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HomeMy WebLinkAbout11-3506I . IEO-OFFICE 4:,,t- "' ?0T ;ONOTAR 2911 AIF'R -6 PM is 17 .?, MPSERLAND COUNTY b-INSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: U V VS. COMPLAINT IN CIVIL ACTION LYNNE L NGO 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 09023155 C A Pit CXC $9a p0?da 6" 511 57jS" Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No LYNNE L NGO 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 ages, 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: LYNNE L NGO 108 WESLEY DR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2419 . 4. Defendant made use of said credit card and has a current balance due of $2460.54 , as of February 04, 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 19.49096 per annum on the unpaid balance from February 04, 2011 . 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 , LYNNE L NGO INDIVIDUALLY , in the amount of $2460.54 with interest at the rate of 19.490W per annum from February 04, 2011 plus attorneys' fees of $125.00 , and costs. vameS . warmbroat,42524 WELT WEINBERG & REIS CO., L.P.A. 436 a enth Avenue, Suite 1400 Pit b rgh, PA 15219 (41 ) 434-7955 F 12-338-7130 09 2 155 C A Pit CXC This law firm is a debt collector atterj ting to collect this debt for our client and any information obtained will be used for that purpose. DISCOVER New Balance Minimum Payment Du Account Number ending in 2419 $2,460.54 $2,460.54 Enter Amount Enclosed Below Payment Dw Date DUE IMMEDIATELY 08 SDSN6A01 0001412 LYNNE NGO 108 WESLEY DR MECHANICSBURG PA 17055-3541 Go paperises and make your account information more secure wlth pasmud- protscted statements ony you can access. Learn more at discover.com/paparless. PO BOX 6103 lllnr.llnrlluslulnnlnll CAROL STREAM IL 60197-6103 Address, e-mail or telephone charge!! ?n?lnl?nnn?l?n?n?nnlrl?nnnl??lnunl?r??nnr?ln?n+? Go to www.Discovw.com or print change in space above. 000001986458369161878024605400000000246054 EXHIBIT 7pensng vats: January I, !u I 1 closing Date: Discover More Card Account Summary Account number ending in 2419 Previous Balance $2,460.54 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 2, 60.54 See Interest Charge Calculation section following transactions for detailed APR information Credit line $2,100.00 Credit Line Available $0.00 Cash Advance Credit Line $0.00 Cash Advance Credit Line Available $0.00 Cas t Bonuse Anniversary Month October Opening Cashbock Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 Cashbock Beaus Balance $ 0.00 To horn more, log in at www.DhKover.com 3 Easy Ways to Contact Us 1 Access your account securely at www.Disc~.com 2. Coll 1.800-DISCOVER (1-80D-347.26831 Please have your Discoverecard available. 3. Write to us at Discover PO Box 30943, Salt Lake City, LIT 841 50 (Not a payment address( For payments, Please send to address on remittance or Discover, PO Sox 6 t03, Carol Stream, IL 60197-6103 For TDD (Telecommunications Device for the Deaf) assistance, please call I.804347-7449. 'Transactions 8, 2011 -A.i- - L? pap I -3= I Payment Information New Balance $2,460.54 Minimum Payment Due* $2,460.54 Payment Due Date DUE IMMEDIATELY *Includes past due amount of $404.00 Lab 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 24.4990 variable. Minimum 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: `::. Y?WaAalr??ta ipltf+?, Only the minimum 8 years $2,461 Payment IF you would like information about credit counseling services, call 1-800.347.1121 Manap Your Account Online at www.Dinow.com • Access free online tools like Paydown Planner to create a plan to lay down your balance, securely access statements, pay bil s online and easily track all transactions • Make your money worth morssm -find easy ways to earn and redeem cash rewards • NEW] Access your account securely through your mobile phone 9023155 Dates. Post Fees TOTAL FEES FOR TM PERIOD $ 0.00 Interest Charged TOTAL INTEREST FOR TM PERIOD $ 0.00 2011 Totals Year-to-Date TOTAL FEES CHARGED IN 2011 TOTAL INTEREST CHARGED IN 2011 0.00 0.00 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DI ER DISCOVER It pays to LYNNE NGO DISCOVER Account number ending in 2419 page 2 of 2 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Current Milling Period: 8 days TYPE OF BALANCE Purchases' 07/06/2010 and after 07/05/2010 and prior Cash Advances V ar Variable Rate ANNUAL PERCENTAGE RATE JAPIQ 19.49% V 14.49% V 20.99% BALANCE SUBJECT TO INTEREST RATE $0 $0 $0 INTEREST CHARGE $0 $0 $0 e Dates apply to non-promotional purchases and to expired promotions with dart dates within the specified date range Additional rnportam a" tim important Information. If there is more Own one page to this billing statement, we de back of each page for additional important information. See Your Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account. Lod or dolen cards. Report Immediately! Call 1-800-347.2683. What To De M You I'll" You Pied A Mistake On Year Statesseerst if you think Rare is an error an your statement, write to us at Discover, PO Box 30421, Sob Lake City, UT 841300421. In your letter, give us olio following information: 'Accourli T _ aFon: Yaii nolne onduccount nurimbeil - - - Dollar amount: The dollar amount of the suspected error. " Description of Problem: II you think Rare is an error on your bill, describe what you belle" is wrong and why you believe his a mistake. You must contact us within 60 days after the error appeared on your statement. You must notify us of any potential errors in writing. You may call us, but if you do we are not required to investigate any potential errors and you may have to pay the amount in question. While we investigate wheeler or not Ihere has been an error, Rat following are true: We cannot try to collect the amount in question, or report you as delinquent on Rat amoum. The charge In qquestion may remain on your statement, and we may continue to charge you interest on that amount. But, if we determine that we made a mistake, you will not have to pay Ow amount in question or airy Interest or other fees related to that amount. While you do not 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. Your Rights 0Yeu Are DLeoNsRed Willits Your Credit Card Purchases R you are dissatisfied with the goads or services that you have purchased with your credit card, and you have hied in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase. To use this right, all of the following must be true,- i . The purchase must haw been made in your home smote or widein 100 miles of your current mailing address, and the purchase price must have been more than $50. (Note: Neither of these are necessary il your purchase was based on on advertisement we mailed to you or 6 we own the company Rhat sold you to goods or services.) 2. You must haw used your credit card for the purchase. 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 haw fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in wrilirg at: Discover, PO Box 30945, Sall Lake City, UT 84130094S While we investigate, the some rules apply to the disputed amount as discussed above. Aber we finish our investigation, we will tell you our decision.. ALthat point, 6 we think you owe on amount and-you do not pay vire-maylepart.you as delinquent. Payments. Send only your payment and the top portion of this statement in the envelope provided. Do not send cash. By sendinngg yaw check w described above, you authorize us to use information on your cheek to make an electronic fund transfer from your account at t her Financial tratihtion indicated on your check or to process to payment as a check transaction. If payment is processed as on electronic Furhd transfer, des transfer will be for the amount of the check. When we use information from your check to make an electronic fund confer, funds may be withdrawn from your account as soon as the some day we receive yaw payment, and you will not receive your check beck from your financial institution. The processing of your poymeert tnoy he delayed 6 you send cash, eorrespondenu a other Bsms with your payment iF yyoou send Repayment to any other addressor if you use an emebpe other thou Rat o e provided. Payments received In pro feint at ow feracessrng (acilRy by SPM locol time on an day will Fie ":d ded 10 your Account as of Ilan day. Payments received al our pracesst (acRiry after S PM local Irma will be credited b yaw Account m of the next day. you haw misplaced your enwbpe, send your payment ta Discover, POx 6103, Carol Stream, IL 601974103. Please allow 7.10 days For del very. 6 youpayment I. rotwned unpaid, we reserve the right b resubmb it as an alectronk debit. You can pay your mimmum payment or a greater amount over the telephone, and you can set up automatic payments. Cog us at 1400347-2683. You will need this statement and yaw bank account information. You must ensure that sufficent funds are available in your bank account, and all transactions must comply with U.S. low. You will be asked to provide the first 5 digits of yaw account stetemert ZIP code. By entering those numbers as your electronic sign Mute, you will be agreeing to this authorization to allow us and your bank to deduct each payment you oullwrin from yaw bank account, and to Indicter debt or credo entries to your bank account, as applicable, to correct an error in the protesting of such payment You must W us de amount of each payment a you can select an amount such as the Minimum Payment Due or de New Balance on each statement You can cancel a payment, however we must receive ndics as least three business days in advance of the scheduled poyrrom. You may notify us by phone at 1400347-2683 or by mall at the address listed in the lZ ious paragraph. d your payments vary in amount, we will ell you on each monthly statement when your payment will be made and how much it will be. Your automatic payment amount may be less than Indicated on the monthly statement based on ere" or payments appiled during the billing cycle. Credit Reporting. We may report fnFormalion about your Account to credit bureaus. Lain payments, missed payments, or odor deleults on your Account may be reflected in your credit report. We normally report tie staNS and payment history of your Account to credit reportinngg agencies each month. If you believe that our report its inaccurate or incomplete, please write us of the following address: Discowr, PO Box 15316, Wilmington, DE 198505316. Reese indicate your name, address, home telephone number and Account number. Paying Infered: We begin to impose Interest Charges on all transactions from the Transaction Dole for the transaction shown on your Will statemem, unleu o transaction is posed b your Account oher the class of de billing period in which 8 occurs, in which caw we begin to impose Interest charges on that transaction horn the first day o (the billing period In which it is posted to your Account. We continue to impose Interest Charges u M the date you pay your entire New Balance shown on your billing statement by making payments or receiving credits. d you paid the New Balance on your previous 614ng statement by the Payment Due Date shown on that bilgeg statement, we will not Impose Interest Charges on new purchases, that is, purchases first oppeo??no on dot current bitting sbememr-or G"LPG tonaftonew pwchow, paid 6y4he Payment Due Date an your current billing statement. We :al-this Maraca period. 11 is not lee than 25 days. Thew is no grace period on balance transfers or cash ocivarsces. As more fully described in the section o?f yyour Cardmember Agreement Oiled 'How We Apply "ems, ' we generally apply payments to your Account hued on the APR applicable to the hot a of each transaction category. This means that 6 you do not pay the New Balance on the current billing statement by the Payment Due Date shown on that billing statement, then, depending on the amount of your payment and dot APRs on oiler balances, you may not get a grace period on new purchases. Minimum Interesl Charge. We will charge you a minimum Interest Charge of 3.50 for any billing period In which Interest Charges of less than $.50 would otherwise be imposed. AnnuN?.??Ioaur Account has an annual fee, it will be billed at the beginning of each anniversary year your Account is open. The amoum of the Fee a nth emont when the fee is billed. The annual his is not refundable unless you notify us that you wish to claw your Account within 30 days of the ma mg or de ivory date f *w satement on which the lee is billed. You will receive this refund even 6 you use your Card during that period, How We Cokuble Interest Charges Daily Balance Method (including current Ironsadions): We figure Interest Charges for each billing period. To do this: We calculate your Interest Charges separately for each bohance subject to different terms (for example, standard purchases, standard cash advances and each purchase, balance transfer and cash advance balance subject to promotional term+l. We refer to these balances as transaction categories. We !pure the "daily balance' for each transaction category. To get the "daily balance' we take the beginn Fig balance for each day, add any new transactions and fees and any Interest Chorgss accrued on 1fe previous day's daily balance. We then wbkoct any credits and payments and make other adjustments (including those adjustments required In 16e section 94W 'Paying Iniereu'j. In calculating Re daily balance for the first day of Ow billing period, we consider the 'previous day's daily bolancs' to have been your balance an the lost day of your previous billing period. This gives us the daily balance for each transaction category. We figure he Interest Charges on your Account by multiplying the doily balance for each tranwcthon category by its daily periodic rate, For each day in the tilling period. NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER 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# 9023155 Lynne L. Ngo 6011002256932419 DISCOVER BANK Plaintiff vs. LYNNE L NGO TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS f FILED-OFFICE CUMBERLAND COUNTY, PENNSYLVANIA `,F THE PROTHONOTARY CIVIL DIVISION 2011 JUL -8 PM 3: 39 CUMBERLAND COUNTY PENNSYLVANIA Civil Action No. 11-3506 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant LYNNE L NGO above named, in the default of an Answer, in the amount of $2764.71 computed as follows: Amount claimed in Complaint $2460.54 Less payments / adjustments made $0.00 Interest on the remaining principal balance of $2460.54 from February 04, 2011 to June 21, 2011 @ the interest rate of 19.490% per annum $179.17 Attorney's fees $125.00 TOTAL $2764.71 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. WELT By: James C. 09023155 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburg & REIS CO., L.P.A. ,425 A Pit SJS PA 15219 And that the last known address of the Defendant is LYNNE L NGO / 108 WESLEY DR MECHANICSBURG, PA 17055 .0 q - 41 F2? ?G ? LoS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-3506 CIVIL NON-MILITARY AFFIDAVIT LYNNE L NGO 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 , LYNNE L NGO 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: LYNNE L NGO 108 WESLEY 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. LYNNE L NGO Defendant Case No. 11-3506 CIVIL IMPORTANT NOTICE TO: LYNNE L NGO 108 WESLEY DR MECHANICSBURG, PA 170 5 Date of Notice: t Q. 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: 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 9023155 A PIT M4Z Request for Military Status Department of Defense Manpower Data Center Ad& Military Status Report 1W Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jun-24-2011 11:01:57 " Last Name First/Middle . Begin Date Active Duty Status Active Duty End Date Service Agency NGO LYNNE Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). iA. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/`vis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional. information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of-contact. 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 https://www.dmdc.osd.mil/appj/scra/popreport.do 6/24/2011 Request for Military Status Page 2 of 2 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:516HFRLHIO https://www.dmdc.osd.mil/appj/scra/popreport.do 6/24/2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff_ vs. Civil Action No. 11-3506 CIVIL LYNNE L NGO NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the f lowing Order of Judgment was entered against you on 79I (xx) Assumpsit Judgment in the amount of $2764.71 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: w PROTHONOTARY OR DEPUT LYNNE L NGO 108 WESLEY DR MECHANICSBURG, PA 17055 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 ,,?N ,? ,? WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire Attorney for Plaintiff(s) I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9023155 DISCOVER BANK Cumberland County -o T Court of Common Pleas =rt-t -?; vs. CIO , LYNNE L NGO NO. 11-3506 CIVIL - `.'. and C-- PSECU Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), PSECU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Jo C Warmbrodt, Esquire ev for Plaintiff I hereby certify that the foregoing is a true and correct This statement is made subject to the penalties of 18 P above case. relating to unsworn falsifications to authorities. +Q.50 PQ ATri 4 e* 103994691 p,t 2q1817 Co WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-3506 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From LYNNE L NGO, 108 WESLEY DRIVE, MECHANICSBURG, PA 17055 (I ) 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 $2,764.71 L. L. Interest $124.07 Atty's Comm % Atty Paid $231.50 Plaintiff Paid Due Prothy $2.25 Other Costs Date: APRIL 18, 2012 (Seal) REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE David D. Buell, Prothonotary Deputy 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. 1 I-3506 CIVIL ?? ? ?aSs LYNNE L NGO WoSle,IDrive, l I W6 Defendant(s) ?t 3 MEMBERS FIRST CU 17 I Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against LYNNE L NGO , Defendant 3. against MEMBERS FIRST CU... Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): art} $a? ? ?° ? lotur, IL1.CV>7ur? 1)0.56 It 0(o /I P T -G'" yam` ..? may. $ $2,764.71 $ $0.00 $ $124.07 $2,888.78 WELTMAN, WEINBERG & REIS CO., L.P.A. - I - 9:: ?-- ? ? 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 0 WWR No. 9023155 l2 r?-7 3 `? ?6F' A j r 1f oI & ?snjt c/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. LYNNE L NGO Defendant(s) MEMBERS FIRST CU Garnishee(s) No. 11-3506 CIVIL 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. 9023155 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor E 2012 APR 26 PM 2: 2 8 £,UMKRLA D COUNTY PENNSYLVANIA Discover Bank vs. Case Number Lynne L. Ngo 2011-3506 SHERIFF'S RETURN OF SERVICE 04/24/2012 09:20 AM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 24, 2012 at 0918 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Lynne L. Ngo, 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 Marisol Barber, Assistant Branch 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 April 25, 2012 to Lynne L. Ngo at 108 Wesley Drive, Mechanicsburg, PA 17055. SO ANSWERS, April 25, 2012 RO IT AN ERSON, SHERIFF f Sh,iwn N.-P frison, Deputy THE PRO ON()TARY 20 12 JUL 27 PM 2-- 0 I CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLv CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 11-3506 CIVIL LYNNE L I+tGO ??rti???S Defendant(s) INTERROGATORIES IN ATTACEDdENT MEMBERS FIRST CU Garnishee(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 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any were you liable to him on any negotiable or other written instrument, or did he claim that you owed him f or were liable to him for any reason (including funds on deposit for checking or savings accounts and cer deposit)? +I:,- - - 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 fund, the present loci the terms, face amount and amount you owe or owed to defendant on each of such negotiable or instruments and the present location of each of such instruments; the amount or amounts that defends claimed that you owe or owed to him; and the nature and amount of each of such liabilities. -PP6 \ -j-kA - d6ck I \ Arr" •;?O r- 'Aka-7 A 16 o r . R 4 -', ?c-\.AAJ1. 3 iney or money gates of thereof; written laims or P-<M'-' 2. At the time you were served or at any subsequent time was there in your possession, ustody or control of yourself and one or more other persons any property of any nature owned solely or in pkrt by the defendant. N 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 anyroperty 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 pro erty to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? NJ 7. If you are a bank or other financial institution, at the time you were served or at any sub qu time did the defendant have funds on deposit in an account in which funds are deposited electronically o a recurring basis and which are identified as being funds that upon deposit are exempt from execution, le or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the a em the amount being withheld under each exemption and the amount of funds in each account, and the enti electronically depositing those funds on a recurring basis. WWR No. 9023155 8. If you are a bank or other financial institution, at the time you were served or at any subs time did the defendant have funds on deposit in an account in which the funds on deposit, not including z otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. so, identify each account. ?) To r % %00l, 8 'A -p . Qt) e 01 § 0123? If 9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. i ?P A aq11- 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, heck or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold b this institution. NX'\ 11. If the response to Interrogatory 7 is in the affirmative, are glh_ff funds comingled in the ac ount which are not deposited electronically on a recurring basis and which are identified as being funds that u n deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? ?4 r A 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt f?ds 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. 9023155 Ca?? Ut ER?-Ay LS kstAIA IN THE COURT OF ?OIP OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. LYNNE L NGO Defendant MEMBERS FIRST CU Garnishee No. 11-3506 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 WWR#9023155 a,,p,.k0, lle.?-6 ??d Q C?k I6(oS3s ? M?A 1? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 1 1-3506 CIVIL LYNNE L NGO Defendant MEMBERS FIRST CU Garnishee PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, MEMBERS FIRST CU, in the amount of $701.84, *hich is less than the amount Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. 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#9023155 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7th Avenue, Pittsburgh, PA 1521 And that the last known address of the Garnishee is: 5000 Louise Drive, P.O. Box 40, Mechanicsburg, PA 1 055 JUL-24-2012 TUE 12:05 PM MEMBERS 1ST MEMBER SVCS FAX NO. 7177956005 P,102 INTMOGATO'RIES IN A'ITTACE MENT 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 mo ey or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificate of deposit)? 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 fund, the present location then of; 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 claim or claimed that you owe or owed to him; and the nature and amount of $h of such liabilities. oc3 ` Mr% 2, At the time you were served or at any subsequent time w ownedusolelyeoriinspacustod or rt by the control of yourself and one or more other persons any property of any nature defendant. No 3, At the time you were served or at any subsequent time did you hold legal title to any prope 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 prope in which the defendant had an interest? Ro S At any p before after you direct ons or consent and of so what was the c nsideraC on there P 14 you or to any person or place pursuant to the 6. At any time Were odid you otherwiserdischarge any claimoof property the de, 'o dant defendant or to any person on or place pursuant against you? Nc. 7. if you are a bank or other financial institution, at the time you were served or at any subsequ 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, [dentify each account and state the reason for the exemI 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. 9023155 JUL-24-2012 TUE 12:05 PM MEMBERS 1ST MEMBER SVCS FAX NO. 7177956005 P.103 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. ?}ti Q?v.a.??? . S \00?, ?} vn' `? ??'? 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. P rN z l? 10. If the answer to Interrogatory I is in the affirmative, state the date the written instrument, check or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. NY-,\ -?? 11. If the response to Interrogatory 7 is in the affirmative, are g1t&r funds comingled in the account which are not deposited electronically on a recurring basis and which are identified as being funds that upon del are exempt from execution, levy or attachment under Pennsylvania or federal law? 1,4 1A 12. If the response to interrogatory 1 I is in the affirmative, state the amount of non-exempt funds deposit in the account. Wl?LTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA T.D. #90963 W,VfMAN, WETNBERG & REIS CO.,'L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 9023155 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 11-3506 CIVIL LYNNE L NGO Defendant MEMBERS FIRST CU Garnishee NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff ( ) Defendant (xx) Garnishee You are hereby notified that the following Order or Judgment as entered against you on / a (xx) Assumpsit Judgment in the amount of $701.84 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 suspended by the Department of Transportation, Bureau of Traffic Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration Award ProthonotaJfMARY By: ' q-,. 3 , PROT (OR DEPUTY) MEMBERS FIRST CU 5000 LOUISE DRIVE P.O. BOX 40 MECHANICSBURG, PA 17055 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire I.D. No.47437 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.79SS Fax: 412.434.7959 File # 90231 SS Attorney for Plaintiff(s~;~ p~~ ~'~Q ~ ~FtC nH~TAFt'Y 2012AUG20 f~M I~ 14 '~~~t,ER~.AND 0~ ~'~~NS YLY NI DISCOVER BANK vs. LYNNE L NGO, and MEMBERS 1ST FCU Garnishee(s) CUMBERLAND County Court of Common Pleas NO. 11-3506 CIVIL PRAECIPE TO SATISFY ATTAC)EIIVIENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter satisfied as to Garnishee(s), MEMBERS 1ST FCU, , only. WELTMAN, WEINBERG & REIS CO., L.P.A. By ~/ William T. Molczan, uire Attorney for Plainti a~. ~- q. ~~~ ~C ~,~- a~ Y 0 ,~o i 8 19573 WRIT OF EXECUTION and/or ATTACHMENT Ct)MMC?NWEALTH OF PENNSYLVANIA) C6)UNTY OF CUMBERLAND) NO 11••3506 Civil CIVIL. ACTION - LA~% ~I'O'1'HE SHERIFF OF CUMBERLAND COUNTY: ~I~o satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From LYNNE L. NGO, 108 WESLEY DRIVE, MECHANTCSBURG, PA 17055 ~ I i You are directed to levy upon the property of the defendant (s)and to sell t~' i You are also directed to attach the property of the defendant(s) not levied upon in the possf:~ssicyn u. GARNISHEE(S) as follows: MEMBERS ]s~ FCU, l7ll SPRING ROAD, CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (bj 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; (~ 1 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 Jue 52,062.87 L.L. $ Interest S209.93 Atty's Comm `gib Due Prothy $2.25 A~tv Paid $286.50 Other Costs Plaintiff Paid Date: l 0/31 /12 David D Buell• Protho of (S~a!1 By: ~ ~Q~_ Deputy RI:QUFS~I I?vG PAKTY: 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 Tr~lephone: 412-434-'7955 Suprerr~e Court ID No. 47437 IN THE COiJRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK PEaintifi~ ~s• Civil Action No. 11-3506 CIVIL - - - Wc~S~e 'fir . rv~, LYNNE L NGO ~ b~ ~ ~ ~aSS ~~ ~~ Defendant(s) ~~~` ~ ~ -_,~ e1 ~ r ~~ SAP ~µ ~ ~~r3 _ ~.. MEMBERS 1 S7' FCU i I ~ « ~ ~ ~ ~ ' ~ Garnishee(s) ~ _ - -~`~ -_- ~ ~-, PRAECIPE FOR WRIT OF EXECUTIOlSf ~ - TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... I . directed to the Sheriff of CUMBERLAND County: 2. against LYNNE L NGO ,Defendant 3. against MEMBERS 1ST FCU, , ,Garnishee 4. Judgment Amount $ S2 764 71 Less Payments/credits received $ $7O1 •g;4 1~p~t ~~~ D~ interest $ `~209.9~3 Costs $ SUBTOTAL: $ $2,272.80 Costs (to be added by Prothonotary): $ ~ ~ `1G eo ,xL,, a-~'`~ ~~ s~,o~ :.a~ ~ t~ .r 1 '~. U~ ~ ~~~~~~ o~ Q1 ~ , ~~', ~~,~, G~ ~ ~ t < <" WELTMAN, WEINBERG & REIS CO., L.P.A. 3 r J r, r, William T. Molczan, Esquire PA I.D. #4743 7 s;% WELTMAN, WEINBF,RG & RE[S CO.. L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 .as~~ ~~ ~a ~~ aaasay WWR No. 90231 a i (~~~ ~~ ~x ~s~~~e~a '~ IN THE C011R"I' OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS~'LVANIA CIVIL DIVISION DISCOVER BANK Plaintitf` v. LYNNE. L NGO Defendant(s) MEMBERS 1 S7~ FCI1 Garnishee(s) No. 1 1-3506 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 l.D. #47437 WELTMAN, WEINBERG & REIS CC)., l,.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR No. 902315 `+ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~ ~? ~~ Sheriff ~ ~° ~ ~ f: ;,, ~ .II ~,,,~'~ Jody S Smith _ ~'~`~ g ~ ~~ Chief Deputy ~ ~r~ ~' !r Richard W Stewart `~` .tip y,~ Solicitor ' Discover Bank Case Number Lynne L. Ngo SHERIFF'S RETURN OF SERVICE 11/05/2012 11:05 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on November 5 2012 at 1100 hours, attached as herein commanded all goods, chattels, rights, debts. credits, and monies of the within named defendant, to wit: Lynne L. Ngo, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County. Pennsylvania, by handing to Connie Barrick, Member 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 November 6, 2012 t Lynne l.. Ngo at 108 Wesley Drive, Mechanicsburg, PA 17055. /~ LI M CLINE, DEPUTY SO ANSWERS, November 06, 2012 RONi~1Y R ANDERSON, SHERIFF L- ' ~ ~ t~ ~. r~~~t~ t ~3C?i'1C~T,"~{'i± A 2p~~. q ~ _ (ti : ; o Nov 6 L U i ~ ~a~.' 7 t7 ~,.~;~~?>~At~~ COUNTY r ~~~~dSYLYANiA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. LYNNE L NGO Defendant(s) MEMBERS 1ST FCU Garnishee(s) Civil Action No. 11-3506 CIVIL INTERROGATORIES IN ATTACHMENT 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. 9023155 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ~~yp DISCOVER BANK Plaintiff vs. LYNNE L NGO Defendant(s) MEMBERS 1ST FCU Garnishee(s) Civil Action No. 11-3506 CIVIL TO: MEMBERS 1ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 RE: LYNNE L NGO , 108 WESLEY DR, MECHANICSBURG, PA 17055 Suggested Reference No.: XXX-XX-6093 XXX-XX- IMPORTANT NOTICES TO GARNISHEE! EtECE N0~ 6 201ti 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. 9023155 RECEWED NOV ~ 201 INTERROGATORIES INATTACHMENT 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)? N 1 a. If the answer to Inter: ogatory 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. ~' 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? ~ 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? ~ ~ 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 considerati'on\thereof? I~ 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? A '~ O 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. ~ .~ WWR No. 9023155 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. t ~/~ ,.~, ~~~Q 'l S •~,~~ 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. t t' ~ I 1 ~ 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. l t (~ I 1 ~ 11. If the response to Interrogatory 7 is in the affirmative, aze 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. t 1( WELTMAN, WEINBERG & REIS CO., L.P.A. By: ~/~M~~ William T. Molczan, Esquir PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 ~~G~~~D ~2Q,~~a N0~ WWR No. 9023155 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that h she s ~~ ~ C S i (Name) 0 w~.. a of ~~~, 1 ~~ ,garnishee herein, Title) (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) ~~ WWR No. 9023 ] 55 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire I.D. No.47437 436 Seventh Avenue, Suite 1400 Pittsburgh,PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9023155 Attorney for Plaintiff(s) DISCOVER BANK CUMBERLAND County Court of Common Pleas vs. LYNNE L NGO, NO. 11-3506 CIVIL and MEMBERS 1ST FCU <;arnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION W; z l: .. ~~ .__ . ...w ~ _;~:, '.. , ~_ ~ v , ~' ~ ;~ ~~.., ~., -~ ~~, .~ ~a _ -- - '~ r~ .. + ~-° ~ : „~ .. ...~, c , TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), MEMBERS 1ST FCU, , only. WELTMAN, WEINBERG & REIS CO., L.P.A. r-- By William T. Molczan, E ire Attorney for Plaintiff ~~~ q.5o~cl a~~ 1o84~S~7 1~ a83Y'lS . ~ � SHERIFF'S OFFICE 0F�CUMBERLAND COUNTY Ronny FiAnderson �y Sheriff � �F -A �-~~ e{ ~ /..� pKOTA�W0Tb�v a�^-- -"*� ~ '""''- ''`� ' Chief Deputy 2013 AUG 30�m�� ����h / '. '_ 2� ' Richard VVStewart CUMBERLAND~°' COUNTY Qn��x ~ Discover Bank Case Number vs. | 2011'8506 Lynne L. Ngo � SHERIFF'S RETURN OF SERVICE 11/O5/2O12 11:O5AM'VW||iomC|ino. Oapub/Ghehff,xvhobeingduh/sxmnnaccordingto|aw.mtmteothmton November 5, 2012 at 1100 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, bowit: Lynne LNgo. in the hands, possession, or control of the within named garnishee, Members 1ot Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania, by handing to Connie Boniok. Member 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 toher. The writ of execution and notice hmdefendant was mailed on November 6.2O12bm Lynne LNgoet1O8 Wesley Drive, Mechanicsburg, PA17O5S. 08/28/2013 Ronny R. Anderson, Sheriff,who being duly sworn according bo law,states this writ of execution ie returned aeABANDONED. Nn action on writ in over Gmonths. P|ainbU"s attorney did not collect any funds from the bank garnishment. SHERIFF COST: s86.95 SO ANSWERS, August 20` 2O13 xummr n ANDERSON, SHERIFF 2- -�S- , � � � � � ^ "-�^ «r ` (c)CounlySufte Sheriff,Teleosoff,Inc, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff I.A: i HE PROTH N 1t'j, ;' �. Jody S Smith Chief Deputy s, r' 2013 AUG 3Q AH 10: 26 Richard W Stewart Solicitor Solicitor OFr) E Or THE SHERIFF PENNSYLVANIA Discover Bank Case Number vs. 2011-3506 Lynne L. Ngo SHERIFF'S RETURN OF SERVICE 04/24/2012 09:20 AM -Shawn Harrison, Deputy Sheriff,who being duly sworn according to law, states that on April 24, 2012 at 0918 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant,to wit: Lynne L. Ngo, in the hands, possession, or control of the within named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Marisol Barber,Assistant Branch 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 April 25, 2012 to Lynne L. Ngo at 108 Wesley Drive, Mechanicsburg, PA 17055. 08129/2013 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. Plaintiffs attorney did collect$701.84 from bank garnishment. SHERIFF COST: $100.20 SO ANSWERS, x 2X��— August 29, 2013 RON R ANDERSON, SHERIFF 07°oZ.S- (o)CountySuite Sheriff,Teleosott,Inc.