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-2029 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From KEITH D. MARTIN, 612 Woodland Avenue, Mt. Holly Springs, PA 17065 (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: MEMBERS 1sT FCU, 1711 SPRING ROAD, CARLISLE, PA 17013 PNC BANK, 105 NOBLE BLVD., CARLISLE, PA 17013 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 $3,281.75 Interest $23.20 Atty's Comm % Atty Paid $167.30 Plaintiff Paid Date: 6/17/11 (Sea!) L.L. $.50 Due Prothy $2.00 Other Costs 1 _ David D. 64f], Prothonot 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-2029-CIVIL KEITH D MARTIN, (2,A woat rld Ave, rylf. rrbcly sro,??,?? p4 176& 5 clg Defendant(s) rn? aM z C:: M MEMBERS FIRST FCU 7n D - ?' PNC BANK oc:) M & T BANK Z-n Garnishee(s) y? D ©?a PRAECIPE FOR WRIT OF EXECUTION C-n TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... I . directed to the Sheriff of CUMBERLAND County: 2. against KEITH D MARTIN , Defendant I`11 try { qb5 111ob1e??. WQ ?? S?: 3. against MEMBERS FIRST FCU, P C BA K, M & T BANK, Garnishee - Car I t1'--'It t PA- (1013 4. Judgment Amount $ $3,281.75 Less Payments/credits received $ $0.00 Interest $ $23.20 Costs $ SUBTOTAL: $ $3,304.95 a Costs (to be added by Prothonotary): } $ ay . SO ?d GL 3 q 3v &gr- ga,oou a. 96 (U-7. 90 FU a 11116- V 2.00 IiNe Co. s .5cat.?. sa9-7 •771 WELTMA ERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR No. 8909686 W(J 6f Fx Tssued IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 11-2029-CIVIL vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) KEITH D MARTIN Defendant(s) MEMBERS FIRST FCU PNC BANK M & T BANK, Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY; Matthew D. Urban, Esquire PA I.D. 490963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8909686 I (LD-Gr-F it F (17 T 1 i J 1_" $ 2 7 AN 10 L s=; CUMBERL `a D C tdS iv .sv; RECEIVED JUN 922011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KEITH D MARTIN Defendant(s) MEMBERS FIRST FCU PNC BATIK M & T BANK Garnishee(s) Civil Action No. 11-2029-CIVIL Ax--wt -5 -1( INTERROGATORIES IN ATTACHMENT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR No. 8909686 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KEITH D MARTIN Defendant(s) MEMBERS FIRST FCU PNC BANK M & T BANK Garnishee(s) Civil Action No. 11-2029-CIVIL TO: MEMBERS FIRST FCU, 1711 SPRING RD, CARLISLE, PA 17013 PNC BANK, 105 NOBLE BLVD, CARLISLE, PA 17013 M & T BANKI WEST HIGH STCARLISLE, PA 17013 RE: KEITH D MARTIN, 612 WOODLAND AVE, MT HOLLY SPGS, PA 17065 Suggested Reference No.: XXX-XX-0429 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. 8909686 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)? F) o I 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. D (a- 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. (W 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? V) 0 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 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? no 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? no 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. W WR No. 8909686 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. r)() 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. n ?Ck. 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? 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. 41 _V715 WELTMAN, WEINBERG & REIS CO., L.P.A. li?L? 15 By: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8909686 A f*Vl@ MEMBERS 1st FEDERAL CREDIT UNION June 22, 2011 Keith D. Martin 612 Woodland Ave Mt Holly Springs, PA 17065-1927 Review Dates (60 Days): April 24, 2011-June 22, 2011 Total Writ of Execution: $3,474.75 Account Number: XXX365-0000 Name on Account: Keith D. Martin Savings: $1,096.46 -5.00 (Membership Fee) $1,091.46 -50.00 (Processing Fee) $1,041.46 Payroll: Account Number: XXX365-0011 Name on Account: Keith D. Martin Checking: $76.85 Payroll: COMM OF PA UCD - May 26, 2011 - $510.00 $300.00 Statutory Exemption was not taken out. Tania S. Young Deposit Operations 4alyst 5000 Louise Drive - P.O. Box 40 - Mechanicsburg, Pennsylvania 17055 - (800) 283-2328 - www.memberslst.org 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 Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNAT RE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ???;tt9 of L?RUnf?rr( ? t k:ax '3}}??N 1tYz... 27 f:ia I Discover Bank vs. Keith D. Martin Case Number 2011-2029 SHERIFF'S RETURN OF SERVICE 06/22/2011 10:06 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, PNC Bank at 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013 Cumberland County, by handing to SHERI GUTTSHALL, BRANCH MRG, personally 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 June23, 2011 to Keith D. Martin at 612 Woodland Avenue, Mt. Holly Springs, Pennsylvania, 17065. 06/22/2011 10:39 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 1 st FCU at 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to DEB FLORLES, BRANCH MRG, personally 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 June 23, 2011 to Keith D. Marting at 612 Woodland Avenue, Mt. Holly Springs, Pennsylvania, 17065. 06/22/2011 10:21 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, M&T Bank at 1 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to DONNA EGOLF, TELLER, personally 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 June 23, 2011 to Keith D. Martin at 612 Woodland Avenuen, Mt. Holly Springs, Pennsylvania, 17065. SHERIFF COST: $261.14 June 23, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 411-1liam-Cline, Deputy Sheriff ro Counh; Suite SFerrfl 7Ele:; :oft. In;; I s r ? rt ?.E D" r4 PRUTNflNOTAh ! jUL 2. U2 CUMBERLAND COUNTY PENNSYLVANIA IN TH ' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BA Plaintiff V$. Civil Action No. 11-2029-CIVIL KEITH D MARTIN Defendan (s) ?es cn S-eS INTERROGATORIES IN ATTACHMENT MEMBERS FIRS FCU PNC BANK M & T BANK Garnishe s) FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8909686 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BA Plaintiff v Civil Action No. 11-2029-CIVIL KEITH D MART N Defendan (s) MEMBERS FIRS FCU PNC BANK M&TBANK Garnishe(s) TO: MEMBE S FIRST FCU, 1711 SPRING RD, CARLISLE, PA 17013 PNC BANK, 105 NOBLE BLVD, CARLISLE, PA 17013 M & T BANK I WEST HIGH STCARLISLE, PA 17013 RE: KEITH DIMARTIN, 612 WOODLAND AVE, MT HOLLY SPGS, PA 17065 Suggested Reference No.: XX.X-XX-0429 XX:X-XX- IMPORTANT NOTICES TO GARNISHEE! A. Y?u 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. I erein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issue l. C. hile 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 Garnishe '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 o the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn du ing the intervening period. WWR No. 8909686 INTERROGATORIES IN ATTACHMENT 1. A 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 a. 1 the answer to Interrogatory l is in the affirmative, state the following: the amount of money you ow 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 we or owed to him, and the nature and amount of each of such liabilities. 2. A the time you were served or at any subsequent time was there in your possession, custody or control of yourse f and one or more other persons any property of any nature owned solely or in part by the defendant. ??N? 3. A? 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? 4. A 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? 6. AI any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to a y person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? M?' 7. It time did the defen recurring basis an, attachment under the amount being electronically dep, you are a bank or other financial institution, at the time you were served or at any subsequent ]ant have funds on deposit in an account in which funds are deposited electronically on a which are identified as being funds that upon deposit are exempt from execution, levy or 'ennsylvania or federal law? If so, Identify each account and state the reason for the exemption, vithheld under each exemption and the amount of funds in each account, and the entity siting those funds on a recurring basis. W WR No. 8909686 8. I fyou 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 tinder 42 Pa.C.S. § 8123? If so, identify each account. 9. I the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. \ 10. I the answer to Interrogatory 1 is in the affirmative, state t r date the written instrument, checking or savings accoun., certificate of deposit, or other finds were frozen, restricted, o?• otherwise put on hold by this institution. 1 L I 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? n?) 12. If deposit in the acc< response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8909686 VERIFICATION The and rsigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsi =ications to authorities, that he/she is LORRIE Il1?T iMAOftme) _ of , 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, infon7nation and belief. (SIGNATURE) WWR No. 8909686 _ FILED-OFFICE" '" ? F;E °POTI-I0,N 0 Ti P"y C7(IJl,11 18 Am If: CUMBERLAND COUNT`' PENNSYLVANIA IN THE (`OURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KEITH D MARTIN Defendant MEMBERS FIRST FCU Garnishee No. 11-2029-CIVIL PRAECIPE FOR JUDGMENT AGAINST GARNISHEE 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#8909686 #IAJ. 0 6 -?Ld)jj , ck?' tc?o?y ?-A ?L14;z? m ?il I L-Ect IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-2029-CIVIL KEITH D MARTIPti Defendant MEMBERS FIRST FCU Garnishee PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, MEMBERS FIRST FCU , in the amount of $818.31, which less than the amount Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interr?,gatories. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D.#90963 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#8909686 I hereby certify that the au dress of the Plaintiff is: c/o Weltman, Weinberg & 'Leis Co., L.P.A., 1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: P.O. Box 40, Mechanicsburg, PA 17055 i I '7 c- iI l.. J - ? 4 A' f'?a1 I F'7 (('?? H l,. i uPOTit? , 2 11 JUN 27 A 10! CUMBERLAND C0 ' 1 PENNSYLVAN1A RECEIVED JUN 2 2 2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KEITH D MARTIN Defendant(s) MEMBERS FIRST FCU PNC BANK M & T BANK Garnishee(s) Civil Action No. 11-2029-CIVIL ,&W e t 5 40 INTERROGATORIES IN ATTACHMENT 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 c z ? ? m eD N ° O W WR No. 8909686 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KEITH D MARTIN Defendant(s) MEMBERS FIRST FCU PNC BANK M & T BANK Garnishee(s) Civil Action No. 11-2029-CIVIL TO: MEMBERS FIRST FCU, 1711 SPRING RD, CARLISLE, PA 17013 PNC BANK, 105 NOBLE BLVD, CARLISLE, PA 17013 M & T BANK1 WEST HIGH STCARLISLE, PA 17013 RE: KEITH D MARTIN, 612 WOODLAND AVE, MT HOLLY SPGS, PA 17065 Suggested Reference No.: XXX-XX-0429 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. 8909686 INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent tithe 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)? (? ? Ic I 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 find, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. n I('. 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. 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? Y1 1 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 ON 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? () 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? 1)e) 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. W WR No. 8909686 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. 00 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. n ?a_ 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. n <C?_ 1 1. 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? ?y 12 deposit in the account. ? aft"616G If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on t 76?? 5 WELTMAN, WEINBERG & REIS CO., L.P.A. By, Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A_ 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8909686 A rVis MEMBERS 1St FEDERAL CREDIT UNION June 22, 2011 Keith D. Martin 612 Woodland Ave Mt Holly Springs, PA 17065-1927 Review Dates (60 Days): April 24, 2011-June 22, 2011 Total Writ of Execution: $3,474.75 Account Number: XXX365-0000 Name on Account: Keith D. Martin Savings: $1,096.46 -5.00 (Membership Fee) $1,091.46 -50.00 (Processing Fee) $1,041.46 Payroll: Account Number: XXX365-0011 Name on Account: Keith D. Martin Checking: $76.85 Payroll: COMM OF PA UCD - May 26, 2011 - $510.00 $300.00 Statutory Exemption was not taken out. j"U"A Tania S. Young Deposit Operations Analyst 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org 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 Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNA P RE) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-2029-CIVIL KEITH D MARTIN Defendant MEMBERS FIRST FCU Garnishee NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff ( ) Defendant (xx) Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $818.31 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 ( ) Default ( ) Verdict ( ) Arbitration Award Prothonotary By:j?rtl?/' MEMBERS 1 ST FCL' PROTHO A R Y (OR DEPUTY) P.O. BOX 40 MECHANICSBURG, PA 17055 WELTMANS, V, EINBERG & REIS CO., L.P.A. BY: Jame,, + WF.rmbrodt, Esquire I.D. No.42,)::4 436 Seventr Ave we, Suite 1400 Pittsburgh, PA X219 Phone: 41?,A z4.7955 Fax: 412.4.4 799 File # 89006 6 DISCOVER PA-1-4K i vs. KEITH D M4R HN i and MEMBERS LIST,"EDERAL CREDIT UNION Gan:iIsh--e(s) Attorney for Plaintiff(s) .,..-, Zc) ?. C . - Gl Cumberland County < Court of Common Pleas NO. 11-2029-CIVIL PRAECIPE TO SATISFY ATTACHMENT EXECUTION TO THE Pkl"'HONOTARY: i Kindly r. l?rked the above matter satisfied as to Garnishee(s), MEMBERS I ST FEDERAL CREDIT [j'I?ON, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to and subscribed Before me the Z_-7day/ r? N ARY P ' 1C ly, 2011 James AWarmbrodt, Esquire Atto for Plaintiff COMMONWEALTH OF PZNNz, Yi:iANi,1 Notarlal Seal Wayne A. )ones, witary Public City of Pittsburgh, Alle 9heny County My Commission Expire,, June 29, ?O14 M+mbcr. Pennsvivania Association of NoUrles ayw? 6, T,00 Lr k* Gp3a?l 1 (? ?laaP WELTMANS WEINBERG & REIS CO., L.P.A. BY: Jame:, W:rmbrodt, Esquire I.D. No.425L4 436 Sevenihvenue, Suite 1400 Pittsburgh. r. 15219 Phone: 41-L4 4.'1955 Fax: 412.4'3.1.7959 File # 8909686 DISCOVER. W4K D M&T BANK (;(,) Cumberland County Court of Common Pleas vs. KEITH D N'.AR % IN and PNC BANi'Gan, TO THE FR, Kindly m 'AND M&T - RG. - RO ? `'T HGNOTA Attorney c? for >P11'1&11 ?I I : (24- CUMBERLAND C1UMBERLAND COUNTY PENNSYLVANIA NO. 11-2029-CIVIL TO DISCONTINUE ATTACHMENT EXECUTION H!)NOTARY: .ed the above matter discontinued and ended as to Garnishee(s), PNC BANK ±,, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to andsubscribed Before me ;!ie 27 day NO AA ZY PU i July, 2011 James/lC armbrodt, Esquire Atto ey or Plaintiff COMMONWEALTH OF PENNS JAWA l Notarial Seal Wayne A. Jones, Notarf Public City of Pittsburgh, Alle.3heny County My Commission Expires June 29, 2034 r,,mbvr, Pennsvivaia Association of Notaries IQD3d/ ?G?-a6a sg? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-2029 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From KEITH D. MARTIN, 612 Woodland Avenue, Mt. Holly Springs, PA 17065 (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: MEMBERS FIRST FCU, 1711 SPRING ROAD, 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 $2,531.14 L.L. Interest $67.70 Atty's Comm % Atty Paid $480.44 Plaintiff Paid Due Prothy $2.00 Other Costs Date: SEPTEMBER 12, 2011 (Seal) Da . Buell, Protho otary 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-2029-CI VIL ooaal0.nd If1 ? ??. LAOWI Spn45S ?? 5 MCO l7 C/) M u KEITH D MARTIN (ALL. -; Defendant(s) ?r MEMBERS FIRST f0-: incj &a d C&r IiSke, PA 1'7ot ? ?-- ' .garnishee 0 ( ) C- C° d 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 KEITH D MARTIN , Defendant 3. against MEMBERS FIRST FCU,, , Garnishee 4. Judgment Amount $ $3,281.75 Les, Paynents/credits received $ $818.31 Interest $ $67.70 Costs $ SUBTOTAL: $ $2,531.14 Costs (to be added by Prothonotary): WELTMAN, WEINBERG & REIS CO., L.P.A. 50 ? 34.36 UP ti. iy a L aa.oo U << 14.00 t, ay.ASO? 1Li .(u? g . cio ? 4?0 Ba al By: N, Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 CL M-- loll %q S I W?WrrR No. 8909686 V-W of 571 wry- of ?? TSsJecl, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 11-2029-CIVIL vs. KEITH D .MARTIN Defendant(s) MEMBERS FIRST F U Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8909686 SHERIFF'S OFFICE OF CUMBERLAND COUNTY . Anderson idly S Smith Chief Deputy Richard W Stewart Solicitor ?$titi?tt+' Q; 4starrt+trffi? Ff Lei? Z FAR 23 PM 2:38 'UMBEF,LAN0 CO-Upj-j-,. PE'W4SYLVANIA. Discover Bank Case Number vs. 2011-2029 Keith D. Martin SHERIFF'S RETURN OF SERVICE 06/22/2011 10:06 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, PNC Bank at 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013 Cumberland County, by handing to SHERI GUTTSHALL, BRANCH MRG, personally 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 June23, 2011 to Keith D. Martin at 612 Woodland Avenue, Mt. Holly Springs, Pennsylvania, 17065. 06/22/2011 10:39 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 1 st FCU at 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to DEB FLORLES, BRANCH MRG, personally 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 June 23, 2011 to Keith D. Marting at 612 Woodland Avenue, Mt. Holly Springs, Pennsylvania, 17065. 06122/2011 10:21 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, M&T Bank at 1 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to DONNA EGOLF, TELLER, personally 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 June 23, 2011 to Keith D. Martin at 612 Woodland Avenuen, Mt. Holly Springs, Pennsylvania, 17065. 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: $20033 SO ANSWERS, March 22, 2012 RON R ANDERSON, SHERIFF ..SU ? L' r?cl ;ci `;oun ySui o, Sherff. Teieosofl. Inc. '/4??o?o SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ay R Anderson ,eriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ???,,titlt, ut 4?unlt?r?fry?d GRiFF P i Qf?0 Ol MAR 23 PM 2:3p, "MIERLANI) CoUn 1, PENNSYLVANIA Discover Bank vs. Keith D. Martin Case Number 2011-2029 SHERIFF'S RETURN OF SERVICE 09/15/2011 01:30 PM - 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 1 st FCU at 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to DENISE HARMAN, ASSIT BRANCH MRG, personally 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 September 15, 2011 to Keith D. Martin at 612 Woodland Avenue, Mt. Holly Springs, PA 17065. 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: $87.62 SO ANSWERS, March 22, 2012 RON R ANDERSON, SHERIFF a •oo Co . +c Gbcu,ty7ulte Sherd, 1&eo=oft Inc WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-2029 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From KEITH D. MARTIN, 612 WOODLAND AVENUE, MT. HOLLY SPRINGS, PA 17065 (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: MEMBERS 1sT FCU, 1711 SPRING ROAD, 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 $2,463.44 Interest 161.87 Atty's Comm % Atty Paid $612.39 Plaintiff Paid Date: March 27, 2012 (Seal) L.L.$.50 Due Prothy $2.25 Other Costs -?)a ?- David D. Buell, Prothonotary 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KEITH D MARTIN wccdj6tt4J Ag- Defendant(s) MEMBERS 1 ST FCU 111 tr) Garnishee(s) TO THE PROTHONOTARY: Civil Action No. 1 I-2029-CIVIL W. f Uty 4*ftiri PR n??s Cav(flk(ph 1-760 PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... I . directed to the Sheriff of CUMBERLAND County: 2. against KEITH D MARTIN , Defendant 3. against MEMBERS I ST FCU,, , Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): fry < C) CD r.: c $ $3,281.75 $ $818.31 VmV $ $161.87 $2,625.31 WELTMAN, WEINBERG & REIS CO., L.P.A. 3y 3b MP 6aial.1 u ba 9 14. CGn t? ..51:> u oo CSO << t. i. IL 5o i` " ? has 39 °i? By: 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 C/(-g I6Qc-;2(e614 y V OA7?6l2 WWR No. 8909686 102, yu 5, #y WO- 4 fy -7?sv-cd . 3 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KEITH D MARTIN Defendant(s) MEMBERS 1 ST FCU Garnishee(s) No. 11-2029-CIVIL 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. 8909686 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson c. Sheriff --- "-' ? ? ; _. Jody S Smith ; M .:o Chief Deputy Richard W Stewart --` Solicitor Discover Bank vs . I Case Number Keith D. Martin 2011-2029 SHERIFF'S RETURN OF SERVICE 03/29/2012 10:31 AM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on March 29, 2012 at 1030 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Keith D. Martin, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Paula Breitenbach, 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 30, 2012 to Keith D. Martin at 612 Woodland Avenue, Mount Holly Springs, PA 17065. SO ANSWERS, March 30, 2012 RON R ANDERSON, SHERIFF Stephen Bender, Deputy WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Matthew D. Urban, Esquire Attorney for Plaintiff(s) I.D. No.90963 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 c File # 8909686 M cn r r'a = z ' `? DISCOVER BANK r -{ - CUMBERLAND County Court of Common Pleas C? vs. C KEITH D MARTIN, _, ro> NO. 11-2029-CIVIL and MEMBERS 1 ST FCU Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), MEMBERS 1 ST FCU,, only. WELTMAN, WEINBERG & REIS CO., L.P.A. B Y Matthew D. Urban, Esquire Attorney for Plaintiff Q. 5o p n A-my ?# jQSaarao P-,* x55-99 __ _ _ _ .,,~~:_ SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~ R Anderson ~,~~ ©~.~~~~ iff ~dy S Smith ~ ~ Chief Deputy o~O~a ~ov / P /N oZ' ~~ Richard W Stewart n- Solicitor (~,rK. ~1-G"Ca,H.~ ~uK '7 ~~aas y/vak~ a Discover Bank Case Number vs. 2011-2029 Keith D. Martin SHERIFF'S RETURN OF SERVICE 03/29/2012 10:31 AM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on March 29, 2012 at 1030 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Keith D. Martin, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Paula Breitenbach, Customer Service Representative, personally three copies of interrogatories together with three true and attested copies of ±he writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 30, 2012 to Keith D. Martin at 612 Woodland Avenue, Mount Holly Springs, PA 17065. 10/26/2012 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: $87.92 October 26, 2012 SO ANSWERS, ~~1 ~. RON R ANDERSON, SHERIFF a•aS~,d. Cfl- ~s~ ~~p~. ~~ ~~a~ ,~ ~~ a59~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK VS. NO. 2011-2029 KEITH D MARTIN TO THE PROTHONOTARY: Please enter my appearance for in the above case. Date: December 18, 2014 PRAECIPE FOR APPEARANCE DISCOVER BANK 17475 , SgnatureIDNum Ste shen Seli Print Name Eltman, Eltman & Cooper, PC Firm 140 Broadway, 26th Fl Address New York, NY 10005