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HomeMy WebLinkAbout11-3123 TIC: r! OTHONOTARY l l li R 13 PM 3: c4; Lt CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DANNA S LUTES Defendant No: 11,303 Evil 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 08971058 C A Pit CXC 0,0,f 'tq'p Sb? Ys 60 iz€-a5l?gaa IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No DANNA S LUTES 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 i 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: DANNA S LUTES 2903 SOCIETY HILL DR CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX4027 . 4. Defendant made use of said credit card and has a current balance due of $5798.76 , as of January 06, 2011 . 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 13.9906 per annum on the unpaid balance from January 06, 2011 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 8. Plaintiff avers that such attorneys' fees will amount to $125.00 . 9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , DANNA S LUTES INDIVIDUALLY , in the amount of $5798.76 with interest at the rate of 13.990. per annum from January 06, 2011 plus attorneys' fees of $125.00 , and costs. James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 e enth Avenue, Suite 1400 Pit sb rgh, PA 15219 (41 ) 34-7955 F 12-338-7130 08 7 58 C A Pit CXC This law firm is a debt collector attekiting to collect this debt for our client and any information obtaineff will be used for that purpose. DISCOVER $5Now Balance ,798.76 08 SDSN6A010001955 DANNA LUTES APT 304 2903 SOCIETY HILL DR CAMP HILL PA 17011-8112 Minimum Payment Due Account Number ending in 4027 $5,798.76 Enter Amount Enclosed Below Payment Due Date $ DUE WAUDIATELY Address, e-mail or telephone changer Go to www.Dieeover corn or print change in space above. Go papedess and make your account Information more secure with Password- pprratected statements any you can access. ream more at d1-wmt r conVpapwkss. PO BOX 6103 Ill 1sellemsllesmisslsrslsll CAROL STREAM IL 60197-6103 LI6mILnnnnJll,IrJmmJJLmnmrllllnmmmnllmlLnrrmlLmlmJl 000001986459151321241057987600000000579876 Opening Deft: Deownbw 1, 2010 - Cbsing Dale: Doc D'IScover Moro Card Account Summary Account number ending in 4027 Previous Balance $5,798.76 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 Bolonco 5,798.76 See Interest Charge Calculation section hollowing transactions for detailed APR Information Credit line $5,000.00 Credit Line Available -$0.00• Cash Advance Credit line $0.00 Cash Advance Credit Line Available $0.00 Cas C Bane Anniversary Month February Opening Cashback Bonus Balance S 0.00 Now Cashback Bonus This Period + 0.00 coshhodc term a -, .e $ 0.00 To ham mom, lop in of www.Diseover wm 3 Easy ways to Contact Us 1 Access your account securely at www.D scowr.cem 2. Call 1-800•DISCOVER (1-804347-2683) Please have your Discover* card available 3. Write to us ot Discover, PO Box 30943, Salt Lake City, UT 84130 For TM (Telecommunications Device for lM Deaq assistance, p" call 1-800 347.7449. EXHI T MWW o, w m v page !OF A Payment Information New Balance $5,798.76 Minimum Payment Due* $5,798.76 Payment Due Dale DUE IMMEDIATELY *Inckmdes past due amount of $973.00 Lob Faye mW Warning: If we do not receive your minimum payment by the dais 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 18.99% variable. Minimum Paynont 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: an ;. fee ?1?;..,.,...~?...::.........Y!.!.R;: ?f .... `...".l'WRi7.. .. ...... Only the minimum 12 yeah $5,799 payment If you would like information about credit counseling services, call 1-800.347.1121 Manage Your Account Online at www.Discavor.com • Access free online tools like Paydown Planer to create a plan to pay down your balance, securely access statements, pay bills online and easily track all transactions • Make your money worth more sm-find easy ways to earn and redeem cash rewards - "NEWt Access your account sscurshy throagh your- mobile phone Transactions Trans. DoleDPost eft at loss TOTAL FE S FOR THIS PERIOD $ 0.00 .. - a-wood TOTAL WMEST FOR THIS PERIOD $ 0.00 2010 Totals Year-to-Date TOTAL FEES CHARGED IN 2010 $ 641.81 TOTAL INTEREST CHARGED IN 2010 501.20 Continued on reverse side. DISCOVER Paperless statements mean less clutter, more convenience Easily access up to 24 months of downloodable, password protected statements. • See your statement as soon as it's available rather than wait for it to arrive in your mailbox. • Get helpful payment reminders through e-mail or text messages on your mobile phone. • Print a paper copy of your statement anytime. • Sign up today at Dixomccoro/popplass 02010 Discover Rank, MNnbr FDIC PAPER.0310 OJ 0 y g 8 ?N X V 8971058 QUOStkMS? Visit www.D6cavw.com or call 1-800-DISCOVER (1-800-347-2683), DISCOVEtf DISCOVER It pays to I DANNA LUTES m?1YEK ! Account number ending in 4027 pogo 2 of 2 Interest Charge CakuWon Your Annual Percentage Rate (APR) is the annual interest rote on your account. ANNUAL Current Ding Perked: 8 days RATE (APR)PERCBRAGE RM 2AhW TO INTEREST CHARGE Purchases 13.99% V $0 $0 Cash Advances 23.99% $0 $0 V as Variable Rate Additional Wised Imporfard Informadon. IF them is room don one page to this hitting statement, see the hack of each page for additional important information. See your Carc member Agreement. Your Cardmsmber Agreement contains all No terms of your Account. Lad or stolen cards. Report immediablyl Call 1.800.347-2663. N&W ye fie IF You Thfialt You find A Alidake On Yew SMhessas IF you think them is an error on your statement, write to us at Diwaver, PO Box 30421, Sak take City, UT 84 130042 1. In your letter, give us the following Informaiorh: Account information: Your name and account number. DoBor anoint: The dollar amount of the suspected error. Doscnphon of Problem: IF you think there Is an error on your big, describe what you believe Is wrong and why you believe b is a mistake. You must contact us within 60 days after the error appeared on stotemera. You must noidy us of any potential errors in writing. You may call w, but if you do we am not required b invesltgWe any potential errors and you may have b pay the amount in question. - - - _. While we instigate whodner or nottershas been an error, the following ae.trus: We cannot try to called the amount In question, or report you as dekrgnast an duet amount. The charge in short may remain on your statement, and we may continue to charge you interest on tat amount. But, If we determine that we made a mistake, you w7B not taw to pay the amount In question or any interest or odw fees related b that amount. While you do not haw to pay the amount in question, you as responsible fa the remainder of your balance. We can apply any unpaid amount against your credit limb. Year MgMe if You M Oftiods"d wigh Yew creM tier/ Purdsesee t you are diswlisiied with the goods or services that you have purchased with yaw credo card, and you have hied in good faith to correct the problem with to merchant, you may have -to riglti not to pay the remaining amount due on the purchase. To use this right, all of the following must `q hue: 1, The purchase must have been made in your home state or within 100 miles al your current moghng address, and to purchase price must have been more than SM. (Notet Neither of These we necessary if your purchase was based on an advertisement we ringed to you or g we awn the company that sold you the goods or services. 2. You mud have used your credo card for the pure. Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not qualify. 3. You must not yet have tally paid for the purchase. If all of the criteria above are met and you am dill dista shod wi6 to purchase, contact us in writing at Discover, PO Box 30945, Soll Lake City, UT 841300945 While we Investigate, to some rules apply b the disputed amount as discussed above. Ale sea finish our investigation, we will tell you our decision. At tlat point, A we think you owe an amount and you do not pay we may report you as delinquent. Payments Send only your payment and the top portion of the sbtemem In tte envelope provided. Do not send cash. By sendsrgg year check as described above, you authorize w to use Warmaton on your check to make an electronic kind lnmsfes from yaw account at the Rrandal tai Y?Ul Indicated an your check or to process it* paymsest as a check transaction. 6 payment Is processed as an electronic hind transfer, to hanger will be for the amount of to check. When we use infornxi W 6ham your check to make an elachada had wonder, kinds may be withdrawn from your account as soon as the same day we receive your payment, and you will not recent your check back from your financial inatitnnion. The processing of your payment may be delayed 4 you send cast, corresporhdeae or other items with your B send the payment to arty other address or i you use an enwbpe odhes than the one provided. POY^e^b raceMd its grope. farm at our proeesskg loch lyuby SPM kxd time on any day will be credited byo_w Account as d that dry. P??o?ymess recsived at our rip loca alter 5PM bed rime wRl be credited •o you Account as of the next day. )Fyou haw misplaced your onvelope, serhd yaw Poy^e^t to DIic M Hox ?103, Card Stidgim, IL 60197.6103. Pldose allow 7.10 days for deNwry. g your payment is returned unpaid, we reserve to right b rese6mit k as on eleehorhk debt. You can pay your minimum payment or a greater amount ever the Nlephorhe and you can sit up automatic paynenb. Call w at 14100347.2663. You will need this statement and your bank account i fornhotbn. You must ensum that aARcWd kinds am ovalbble in yaw bank accaunb and all transactions mud comply with U.S. taw. You will b. asked b provide the Wet 5 alight al yaw «eouM statement DP code. By entering these members as your eksehonk slgrnahwe, you evil its agreekg b thts ohdartzetion b allow usand your bank b deduct enxh payseem you authorize nom your bardq aeeamt, and b IhiNate debt « credit enhtes b year honk account, as opppcobIo, b eorracl an error b the prousskg of such pa?mnent. You mud het w the amowd of eo:k pey?med or you can select an amount such as to Minimum Payment Due or tte New Balance on each daternrnhf. You can wnael a paymerht however we mud recehw tpwresveaeua Iwd tines 6udness days in advance of tin uhedAed paynheM. Yw may molly w by phone a 1800347.2683 a by mall al the addree psted In the oY w asbmaticpoymer ?uamouM bebu Ihao nWind' meted an tie morhcaiAy steseeceitl b Co^ t « ur payment w8 6s node and how much b wBl 6s. payments applted during tte bBprg cycle. Credit Reporting. We may report inbrmation about your Account to credit bureaus. late payments, missed payments, or oiler delouks on your Account maybe reflected in your credit report. We normally report dte statue and payment, hhistary a1your Account to credit mparWha sgendes each month. B you bel that our report b inaccurate or incomplete, tease writs to at to following address: Discover, PO Box 15316, Wi ngbn, DE 198505316. Please Indicate your now, address. home Mleplnone Mm^6er and Account number. Paying Intetwf: We beglin to Impose Interest Charges an all transactions from to Transaction Dols for the transaction shown an your statement, unless a honsactlon is posted to your Account after the close of the billing period In which b occur, in which case we 'n b impose intend charges an that transaction From tte first day of the billing period in which it is posted b your ACCauM. We contiree to Im out Interest Charges until the dale you pay your entire New Oaks- shown on your filling swenerd by making po Is a credits. NY. paid the Now Balance on yaw previous bgWsg statement, by dw PayuwM Due Doe shown an tat Wkng sbemera, we evil na Impose InMesr Zhorges on new purchases, the is, purchases first appearhg an the current m8 slaterwnt, a any portion of a caw purchase, paid by the fbynwrhl Due Doe on your carrell bigkg staMwM. We exng Ihb tie' - nod. It is rhd lei than 25 days. These is no grace period on boknce hansfen a cash adwnees. As mom kitty descr8bed in IM secdah of your Cardmgsmba? . Agrme wnt tided 'How Ws Apply Paynwnb, vin gsrteragy apply paymeMS b your Account based on the APR applicable b the babnn of each transoctlon category. This hrheans tat g you do no pay thte New Balanc?s on the current b8 statement by the Payment Ow Date shown on the bdkng slaMwre, then, depending ca the amount of year payment oral to APRs on oiler bobaces, you may no Bar a grace peed on maw purchases. Minimum Intend Charge. We will charge you a minimum Interest Charge of $.50 for any billing period In which Interest Charges of Ion than $.50 would otherwise be Imposed. Annual Film .0-your Account las_anshnual fee, b will be bikxl at Ibe_bsdnMrg of each anniverwry ye« your Account is open. Tlupmaunt of to Fee- appears on the statement when the fee is billed. Tie annual fit b no reefunnOdaable unless you notify us that you wish to close your Account within 30 days of the mailing « delivery date of tw staerwN «h which the fit is billed. You will recent alts re" even i you use your Card during that period. How We Calculate IMered Charges Daily Balance Methad Prick ding current tnnsadiomlt We figure interest Charges for each billing period. To do this We e: Lae your Interest Charges separately for each balance subject to dtferont terms (for example, standard purchases, standard cash advances and each purchase, balance transfer and cash advance balance subject to promotional terms). We refer to dnese balonces as transaction categories. um the •daiy babnee' torn each Ironsactica category. To gN ths'dally baloace' vve take to be?hnning babace for each day, odd ary 897'1 t ores anWa kgwe the kberes d less and any IMerod Charge accrued an to previous ?y s daffy bobnc?e. We tan wWroct arty credits ad paynherhts and make otter adjushnenb (including those adlushnenb required b to section titled •Poying IntemsYl. In eakubtinp the duty bobnce f« tin Bret day al the tiling period, ore confider dte'prevlous day's daffy bobnes' b hove been yaw babace on use tad day al your previous billing period. This gives w tte daily boloace for each hansoeton eaMgory? t Charges on your Account by mukfplybg Ins dilly balance tar each hanaaeton cwmgory by its dally pabdk rate, For each day in the bppng per The total Interest Charges for the billing period are the sum of the daily Interest Charges for each transaction category for each dry during Ifat billing period. When we calculate dad balances, we add a new transaction as of to Transaction Dote shown on your biling daMnert unless to transaction is pasted to Account after "close of to billing period in which b occurs, in which caw the transaction wig be added b des doily balance as of tie Wst day of tin C'Zg period in which b I posted to yaw Account. All furs charged to yaw Account am added to the standard purchase transaction category with to exception of Cash Advance fees which are added to the oppkc cash advance tronsoction category and Balance Transfer fees which are added to the applicable balance honslor Imnsectio n category. Continued on reverse side. DISCOVER Foreign Currency Fee: 2% of the U.S. dollor amount of each purchase made in a foreign currency. Penally APRs: Each time you fat to malor a payment when due, we may, in accordance wdh applicable low, 11 trmirala tin availability of any inkociml ry/promdiond APRs on new transactions, and 1.1 increase your APRs for new transactions to vark&6 Penally APRs which will be determined by adding up to an additional 5 prcenkge points to the otherwise applicable APR. Your Penally APR Is determined based on your credkworA*w" and a" factors such as your current APRs, and your account history. I your APRs for new, konsoctions we increased for a late payment, the Penalty APRs will apply indelinilehr. For TDO )Teleeo?wnurticotioas Deeire for the Del) oaidonce, please coN 14800-347-7449. Discover may monitor and/or record telephone calls bekeaen you and Discover representatives far quality assn snca purposes. The Discoverm card is issued by Discover Bank Member FDIC O 1 TBK 172 m V 8971058 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# 8971058 Danna S. Lutes 6011003349824027 . I DISCOVER BANK Plaintiff vs. DANNA S LUTES TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION C--) c_A ?3C ?' - Civil Action No. 11- 3123 CI C7' t- ".._' n 'C C) -71 PRAECIPE FOR DEFAULT JUDGMENT D " M Kindly enter Judgment against the Defendant DANNA S LUTES above named, in the default of an Answer, in the amount of $6394.45 computed as follows: Amount claimed in Complaint Less payments / adjustments made Interest on the remaining principal from January 06, 2011 to August 09, C the interest rate of 13.9900 Attorney's fees TOTAL $5798.76 $0.00 balance 2011 per annum $470.69 $125.00 $6394.45 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 : \y James C. ar rodt,42 08971058F IC A Pit SJS Plaintiff's address is: 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 Defendant is DANNA S LUTES 1477 HILLCREST CT APT 804 CAMP HILL, PA 17011 W %l oo pd ablj C?-? 10b(?? dog IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DAN NA S LUTES Defendant Case No. 11-3123 CIVIL IMPORTANT NOTICE TO: DANNA S LUTES 1477 HILLCREST CT APT 804 CAMP HILL, PA 17011-`027 Date of Notice: .t , li? YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY X4D FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YGU 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. .'JU 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 THH," 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 tSy: Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 (412) 338-7130 8971058 A PIT H4N IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-3123 CIVIL DANNA S LUTES 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 , DANNA S LUTES 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: DANNA S LUTES 1477 HILLCREST CT APT 804 CAMP HILL, PA 17011 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsification to authorities. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Aug-16-2011 11:46:28 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency LURES DANNA • 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. vj0jj4, - Aut fn A?M_ Mary M. Snavely-Dixon, Director Department of D,:: fense - Manpower Data Center 1600 Wiison Blv.a , Suite 400 Arlington, VA 22:`09-2593 The Defense Mai.- power 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" 1JRL http:;'/w-wtiv.defeiiselin.k.m_il/fag/pis/P('09SL...DIZ.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), yoE: can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https:/;'wwN .dmdc.osd :nil/appj/scra/popreport.do 8/16/2011 Request for Military Status Page 2 of 2 More it V6 1-mation on "Active Duty Status" Active d+aty 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 prote ;tions 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 fast dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guE.ranteed to Service members under the SCRA are protected. WARNING: This ??.erti:icate was provided based on a name and SSN provided by the requester. Prcvidinb an erro?)eous name or SSN will cause an erroneous certificate to be provided. Report ID:BGJRI.'N8DBH httr?s://www.dm(+.-?.osd.inil/appj/scra/popreport.do 8/16/2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-3123 CIVIL DANNA S LUTES NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the ollowing Order of Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $6394.45 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Prothonotary By: DANNA S LUTES 1477 HILLCREST CT APT 804 CAMP HILL, PA 17011 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 WRIT OF EXECUTION and/or A.TTACHMEN'lf COMMONWI:ALTI-I OF PENNSYLVAIvfIA) COUNfI' OF CUMBERLAND) NO 2011-3123 Civil CIVIL ACTION -LAW TO THI SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From DANNA S. LUTES, 1477 HILLCREST CT., APT 804, CAMP HILL, PA 17011 (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: METRO BANK, 20 NOBLE BLVD., CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3 i 1 f property of the defendant(s) not levied upon an subject ro 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$5,744.45 L.L. $.Sa Interest - ; 31/5. ~,~{ Atty's Comm "/a Due Prothy $2.25 Atty Paid $195.50 Other Costs Plaintiff Paid Date: AUGUST 1.~, 2012 David D. Buell, Prothonotary (Seal) ~--~'~ ^ 1 - _ - Deputy REQUESTING PARTY: Name :MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA ]5219 Attorney for: PLAINTIFF Telephone: 412-434••7955 Supreme Court ID No. 90963 IN THE COURT OF COMMON FLEAS OF CUMBERLAND COCINTY, PENN SYLVANIA CIVIL DIVISION DISCOVER BANK ~ - Plaintiff "'`" =~= ~ z ~ ~ ' ~~ _~. r- - .", vs. Civil Action No. 11-3123 CIVIL u, r" -- c~. e~ C~ ~. ~'o~l. ~~;Ut ~ t-~otl DANNA S LUTES 11 ~ ~~ ~'M~ ~ -~v w ~ o ' ~'=-e~ ) y ~ ~ -v ~ '' Defendant(s) ~~t l~o13 le ~ l ' ~' ~ ~ ~ ~5 ~T3lvd. ~~o1e ° ~ METRO BANK , ~~ ~ o Garnishee(s) --C v~ PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTAKY: Kindly issue a Writ of Execution in the above matter... I . directed to the Sheriff of CUMBERLAND County: 2. against DANNA S LUTES ,Defendant 3. against METRO BANK, , ,Garnishee 4. Judgment Amount $ $6,394.45 Less Payments/credits received $ ~ ,~~ t($ $650.00 ~ ~ Interest $ $345.24 Costs $ SUBTOTAL: $ $6,089.69 Costs (to be added by Prothonotary): $ ~~q, °~~ Ou~~ S$ , ~, caF Gl 'off . ~ ~ ~ u ~~~"~~~ mi~s•~ WELTMAN, WEINBERG &REIS CO.. L.P.A. Matthew D. Urban, Esquire PA LD. #90963 WELTMAN, WEINBERG &REIS CO., L.P.A. ] 400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 S ~` W. ~~a Saw C~~ Ibl~S3~~ WWR No. 8971058 \,~ w IN THE COURT OF COMMON FLEAS OF CUMBERLAND COiJNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. I1-3123 CIVIL ~~~ vs. PRAECIPE FOR WRIT OF EXECUTION ~~1 DANNA S LUTES Defendant(s) METRO BANK Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA LD. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building ', 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR No. 8971058 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff itr of?iunbffil G Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. Danna S. Lutes SHERIFF'S RETURN OF SERVICE a. i? AU- 22 Ah Case Number 2011-3123 08/17/2012 10:50 AM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on August 17, 2012 at 1055 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Danna S. Lutes, in the hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Taryn L. Walters, Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on August 21, 2012 to Danna S. Lutes at 1477 Hillcrbst Ct, Apartment 804, Camp Hill, PA 17011. SO ANSWERS, August 21, 2012 RON R ANDERSON, SHERIFF d2t?? n Gu tsrSa Deputy , C-- 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAIiA a-... _.... F CIVIL DIVISION Cr% <771 DISCOVER BANK C© - cs- i Plaintiff Zo CD c N vs. Civil Action No. 11-3123 CIVIL CIO ` DANNA S LUf I'ES Defendant(s) METRO BANK Garnishee(s) TO: METRO BANK, 20 NOBLE BLVD, CARLISLE, PA 17013 RE: DANNA S LUTES, 1477 HILLCREST CT APT 804, CAMP HILL, PA 17011 Suggested Re4rence No.: XXX-XX-7662 XXX-XX- Sue IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon y6u. 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 i4ued. 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 liabililty 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. W WR No. 8971058 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)? Defendant has less than $300 exemption 1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof, the terms, facei amount and amount you owe or owed to defendant on each of such negotiable or other written instruments anal 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. 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? 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? 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 basin 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. WWR No. 8971058 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. 9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories ?pn 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. 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 fro>,n 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. 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 W WR No. 897 ] 05 8 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 Jennifer Hilbish (Name) Levi Specialist _ of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. "? , 1 0 ( 4111glIE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY nny R Anderson r ( 'a_OFF IC- Sheriff OF THE PRoTH 0 4 T,4 F, Jody S Smith �� 8 Chief Deputy g pH 2 35 Richard W Stewart Solicitor OFFICE OF THE SKRIFF Proo$ 'No Gotha y [.VANIA Discover Bank Case Number vs. 2011-3123 I Danna S. Lutes SHERIFF'S RETURN OF SERVICE 08/17/2012 10:55 AM-Shawn Gutshali, Deputy Sheriff,who being duly sworn according to law, states that on August 17, 2012 at 1055 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant,to wit: Danna S. Lutes, in the hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Taryn L.Walters, Manager, personally lbree copies of interrogatories together with three true and attested copies of the writ of execution and ma a the contents there of known to her. The writ of execution and notice to defendant was mailed on August 21, 212 to Danna S. Lutes at 1477 i Hillcrest Ct,Apartment 804, Camp Hill, PA 17011. 03/18/2013 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: $87.93 SO ANSWERS, March 18, 2013 RON R ANDERSON, SHERIFF ici CountySuite Sheriff,Teleosoft,Inc. ,� �� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-3123 CIVIL DANNA S LUTES • 9413) AY 6 - C% Defendant(s) hAf 114:)‹ pSS METRO BANK t au Svc b�� �-�� 06..v -'sly SUSQUEHANNA VALLEY FEDERAL CREDIT UNION 1 Garnishee(s) PRAECIPE FOR WRIT TO THE PROTHONOTARY: 11or3 2 s I416,A /dale Mt" N;tt, Pp (90fi OF EXECUTION C:.) o .._i Kindly issue a Writ of Execution in the above matter... 1 directed to the Sheriff of CUMBERLAND County: 2. against DANNA S LUTES , Defendant 3. against METRO BANK, SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, , Garnishee 4. Judgment Amount $ $6,394.45 $780.61 -1 Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): 3.\\\03 gat �v ��.93n /4f,1` 00 019, c° J <4 'I $1,123.61 $6,737.45 WELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. alecko, Esquire PA I.D. #°79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 aa,as bli//dcwo3 R{-213111, 411( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. No. 11-3123 CIVIL PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) DANNA S LUTES Defendant(s) METRO BANK SUSQUEHANNA VALLEY FEDERAL CREDIT UNION Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8971058 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID. D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net DISCOVER BANK Vs. DANNA S. LUTES WRIT OF EXECUTION (Pa R.C.P. 3252) NO 11-3123 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against DANNA S. LUTES, 2127 ARBOR CT., MECHANCISBURG, PA 17055 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of METRO BANK, 20 NOBLE BLVD., CARLISLE, PA 17013 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, 3850 HARTZDALE DRIVE, CAMP HILL, PA 17011GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $5,613.84 Plaintiff Paid Interest $1,123.61 Law Library Attorney's Comm. % Due Prothonotary $2.25 Other Costs Attorney Paid $311.'13 Date: 11/21/14 (Sea I) ;c- David D. Buell, Prothonotary By: REQUESTING PARTY: Name : JAMES P. VALECKO, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A 436 7Th AVENUE, SUITE 2500 PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 79596 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 - • ": .c. u I I0 IA 21-'4111 DEC —14 34 PE;',:;•!SYY 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DANNA S LUTES Defendant(s) Civil Action No. 11-3123 CIVIL CU\Sveis INTERROGATORIES IN ATTACHMENT METRO BANK SUSQUEHANNA VALLEY FEDERAL CREDIT UNION Garnishee(s) FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8971058 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DANNA S LUTES Defendant(s) METRO BANK SUSQUEHANNA VALLEY FEDERAL CREDIT UNION Garnishee(s) Civil Action No: 11-3123 CIVIL TO: METRO BANK, 20 NOBLE BLVD, CARLISLE, PA 17013 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, 3850 HARTZDALE DR, CAMP HILL, PA 17011 RE: DANNA S LUTES , 2127 ARBOR CT, MECHANICSBURG, PA 17055 Suggested Reference No.: XXX -XX -7662 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 atthe 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. 8971058 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)? No Accounts 1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. no 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. no 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? no 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? no 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. no WWR No. 8971058 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. no 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. 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. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. alecko, Esquire PA I.D. # .9596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8971058 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 Jennifer Hilbish (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ,f SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson .iLt° U Sheriff i .i PRO MONO O !P 1 '`ti PtOt-. xry Jody S Smith Chief Deputy DEC 10 P 3:24 Richard W Stewart ' CUMBERLAND COUNTY '•° Solicitor OFFICE; FmESPERIFF PENNSYLVANIA Discover Bank vs. Danna S. Lutes Case Number 2011-3123 SHERIFF'S RETURN OF SERVICE 12/01/2014 03:03 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, Metro Bank, 20 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Jane Adams, Manager, personally three copies •f interrogatories together with three true and attested copies of the Writ of Execution and mad: th 7 ontents there of known to her. 1 SO ANSWERS, , DEPUTY December 02, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuito Sherif(, Teieosc8, Inc Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OFTME E!(ERIFF PROTHONO. lA:l i 2511.1 DEC 10 PM 3: 26 CUMBERLAND COUNTY Discover Bank vs. Case Number Danna S. Lutes 2011-3123 SHERIFF'S RETURN OF SERVICE 12/08/2014 04:00 PM - Christopher Sharpe, 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 gamishee; Susquehanna Valley Federal Credit Union, 3850 Hartzdale Drive, Lower Allen Township, Camp Hill, PA 17011, Cumberland County, by handing to Cathy L. McLaughln, HR,Accounts Payable Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on December 9, 2014 to Danna S Lutes at 2127 Arbor Court, Mechanicsburg, PA 17055. CHR TOPHER SHARPE, DEPUTY SO ANSWERS, December 09, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff. Teleosoft, Inc. WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James P. Valecko, Esquire I.D. No. 79596 436 Seventh Avenue, Suite 2500 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 8971058 Attorney for Plaintiff(s) DISCOVER BANK CUMBERLAND County Court of Common Pleas vs. DANNA S LUTES NO. 11 -3123 -CIVIL and METRO BANK SUSQUEHANNA VALLEY FEDERAL CREDIT UNION Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter settled, discontinued, and ended as to Garnishee(s), METRO BANK and SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By James Valecko, Esquire Attorne for Plaintiff -H iiq.50 PD KM/ p,#.sf5130