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HomeMy WebLinkAbout12-6851~ ~i [ ~3 ~ P na ~: i --~ i~L;,~rii CC~"~~''f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Bank, Through Its Servicing Agent, DB Servicing Corporation Plaintiff vs. NATOSHA L STIFFLER Defendant I _ C~VL) No : ~ d~- ~-1~ ~S 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: 412-338-7130 30054993 C A Pit SJS S a~,} ~ ~us.~sPd a~ ~~~ 16~~3~31 Qua 8a9o 3 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 NATOSHA L STIFFLER 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 banking institution organized under the laws of the State of Delaware and maintains a business address of 12 Reads Way, New Castle, DE 19720. 2. DB Servicing Corporation is the servicing affiliate for Discover 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, business management services in support of Discover Bank business lines, including, among other things, credit cards, deposits, personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the account to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. 3. At all times pertinent hereto, DB Servicing Corporation is the 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 147 PORTER AVE CARLISLE, PA 17013 5. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX1954 . 6. Defendant made use of said credit card and has a current balance due of $9156.27 A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1". 7. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff . 8. Although repeately requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due the Plaintiff. WHEREFORE, Plaintiff prays for Judgment in its favor and against Defendant, NATOSHA L STIFFLER ,INDIVIDUALLY in the amount of $9156.27 with interest at the statutory rate of 6.00 g per annum from date of judgment and costs. C"' ,i"~ - Wi iam T. o c n,47437 WELTMAN, WEINB G & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 WWR# 30054993 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 s o ~°"`° s i,~; ~ °'""°~ Payment Due Date August 26, 2012 31 SDSNt1A01 0009275 NATOSNA L STIFFLER 147 PORTER AVE CARLISLE PA 17013-2547 Account Number ending in 1954 Enter Amount Encbsed Bebw S Text APP ro DIBCOV' to receive a IiMt ro our free mobie app and pay your bill in seconds from enywherel PO BOX 6103 Illsssllsssrsllrsssll~Ilsr~ CAROL STREAM IL 60197-6103 RRT Addreu,emoilatelephan.change4 ~rl~r~~~~rrrr~~~irl~~i~~~~~i~rr~r~I~I~~~~~~~I~~~~~n~Ilu~~~i~ ~~~YMI Go ro www.0iscew.can a print charge i^ space above. 0000019866180190614690000000000000001581D0 r;7pantttg uas:.wty 16, ZO 1 Z - (,1Ni11g DON; July 31, Discover CI'psn Rood Card Aaount Summa Account number ending in T 954 Previous Balance 69,156.27 Payments And Credits 9,156.27 Purchases + 0.00 Babncs TransFers + 0.00 Cosh Advances + 0.00 Fsss Charged + 0.00 Interest Charged + 0.00 New Balance 0.00 Sw Interest Charge Cak:ukstion section iosowirg hansoctions for detailed APR information ..... Ins ~ ur ~ Payrr»nt Information New Bolanee 60.00 Minimum Payment Dw 61,581.00 Payment Due Date August 26, 2012 lale Wanisg: If vrs do not receive your minimum payment by If 1e data listed Dhow, you may haw ro pay a ksh Fie of up ro 635.00 and your porches. and balance hnnsfa APRs Fa nave transactions may bs increased up to R» Penahy APR of 17.999: variable. Manage Your Account Online at www.Discov~r.wm Securely acceu sfahmads and Gee online tools, pay bills online and track and view aA hansactions simply and easily Make yaw money worth moron-find easy ways ro cam and. nelnm. cosh swords. NEWT Access yaw account securely through your mobile phone 3 Easy Wolys to Contact Us BOnuSe 1 Access yaw account sscu-ely at www.Dacowrcan AnnivasaryMoMh 2. Cdl 1-800~DISCOVER (l•800.347.2683 . February Pleaw haw your Discovers cad avaiksb~. Opening Cashback Bonus Balance 6 0.00 3. Write ro w ar Dixowr PO Box 30943, Sale Lake Ciy, l1T 841 ~0 f Wof a payment address) New Cashback Bonus This Period + 0.00 For payment,~a! send ro addreu on remitiaue a Coshbadc saws selance 6 0.00 Discover, PO aax a i 03, Cad Stream, IL 60197.6103 ro Iwrn aror., lea ~n m vsww.Oisoovereom For TDD (ielaoanmu^icdions Dwice far IM Deai) assistance, please call 1-800.347-7449. Transactions Trans. test oe>M. ~ Payments and 6rtdrfs Jul 31 Jul 31 INTERNAL CHARGE-OFF 6 •9,156.27 Fws IOTA! fEES FOR THI6 F'ERlOD 6 0.00 1Mered CMrged - - - - - DOTAL NT~ST FOR TINS 1QIOD S 0.00 2012 Totals Year-b-Date TOTAL FEES CHARGED IN 2012 S 393.79 TOTAL INTEREST CHARGED iN 2012 657.57 30054993 NOTICE: SEE REVERSE SIDE FC~R IMPORTANT INFORMATION Paperless statements mean less clutter, more convenience Easily access up ro 24 months of downloodoble, password protected statements. • See your statement as soon as it's available rather than wait hx 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 Discowrtom/papsrless ®2010 Diuwer Boni, Member FDIC - PAPER.0310 O Z or D _o N V N~ X 30054993 QUBSifOnS? Visit www.Discover.aom or call 1-800-DISCOVER (1 800-347-2683). ~~,~R DISCOVER NATOSHA L STIFFLER It pays ro Account number ending in 1954 page 2 of 2 Interest Chalrge Cclcula ' n Your Annual Percentage Rafe (APR) is tin nuai irttersst rate on your «covnt. Current biting Pmiod: 6 days TYPE OF BAIANCE ~ ~PERCEMAGE ~~~SU1 JECf TO WTEREST CWIRGE ~~~ 2.99% V SO ~ Cash Advances 3.99% V =0 V ~ Variable Rote Additiotta! kttperlarst bferrrtadiort Sea yeti Casdrrtentber /lgreetsteM. Your rdmember Agreement cortMins all the terms of your Account. lost or stolen cards. Report immedialslyl Csi 1.600.347.2683. >r Y ~ CEn Y Srahnsarst IF you think then is an error on your ent, write to us at: Dixover, PO Box 30421 Sah Laks City, UT 84 1 34042 1 In your IeMer, give us the foNowing m 'on: Account information: Your name nil «counf number Dollar amount: The dollar amount the suspected error. p~,~ri_d_ron of Problem: If you thi there is an error on your bill, describe whd you t»liwe is wrong and why you believe i i'f i a mis a'FT;i.-- You must contact w within 60 days the error appeared on your statement. You must notify us of any polerdiai ~ wri .You may call us, but iF you do ws aro not required to investigate any pobntial errors and you may haw pay tM amount in question. While we investigate whether or not has been an error: the Fdbwing aro true: We eanraf try to collect Cite am in question, or roport you as delinquent on drat amount, The charge in quwesfion may remai on your statement, and we may continue to charge you interest on Ihat amount. But, if we determine that we made a mi e, you wit not haw ro pay ire amount in question or any interest or other Fees related ro that amount. While you do not haw to pay the motmt in question, you aro responsible Far the romainder of your bakurcs. We can apply any unpaid am against your crodit limit. Yaw 1f Y' ~ h card P+ureheesrr If you are dissatisfied with the s or services that you haw purcFtased with your crodit card, and you haw hied in good forth to coned the with the merchant, you may haw rtes right not ro pay 1M remaining amount due on dte purcho». To u» this right, all of the Fogowi must be hue: 1 The purcha» must haw been m e in your home stile a within 100 miles of your current mailing address, and the purcha» price must haw more thou 550. (Note: Weiltre- of IMw aro necettary if your purcha» was based on an advertisement we ailed to you or if we own Nye comparry $taf sold you the goods or serness.) 2. You must haw wed your credit for the purcha». Purchases made with cash advances from an ATM or with a check That «as»s your eredH «counf do trot qualify. 3. You must not yet haw fully paid dte purchase. if aN of threriteria above ors .and..yo~+.ara atiq disad+sfied with the~purehase> cont«t_us In wr' • at: Oiacowr, PO Box 30945, Sak a Ci yt , UT 84130-0945 While ws investigate, the some (es apply to the disputed amount as discussed above. After we finish our inwdigafion, we wiN bll you ou decision. At that point, if we think you owe on amount and you do not pay we may report you as delinquent. Paprwrsb. You may ppaayy aN or part of you Account bakxxs at anytime. However, you must pay of least the Minimum Payment Due by the Paymerd Dw Dale. only your payment and A-e tap portion of this statement in rtes enwtope provided. Do not send cash. B sending check w dsacnbed above, you authorize vs to u» information on ya+r check to males an elecronie fund tro From account at the financial instilufion indicated on your check or to process IFie payment as a check transaction. If is processed as an electronic fund transfer the trartaFer wit be for the aniourtt of N» cMek. When we u» information om r cheek to make an alechonie Fund hansfer funds may be withdrawn Gam your account as soon as the same day we re<ei your payment, and you will not receive your check b«k from your Firroncia) inafitufion. Ths processing of your payment may be if you send cash, correspondence or other items wish your payment, if you send the payment to wiy eiMr addrsu or i you rue an emnlope other than the ore provided. Payments received in proper form at our processing facility b~SPM I time on city desyy wit be crodiled b your Account as of that day. Payments received at our procssing foal offer 5P kxal Nine will bs credited to Account as of the next day. IF you have misplaced yyoouurr envelope, send your to Discover, PO Box 6103 Corot Stream, {l 60197.6103. Plea» allow 7.10 days for ds+livery. If your payment is retu unpaid, we reserve the rig~it to rosubmit it as an electronic debit. ;30054993 NOTICE: SEE REVERSE SIDE FOR You can r monthly Minimum Payment Due, a a greater amount Choi does Trot sxcwd your current Account bakancs, over the or you con setup automatic payments through a customer service npraentafiw by coNirg 1.800-347. 683. Automatic payments vriN bs deducted on the Payment Dw Date urdess you request o recurring p~ymer~ date (e.a. Ilre 15th of the month) that «curs before your Payment Dw Doh. If your scheduled payment doN~FaRc on a weekend or bank hdidoy, yaw payment wiN bs processed the busrneas day for la the wwkand or bads fwhdoy. In order ro xh.dule monthly payments b you wrq need this statement ard~yow bank account inFormation. You will be asked ro provide tM bat four (4~dig' of the s«ial security number of fire primary borrower. By pprorovviiding chose numbers as your electronic signature, you wtN be agreeing ro this auNtorizdion ro aNow vs and yaw bank ro deduct each payment you authorize, in the amount aelschd by you, from yaw bank «coud. You abo authonze us ro initiate debit a credit enhies to your bank account, as applicable ro correct an error in the processing of such payment. You can cancel a xfreduled payment by phone at 1800.347-12683 a by mail d Discover, PO Box 30421 SaN yoke City, UT 84130A421 however ws must roceiw notice of least three business days in advance of the xherJrlled payment. If your payments may vary in amount, we wiN tell you on each monthly biNing statement when yaw payment wiN bs made and how much it wiN be. You must enwro Ihot wiHcisnt funds aro available in yaw bank account, and oN honsactions must canply with U.S. law. You con set auomatic payments for• (i) sfaternent New Balance, (ii) statement Minimum Payment Due, (iii) statement Minimum Payment Due plus a fixed dollar amount, or (ivj o fixed doNor amount. If yaw xMduled fined payment is red enout~ ro cover the Minimum Payment Dw as listed on your monlldy bi~N~'mmgg ~s~ta~terrrent, your scheduled payment for that month wiN increased ro cover the Minimum Paymerd Due, If the scMdtAed payment ra grooter Ifran dre Minimum Payment Due, any excess will be toil in «cadarres with your Cardmember Agreement. If yaw scheduled is greater lfran the New Baksnce on yax' billing statement, tfwt payment wiN bs processed only for tl» amount of your ew~Balarrce. Yow autanalic amount maybe bss Ilan the amount Indic on the psi is statement based on credits or payments after tfre losing Date. If you enrdl by phone in our automatic payment service, please tilLin the fdbwing blanks below and retain the authorization For your records. Amount: ^ Full Pay ^ Min Pay ^ Min Pay + S ^ Fixed Pays mo Bank Routing #: ,Bards Account #:_ _ .Frequency: ~ Caedil fteportin8. We may report inFormation about your Account to credit bweaus. late payments, missed payments, or ~ other defauMs on yaw Account maybe reflected in your credit repot. We normaNy report the status aril payment history of yaw Account ro credk reporting agencies each month. If believe Ifrd our report is moccurate a incomplete, please writs °g us of 1M foNowing address: Dixover PO Box 1531 b, rlmingron, DE 1985 531 b. Plwse indicab your name, address, home telepFwne number and Account number ~ P Merest We bsain M impose interest cho-gsa on a hansodion fee a ir~rest chage from the day we add it 10 t~ N daily lance. We c nw ro impose interest charges until you pay I~ie total amount you owe us. You con avoid poy~ng ux, interest on Purchases as dexribed bebw. However, you correct avoid paying interest on Balance Transfers a Cosh Advances. How to Avoid Pavino Ir,tsrest on Purchases ("Grace Period") fFyou pai~ii F7sw on your previous EAiiint by the Payment Dw Date shown on that biNirrg st~menf, we will not impox interest charges on new Purchwes a an portion of a new Pwchase, paid by the Payment Dw Date on your current biting stoternent. tJew Purchases ors Purc)ases that First appear ae the curru~ biging sMtemenf. How We Andy Pavmsnts Merv Imoad Your Period ~Ya~~PaY Y~~Ba"Tance'm e« m en, depending on the balance to which we apply your payment, you may not get a grace period on new Purchases. ifew w. cakulote Merest aarg.e Doyy D.foac. iMethod ('ndadirg aurnM trace«tien:l: We cakubte interest chages oath billing period by first figguring the "doily balance" for a«h Transaction Cabgory. Transaction Categories include stand6idl Piirchasei, srond6rd"Cd' Adii(sni:es crid'd~ffusrit promotional balances; such as Balance Trans rs. flow We Figure the Daily Neieace for Each Trassoetion CaNyay Ws start with the begiming balance For each day. The inning baksncs for the first day of the billing period is yaw baksnce on the Ilaast day of your previous billing pert We add any interest charges accrued on the previous day's doily baksrrce and any new hansactions and fees. We add an raw transactions or foes as of die later of the Transaction Dah or tf to first day of the biNirg period in which the ironsoction or Fee posted ro yaw Account. We subhad any new crodits and payments. We maker other adjustments (including dross adjustments required in the "Paying Interest" section). How We Figure Your Total Merest Charges We mukiply the dot botorta For a«h Tranwction Cdegory by its doily penodic rah. We do this Far each day in the biNing period. is giros us the interest charges far such Troraaction Category. To get a daily periodic rote, ws divide the APR drat applies ro the Tranwction Category by 365. We add up aN tfrs daily interest charges. Tfa vim is Ifs total interest charge For the biNing period. Ftovv YVe Include Fees Ws add Baionce Transfer Fees ro tM applioobte Balance TransFsr Transaction Ca~e~ary We add Cash Advance Fees to the applieobb Cosh Advance 7ronsaciion Category. We add oN other Fess fo iM standard Purchase Transaction Category. Balance Subject to YNerest Rafe. Your stahmerd shows a Babncs Subject ro IntsresF Rah. U shows this For each transaction cntegory, The Balance Subject ro Inhrost Rate is the average of the doily boksncss during Ifs billing period. Credit balances. If your Account has a credit bdonce, H» amount is shown on tfte front of yax biAing statement. A credit bobnce is money drat is owed ro you, You may make ch~r~~ agairM Ihia amounF iF your Account is open. We wiN send you a refund of any remoming balance of j1.00 or more aRer b months, or os otherwise regwred by applicable law. Fq ZDQlfelec~aications Device ter Ise Deaf] aaiparxe, please caA 1.806547-7419. D xover may moniror aril/w record telephone eons between you aril Dixovx reprossnlafives for quality assurance purposes. The Dixovsrmcard is issued by Oixover Bank, Member FDIC RZNfE00t Qtlf°St1O11S~ Visit www.Disaover.can or ~~~~ colt 1-800-DISCOVER (1-800-347-2683). VERIFICATION ~,. i~.ru- Legal Placement Account Manager (Name) (Title) of DB Servicing Corporation, servicing; affiliate of Discover Bank, (Company) does hereby verify, under penalty of perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities states, that he/she is a duly authorized representative of plaintiff herein and authorized to make this verification, and that the facts sets forth in the foregoing Complaint are true and accurate to the best of his/her knowledge and information and that he/she is personally familiar with the. account and the relationship between Discover Bank and DB Servicing Corporation. That Discover Bank, f/k/a Greenwood Trust Company, is aFDIC-insured Delaware State bank, and its servicing affiliate DB Servicing Corporation, extends credit through issuance of the Discover Card. As the servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank including business management services in support of Discover Bank business lines, including, among other things, credit cards, deposits, personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the same to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank are wholly owned subsidiaries of Discover Financial Services. Date I U - l ~ - t a- NATOSHA L STIFFLER XXXXXXXXXXXX1954 (S nature) DB Servicing Corporation serving affiliate for Discover Bank PO Box 3025 New Albany, OH 43054 WWR# 30054993 C A Pit SJS SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~4,~«~r of ~~t~ri~,~tr~~~ 1 F, i~ri~-" P~~J7NC'~l~ ~~~ ~~~2 ~~~ ~7 ~~ ~~ % J~ ~~~~Ef~~.~~~ ~~~~~~ PENNSYLVANIA Discover Bank Through Its Servicing Agent, DB Servicing Corporation Case Number vs. 2012-6851 Natosha L Stiffler SHERIFF'S RETURN OF SERVICE 11/19!2012 03:54 PM -Deputy Shawn Harrison, being duly sworn according to law, served e r uested Complaint & Notice by "personally" handing a true copy to a person representing t mse es t be the Defendant, to wit: Natosha L Stiffler at 147 Porter Avenue, Carlisle Borough, Carlis 7013. DEPUTY SHERIFF COST: $40.00 November 21, 2012 SO ANSWERS, )~~ RON R ANDERSON, SHERIFF iv! Ceu^tySttite Sheri ti, Tc-leisoft, If;. . i a jJ yOil: ti} }2�� �SP f EIkJ�V llt�i91 is 2013 MAR 14 Pli 2: 3 9 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 No. 12-6851 CIVIL VS. PRAECIPE FO + UTION NATOSHA L STIFFLER )y7 P,.� Aot 1 Defendants) �(�1 r ltS?-p , PP /70i3 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 S (412)434-7955 -� °�,� a g0 . 00 CBr- 103. (( 4 - d a . �ifs� � I s . sow. W"WR No. 30054993 c� i)e 'ct j r + 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. 12-6851 CIVIL NATOSHA L STIFFLER Defendant(s) MEMBERS 1 ST FCU 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 NATOSHA L STIFFLER ,Defendant 3. against MEMBERS 1 ST FCU,,,Garnishee 4. Judgment Amount $ $9,156.27 Less Payments/credits received $ $0.00 Interest $ $70.74 Costs $ SUBTOTAL: $ $9,227.01 Costs(to be added by Prothonotary): $ WELTMAN, WEINBERG&REIS CO.,L.P.A. By. .� William .Molczan,Esyyl e 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. 30054993 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-6851 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 NATOSHA L.STIFFLER,147 PORTER AVENUE,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: 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$9,156.27 L.L. $.50 Interest $70.74 Atty's Comm % Due Prothy$2.25 Arty Paid $189.25 Other Costs Plaintiff Paid Date: MARCH 14,2013 David D. Buell,Prothonotary (Seal) Deputy REQUESTING°)'ARTY: 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 2013 APR -4 AM 11: 42 R 2 91013 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. 12-6851 CIVIL NATOSHA L STIFFLER S�rP�s Defendant(s) /-0 MEMBERS 1ST FCU INTERROGATORIES IN ATTACHMENT 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. 30054993 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, RECEIVED DB SERVICING CORPORATION Plaintiff OAR 2 9 2013 vs. Civil Action No. 12-6851 CIVIL NATOSHA L STIFFLER Defendant(s) MEMBERS 1 ST FCU Garnishee(s) TO: MEMBERS 1 ST FCU, 1711 SPRING RD,CARLISLE, PA 17013 RE: NATOSHA L STIFFLER, 147 PORTER AVE, CARLISLE, PA 17013 Suggested Reference No.: XXX-XX-1524 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 into the Garnishee's possession thereafter until Judgment is entered against the Garnishee. For defendant example, tthe 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. 30054993 INTERROGATORIES IN ATTACHMENT BAR 2 9 1. At the time you were served or at any subsequent time did you owe the defendant any mo 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)? � a I 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. ` �14. �� - c..n ' 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? N 0 5. At any time before or after you were served, did the defendant transfer or deliver any property 10 you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? N0 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? ?. If you are a bank or other financial institution,at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law?If so,Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account,and the entity electronically depositing those funds on a recurring basis. No WWR No.30054993 8. If you area bank or other financial institution,at the time you were served or at any subs exl a(rl time did the defendant have funds on deposit in an account in which the funds on deposit,not including airy otherwise exempt funds,did not exceed the amount of the general monetary exemption under 42 Pa.C.S. 8 12?7 f 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. N1(�r C 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 1h s institution. March 11. If the response to Interrogatory 7 is in the affirmative,are other funds comingled in the accolir t which are not deposited electronically on a recurring basis and which are identified as being funds that upon di-posit are exempt from execution, levy or attachment under Pennsylvania or federal law? �jv 12. If the response to Interrogatory 11 is in the affirmative,state the amount of non-exempt funds ort deposit in the account. WELTMAN, WEINBERG&REIS CO., L.P.A. By:4#4�7437 YEuire Will PA I WELTMAN, WEINBERG& REIS CO.,L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 WWR No. 30054993 RECEIVED VERIFICATION MAR 2 9 Z013 The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/she is (N e) COUSr oct LOW of�,'��Ellll�ti�'S f St '(Title) garnishee herein, CL��`�t— (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. (S ) WWR No. 30054993 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION C DISCOVER BANK, THROUGH ITS rnrn SERVICING AGENT,DB SERVICING N ,M CORPORATION v �> r� c Plaintiff No. 12-6851 CIVIL vs. PRAECIPE FOR JUDGMENT AGAINST!:!; . ' GARNISHEE NATOSHA L STIFFLER Defendant MEMBERS I sT FCU Garnishee 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 Bldg. 436 Seventh Avenue Pittsburgh,PA 1.5219 (412)434-7955 WWR#030054993 I(o.50 Pb Al7-( e*i 1190-78y �# agz)13q No�-u A-@�1,ed 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. 1.2-6851 CIVIL NATOSHA L STI.FFLER Defendant MEMBERS 1 ST FCU Garnishee PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, MEMBERS 1 ST FCU, in the amount of$222.22,which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG&REIS CO.,L.P.A. William T Molczan Esqui PA I.D.#47437 Weltman, Weinberg&Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 WWR#030054993 I hereby certify that the address of the Plaintiff is: c/o Weltman,Weinberg&Reis Co.,L.P.A., 1400 Koppers Building,436 7`"Avenue,Pittsburgh,PA 15219 And that the last known address of the Garnishee is: 1711 SPRING ROAD, CARLISLE,PA 17013 St via MEMBERS 1St FEDERAL CREDIT UNION April .8, 2013 William T Molczan, Esquire 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 RE: Writ of Execution for Natosha Stiffler/LeBlanc Dear Sir: A search of our records has revealed one account bearing the name Natosha Stiffler/LeBlanc with an address of 147 Porter Ave, Carlisle, PA 17013. The account reflects an available balance of$522.22, Pursuant to the writ, all funds in the aforementioned accounts above and beyond the monetary exemption provided by 42 P.S. Section 8123 and Pa. Rule of Civil Procedure 3111.1(3) in the amount of$300.00.have been frozen. Except for the exempt funds in the amount of$300.00 which are statutorily not subject to attachment, the accounts have been restricted from any further withdrawal transactions. Should you have any questions or need any additional information, feel free to contact me at (800) 283-2328, ext. 6022. Sincerely,, Jessica Nguyen Deposit Operations Analyst 5000 Louise Drive P.O. Box 40 Mechanicsburg,Pennsylvania 17055 (800) 283-2328 www.metnberslst.org x _ x r r RECEIVED 'Reced10 a : i ¢ APR 08 2013 AR292013 2013 APR -4 A.M 11= 42 IN THE COURT OF COMMON PL ERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK,THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff vs. Civil Action No. 12-6851 CIVIL NATOSHA L STIFFLER Defendant(s) MEMBERS 1 ST FCU INTERROGATORIES IN ATTACHMENT 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. 30054993 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, RECEIVED RECEIVEID DB SERVICING CORPORATION Plaintiff APR 0 8 2013 MAR 2 9 2013 VS. Civil Action No. 12-6851 CIVIL NATOSHA L STIFFLER Defendant(s) MEMBERS 1 ST FCU Gamishee(s) TO: MEMBERS 1 ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 RE: NATOSHA L STIFFLER, 147 PORTER AVE, CARLISLE, PA 17013 Suggested Reference No.: XXX-XX-1524 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 ro e attachment which is then in the hands of the garnishee, it also attaches all property r rtY of the Defendant subject to into the Garnishee's possession thereafter, until Judgment is entered against t GarnisheeenFor example, the to 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. p WWR No. 30054993 r RECEIVED . � APR Q$ 20 INTERROGATORIES INTERROGATORIES IN ATTACHMENT MAR 9 1. At the time you were served or at any subsequent time did you owe the defendant any monnl? 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)? fS I a. If the answer to Interrogatory 1 is in the affirmative,state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location 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. r 1 rr-, Sc�v1 X25 t I S Ill C. 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? 0 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? �V b. 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? 1 D 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.30054993 MAR 2 9 2013 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. RECEIVED APR 08 2013 9. If the answer to Interrogatory 1 is in the affirmative,state the date the sheriff served these interrogatories on this institution. NkA ' �.h 2._q , W 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. /146.r ch 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 I I 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, E uire 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. 30054993 RECEIVED VERIFICATION APR 0 8 2013 MAR 2 9 2013 The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she isS Wei �(-Yuj of Mfnl�m'r� (Title) , garnishee herein, (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. (S URE) WWR No. 30054993 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. 12-6851 CIVIL NATOSHA L STIFFLER Defendant MEMBERS 1 ST FCU Garnishee NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff ( )Defendant (xx)Garnishee t' You are hereby notified that the following Order or Judgmen w s entered against you on 5 �3 (xx) Assumpsit Judgment in the amount of$222.22 plus costs. ( ) Trespass Judgment in the amount of$ 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 ( ) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PROTHONOTARY(OR DEPUTY) Members 1 S`Fcu 1711 Spring Road Carlisle,Pa 17013 WELTMAN,WEINBERG&REIS CO.,L.P.A. BY: William T Molczan,Esquire I.D.No.47437 Attorney for Plaintiffs) CD 436 Seventh Avenue, Suite 1400 w " Pittsburgh, PA 15219 me rn- Phone: 412.434.7955 -c _or—n Fax: 412.434.7959 N o= File#30054993 -<3> .17 -cc -v d DISCOVER BANK o THROUGH ITS SERVICING AGENT DB SERVICING CORPORATION Cumberland County VS. Court of Common Pleas NATOSHA L STIFFLER and NO. 12-6851 CIVIL MEMBERS 1 ST FCU Garnishee(s) PRAECIPE TO SATISFY ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter satisfied as to Garnishee(s), MEMBERS 1 ST FCU, only. WELTMAN, WEINBERG&REIS CO., L.P.A. By 4 William T Molczan,Esqu' Attorney for Plaintiff awe+ q. so d ` SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ; "L J-f F-HC ., Sheriff T H P R 0 N 0 Jody S Smith Chief Deputy 47313 SEP 26 P-M 2: F i Richard W Stewart CUMBERLAND COLINTY Solicitor OFFICE_ F T"%SHERIFF PENNSYLVANIA Discover Bank Through Its Servicing Agent, DB Servicing Corporation Case Number vs. Natosha L Stiffler 2012-6851 SHERIFF'S RETURN OF SERVICE 03/28/2013 01:45 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, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Jan Finkle, Member 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 April 2, 2013 to Natosha L. Stiffler at 147 Porter Avenue, Carlisle, PA 17013. 09/26/2013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.93 SO ANSWERS, &�— X ZX�� September 26, 2013 RON R ANDERSON, SHERIFF I. aS" �,d . & (y CountySuite Shariff,TeleosoR,Inc. joiS- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, Q . , DB SERVICING CORPORATION Plaintiff �- vs. Civil Action No. 12-6851 CIVIL r a 52,7L- -37 C.? t : NATOSHA L STIFFLER Defendant(s) p r MEMBERS 1ST FCU 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 NATOSHA L STIFFLER , Defendant 3. against MEMBERS 1ST FCU, , ,Garnishee 4. Judgment Amount $ $9,156.27 Less Payments/credits received $ $222.22 Sq. v S Interest $ $505.72 Costs $ SUBTOTAL: $ $9,439.77 Costs(to be added by Prothonotary): $ WELTMAN, WEINBERG& REIS CO., L.P.A. By: A/ ✓ (� William T. Molczan, Es• ire PA I.D. #47437 WELTMAN, WEINBERG& REIS CO., L.P.A. 1400 Koppers Building n 436 Seventh Avenue Qtk coq' a Pittsburgh, PA 15219 4)(, Cfi (412)434-7955 ( (o . SO " 11 it (t ti tw 1/(/d201 V 7 7 WR No. 30054993 2:5i_pfred K--ft 6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK,THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff No. 12-6851 CIVIL vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) NATOSHA L STIFFLER Defendant(s) 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. 30054993 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-6851 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 NATOSHA L. STIFFLER, 147 PORTER AVENUE,CARLISLE,PA 17013 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of • GARNISHEE(S)as follows: 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; (2) 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$8,934.05 Plaintiff Paid$ Interest$505.72 Attorney's Comm. % Law Library$ Attorney Paid$332.18 Due Prothonotary$2.25 Other Costs$ Date: 12/30/13 David D.Buell,Prothonotary : • A, • -7, _ Deputy REQUESTING PARTY: Name: WILLIAM T. MOLCZAN,ESQUIRE Address: WELTMAN,WEINBERG &REIS CO.,L.P.A. 1400 KOOPERS 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 Jody S Smith Chief Deputy Richard W Stewart Solicitor F■ �E_N S Y L.!.+`r E Discover Bank Through Its Servicing Agent, DB Servicing Corporation Case Number vs. Natosha L Stiffler 2012-6851 SHERIFF'S RETURN OF SERVICE 01/06/2014 02:13 PM- Shawn Gutshall, 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, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Kathleen Nissley, Sales Assistant, 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 7, 2014 top Natosha L. Stiffler at 51A Konhaus Road, Mechanicsburg, PA 17050 (address of 147 Porter Avenue, Carlisle, PA 17013, provided by attorney's office is incorrect). ' ' • "e " SHALL, DE'T SO ANSWERS, tom- January 07, 2014 RONNR ANDERSON, SHERIFF ,ur; rc rJV+ 1 • OF i tk, PRO MONO TARY 2014 JAN 10 Pti 1: 12 CUMBERLAND COUNTY PENNS MANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RECEilfFr DISCOVER BANK,THROUGH ITS SERVICING AGENT, JAN 0 7 2014 DB SERVICING CORPORATION Plaintiff vs. Civil Action No. 12-6851 CIVIL NATOSHA L STIFFLER Defendant(s) (�! INTERROGATORIES IN ATTACHMENT 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. 30054993 . 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. 12-6851 CIVIL NATOSHA L STIFFLER Defendant(s) MEMBERS 1ST FCU Garnishee(s) TO: MEMBERS 1ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 RE: NATOSHA L STIFFLER, 147 PORTER AVE, CARLISLE, PA 17013 Suggested Reference No.: XXX-XX-1524 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. 30054993 4 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)? yes 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. SGT' n , yO(1 +? i \d 3°C) cam,C it 33-7.5L bc 2. At the time you were served or at any subsequen 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. n'CL 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? n1a 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? n Q 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. 30054993 4 • 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. na 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. J �. al'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. ,-)cn Lo, o19 1 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? fl`Q 12. If the response to Interrogatory 11 is in the affirmative,state the amount of non-exempt funds on deposit in the account. n10,- WELTMAN, WEINBERG& REIS CO., L.P.A. By: 1,/,,L.-2:77/71 ,----- William T. MolczanEsqui 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. 30054993 _ p 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 (.`1310, c -c e�Cly (Name) +w-A n, saw f (` ''UesS i5 �rC�.1 , garnishee herein, (Title) (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. I (SIGNATURE) • WWR No. 30054993 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff No. 12-6851 CIVIL VS. PRAECIPE FOR JUDGMENT AGAINST ' GARNISHEE - - NATOSHA L STIFFLER =r C cn�' — Defendant ., CD c_) MEMBERS 1ST FCU 3,, n? t-'r C' _ Garnishee 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#30054993 n Ctif li yrxyeso Nlid\/0 INkti 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. 12-6851 CIVIL NATOSHA L STIFFLER Defendant MEMBERS 1ST FCU Garnishee PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, MEMBERS 1ST FCU , in the amount of$39.99,which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG & REIS CO., L.P.A. By. William T Molczan E ire PA I.D.#47437 Weltman, Weinberg& Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#30054993 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg& Reis Co.,L.P.A., 1400 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: 5000 Louise Drive, PO Box 40, Mechanicsburg, PA 17055 • St MEMBERS 1st FEDERAL CREDIT UNION January 13, 2014 William T. Molczan, Esquire 1400 Koppers Building 436 Seventh Avenue Pittsburg, PA 15219 RE: Writ of Execution for Natosha L Stiffler Dear Sir: A search of our records has revealed one account bearing the name Natosha L Stiff ler with an address of 51A Konhaus Rd Mechanicsburg, PA 17050. The account reflects an available balance of$339.99. Pursuant to the writ, all funds in the aforementioned accounts above and beyond the monetary exemption provided by 42 P.S. Section 8123 and Pa. Rule of Civil Procedure 3111.1(3) in the amount of$300.00 have been frozen. Except for the exempt funds in the amount of$300.00 which are statutorily not subject to attachment, the accounts have been restricted from any further withdrawal transactions. Should you have any questions or need any additional information, feel free to contact me at (800) 283-2328, ext. 6022. Sincerely, , Melissa Greenwood Deposit Operations Manager 300S Leg C13. 5000 Louise Drive • P.O. Box 40 • Mechanicsburg,Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org f 2a 1' JAN 10 PH I: 12 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RECFn r' DISCOVER BANK, THROUGH ITS SERVICING AGENT, JAN 0 7 2014 DB SERVICING CORPORATION Plaintiff vs. Civil Action No. 12-6851 CIVIL NATOSHA L STIFFLER Defendant(s) INTERROGATORIES IN ATTACHMENT 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 11`,'.'a `Nu. 3( 0 4993 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)? des y 3 Sav n5 S 331,5Lo c�klec�k�ny I a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location 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. a_y3 sc n ifc 300. 00 33 Lo chcc.t-��5 exe��►P� 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. ,n 4a 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? n C. 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? n C'• 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? n 1GL 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. W1VR No. 30054993 8. I f 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. 1.p. Ol1 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. Lo,D,019 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? f1 o. 12. If the response to Interrogatory 11 is in the affirmative,state the amount of non-exempt funds on deposit in the account. n'� WELTMAN, WEINBERG & REIS CO., L.P.A. By: G11 7' � William T. Molczan, Esqui,r PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 \V\VR No. 30054993 r 1. 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 )iCc2 (Name) . ► i. ��. - _ •f f1 1n1` s )5t , 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. (Y) y (SIGNATURE) 1VAVR No. 30054993 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. 12-6851 CIVIL NATOSHA L STIFFLER Defendant MEMBERS 1ST FCU Garnishee NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff ( ) Defendant (xx)Garnishee You are hereby notified that the following Order or Judgmen vas entered against you on I Ip I� (xx) Assumpsit Judgment in the amount of$39.99 plus costs. ( ) Trespass Judgment in the amount of$ 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 ( ) Default ( ) Verdict ( ) Arbitration Award �j Prothonotary 'g By: 10%) 2,43) ut-,(1.-"" PROTHONOTARY (OR DEPUTY) Members 1 S`FCU 5000 Louise Drive PO Box 40 Mechanicsburg, PA 17055 WELTMAN,WEINBERG & REIS CO.,L.P.A. BY: Matthew D Urban,Esquire Attorney for Plaintiff(s) I.D.No.90963 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File# 30054993 DISCOVER BANK THROUGH ITS SERVICING AGENT DB SERVICING CORPORATION Cumberland County Court of Common Pleas - vs. Ca -6 NATOSHA L STIFFLER c =� NO. 12-6851 CIVIL , - and cn r-' ta) c.s -<> c; r— MEMBERS 1ST FCU y° ° ? ; rr.. Garnishee(s) �. . .r PRAECIPE TO SATISFY ATTACHMENT EXECUTION, TO THE PROTHONOTARY: Kindly marked the above matter satisfied as to Garnishee(s),MEMBERS 1ST FCU,only. WELTMAN, WEINBERG& REIS CO., L.P.A. By Matthew D Urban, Esquire Attorney for Plaintiff 4 91.50 PA Rte`/ 4. • • • • • • • • • • • • • • • • • • • • • • Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY if f HE PROTHONO IA , 2 IEI AUG 29 PM 2:02 CUMBERLAND COUNTY PENNSYLVANIA OFFICE OF THE $It6RIFF Discover Bank Through Its Servicing Agent, DB Servicing Corporation Case Number vs. Natosha L Stiffler 2012-6851 SHERIFF'S RETURN OF SERVICE 01/06/2014 02:13 PM - Shawn Gutshall, 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, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Kathleen Nissley, Sales Assistant, 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 7, 2014 top Natosha L. Stiffler at 51A Konhaus Road, Mechanicsburg, PA 17050 (address of 147 Porter Avenue, Carlisle, PA 17013, provided by attorneys office is incorrect). 08/27/2014 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: $88.25 SO ANSWERS, August 27, 2014 RONNY R ANDERSON, SHERIFF 3/6 4/37 (c) CountySuita Sheriff, Te!eosoft. Inc.