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Home My WebLink About11-2030r, !. C' P t ' a t } iIfFF ff3 E,',e r - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. PAULA A LEHMER Defendant No : I/- "1 Zi341 ? / l l 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 08912108 C A Pit CXC 1 6? Gb 5? 3yy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No PAULA A LEHMER Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, DISCOVER BANK is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 . 2. Defendant is adult individual(s) residing at the address listed below: PAULA A LEHMER 1521 ENGLISH DR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX1507 . 4. Defendant made use of said credit card and has a current balance due of $6024.07 , as of December 04, 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 16.460% per annum on the unpaid balance from December 04, 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 , PAULA A LEHMER individually , in the amount of $6024.07 with interest at the rate of 16.460% per annum from December 04, 2010 plus attorneys' fees of $125.00 , and. costs. Dames . warmnroau,4ZbZ4 WELT EINBERG & REIS CO., L.P.A. 436 Se en h Avenue, Suite 1400 Pitts urgPA 15219 (412) 43 -7955 FAX: 412 338-7130 089 10 C A Pit CXC This law firm is a debt collector atteTrkt-/hg to collect this debt for our client and any information obtainegi grill hie used for that purpose. New Balance Minimum Payment Due DISCOVER $6,024.07 $6,024.07 Payment Due Date DUE IMMEDIATELY 08 SDSN6A01 0001 471 PAULA LEHMER 1521 ENGLISH DR MECHANICSBURG PA 17055-5687 EXHIBIT PO BOX 6103 Illrrrllrr1llrrrlrrlrrrlrll I CAROL STREAM IL 60197-6103 ??*amail or onrchange? Irllullrnnrlllili?lrirlrlluurllllinnll?lln?nllrrlnll to www.Drscover.cor.com or print change in space above. Account Number ending in 1507 Enter Amount Enclosed Below sC Go paperless and make your account intortrlation more secure with password- protected statements only you can access. Learn more at discover.cmVpaperiess. 000001986458941002954060240700000000602407 mbar 8, 2010 page 1 of 2 ipening vats: 11.10000ttr Y, to t v a.tosing ware: rtovs Discover More Card Account Summary Account number ending in 1507 Previous Balance $6,024.07 Payments And Credits 0.00 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Interest Charged + 0.00 Fees Charged + 0.00 New Balance ,024.07 See Interest Charge Calculation section following transactions for detailed APR information Credit Line $5,900.00 Credit Line Available $0.00 Cash Advance Credit Line $0.00 Cash Advance Credit Line Available $0.00 Anniversary Month December Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 I Cashback Bonus balance $ 0.00 I To barn more, log in of www.Discowr.com 3 Easy ways to Contact US 1 Access your account securely at www.Discover.com 2. Call 1-800-DISCOVER (1-800.347-2683) Please have your Discover® card available. 3. Write to us at Discover, PO Box 30943, Salt Lake City, UT 84130 For TDD (Telecommunicofions Device for the Deaf) assistance, please call 1-800.347-7449. Payment Information New Balance $6,024.07 Minimum Payment Due" $6,024.07 Payment Due Date DUE IMMEDIATELY "Includes past due amount of $1 152.00 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 $35.00 and your purchase and balance transfer APRs For new transactions may be increased up to the Penalty APR of 21.49% variable. Mifimsn Payment Warning: If you make only the minimum payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: f you 3.... nct u; 111 pwy f Ntt Y -6, a ' ' w erid tlfC!1'? ?tq?s skews on '?P pe'yh'$ ?; . ag *it card and tflilF statement id . __ eviendted Wd 6f . bsnnf??yauY ; bttirwt Only the minimum 12 years $6,024 payment If you would like information about credit counseling services, call 1-800.347.1121 Manage Your Account Online at www.Discover.com • Access free online tools like Paydown Planner to create a plan to pay down your balance, securely access statements, pay bil s online and easily track all transactions • Make your money worth moresm-find easy ways to earn and redeem cash rewards • NEWI Access your account securely through your mobile phone ;Transactions Trans. Pas! Date Date Fees TOTAL FEES FOR THIS PERIOD $ 0.00 Merest Charged TOTAL WTEREST FOR THIS PERIOD $ 0.00 2010 Totals Year-to-Date TOTAL FEES CHARGED IN 2010 $ 156.00 TOTAL INTEREST CHARGED IN 2010 302.77 Continued on reverse side. DISCOVER Paperless statements mean less clutter, more convenience Easily access up to 24 months of downloadable, password protected statements. j • 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 Discover.com/popedess 02010 Discover Bank: M mba FDIC PAPER.0310 O to 2 rn D _o 0 0 0 A V N X V 8912108 Questions? Visit www.Discover.com or DISCOVER call 1-800-DISCOVER (1-800-347-2683). 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# 8912108 Paula A. Lehmer 6011002832911507 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA .? CIVIL DIVISION t? DISCOVER BANK Plaintiff vs. PAULA A LEHMER TO THE PROTHONTARY: Civil Action No m rut 70 cn ? 11-2030-CIVI? C -t PRAECIPE FOR DEFAULT' JUDGMENT tV r? ._F r1 F 4..J CD - -i Kindly enter Judgment against the Defendant PAULA A LEHMER above named, in the default of an Answer, in the amount of $6484.70 computed as follows: Amount claimed in Complaint Less payments / adjustments made Interest on the remaining principa $6024.07 from December 04, 2010 @ the interest rate of 16.4600 Attorney's fees TOTAL $6024.07 $0.00 1 balance of to April 07, 2011 per annum $335.63 $125.00 $6484.70 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. armrodt, 0891210$ C/A Pit DFO Plaintiff's address is: t / c/o WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburg ,/PA 15219 And that the last known address of the 4 fendant is PAULA A LEHMER Vf1 1521 ENGLISH DR MECHANICSBURG, PA 17055 ?Zit, as$a?3 ?q o iica IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case No. 11-2030-CIVIL VS. PAULA A LEHMER Defendant IMPORTANT NOTICE TO: PAULA A LEHMER 1521 ENGLISH DR MECHANICSBURG, P 17055 Date of Notice: ?l 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: Z Y4 Mattl6w rban - 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 8912108 A PIT B41 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-2030-CIVIL PAULA A LEHMER 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 , PAULA A LEHMER 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: PAULA A LEHMER 1521 ENGLISH DR MECHANICSBURG, PA 17055 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-14-201108:34:39 40 Military Status Report Pursuant to the Service Members Civil Relief Act +< Last Service First/Middle Begin Date Active Duty Status Active Duty End Date Name Agency Based on the information you have furnished, the DMDC does not LEHMER PAULA A 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). y6t In . )4(t4j4-- A?*_ 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/faglppis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). https://www.dmdc.osd.mil/appj/scra/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:KGS6CAALCO 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 11-2030 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From PAULA A. LEHMER, 1521 ENGLISH DRIVE, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$5,734.70 L.L.$50 Interest $217.38 Atty's Comm % Due Prothy $2.00 Atty Paid $170.00 Other Costs: Plaintiff Paid Date: DECEMBER 12, 2011 ? ? • o ?L1EE?? David D. Buell, Prothonotary (Seal) 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 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. Civil Action No. 11-2030-CIVIL PAULA A LEHMER 5 a t Defendant(s) M&T BANK I W. th st ?i S? 1? p llo? 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: rj . C:) .." 2. against PAULA A LEHMER , Defendant 3. against M&T BANK... Garnishee 4. Judgment Amount $ $6,484.70 73y. Less Payments/credits received $ $750.00 Interest $ $217.38 Costs $ SUBTOTAL: $ $5,952.08 Costs (to be added by Prothonotary): WELTMAN, WEINBERG & REIS CO., L.P.A. r-zL Qu? ? ?l . Oa k 't By: William T. Molczan, Esquire ?. PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 qua l? t4 m 4L .so? Ctd- iaav(ays WWR No. 8912108 Wfz4 d Ar 7szjPnl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 11-2030-CIVIL VS. PRAECIPE FOR WRIT OF EXECUTION (BAND ATTACHMENT ONLY) PAULA A LEHMER Defendant(s) M&T BANK Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8912108 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. Paula A. Lehmer HLE0-Uqzt=!C' Ry SHERIFF'S OFFICE OF CUMBERL 11 Wd 2011 DEC 2l FM 2" 29 01„t1r ? C3Utl t't/1cuMBERLAND COUNTY QENMYLVANIA Case Number 2011-2030 SHERIFF'S RETURN OF SERVICE 12/16/2011 09:05 AM - Gerald Worthington, 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 Amy Whiteman - 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 December 19, 2011 to Paula A. Lehmer at 1521 English Drive, Mechanicsburg, PA 17055. December 16, 2011 SO ANSWERS, RbNNrY R ANDERSON, SHERIFF Gerald orthi ton, Deputy J ' F1.ED-0FF suC: r TH- PROTHONOTARY' 2012 JAI -9 PM 2: 14 CUMBERLAND COUNTY PENNSYLVANIA (AWRT OF (='OIVIMON PLE,-\S OF CUMBERLAND COUNTY, 11ENiNISY[.VAN! lA CIVIL DIVISION DISCOVER BANK Plaintiff vs. PAULA A LEHMER Defendant(s) M&T BANK Garnishee(s) Civil Action No. 11-2030-CIVIL An scan -a INTERROGATORIES IN ATTACHMENT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. 4,47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8912108 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 fo any reason (including funds on deposit for checking or savings accounts and certificates of deposit)? k ealan DO T?naa Re? U 1 dad cumont pr?ima or?'o , ea l a. if the answer to Interrogatory 1 is in the affirmative, Mate the following: the afnount ?@SS-n a/ 0i, llloneti oil otiv?? OF owed to defendant, and, if such money is in the form or a find, the pi-osent location theRdFoea 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 c,we or owed to him; and then urr-ee and amount of each of such liabilities. 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. tv(? 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? 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? kA) 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? 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. 0 WWR No. 8912108 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 y otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa???t/ 23?? If so, identify each account. O004r, Tray lRe?, p?? 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these eft snterj-ogatori,_-s 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. [*11( H. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? 12. If the response to Interrogatory 1 I is in the affirmative, state the amount of non-exempt funds on deposit in the account. Melissa M. Peters M&T B r OVII WELTMAN, WEINBERG & REIS CO., L.P.A. 1 4.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 WWR No. 8912108 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unSworn tarsi`ications to authorities, that he/she is Melissa M. Peters --- -- --i Rank - -- Name) C? of , garnishee herein, (Title) (Company) that he/she is du ,y 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, inforr ation and belief. (SIGNA WWR No. 8912108 SHERIFF'S OFFICE OF CUMBERLAND COUNTY c Anderson -,dy S Smith Chief Deputy Richard W Stewart Solicitor 44j, ytlYw Qj i. It 71lU{'t,?4j14 AP" -5 PP41 2: Discover Bank Case Number vs. 2011-2030 Paula A. Lehmer SHERIFF'S RETURN OF SERVICE 12/16/2011 09:05 AM - Gerald Worthington, 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 Amy Whiteman - 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 December 19, 2011 to Paula A. Lehmer at 1521 English Drive, Mechanicsburg, PA 17055. 06/05/2012 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: $93.11 SO ANSWERS, June 05, 2012 RON R ANDERSON, SHERIFF ?2 -Dp pd • & 7G oun ??3uite Shenff. Teleo=oft. 6x:. WELTMAN, WEINBERG & REIS,CO., L.P.A. BY: William T. Molczan,47437 I.D. No. 47437 436 7th Ave Ste 1400 Pittsburgh PA 15219 -1827 (412) 434 -7955 FAX: 412 - 338 -7130 File # 08912108 C A Pit SJS Attorney for Plaintiff(s) DISCOVER BANK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. PAULA A LEHMER CASE NO. PRAECIPE TO SATISFY TO THE PROTHONTARY: 11- 2030 -CIVIL rn .j7 - wh Kindly mark the case and judgment entered against Defendant PAULA A LEHMER as satisfied. WELTMAN, WEINBERG & REIS CO., L.P.A. William T. M'oYcza Attorney for Pla tiff �as61.5)p 0 fr4/ //0P-.11 - lL3�No�d