HomeMy WebLinkAbout11-6056r;t-OFF1C
.? 1L PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
TONYA L REDCAY
Defendant
No: ?- ?Q?s?Q C(Ut
COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
09229795 C A Pit SJS
arn9-?j
Cig lOwl/S
04- aeasYY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
TONYA L REDCAY
Defendant
COMPLAINT AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within
twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing
with the court your defenses or objections to the claims set forth
against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or
for any other claim or relief requested by the plaintiff. You may lose
money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
1. Plaintiff, DISCOVER BANK is a corporation with offices at 6500 NEW
ALBANY ROAD NEW ALBANY , OH 43054
2. Defendant is adult individual(s) residing at the address listed
below:
TONYA L REDCAY
2260 RITNER HWY
CARLISLE, PA 17015
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX6486 .
4. Defendant made use of said credit card and has a current balance
due of $13918.97 , as of April 30, 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
28.2400 per annum on the unpaid balance from April 30, 2011 . A copy
of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and
made a part hereof.
7. Plaintiff avers that the Agreement between the parties provides
that Defendant will pay Plaintiff's attorneys' fees.
8. Plaintiff avers that such attorneys' fees will amount to $125.00 .
9. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and/or refused to pay the balance due to Plaintiff.
Wherefore, the Plaintiff prays for Judgment in its favor and
against Defendant , TONYA L REDCAY INDIVIDUALLY , in the amount of
$13918.97 with interest at the rate of 28.2406 per annum from April
30, 2011 plus attorneys' fees of $125.00 , and costs.
James Warm ro t,42524
WELT WEINBERG & REIS CO., L.P.A.
436 e enth Avenue, Suite 1400
Pitt b rgh, PA 15219
(41 ) 434-7955
F 12-338-7130
09 795 C A Pit SJS
This law firm is a debt collector attempting to collect this debt for
our client and any information obtained will be used for that purpose.
DISCOVER
New Balance Minimum Payment Due
S13,1 18.97 $13,918.97
ayment e
June 17, 2011
22 SDSN6A01 0010676
TONYA REDCAY
2260 RITNER HWY
CARLISLE PA 17015-9307
Address, e-mail or telephone change?
Go to www.Discavw.com or print change in space above.
Account Number ending in 6486
Enter Amount Enclosed Below
Please make check payable to Discover Card.
Minimum payment due includes a post due
amount of $2,377.00. Phone and Internet
payments must be made by 5:00pm ET for some
day postin
Go pakerless and make your account
information more secure with password-
protected statements only you can access.
Learn more at discover.conVpaperless.
PO BOX 6103 "Irrrll"rEXHI IT
CAROL STREAM IL 60197-6103
000001986451813388304139189700000001391897
Opening Date: May], 2011 - Closing Date: May 22, 2011
Discover More Card Account Summary
Account number ending in 6486
Previous Balance $13,918.97
Payments And Credits 0.00
Purchases + 0.00
Balance Transfers + 0.00
Cash Advances + 0.00
Fees Charged + 0.00
Interest Charged + 0.00
New Balance $13,918.97
See Interest Charge Cakulation section following
transactions for detailed APR information
Credit Line $12,100.00
Credit Line Available $0.00
Cash Advance Credit Line $0.00
Cash Advance Credit Line Available $0.00
Cash back BonuSe Anniversary Month
July
Opening Coshbock Bonus Balance S 0.00
New Cashbock Bonus This Period + 0.00
Cash6ock !taws defence $ 0.00
To born more, log in at www.Disco~.com
3 Easy Ways to Contact Us
1 Access your account securely at www.Discover.com
2. Call 1-800-DISCOVER (1-800-347-2683)
Please have your Discover* card available. 3. Write to us at Discover, PO Box 30943,
Soft Lake City, LIT 84130 (Not a payment address)
For payments, please send to address on ranilfa ice or
Discover. PO Box 6103, Card Stream, IL 60 1 97-61 03
For TDD (relecommunicahons Device for the Deal)
assistance, please call 1-800.347-7449.
page 1 of 2
Payment Information
New Balance $13,918.97
Minimum Payment Due* $13,918.97
Payment Due Date June 17, 2011
*Includes past due amount of $2,377.00
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 29.99% variable.
Minimurn 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 would like information about credit counseling services,
call 1-800.3471121
#Yotlu intake no: Yau'viR ?rgyru?? ;fitid youwR end<
riianal cfwi+gds Isalarrre shawtt vn ufi paying an
;mg Ikis card and this. statement in estimated total of,
r4ion8+ yQU piny- about.
Only the minimum 11 years $13,919
payment
Manages Your Account Online at www.Diswver.com
• Access free online tools like Paydown Planner to create a plan
to pay down your balance, securely access statements, pay
bills online and easily track aA transactions
• Make your money worth moron-find easy ways to earn
and redeem cash rewords
• NEW! Access your account securely through your
mobile phone
Date ans. Pie
Fees TOTAL FEB FOR THIS PERIOD S 0.00
Transactions
9229795 Tr
Int.resr Charged TOTAL lWTEREST FOR TF85 PERIOD $ 0.00
2011 Totals Year-to-Date
TOTAL FEES CHARGED IN 2011
TOTAL INTEREST CHARGED IN 2011
818,24
S 140.00
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.
• Sign up today at Discovercom/paperless
02010 0ixo.er Back, Member FDIC
PAPER 03 10
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9229795
QueStiOnS? Visit www.D'tscover.com or
call 1-800-DISCOVER (1-800.347-2683). DISCOVER
DISCOVER
It pays to 1 TONYA REDCAY
DISCOVER' I Account number ending in 6486
page 2 of 2
Interest Charge Calculation
Your Annual Percentage Rafe (APR) is the annual interest rate on your account.
Current 9869 Period: 22 days
TYPE OF BALANCE
Purchases
11/14/2010 and after
08/14/2010 to 11/13/2010
08/13/2010 and prior
Cash Advances
V = Vanable Rate
Additional Important Information
See your Cardmember Agreement.
R (APR) PERCENTAGE
RAATEE
BALANCE SUIUECf TO
INTEREST RATE
WREST CHARGE
28.24% V
23.24% V
18.24% V
23.99% V
$0
$0
$o
$0
Your Cardmember Agreement contains all the terms of your Account.
Lost or stolen cards. Report immediately! Call 1-800-347-2683.
$0
$0
So
$0
What To Do of You Think You Find A Mistake On Your Staterrsenf
If you think there is an error on your statement, write to us at: Discover, PO Box 30421 Salt Lake City, UT 84130-0421
In your letter give us the following information:
Account information: Your name and account number
Dollar amount. The dollar amount of the suspected error
R-- "on of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe
nt I. a mi e.
You must contact us within 60 days after the error appeared on your statement.
You must notify us of any potential errors in writin You may coil us, but if you do we are not required to investigate any
potential errors and you may have to pay the amourrt in question.
While we investigate whether or not there has been an error, the following are true:
• We cannot try to coiled the amount in question, or report you as delinquent on that amount.
The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, if
we determine chat 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, y«? are responsible For the remainder of your balance.
We can apply any unpaid amount against your credit limit.
Your Riahts N You Are Dissatisfied With Your Credit Cord 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 merchord, 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 an&77* still dissatisfied with the purchase, contact us in writing at:
Discover, PO Box 30945, Soft Lake 84130-0945
While we investigate, the some rules apply to the disputed amount as discussed above. After we 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.
Paym«rts Sand only your payment and the top ppoorrttion of this statement in the envelope provided. Do not send cash. By
sending your check as described above, you authorize us to use information an your check to make an electronic fund
transfer ham your account of the financial instihAion indicated on your check or to process the payment as a check
transaction. If ?+menf is processed as an efechonie fund lronsfer, the transfer will be for the amount of the check. When we
use information from your check Fo make an electronic fund transfer, funds maybe withdrawn from your account as soon as
the same day we reserve your payment, and you wiR not receive your check back from your financial institution.
The processing of your payment may be delayed if you send cash, correspondence or other items with your payment, if you
send the payment b on ether address or if ycu use an envelope athe than the one provided. Payments received in proper
form at our processing facility by 51PM kcal time on arty day will be credited to your Account as of that day. Payments
received at our processing facility after 5PM local time will be credited to your Account as of the next day. If you have
misplaced your envelope, send your payment to Discover PO Box 6103, Carol Stream, IL 601 97-6 1 03. Phase allow 7- 10
days for delivery. If your payment is returned unpaid, we reserve the rit to resubmit it as an electronic debit.
You can pay your scheduled monthly payment or a greater amount that does not exceed your remaining current account
balance over the telephone or you can setup automatic payments through a customer service representative by calling
)-800347-2683. Automatic payments will be deducted on the payment due date unless you request a ppaa at date that
occurs before your payment due dote. If your scheduled payment date falls on a weekend or bank holix7yyoor payment will
be processed the business day prior to the weekend or bards holiday. In order to schedule monthly payments
i%_ you will need this statement and your bank account information. You will be asked to provide the last lour (4) gitst its f the'
social security number of the primary borrower By providing those numbers as your electronic signature, wi be
agreeing to this authorization to allow us and yax bank to dedrxt each payment you authorize, in the amount selected by
you, from your bank account. You also authorize us to initiate debit or credit entries to your bank account, as cable, to
correct an error in the processing of such pparsyymeenrtd.? You can cancel a scheduled payment by at 1-800-347-2683 or
nI at the correspondence address listed above; however we must receive nahce at least three business days in advance
payment. If your payments may vary in amount, we will fell you on each morthly statement when your
payment ow made and tow much it will be. You must ensure that sufficient funds are available in your bank account, and
oR transactions must comply with U.S. law. If your scheduled payment is not enough to cover the Total Amount Due as listed
on your monthly billing statement, you will be responsible for paying the difference. Your automatic payment amount may be
less than the amount indicated on the periodic statement based on credits or payments after the closing date.
If you enroll by phone in our automatic payment service, please fill-in the following blanks below and retain the authorization
for your records.
Amount: ? Full Pay ? Min Pay ? Min Pay + S
Bank Routing
Bonk Account
Frequency:
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DID OVER
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# 9229795
Tonya L. Redcay
6011005590256486
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff FILED-OFFICE
Jody S Smith ???itt' al ?1t?nGrrl,4,?Or THE f"ROTHO' OTAR R
Chief Deputy 2 I I AUG 22 AM 8.4 p
Richard W Stewart Solicitor OFF -RIFF CUMBERLAND COUNTY
PENNSYLVANIA
Discover Bank
vs.
Tonya L. Redcay
Case Number
2011-6056
SHERIFF'S RETURN OF SERVICE
08/16/2011 05:30 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on August
16, 2011 at 1730 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Tonya L. Redcay, by making known unto Tawnyia Redcay, Step Daughter of Defendant
at 2260 Ritner Highway, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same
time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $34.00
August 17, 2011
ROBE T BITNER, brWry
SO ANSWERS,
RON R ANDERSON, SHERIFF
id; -r;'M:yS,tiin Sheriff. Teiecs 't. L`: .
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-6056 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From TONYA L. REDCAY - 2260 Ritner Hwy, 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 St., 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 $15657.04
Interest $226.49
Atty's Comm %
Atty Paid $171.50
Plaintiff Paid
Date: 1/19/12
L.L.$.50
Due Prothy $2.25
Other Costs
David D.
(Seal) By:
REQUESTING PARTY:
Deputy
Name WILLIAM T. MOLCZAN, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO., L.P.A
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 47437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No. 11-6056 CIVIL
vs. PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
TONYA L REDCAY
Defendant(s)
M&T BANK
Garnishee(s)
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W" No. 9229795
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. 11 Civil Action No. 11-6056 CIVIL
TONYA L REDCAY -;.;.(j0 giT q r h1wy'
Defendant(s) /?
M&T BANK - 1 1X1"5 171 h (7a'( t S le 09,4 /7013
Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
I . directed to the Sheriff of CUMBERLAND County:
C-) ` `.,?
r"nw
?P' C-11
2. against TONYA L REDCAY , Defendant
3. against M&T BANK... Garnishee
4. Judgment Amount
Less Payments/credits received
Interest
Costs
SUBTOTAL:
$ $15,657.04
$ $0.00
$ $226.49
Costs (to be added by Prothonotary):
O
2R' 00 ?d
34 0 0 C 8?
q? • 00 tt
p0 tl
$15,883.53
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: w
William T. Molczan, Ewilire
PA I.D. #47437 V
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
e Ob
a.?S -D
Cb ZZ
C / 0 3 //-;lI
2699 /S
\Xlr,i Of rX. l5 5 ? ? e?
W WR No. 9229795
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
11111p °t 614117,"t"44
f;
IL ED 0 F F I G
J HE PROTI•IONOTAR r
2012 FEB - I PM I : 49
Richard W Stewart
Solicitor
CUMBERLAND COUNTY
PENNSYLVANIA
Discover Bank
vs.
Tonya L. Redcay
Case Number
2011-6056
SHERIFF'S RETURN OF SERVICE
01/26/2012 12:31 PM - Ronald E. Hoover, Deputy Sheriff, who being duly sworn according to law, states that on
January 26, 2012 at 1220 hours, attached as herein commanded all goods, chattels, rights, debts, credits,
and monies of the within named defendant, to wit: Tonya Redcay, 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 Joan Crowl, 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.
The writ of execution and notice to defendant was mailed on January 27, 2012, to Tonya L. Redcay, 2260
Ritner Highway, Carlisle, PA 17015.
SO ANSWERS,
January 27, 2012 RON R ANDERSON, SHERIFF
Ronald E. Hoover, Deputy
jci Cur ;+Suite S?en?f_ Teiea ?of1, In;:.
F1LED-OFF«-
3t ??c. FROTHOWTAR {
202 FED -2 P1 : 42
CDMB ?NSYLVA? ATTY
PE
?- Q1- ^(-) NI,;I N* PTC C!-yUr,TI T?T n
i
DISCOVER BANK:
Plaintiff
17S.
TONYA L REDCAY
Defendant(s)
M&T BANK
Garnishee(s)
Civil Action No. 11-6056 CIVIL
pqq3e,15
INTERROGATORIES IN ArFACHMENT
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PAR FY:
William T. Molczan, Esquire
PA l.D, 4474>7
WELTMAN, W :INBERG & REAS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W WR No. 9229795
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
„ . .,
M&T BANK
Garnishee(s)
Civil Action No. 1 1-6056 CIVIL
TO: M&T BANK, I WEST HIGH ST, CARLISLE, PA 17013
RE: TONYA L REDCAY, 2260 RITNER HWY, CARLISLE, PA 17015
Suggested Reference No.: XXX-XX-6601
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 tivrit of
Execution is issued.
C` V1,1?11e sere-ice of Writ upon the Garnishee attaches all property of 0-t_- Defendant subiect 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.
W" No. 9229795
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)?
t?
i
the teens, race ?iin,)unt 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. alt 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 solell 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. 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? l? ? N
7. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which funds are deposited electronically on a
recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or
attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption,
the amount being withheld under each exemption and the amount of funds in each account, and the entity
electronically depositing those funds on a recurring basis.
W WR No, 9229795
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. [fthe answer to Interrogatory I is in the affirmative, state the date the sheriff-served these
10. ff the answer to Interrogatory I 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.
A
H. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account
which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law?
12. If the response to Interrogatory 1 1 is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
fL ?
WEIA MAN, WI INBERG & RE IS CO.. {,.P.A.
BY:
William T. Molczan, Esqui
PA I.D. #47437
WELTMAN, WI?fNBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W WR No. 9229795
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
that +t?iS .a
PAST BANK `.
-_-- of --- _-----_-_-, garnishee Herein.
(Title) (Company)
that he/she is di ily authorized to make this verification, and that the ,.acts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief.
a?
(SIGNATURE)
10 M&T BANK
WWR No. 9229795
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFF 'L 'r '-E >"ERiFF
OF THFEILPER00-10IFFICE
THONOTARY
2012 FEB 15 AM 8: 24
CP fRLAND COUNTY
MRSYLVANIA
Discover Bank
vs.
Tonya L. Redcay
Case Number
2011-6056
SHERIFF'S RETURN OF SERVICE
01/26/2012 12:31 PM - Ronald E. Hoover, Deputy Sheriff, who being duly sworn according to law, states that on
January 26, 2012 at 1220 hours, attached as herein commanded all goods, chattels, rights, debts, credits,
and monies of the within named defendant, to wit: Tonya Redcay, 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 Joan Growl, 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.
The writ of execution and notice to defendant was mailed on January 27, 2012, to Tonya L. Redcay, 2260
Ritner Highway, Carlisle, PA 17015.
02/14/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned STAYED, per request from plaintiffs attorney.
SHERIFF COST: $88.38 SO ANSWERS,
February 14, 2012 RON R ANDERSON, SHERIFF
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;c1 Count,SUte Sheriff. Telecsoft Inc.
I HEIR O T
"Di" NONOTAR)' WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: James C Warmbrodt, Esquire
I.D. No.42524
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 9229795
DISCOVER BANK
vs.
TONYA L REDCAY
and
M&T BANK
Garnishee(s)
Attorney forVaMfi'(4l 7 PH E2: j6
CUMBERLAND COUNTY
.PENNSYLVANIA
Cumberland County
Court oi' Common Pleas
NO. 11-6056 CIVIL
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THE, PROTHONOTARY:
Kindly marked the above matter discontinued and ended as to Garnishee(s), M&T BANK,
only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
James Twarmbrodt, Esquire
Atto y r Plaintiff
Sworn to and subscribed
Before me the day of February, 2012
O
?- NOTARY BLIC
v
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sheila G. Bevan, Notary Public
Ross Twp., Allegheny County
TI Commission Tres Nov. 15, 2014
EnnAC? ^BNM,SYI VANIA ASSOCIATION OF NOTARIES
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