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HomeMy WebLinkAbout11-4955t - TiE Pr OTHOENOTAfl Y "Q 11 JU' 15 PM 2: U 7 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: I I.- qq SS ci"*' vs DAVID A STUM COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 09134103 C A Pit KMJ S %gaaaVa CL 4t cLIt SPIUgq 3 9 4 aGa?7? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No DAVID A STUM Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, DISCOVER BANK is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 2_ Defendant is adult individuals; residing at the address listed beIow: DAVID A STUM 3059 RITNER HWY CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX6122 . 4. Defendant made use of said credit card and has a current balance due of $12372.59 , as of February 28, 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 17.240% per annum on the unpaid balance from February 28, 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. ai.thougth -etieatediy regraeszed 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 , DAVID A STUM individually , in the amount of $12372.59 with interest at the rate of 17.240% per annum from February 28, 2011 plus attorneys' fees of $125.00 , and costs. Li ames WELTM 436 S Pitts (412) FAX: 0913 This law firm is a debt collector atte our client and any information obtaine Warm b t,42524 WEINBERG & REIS CO., L.P.A. nth Avenue, Suite 1400 gh, PA 15219 4-7955 -338-7130 3 C A Pit KMJ ?ng to collect this debt for ill be used for that purpose. DISCOVER New Balance I Minimum Payment Due $12,372.59 2,372.59 $12,372.59 _ Payment Due Date DUE WIMEDIATELY 08 SDSN6AOt 0005534 DAVID STUM 3059 RITNER HWY CARLISLE PA 17015-9491 Account Number ending in 6122 Enter Amount Enclosed Below Go paperless and make your account information more secure with password- protected statements only you can access. Learn more at discoveccorn/papedess. PO BOX 6103 111+nflmilnsf ulnnlrll CAROL STREAM IL 60197-6103 Address. -cil or?eiephone chanye2 ?i+l l?iu ut)i??irln ?lt(tnn+ll?l+i utllill nt?tlli ?lnll Go to www.Discovw.com or print change in space above. 000001986618299975438123725900000001237259 EXHIBIT 1 Opening Date: March 1, 2011 - Closing Date: March 8, 2011 I Discover More Card Account Summary Account number ending in 6122 Previous Balance Payments And Credits Purchases Balance Transfers Cash Advances Fees Charged Interest Charged New Balance $12,372.59 0.00 + 0.00 + 0.00 + 0.00 + 0.00 + 0.00 $12,372.59 See Interest Charge Calculation section following transactions for detailed APR information Credit Line $12,200.00 Credit brie Available $0.00 Cash Advance Credit Line $0.00 Cash Advance Credit Line Available $0,00 Cashback Bonuse Anniversary Month April Opening Cashbock Bonus Balance S 0.00 New Cashbock Bonus This Period + 0.00 Cashback Bonus Balance $ 0.00 To I- more, log in at www.Diima mncom page 1 of 2 Payment Information New Balance $12,372.59 Minimum Payment Due' $12,372.59 Payment Due Date DUE IMMEDIATELY `Includes past due amount of $2,081.00 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee of up to $35.00 and your purchase and balance transfer APRs For new transactions may be increased up to the Penalty APR of 22.24% 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: If you make no You will pay off ifte And you will and adattional charc3e3 balance shown 'on up payhV an usiing card and this statement in estimated totcl of: each month you pay about Only the minimum 15 years $12,373 payment It you would like information about credit counseling services, call 1-800-3,47-1121 3 Easy Ways to Contact Us Manage Your Account Online at www.Discover.corn 1 Access your account securely at www.Dirscavw.corn 2. Call 1-800-DISCOVER (1-800347-26831 Please have your Discoverecard avoilob(e Access free online tools like Paydown Planner to create a plan to down your balance, securely access statements, pay b . 3. Write to us at Discover, PO Box 30943 ills online and easily track all transactions , Salt Lake City, UT 84130 (Not a payment address) Make your money worth more l-find easy ways to earn For payments, please send to address on remittance or and redeem cash rewards Discover PO Box 6103, Carol Stream, IL 60 1 97-6 1 03 NEW! Access your account securely through your For TDD (Telecommunications Device far the Deaf) mobile phone assistance, please call 1-800.347-7449, Transactions 9134103 TDa`O11ia PD°o e F"S TOTAL FEES FOR THIS PERIOD S 0.00 Interest Charged TOTAL INTEREST FOR THIS PERIOD S 0.00 2011 Totals Year-to-Date TOTAL FEES CHARGED IN 2011 TOTAL INTEREST CHARGED IN 2011 $ 70.00 369.04 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION 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. 5n •.;p 'oaay of Discover.com/papedess 02010 Disc- Bono- M-6e FDIC PAPER 03 110 m Z rn D o_ 0 0 0 A N X J 9134103 Questions? visit www.Discover.com or call 1 800-DISCOVER (I -800-3A7-2683), DISCOVER DISCO-VEIZ It pays to DAVID STUM _. DSCOVUr- Account number ending in 6122 page 2 of 2 Interest Charge Calculation Your Annual Percentage Ratej,is the annual interest rate on your account. Current SAing Period: 8 days TYPE OF BALANCE Purchases' 08/29/2010 and after 08/28/2010 and prior Cash Advances ANN EUAL PERCENTAGE RAT (AM BALANCE SUBJECT TO INTEREST RATE INTEREST CHARGE 17.24% 15.24% 23.99% $0 s0 s0 $O $0 $O V = variable Rate mares acciv to non-promotional aurchases and,'o expired promotions,wth start dates within ,tire specified date rarge Additional Important Information -- See your Cordmember Agreement. Your Cardmember Agreement contains all the terms of your Account Lost or stolen cards. Report immediately! Call 1-800-347-2683. What To Do If You Think You Find A Mistake on Your Sta?errrent If you think there is an error on your statement, write to us at: Discover PO Box 30421 Salt Lake City, UT 84 1 30-042 1 In your letter, give us the following information: Account information: Your name and account number Dollar amount: The dollar amount of the suspected error Description of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. You must contact us within 60 days 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 whether or not there has been an error, the following are true: We cannot try to collect the amount in question, or report you as delinquent on that amount. The charge in qquestion ma remain on your statement, and we may continue to charge you interest on that omount. But, if we determine that we made a mistake, you will not have to pay the amount in question or any interest or other fees related to that amount. While you do not have 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 If You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase. To use this right, all of the following must be true: 1 The purchase must have been made in your home state or within 100 miles of your current mailing address, and the purchase price must have been more than $50. (Note: Neither of these are necessary if your purchase was based on an advertisement we mailed to you , or if we own the company that sold you the goods or services.) 2. You must have 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 have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writing at: Discover, PO Box 30945, Sak Lake City, UT 84130-0945 While we investigate, the same rules apply to the disputed amount as discussed above. After WS finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent Paymenh. Send only your payment and the top portion of this statement in the envelope provided. Do not send cash. By sending your check as described above, you authorize us to use information on your check to make an electronic fund transfer from yyour account at the Financial institution indicated on your check or to process the payment as a chock fransadion. If payment is processed as an electronic fund transfer the transfer wifl be for the amount of the check. When we use information from your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your financial institution. The processing of your payment may be delayed if you send cosh, correspondence or other items with your payment, if you send the payment to an other address or if you use an envelope other than the one provided. Payments received in proper form of our processing facility by 5PM local time on any day will be credited to your Account as of that day. Payments received at our processing facility affsr SPM local time will be credited to ur count as of }hs next day. If you have misplaced your envelope, send your payment to Discover PO Box 6103/ Carol Stream, IL 601 97-6 1 03. Please allow 7 10 days for delivery. If your payment is returned unpaid, we reserve the rig?t to resubmit it as an electronic debit. You can pay your minimum payment or a greater amount over the telephone, and you can set up automatic payments. Call us at 1-800 347-2683. You will need this statement and your bank account information. You must ensure that sufficient funds are available in your bank account and all transactions must campti with U.S. law. You will be asked to provide the first 5 digits of your account statement ZIP code. By entering those numbers as your electronic signature, you will be ocireeing to this authorization to allow us and your bank to deduct each payment you authorize from your bank account, and to Initiate debit or credit entries to your bank account, o3a Icab6, to correct an error in the processing of such payment. You must tell us the amount of each payment or you can select an amount such as the Minimum Paymerlf Due or the Now Balance on each statement. You can cancU;, ymenthowever we must receive notice at least three business days in advance of the scheduled p ent. You may s by phone at 1-800.347-2683 or by moil at the address listed in the previ s ou parsyraph. If your payments vary in amount, we will tell you on each monthly statement when your end, Il b u and how much it will be. Your automatic payment amount may be less than indicated on the month=ement based on c94i$??Ients applied during the bilfing cycle. Credit Reporting. We may report information about your Account to credit bureaus. Late payments, missed payments, or other defaults on your Account may be reflected in your credit report. We normally report the status and payment history of your Account to credit reporting agencies each month. If you believe that our r,, is inaccurate or incomplete, please write us at the following address: Discover, PO Box 15316, Wilmington, DE 19850-5316_ Please indicate your name, address, home telephone number and Account number NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER Paying Interest We begin to impose Interest Charges on all transactions from the Transaction Dale For the transaction shown on your billing statement, unless a transaction is posted to your Account after the close of the billing period in which it occurs, in which case we begin to impose interest charges on that transaction from the first day of the billing period in which it is posted to your Account. We continue to impose Interest Charges until the date Cow your entire New Balance shown on your billing statement by making payments or receiving credits. If you paid the Now Balance on your previous billing statement by the Payment Due Date shown on that billing statement, we will not impose Interest Charges on new purchases, that is, purchases first appearing on the current billing statement, or any portion of a new ppurchase, T. by the Payment Due Date on your current billing statement. We call this the "grace period. It is not less than 25 dayyss There is no grace period on balance transfers or cash advances- As more fully described in the section of your Cardmern r Agreement hued "How We Apply Payments," we generally apply payments to your Account based on the APR a piicable to the balance of each transaction category. This means that if you do not pay the Now 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 the APRs on other balances, you may not get a grace period on new purchases. Minimum Interest Cher . We will charge you a rninimum Interest Charge of 5.50 For any billing period in v.hich Interest Gorges of tens than S0 would otherv'se oe Imposed Arinuai Fee. it your ,Account has an annual fee d nll be btlled at 'he oeginninq of each anniversary,/ear dour Account is open he amount of the lee appear: on the statement when the tee is billed The annual fee is rot -efundabie unless You notet?yy ;hat you wish to close your Account within 30 days of the mailing or delivery date of the statement an which the fee is billed. You will receive this refund even if you use your Card during that period. How We Cakt" Interest Charges Doily Balonee Method (including current transactions): We figure Interest Charges far each billing period. To do this: We calculate your Interest Charges separately for each balance subject to different terms (for example, standard p:_rchasas, standard cash advances anci each purchase, balance transfer and cosh advance balance subject to promotional terms). We refer to these balances as transaction categories. We figure the "daily balance" for each transaction category. To get the "daily balance" we take the beginning balance for each day, add any new transactions and Fees and any Interest Charges accrued on the previous day's daily balance. We then subtract any credits and payments and make other adjustments (including those adjustments required in the section titled "Paying Interest"). In calculating the daily balance for the first day of the bil?ing period, we consider the "previous day's daily balance" to have been your balance on the last day of your previous billing period This gives us the daily balance For each transaction category. We figure the Interest Charges on your Account by multiplying the daily balance for each transoction category by its daily periodic rote, for each day in the billing period. The total letterise Charges for the billing period are the sum of the daily Interest Charges for each transaction category for each day during that billing period. When we calculate daily balances, we add a new transaction as of the Transaction Date shown on your billing statement unless the transaction is posted to your Account after the close of the billing period in which it occur, in which case the transaction will be added to the daily balance as of the first day of the billing period in which it is posted to your Account. All fees charged to your Account are added to the standard purchase transaction category with the exception of Cash Advance Fees which are added to the applicable cash advance transaction category and Balance Transfer Fees which are added to the applicable balance transfer transaction category. Foreign Currency Fee: 2% of the U.5 dollar amount of each purchase made in a foreign currency. Penalty APRs: Each time you Fail to make a payment when due, we may, in accordance with applicable law, (i) terminate the availability of any introductory/promotional APRs on new transactions and (ii) increase your A s for new transactions to variable Penalty APRs which will be determined by adding up to an a?difionaf 5 percentage points to the otherwise applicable APR. Your Penalty APR is determined based on your creditworthiness and other lectors such as your current APRs, and your account history - it your APRs for new transactions are increased for a late payment, the Penally APRs will apply indefinitely. For TDD (Telecommunications Device for the Deaf) assistance, please call 1-800-347-7449. Discover may monitor and/or record telephone calls between you and Discover representatives for quality assurance purposes The Discovermcard is issued by Discover Bank, Member FDIC 0118C72 9134103 Questions? Visit www.Discover.com or call 1 800-DISCOVER (1-800-347-2683) 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 Szczveiel, Legal Placement Account Manaser (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. f (ignature) WWR# 9134103 David A. Stum 6011298812856122 Y SHERIFF'S OFFICE OF CUMBERLAND COU r -, Ronny R Anderson Sheriff Jody S Smith Chief Deputy "" == Richard W Stewart -- Solicitor Discover Bank vs. David A. Stum Case Number 2011-4955 SHERIFF'S RETURN OF SERVICE 06/20/2011 08:44 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 20, 2011 at 2044 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: David A. Stum, by making known unto Michael Crawford, adult in charge at 3059 Ritner Highway, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $34.00 June 21, 2011 TIM BCAQK DEPUTY SO ANSWERS, RON ~ R ANDERSON, SHERIFF ?C, 000t1tySU1t0 Shrer!ff. TeleosOft, Iii-. 4 DISCOVER BANK Plaintiff vs. DAVID A STUM TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NOTA.., ;?°9E EnLr TdD COUNT`,` Civil Action No. 11-4955-CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant DAVID A STUM above named, in the default of an Answer, in the amount of $13401.30 computed as follows: Amount claimed in Complaint $12372.59 Less payments / adjustments made $0.00 Interest on. the remaining principal balance from February 28, 201:1 to August 02, 2011 C the interest rate of 17.240. per annum $903.71 Attorney's fees $125.00 TOTAL $13401.30 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. James C . l air ro t , 4 09134103/0 A Pit SJS Plaintiff's address is: c/o WELTMAN, WEINBERG & RE:IS CO., L.P.AJrdant 436 Seventh Avenue, Suite :1400 PittsburA 15219 And that the last known address of the is DAVID A STUM 3059 RITNER HWY CARLISLE, PA 17015 4 Qrv?? ;1 y 06 FCAa 1 c" 1604clibq V Wd bgs 5 a .IN THE t'OURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DAVID A STUM Defendant Case No. 11-4955-CIVIL IMPORTANT NOTICE TO: DAVID A STUM 3059 RITNER HWY CARLISLE, PA 1701;: Date of Notice: YOU ARE IPi DEF'WLT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR ;13Y ATTORNEY AND FILE. 1N 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 ENTEREC? 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 0-- TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATON 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 9134103 A PIT M4Z IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-4955-CIVIL DAVID A STUM 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 staters that based upon investigation it is the affiant's belief that the Defendant , DAVID A STUM is not in military service. Affiant further stater 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: DAVID A STUM 3059 RITNER HWY CARLISLE, PA 17015 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 Ad1h Military Status Report 1W Pursuant to the Service Members Civil Relief Act -,K;. Last Name Begin Date I Active Duty Status STUM I DAVID Page 1 of 2 Aug-04-2011 07:51:38 Active Duty End Date I Service on the information you have furnished, the DMDC does not possess any information ing 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). Ak ? 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/-pis/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 RDAs. 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,lappj/'Scra/popreport.do 8/4/2011 Request for Military Status Pa e 2 of 2 g 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:R7KQB46TUL https://www.dmde.osd.mil/appj/scra/popreport.do 8/4/2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DAVID A STUM Civil Action No. 11-4955-CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following order of Judgment was entered against you on 2 17 (xx) Assumpsit Judgment in the amount of $13401.30 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 ward Prothonotary By: _ (OAO T)v( UnrTnmTr?ti ., DAVID A STUM 3059 RITNER HWY CARLISLE, PA 17015 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 ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-4955 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From DAVID A. STUM, 3059 RITNER HIGHWAY, CARLISLE, PA 17015 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: M & T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $13,401.30 Interest $26.44 Atty's Comm % Atty Paid $167.00 Plaintiff Paid Date: SEPTEMBER 12, 2011 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs David 15 Buell, Proth otary By: Deputy REQUESTING PARTY: Name MA'rTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING, 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone : 412-434-7955 Supreme Court ID No. 90963 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. ' Civil Action No. 11-4955-CIVIL DAVID A STUM 'W51 Q,L?w ?104vv I ?Wu-%Wtvj? ao1 S Defendant(s) M & T BANK ? U-VSf lfi9h SA, Car lisle t PA 1'7013 Garnishee(s) TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION - rrr7 M ? -c7 -<2 rv r- <C=7 acs C7. ?o Kindly iss,,e a Writ of Execution in the above matter... i . direr+ed to the Sheriff of CUMBERLAND County: :. against DAVID A STUM , Defendant 3. against M & T BANK, , , Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): I) 34-M Car- 9 P. CC) Lk U -ft .0 $ $13,401.30 $ $0.00 $ $26.44 ,-_ cr ?. y* $13,427.74 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 %2, CU LC- ? !? l0 l t ? a a., WWR No. 9134103 '/ ?' W(l'1 IN THE COURTOF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 11-4955-CIVIL vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) DAVID A STUM Defendant(s) M&TBANK 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.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 9134103 SHERIFF'S OFFICE OF CUMBERLAND COUNTY , Anderson ,y S Smith nief Deputy Richard W Stewart Solicitor ???yY1i? €Y? 4aiiubrt'f,?rt d €jFF. r :I i.. ;-FpiFF U 1- E DRS kt?? r, ?1012 KAP 23 PK 2:39 PENNSYLVANIA Discover Bank vs. David A. Stum SHERIFF'S RETURN OF SERVICE Case Number 2011-4955 09/15/2011 01:48 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, M&T Bank at 1 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Donna Egolf, Customer Service Rep., 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 September 16, 2011 to David A. Stum at 3059 Ritner Highway, Carlisle, PA 17015. 03/22/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $88.13 SO ANSWERS, March 22, 2012 RON R ANDERSON, SHERIFF wlir -un*;?utte Snenti ieioosOtt. Inc:. ??a? 9d WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-4955 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From DAVID A. STUM, 3059 RITNER HIGHWAY, CARLISLE, PA 17015 (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 M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $13,401.30 L.L.$.50 Interest $491.26 Atty's Comm % Due Prothy $2.25 Atty Paid $289,,63 Other Costs Plaintiff Paid Date: April 9, 2012 David D. Buell, Prothonotary (Seal) B Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO ., L.P.A. 1400 KOPPERS BUILDING, 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 . 71 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. l? y Civil Action No. 11-4955-CIVIL DAVID A STUM 30Sq I Defendant(s) /? _ METRO BANK 96 t\)O1Vjp ?kV6• Ci-v`jSie_t PA F7013 M&T BANK I L,,) . VclSk S`F•. i CDyV'S_ i PA 1'76(.3 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 DAVID A STUM , Defendant 3. against METRO BANK, M&T BANK,, Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): G z ? 34 ?o CD ?F- $ $13,401.30 $ $0.00 $ $491.26 $ $13,892.56 WELTMAN, WEINBERG & REIS CO., L.P.A. 0) G kviai,m T9 a? 3y.oo r,,6F U 4f 9 a, a? ? y 1 ?{, Oo4 4 ?4 . So <<„ db By: :; William T. Molcz' Esqui PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 ?,?# 16U4S?j SAO P-4 o? -7'3 Y FS WWR No. 9134103 WIC b? 6y- _nsdOd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DAVID A STUM Defendant(s) METRO BANK M&T BANK Garnishee(s) No. 11-4955-CIVIL PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 9134103 CTIBIERLAND IN THE COURT OF COMIR6011k'PCUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DAVID A STUM Defendant(s) METRO BANK M&T BANK Garnishee(s) Civil Action No. 11-4955-CIVIL A 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. 9134103 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DAVID A STUM Defendant(s) METRO BANK M&T BANK Garnishee(s) Civil Action No. 11-4955-CIVIL. TO: METRO BANK, 20 NOBLE BLVD, CARLISLE, PA 17013 M&T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013 RE: DAVID A STUM, 3059 RITNER HWY, CARLISLE, PA 17015 Suggested Reference No.: XXX-XX-2269 XXX-XX- IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. WWR No. 9134103 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. 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 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. 9134103 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 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 l 1 is in the affirmative, state the amount of non-exempt funds on deposit in the account. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Es ire 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. 9134103 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 (Name) (Title) garnishee herein, of (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. 9134103 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 belief of his/her owledge, information and ( U SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OFFICE OF THE V ERIFF Id ;rte LA 110 COU `! I SYU1=-, Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. David A. Stum Case Number 2011-4955 SHERIFF'S RETURN OF SERVICE 04/13/2012 10:18 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2012 at 1011 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: David A. Stum, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Connie Negley, Teller, 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. 04/13/2012 10:23 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2012 at 01023 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: David A. Stum, 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 Walters, Office 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 17, 2012 to David A. Stum at 3059 Ritner Hwy, Carlisle, PA 17015. SO ANSWERS, April 16, 2012 RON R ANDERSON, SHERIFF i1lia, Deputy 0 X m CElince (C CoLmtySUIle Shenk Teleosoft. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-4955-CIVIL DAVID A STUM x& 40 4 Defendant(s) xsux INTERROGATORIES IN ATTA CHMd5N a C% METRO BANK M&T BANK ? E Garnishee(s) z? r-- ?? 0 ©d FILED ON BEHALF OF: Plaintiff rv 3 COUNSEL OF RECORD OF .. .# cn v 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. 9134103 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DAVID A STUM Defendant(s) METRO BANK M&T BANK Garnishee(s) Civil Action No. 11-4955-CIVIL TO: METRO BANK, 20 NOBLE BLVD, CARLISLE, PA 17013 M&T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013 RE: DAVID A STUM, 3059 RITNER HWY, CARLISLE, PA 17015 Suggested Reference No.: XXX-XX-2269 XXX-XX- IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. WWR No. 9134103 INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of deposit)? 1 . 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 liabik PIOLU PLACED BALANCE DOES NOT EXCEED EXEMPT AMOUNT 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. / tA--? 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? ? 1A 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? ANA 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? . -I I A 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. fl b, WWR No. 9134103 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 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. t VV ]L 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? Al%-j 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. l Z WELTMAN, WEINBERG & REIS CO., L.P.A. BY: /'? - William T. Molczan, Es ire 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. 9134103 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 I ORRIEUASKA M& 9 me) W 4 of ` , garnishee herein, (Title) (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ?6U v MApR 17 2012 WWR No. 9134103 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Matthew D. Urban, Esquire I.D. No.90963 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9134103 Attorney for Plaintiff(s) .'7 J0 P?14 DISCOVER BANK VS. DAVID A STUM, and METRO BANK M & T BANK Garnishee(s) CUMBERLAND County Court of Common Pleas NO. 11-4955-CIVIL PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), METRO BANK, M & T BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Matthew D. Urban, Esquire Attorney for Plaintiff I hereby certify that the foregoing is a true and correct statement of the above case. This statement is made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsifications to authorities. Q + %9. So Pd a ?? gyY3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY .ac`onny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. David A. Stum ~•lLLU-C~.~=iCl ~oYtytz1, ~r ~~trr~b~~.f~~e _ CJ t= THE ~RQ1'HO-~OT~~'~` ;~~~: .r ~ CUt''~BERLANO COt1NTY rF" ~ ` ` ..E "~` ~~ W~NNSYLVANIA Case Number 2011-4955 SHERIFF'S RETURN OF SERVICE 04/13/2012 10:18 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2012 at 1011 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: David A. Stum, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Connie Negley, Teller, 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. 04/13/2012 10:23 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2012 at 01023 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, td wit: David A. Stum, 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 Walters, Office 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 17, 2012 to David A. Stum at 3059 Ritner Hwy, Carlisle, PA 17015. 11/09/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $144.02 November 09, 2012 SO ANSWERS, L~,,~~~_ RON R ANDERSON, SHERIFF ~ • a.Srpd • Co ..sue t,G~. G(z~ ~'~o ~`~ ,ef~- ~ ~ags~ ic! CountvSuite Sheriff, TeleosoR, Inc.