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Home My WebLink About12-4770IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL DIVISION Discover Bank, Through Its Servicing Agent, DB Servicing Corporation Plaintiff No:/;, qr7r7 0 vs ANGELA D CHRISTOPHER Defendant PENNSYLVANIA r.? Pr I Q C '- "1 r > o . COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan,47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-71.30 09685384 C A Pit SJS ,2# a? 863 g IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Bank, Through Its Servicing Agent, DB Servicing Corporation Plaintiff vs. Civil Action No ANGELA D CHRISTOPHER Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against he claims set forth in the following pages, you must. take action wit in twenty (20) days after this complaint and notice are served, by e tering a written appearance personally or by an attorney and filing in w iting with the court your defenses or objections to the claims set fort 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 he court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You ma lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU D 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 AB TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEG 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 T COMPLAINT 1. Plaintiff, Discover Bank, is a banking institution organized under the laws of the State of Delaware and maintains a business addres? of 12 Reads Way, New Castle, DE 19720. 2. DB Servicing Corporation is the servicing affiliate for Disco er Bank, f/k/a Greenwood Trust Company, an FDIC-insured Delaware State bank. As the servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank including, among other things, the collection of delinquent accounts, marketing, application approval, transaction approval, customer service, and billing. The collection of delinquent accounts includes the right to forward the account to the attorneys and/or collection agencies for collectio and to file suit on Discover Bank's behalf. 3. At all times pertinent hereto, DB Servicing Corporation is t servicing affiliate for Discover Bank, in reference to Defendant account, which is the subject of this litigation. 4. Defendant is adult individual(s) residing at 8 KINGSBRIDGE C CARLISLE, PA 17013 5. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2942 . 6. Defendant made use of said credit card and has a current balance due of $5801.34 , as of May 31, 2012 . 7. Defendant is in default by failing to make monthly payments due. As such, the entire balance is immediately due and payable Plaintiff. 8. Plaintiff is entitled to the addition of interest at the rate 10.240. per annum on the unpaid balance from May 31, 2012 . A cc Plaintiff's STATEMENT is attached hereto, marked as Exhibit "I',- 9. Although repeately requested to do so by Plaintiff, Defendant willfully failed and/or refused to pay the balance due the Plainti of of has ff. WHEREFORE, Plaintiff prays for Judgment in its favor and aganst Defendant, ANGELA D CHRISTOPHER INDIVIDUALLY , in the amount of I $5801.34 with interest at the rate of 10.240% per annum from May 31, 2012 until date of judgment and costs. U William T. Molcza 47437 WELTMAN, WEINBER & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 WWR# 09685384 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 $0.00 $991.00 _ Payment Due Date June 26, 2012 31 SDSN6A01 0002118 ANGELA CHRISTOPHER 8 KINGSBRIDGE CIR CARLISLE PA 17013-4808 2012 PO BOX 6103 111 111111119411111111111111 CAROL STREAM IL 60197-6103 Address, e-mail or telephone change? Irllnl{unnlIli{nlnrlrllnur{l{luntllrllnnr{InInI{ Go to www.Discover.com or print change in space above. 000001986458882295070000000000000000099100 Opening Dots: May 14, 2012 - Closing Date: May 31 Discover More Card Account Summary Account number ending in 2942 Previous Balance $5,801.34 Payments And Credits 5,801.34 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Fees Charged + 0.00 Interest Charged + 0.00 New Balance W.-N0 See Interest Charge Calculation section following transactions for detailed APR information Credit Line $5,200.00 Credit Line Available $0.00 Cash Advance Credit line $2,500.00 Cash Advance Credit Line Available $0.00 t.asnoaCK bonus- Anniversary Month January Opening Cashbock Bonus Balance S 0.00 New Cashback Bonus This Period + 0.00 Cashback bonus Balance 5 0.00 To learn more, leg in at www.oluovor.com Account Number ending in 2942 Enter Amount Enclosed Below $ C Text APP to DISCOV' to receive a link to our free mobile app and pay your bill in seconds from anywherel page 1 of 2 Payment Information New Balance $0.00 Minimum Payment Due $991.00 Payment Due Date June 26, 2012 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 15.24% variable. Manage Your Account Online at www.Discover.com • Securely access statements and Free online tools, pay bills online and track and view all transactions simply and easily • Make your money worth moresm -find easy ways to earn and redeem cash rewards • NEW Access your account securely through your mobile phone 3 Easy Ways to Contact Us 1 Access your account securely at www.Disc~.com 2. Call 1-8004DISCOVER (1-800.347-2683) Please have your Discovers card available, 3. Write to us at Discover PO Box 30943, Salt Lake City, UT 84150 (Not a payment address) For payments, send to address on remittance or Discover, PO ox 6103, Carol Stream, IL 60197-6103 For TDD (Telecommunications Device for the Deaf) assistance, please call 1$00.347-7449. Transactions Trans. Post Payments and Credits May 31 May 31 INTERNAL CHARGE-OFF 5 -5,801.34 Foes TOTAL FEES FOR THIS PEROD $ 0.00 Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 0.00 2012 Totals Year-to-Date TOTAL FEES CHARGED IN 2012 $ 175.00 TOTAL INTEREST CHARGED IN 2012 237.70 9685384 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER DISCOVER rI It Pcr 10 ANGELA CHRISTOPHER oYEa Account number ending in 2942 L_-Disc page 2 of 2 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Current Wing Period; 18 days TYPE OF BALANCE ??U(LPERCENTAGE INTEREST BALANCE SSUUL ECT TO INTEREST CHARGE Purchases 10.24% V $0 $0 Cash Advances 23.99% V SO $0 V = Variable Rate Additional Important Information See your Cardnwmbor Agreement. Your Cordmember Agreement contains all the terms of your Account. Lost or stolen cards. Report immediately) Call 1.800-347-2683. What To Do ff You Think You Find A Mstake On Your Statement 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 Descry hond'.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?wnting. 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 tolled 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 that we mode 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 Riahts N 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 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: 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 maiksd 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 0U are still dissatisfied with the purchase, contact us in writing at: Discover PO Box 30945, Salt Lake CiT 84130.0945 While we investigate, the same 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. Payments. You may pay all or part of your Account balance at any time. However, you must pay at least the Minimum Payment Due by the Payment Due Date. 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 fo make an electronic fund transfer from your account at the financial institution indicated on your check or to process the payment as a check transaction. If payment is processed as an electronic fund transfer, the transfer will 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 cash, correspondence or other items with your payment, if you send the payment to any other address or if you use an envelops other than the one provided. Payments received in proper form at 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 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 60197-6103. Please allow 7.10 days for delivery. If your payment is returned unpaid, we reserve the rigk to resubmit it as an electronic debit. 9685384 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER You can pay your monthly Minimum Payment Due, or a greater amount that does not exceed your current Account balance, over the telephone or you can setup automatic payments through a customer service representative by calling 1-800.347.2683. Automatic payments will be deducted on the Payment Due Date unless you request a recurring pa ment date (e.g. the 15th day of the month) that occurs before your Payment Due Date. If your scheduled payment date falls on a weekend or bank holidyoy, your payment will be processed the business day prior to the weekend or bank holiday. In order to schedule monthly payments b telephone you will need this statement and your bank account information. You will be asked to provide the lost four (4?digi s of the social security number of the primary borrower. By providing those numbers as your electronic signature, you will be agreeing to this authorization to allow us and your bank to deduct 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 applicable, to correct on error in the processing of such payment. You can cancel a scheduled payment by phone at 1.804347-2683 or by mail at Discover, PO Box 30421 Salt Lake City, UT 84130-0421, however we must receive notice at least three business days in advance of the scheduled payment. If your payments may vary in amount, we will tell you on each monthly billing statement when your payment will be made and how much it will W. You must ensure that sufficient funds are available in your bank account, and all transactions must comply with U.S. law. You can set automatic payments for- (t) statement New Balance, (ii) statement Minimum Payment Due, (iii) statement Minimum Payment Due plus a fixed dollar amount, or (iv) a fixed dollar amount. If your scheduled fixed payment is not enough to cover the Minimum Payment Due as listed on your monthly billing statement, your scheduled payment for that month will be increased to cover the Minimum Payment Due. If the scheduled payment is reater than the Minimum Payment Due, any excess will be applied in accordance with your Cordmember Agreement. It your scheduled pa ent is greater than the New Balance on your billing statement, that payment will be ocessed onI for the amount of your New Balance. Your automatic ayment amount maybe less than the amount indicated c the periodic statement based on credits or payments after the losing 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 ? Fixed Pay$ Bank Routing #:_ Bank Account Frequency: report rheit RWe ay dultn your of Account t u o credit reporting agencies each month. If ou believo that our report is inaccurate or incomplete, please write s at me the following address: Discover, PO Box 15316, W Imington, DE 1985Q5316. Please indicate your name, address, ho le phone number and Account number Paying Interest: We begin to impose interest charges on a transaction, fee or interest charge from the day we add it to the daily balance. We continue to impose interest charges until you pay the total amount you owe us. You can ovoid paying interest on Purchases as described below. However you cannot avoid paying interest on Balance Transfers or Cash Advances. How to Avoid Paving Interest on Purchases I"Grace Period" you paid t New a nce on your previous billing statement by the Payment Due Date shown on that billing statement, we will not impose interest charges on new Purchases or any portion of a new Purchase, paid by the Payment Due Date on your current billing statement. New Purchases are Purchases that first appear on the current billing statement. How We Apply Payments May Impact Your Grace Period you o not pay your a BaTonce in lull each month, then, depending on the balance to which we apply your payment, you may not get a grace period on new Purchases. How We Calculate Interest Charges Daly Balance Method (including current transactions): We calculate interest charges each billing period by first figuring the "daily balance" For each Transaction Category. Transaction Categgories include standard Purchases, standard Cash Advances and different promotional balances, such as Balance Transfers. How We Figure the Daly Balance For Each Transaction Category We start with the be inning balance for each day. The beginning balance for the first day of the billing period is your balance on the last day of your previous billing period We add any interest charges accrued on the previous day's daily balance and any new transactions and fees. We add any new transactions or fees as of the later of the Transaction Date or the first day of the billing period in which the transaction or fee posted to your Account. We subtract any new credits and payments. We make other adjustments (including those adjustments required in the "Paying Interest" section). How We Figure Your Total Interest Charges We multiply the daily balance for each Transaction Category by its daily Periodic rate. We do this for each day in the billing period. This gives Us the interest charges for each Transaction Category. To get a daily periodic rate, we divide the APR that applies to the Transaction Category by 365. We add up all the daily interest charges. The sum is the total interest charge for the billing period. How We Include Fees We add Balance Transfer Fees to the applicable Balance Transfer Transaction Category We add Cash Advance Fees to the applicable Cash Advance Transaction Category. We add all other fees to the standard Purchase Transaction Category. Balance Subject to Interest Rate. Your statement shows a Balance Subject to Interest Rate. It shows this for each transaction category. The Balance Subject to Interest Rate is the average of the daily balances during the billing period. Credit Balances. If your Account has a credit balance, the amount is shown on the front of your billing statement. A credit balance is money that is owed to you. You may make charges against this amount if your Account is open. We will send you a refund of any remaining balance of $1.00 or more after 6 months, or as otherwise required by applicable law. For TDD (Telecommunications Device for the Dean assistance, please call 1.800-347-7449. df1RRb M.c.nitor and/or record telephone calls between you and Discover representatives for quality assurance purposes. The Discover ®card is issued by Discover Bank, Member FDIC RZNFE001 Questions? Visit www.Discover.com or call 1.800-DISCOVER (1.800-347-2683( Paperless statements mean less clutter, more convenience Easily access up to 24 months of downloadable, 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/papedess 1 02010 Discover Bonk, Mem6 FDIC PAPER 03 10 i rn 0 Cn 2 m D o_ 0 0 0 N N X 9685384 Questions? Visit www.Discover.com or DISCOVER call 1 800-DISCOVER (1.800-347-2683) VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that she is Natasha Szczygiel, Legal Placement Ac (Name) (Title) of DB Servicing Comoration successor to DFS Services LLC, servicing agent for (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. (Signature) WWR# 9685384 Angela D. Christopher 6011002798782942 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~,~~tu mt ~'uipb~r~~h~ ,,G t~#.'.~r t+i~~ ,e ~;.. r.. Off1CE ~F THE SHERIFF Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~I'2 AUG 17 AM 9~ i Z ~~ ~~~~~Y~~~~ A ~~~ Discover Bank vs. Angela D. Christopher Case Numt~i 2012-4770 SHERIFF'S RETURN OF SERVICE 08/06/2012 07:35 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on Augu t 6, 2012 at 1935 hours, he served a true copy of the within Complaint and Notice, upon the within Warn d defendant, to wit: Angela D. Christopher, by making known unto Amanda Garrick, Sister of Angela D. Christopher at 8 Kingsbridge Circle, Carlisle, Cumberland County, Pennsylvania 17013 its contents an at the same time handing to her personally the said true and correct copy of the same. _.G TIM K, DEPUTY SHERIFF COST: $34.00 August 09, 2012 ~+: . (c) CeuntgSuite Sheritt, Teleesoft, Inc. SO ANSWERS, RON R ANDERSON, SHERIFF FFICE OF CUMBERLAND COUNTI~ ' ~' ~, S O SHERIFF r*t~ r3 ...\.. '-C`t `~ Ronny R Anderson ~ ~ ~ ~Ri~, Sheriff II!` 6~_~ 4~~,tu pt ~9~,r,Gr~,~~„ rv ~c~ Jody S Smith ~ ~ ~` '~~ ~ '°}~' JM -~-~ Chief De ut - Richard W Stewart ~~ ~ ~' ~ ~{~ ~ Solicitor ~,=r,:-~ ~F -~:G :..~~~~F „~.. -Fi :. -~r~• Discover Bank Case Number vs. 20 12-47 70 Angela D. Christopher SHERIFF'S RETURN OF SERVICE 11/19/2012 03:13 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 19, 2012 at 1510 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Angela d. Christopher, 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 Lannie Wolf, 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 November, 12 to ngela D. Christopher at 8 Kingsbridge Circle, Carlisle, PA 17013. ,DEPUTY November 20, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF CaintySuite Sheri Ff: 1"re.^sott, In^:. f 1N THE; COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION r _ ~~-, - _ -,. DISCOVER BANiK, THROUGH ITS SERVICING AGENT, ~ ti ~ ~-~ ~, ~ +..T., ,. r~ DB SERVICING CORPORATION r= ~:- _..,r- Plaintiff Wiz'' N vs. ANGELA D CHRISTOPHER Defendant(s) MEMBERS 1ST FC'U Garnishee(s) Civil Action No. 12-4770 .--- r_: ~`c- ~'' _._~ . '~° `'~ LL ` ~ ~ ~ n~"""" INTERROGATORIES INATTACHMENT 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 ~~~ ±4`1dI ~ ~ ~~p9~ WWR No. 9685384 IN THF. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff vs. Civil Action No. 12-4770 ANGELA D CHRISTOPHER Defendant(s) MEMBERS 1ST FC'U Garnishee;(s) TO: MEMBERS 1ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 RE: ANGELA D CHRISTOPHER , 8 KINGSBRIDGE CIR, CARLISLE, PA 17013 Suggested Reference No.: XXX-XX-3240 XXX-XX- IMPORTANT NOTICES TO GARNISHEE! A. 1'ou 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. 9685384 ~~~:~. 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)? ,VO 1 a. If the answer to Interrogatory I 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? ~jl 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? N~' 6. At any hme after you were served drd you pay, transfer, or delrver 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? n n 6~v 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. ~'F~~~ WWR No. 9685384 ~~ ~ ~ ~ c~17~~ ~ ° ~ M 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. ~~ 9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. ~1 A ~ ~~/'~ ~/~ i? 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. ~j~ ~- ~ ~/~~~i z 1 1. 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? IVU l2. [f the response to Interrogatory 11 is in the affirmative, state the amount ofnon-exempt funds on deposit in the account. IvV WELTMAN, WEINBERG & REIS CO., L.P.A. B G ~ ~~`~~~•L',~~ y• ~ __ 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 ~~~E ii~V ~ ®ZD1~ WWR No. 9685384 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff vs. Civil Action No. 12-4770 • ANGELA D CHRISTOPHER %kw:4c Corcle, v Defendant(s) Ca ie PR O 13 LI)37 SOVEREIGN BANK �`} l^). 1' 15 k S+11 ( Ix5� l l Y a Cr MEMBERS 1ST FCU t i 1 u 5 r�i�) ( . t l..tcv-1. S l� I 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 ANGELA D CHRISTOPHER , Defendant 3. against SOVEREIGN BANK, MEMBERS 1ST FCU, ,Garnishee 4. Judgment Amount $ $5,979.67 Less Payments/credits received $ $0.00 Interest $ $381.39 Costs $ SUBTOTAL: $ $6,361.06 Costs(to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: 61- J� �� `� William T. Molczan, Es. ire �� ( ' CEF PA I.D. #47437 . �� WELTMAN, WEINBERG & REIS CO., L.P.A. ' c / I /s 1400 Koppers Building ( I I 436 Seventh Avenue t `p , S6 Pittsburgh, PA 15219 O` 1 t I( (412)434-7955 oi <t OlAg-i/ dt., • CL14 1( 3S8<< < WWR No. 9685384 WcA scree I►• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff No. 12-4770 vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) ANGELA D CHRISTOPHER Defendant(s) SOVEREIGN BANK MEMBERS 1ST FCU Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR No. 9685384 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2012-4770 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK,THROUGH ITS SERVICING AGENT,DB SERVICING CORPORATION Plaintiff(s) From ANGELA D. CHRISTOPHER,8 KINGSBRIDGE CIRCLE,CARLISLE, PA 17013 (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: SOVEREIGN BANK, 17 W. HIGH STREET,CARLISLE,PA 17013 MEMBERS 1ST 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$5,979.67 Plaintiff Paid$ Interest$381.39 Attorney's Comm. % Law Library$.50 Attorney Paid$221.75 Due Prothonotary$2.25 Other Costs$ Date: 11/4/2013 L�it.�GGI!� : iz.a_ 1 David D. Buell, Prothonotary // /</_ 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff t " THE PRD P4D D FA o Jody S Smith Chief Deputy �OY 14 AN 9: 33 ? Richard W Stewart CUMBERLAND CDtJI NT Y Solicitor � �x.F r�TV PENNSYLVANIA Discover Bank Case Number vs. Angela D. Christopher 2012-4770 SHERIFF'S RETURN OF SERVICE 11/07/2013 12:34 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, Sovereign Bank, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Denise Beecher,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. WILLIAM CLINE, DEPUTY SO ANSWERS, November 12, 2013 RON _ R ANDERSON, SHERIFF (c)CountySultc Shent',Teleosott,'nc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F[LED-01zl"iCE Sheriff H 1.1 TE E Jody S Smith ?1313 NOY 14 Al"i 9: 3 3 Chief Deputy Richard W Stewart CUMBERLAND COUINTY Solicitor PENNSYLVANIA Discover Bank Case Number vs. 2012-4770 Angela D. Christopher SHERIFF'S RETURN OF SERVICE 11/07/2013 01:05 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, Members 1 st Federal Credit Union, 321 York, Carlisle, PA 17013, Cumberland County, by handing to Melisa Hollis, 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 November 13, 2013 to A gela D. Christopher, 8 Kingsbridge Circle, Carlisle, PA-17013. Wli� I�Z IAM CLINE, DEPUTY SO ANSWERS, November 12, 2013 RbNW R ANDERSON, SHERIFF I-)CowntySuile Sheriff.Tolleos0fi, f��L' D OF THE PRCTFIO:N TAB;t 2013 NOV 19 P11 is 27 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK,THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff vs. Civil Action No. 12-4770 ANGELA D CHRISTOPHER C/'.^��} ` C Defendant(s) } )V' INTERROGATORIES IN ATTACHMENT SOVEREIGN BANK MEMBERS 1ST FCU 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 W R No. 9685384 i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK,THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff vs. Civil Action No. 12-4770 ANGELA D CHRISTOPHER Defendant(s) SOVEREIGN BANK MEMBERS 1ST FCU Garnishee(s) TO: SOVEREIGN BANK, 17 W HIGH ST, CARLISLE, PA 17013 MEMBERS 1ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 RE: ANGELA D CHRISTOPHER , 8 KINGSBRIDGE CIR, CARLISLE, PA 17013 Suggested Reference No.: XXX-XX-3240 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. 9685384 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)? ffc Ia. 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. Chf(K6(1,5 -- bra 1cer 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. 01 (11- Otg 0 141—k 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? flo 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? 10 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? n� 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? tit 0 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. 1n WWR No. 9685384 • • 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. nn 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. INUAIW ?'41r1 I21) 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. NIM14190( 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? M/ 12. If the response to Interrogatory 11 is in the affirmative,state the amount of non-exempt funds on deposit in the account. W1k WELTMAN, WEINBERG& REIS CO., L.P.A. By: William T Molczan, quire PA I.D. #47437 WELTMAN, WEINBERG& REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 W WR No. 9685384 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating r to unsworn falsifications to authorities, that he/she i L SS k L e) OWE 01'1.5 of V-- % 1c1- F , garnishee herein, Title) ' / Gt� (Company) y) 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 (SI NATO W WR No. 9685384 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff VS. Civil Action No. 12-4770 ANGELA D CHRISTOPHER Defendant(s) k-(S INTERR0G&4"Vpq ATTACHMENT SOVEREIGN BANK MEMBERS 1 ST FCU 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 Fri .< - ?�c; - C_ WWR No. 9685384 r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff VS. Civil Action No. 12-4770 ANGELA D CHRISTOPHER Defendant(s) SOVEREIGN BANK MEMBERS 1 ST FCU Garnishee(s) TO: SOVEREIGN BANK, 17 W HIGH ST, CARLISLE, PA 17013 MEMBERS 1 ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 RE: ANGELA D CHRISTOPHER , 8 KINGSBRIDGE CIR, CARLISLE, PA 17013 Suggested Reference No.: XXX-XX-3240 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. 9685384 r 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)? See attached la. 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. See attached 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. Yes 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? No 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? No 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? No 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? No 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. n/a WWR No. 9685384 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. See attached 9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. 11/7/13 10. If 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. 11/7/13 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? n/a 12. If the response to Interrogatory 11 is in the affirmative,state the amount of non-exempt funds on deposit in the account. n/a WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T' quire 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. 9685384 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unswom falsifications to authorities, that he/she is Camille Neiiwinger (Name) C.O.P. Lead Specialist of Santander Bank , 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. //CA - L2�3�URE) W WR No. 9685384 ANSWERS TO INTERROGATORIES Account# 7675747399 Balance: $0.00 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $0.00 Account Holder: Angela D Christopher 509 W North St Carlisle, PA 17013 VERIFICATION I, Camille Neuwinger, C.O.P. Lead Specialist of Santander, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Santander By: (" d-T Camille Neuwinger C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Discover Bank by its Servicing Agent DB Servicing Corporation VS. Angela D Christopher CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: William T. Molczan, Esquire Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 Service by certified mail addressed as follows: Angela D Christopher 509 W North St Carlisle, PA 17013 Camill uwinger C.O.P. Lead Specialist Santander MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 November 18, 2013 WELTMAN,WEINBERG & REIS CO.,L.P.A. BY: William T Molczan, Esquire Attorney for Plaintiff(s) t7 -a °t, I.D.No. 47437 <INC(' t� 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 P- C} Phone: 412.434.7955 v29 per Fax: 412.434.7959 90 t;? File# 9685384 DISCOVER BANK THROUGH ITS SERVICING AGENT DB SERVICING CORPORATION Cumberland County Court of Common Pleas vs. ANGELA D CHRISTOPHER NO. 12-4770 and SOVEREIGN BANK, MEMBERS 1ST FCU Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), SOVEREIGN BANK, MEMBERS 1ST FCU, only. WELTMAN, WEINBERG&REIS CO., L.P.A. By 4,� William T Molcza , Esquire Attorney for Pla' tiff 461. •" U=It/P/4/6/60, °' 2_ a '3 93L, 7 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CJJMEERLAND COUNTY T NC 1- RO 19i0 O ;!' 20i JUN 16 PK 2: CUMBERLAND ,r PENNSYLVANIA Discover Bank vs. Angela D. Christopher Case Number 2012-4770 SHERIFF'S RETURN OF SERVICE 11/19/2012 03:13 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 19, 2012 at 1510 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Angela d. Christopher, 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 Lannie Wolf, 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 November 20, 2012 to Angela D. Christopher at 8 Kingsbridge Circle, Carlisle, PA 17013. 06/13/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.96 SO ANSWERS, June 13, 2014 (c) CountySuito Sheriff, Teleosoft, Inc. R ANDERSON, SHERIFF Z76 G Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF THE V4ERIFF THE PRO € Hf]NOTt;i iti JUN i 6 PM 2: 35 CUMBERLAND COUNT'Y PENNSYLVANIA Discover Bank vs. Case Number Angela D. Christopher 2012-4770 SHERIFF'S RETURN OF SERVICE 11/07/2013 12:34 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, Sovereign Bank, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Denise Beecher, 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. 11/07/2013 01:05 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, Members 1st Federal Credit Union, 321 York, Carlisle, PA 17013, Cumberland County, by handing to Melisa Hollis, 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 November 13, 2013 to Angela D. Christopher, 8 Kingsbridge Circle, Carlisle, PA 17013. 06/13/2014 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: $146.09 SO ANSWERS, June 13, 2014 (c) Coun ySui e Sheriff, Teleosofi, Inc. RONNR ANDERSON, SHERIFF e2 as- ty(