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HomeMy WebLinkAbout12-6858~~~? ~~.a-uf Fig 3 '" U , ~'i • ~ ttt"'lll i t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Bank, Through Its Servicing Agent, DB Servicing Corporation ~ 1QYIM ~S ~~ ~t Plaintiff No: ~o~-~ vs. COMPLAINT IN CIVIL ACTION MARK A COLLINS Defendant 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 30054667 C A Pit SJS ~~~~ ~~ o"~~ i~~a-~-rte ~ a~a~ is 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 MARK A COLLINS 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, fJk/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 individuals} residing at 757 CAROL ST NEW CUMBERLND, PA 17070 5. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX9266 . 6. Defendant made use of said credit card and has a current balance due of $13153.98 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, MARK A COLLINS ,INDIVIDUALLY in the amount of $13153.98 with interest at the statutory rate of 6.00 o per annum from date of judgment and costs. ...--~ Tn1i iam T. Mo czan, 47 WELTMAN, WEINBERG & CO., L.P.A. 436 Seventh Avenue, ite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 ~# 30054667 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. New Balance Minimum Payment Due Account Number ending in 9266 D~SC~VER $0.00 $2,220.00 Enter Amount Enclosed Below Payment Due Date J $ I'~ August 26, 2012 31 SOSN6A01 0002f362 MARK A COL L I NS Text APP to DISCOV• to receive a Ilnk to our 721 TRAIL LN tree mobile app and pay your bill in seconds from anywhere! ENOLA PA 17025-1323 PO BOX 6103 (+1~us~~nnr~~nu~~s~~n~ CAROL STREAM IL 60197-6103 Address,e.mailorfebphonechangsZ I Il~rllr~~~~~lll~l~~l~~~l~ll~~~~rllllr~~~rllrll~~~~rll~r~u~~~~ Go to www.Dixever.com or print change in space oboes. ' r1t 000001986458469054502000000000000000222000 le_____ ®.~.d..• Opaning Date: July 20, 2012 - Closing Data: July 31, Discover Mors Card Account Summary Account number ending in 9266 Previous Bolancs 613,153.98 Payments And Credits 13,153.98 Purchaass + 0.00 Baksncs Tmnsfers + 0.00 Cash Advances + 0.00 Fsss Charged + 0.00 Intsroat Charged + 0.00 New Balance _ --gyp-00 Ses Interest Charge Cakubtion section folbwing transactions for detailed APR information Credit Line S 11,400.00 Credit [ira Avcilabls 50.00 Cash Advance Credit Lins 65,300.00 Cash Advance Crodit Line Availabb 60.00 Ca BOnuSe Anniversary Month December Opening Cashbook Bonus 8obncs 6 0.00 New Cashbook Bonus This Period + 0,00 Costibeek Menus balances 6 0.00 To Isarn mars, log in a1 www.Diswwr.tom 2012 page 1 ~ 2 Payment InFormation New e~nCe bo.oo Minimum Payment Due 62,220.00 Payment Due Date August 26, 2012 lele Payment Waning: If we do not receive your minimum payment by the date listed above, you may haw fo pay a late fee of up to 635.00 and your purchase and bdance transFer APRs for new transactions may be increased up to the Panahy APR of 26.99% variable. Manage Your Ac~unt Online at www.Diswver.asm Securely access statements and Free online tools, pay bills online and hack and view all transactions simply and easily Make your money worth moron-find easy ways to eom and redeem cash rowarda NEWT Acceu your account securely through your mobile phone 3 Easy Ways to Contact Us 1 Access your account securely aF www.Dicowr.com 2. Call 1.8001X5COVER 11-800.347-2683}. Pk~ase have your Dixover®card avalb 3. Writs Fo us of Discover, PO Box 30943, 5ah Lake City, UT 841301Not a payment addroxi) For poymenh, w send to address on romiBaxe or Dixowr PO Box~6103, Carol Sfream, IL 60197.6103 For TDD (Teleeommunie~Fons Device for the DeoF) assistance, pksass caN 1-800-347-7449. Transactions T~s. Demote Payments vul Credits Jul 31 Jul 31 INTERNAL CHARGE-Off 6 13,153.98 fws TOTAL FEES FOR TFMS PER10D 6 0.00 irMerestChaged - TOTAL R~ftERESi fOR TtilS Pt:RIOD 6 0.00 2012 Totals Year-b-Date 30054667 TOTAL FEES CHARGED IN 2012 6 245.00 TOTAL INTEREST CHARGED IN 2012 1,504.89 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION D' ~ Paperless statements mean less clutter, more convenience i 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 of Disa»v~com/paperkss X2010 Diuover Bank, M•mtxr FDIC PAPER.0310 y v v, z m D Qo_ g i~i NN X ut 30054667 Questions? Visit Mrww.DiscorK.con, ar call 1-800-DISCOVER (1 800-347-2683. ~SCiVER DISCOVER ~r pot's a i MARK A COWNS Account number ending in 9266 -v~a_ _: page 2 of 2 Ini+erest Chairge Cakulation Your Annvd Percentage Rate (APR) is tM annual interest rate on your account. Currant Bing Period: 12 days TYPE OF BALANCE At~l ~ CENTAGE w~--7s~E M~ SUlJECT TO imtts' ~~--~t~e NrTEREST CHARGE Purchases 10/09/2010 and after 21.99% V 50 50 10/08/2010 and prior 19.99% V 50 SO Cash Adwnces 26.999L 50 SO V =Variable Rate Additiond Importsm h(ormalion See yarn Cardmernl»r Agnenrerrf. Your Cardmember Agrwmerd contains aN the terms of your Account. Lost or stolen cards. Report immedidelyl Cs# 1.800.347.2683. What To Do ff You Think You iind A Aiie~ako On Your 1/aNnsonf If you think then is an error on your statement, write ro us d: Discover, PO Box 30421, Sak lake City, UT 84130-0421 In your krNer: give us the Following information: Account information: Your none and account number. DoNar omounh TM ddlar amount of IM wspeded error- ~sscriotion of Problem: IF you think Ihen is an error on your bill, describe whd you believe is wrong and why you believe d ~s a miaro e. You must contact us within 60 days after 11» error appeared on your stdement. You musF nofify us of any poterrtid errors ''~_~~~p You may wN us, buF if you do we an not squired fo investigate any potentid errors and you may haw ro pay rTii amount in question. While we investigate whether or rat There has been an error: the folowing are true: We cannot try ro coNed tiro amount In question, err report you as delirquerd on that amount. The charge in gwation may ranoin on your dahmerrt, and wv may contiw to charge you iMereat on that amormt. But, if we determine Nat we made a mistala, you wiN rat how ro pay the amaurd in question or any interest or other fees reldad to that amount. While you do not haw ro pay the amount in question, you are responsible For Nre remainder of your balance. We can apply any unpaid omourd apairut your credit limit. Your RiahN H You Ar+e DLeatfeRod NMIt Yaw G+edAt Card Psnrisateoe If you aro diswtisfied with dre or services That you haw purchased with your credit card, and you haw tried in good fadh ro tarred the problem wflh the merchant, you may haw IFro right rrot ro pay the rwnaimng amount due on the purchase. To use this right, aN of the following must be trw: 1 The purchase must haw been mode in your home side or within 100 mils: of your cumnt mailing address, and the purchase price must how been man than 550. (Note: Neither of these are necessary if your purchase was based on an advertisement we mailed ro you , or if we own the company that add you the goods or servicer.) 2. You must hove used your credit card for the purchase. Purchases made with cash advances from an ATM or with a check that accesses yaw credit card oecarrd do not qualify. 3. You must red yet haw fully paid for the purchaw. If all of the criteria Dhow aro met and you an still dissatisfied with the purchase, contact us in wrifira d: Discover, PO Box 30945, Sak ldcs Ci yf , UT 84130-0945 While we investigate, the same ruku apply ro the disputed amount as diuussed above. After we finish our investigation, we wrN tell you our deciaon. At that point, if w~ think you owe an amount and you do not pay we may report you as delinquent. Paymenh. You may pay dl or part of your Accaxd baksnce d any Nms. However, you must pay d ksaat the Minimum Payment Dus by the Payment Dw Dds. Serd only your payment arTd the top portion of this statement in fhs envekaps Provided. Do not send cash. Byy sending your chock os described above, you authorise us ro use infarmdia~ on your cheek to make an elechonic fund }ronsTer from your account d the finoncid inafihfion indioded on your check or ro process the payment as a check transaction. IF payment is processed as on eledronie Fund }romfer IFie transfer wiN be for the amount of IM check. When we use information ham your ehedc to make an ek~el-onie fund hans7er, funds may be withdrawn tress your account as soon as the some day vw nceiw your payment, and you wiN rat nceiw your check back from your financial institution. TM processing of your payment may be deksyed if you send cosh, correspondence or other items with your payment, if you send the poymerd to any etf~r addross or if you use err envebpe other ikon the one provided. Payments recawd m proper form d our proceuing facility .. SPM kxd lime on any ~y wiM be crodited ro your Account as of Ihd day. Payments received d our processing focrh afer 5PM local time vwN 6e rndited to your Account as of the ns~d day. IF you haw misplaced your enwk~pe, send your paymarf ro Discover, PO Box 6103 Carol Steam, IL 60197.6103. Please allow 7.10 days for delivery. If your payment is refumed unpaid, ws reserve the right ro nsubmif it as an electronic debit. 30054667 NOTICE: SEE REVERSE SIDE FOR IMPC~tTANi INFORMATION You can pay mordhly Minimum Payment Dus, or a greater amount that does not exceed your current Account baksnce, over the h or you care setup automatic payments though a customer service repressntottw by calving 1.804347- 683. Automatic payments will be deducted on tM Payment Dw Date unless you request a recumng ent date b .the 15th day of the month) that occurs beFore your Payment Dus Dde. If our scheduled payment dots FaNs on a weekend or bank holi your payment will be processed the business day for fo weekend or honk holiday. In order to xheduk morMhly payments e, you wiN need this statement your bank account information. You wiN be asked to provide the last foix (4~digi of the social security number of the primary borrower. By providing (hose numbers as your onic signature, you wiN be agreeing to this authorization to aNow us and your bank to uct each pa you authorize, in the amount selected by you, from your bank account. You also authorize us to initiate dsbM or credit «dries to your honk account, as applicable, to correct an ercor in the processing of such payment. You can cancel a xhsduk+d payment by phone at 1-804347.2683 or by mail at Dixowr, ('O Box 30421 SaN lake City, UT 84 1 34042 1 however we must receive notice of least three busirass days in advance of the scheduled payment. If your payments may vary in amount, we wiN tell you on each monthlyy billing statement when your payment wiN be made erect how much it wiN be. You must enswe Mat sufficient funds aro avoibbls in your bank account, and all transactions must comply with U.S. law. You can seS automatic payments For (i) statement New Balance, (ii) statement Minimum Payment Due, (iii( statement Minimum Payment Due plus o fixed doNar amount, or (iv) a fixed dollar amount. IF yaw xheduled fixed payment is not er to cover the Minimum oyment Due as listed on your monthly biNing atatemerrt, your scheduled payment for that month wifl increased to cover tM Minimum Payment Due. If the scheduled payment ~s gre~r than the Minimum Payment Due, any excess wiN be lied in accordance with your Cardmembsr Agreement. If-your xheduled paymerd is greeter iFan Mw New Balance on yax biging sfaterneM, Mwt payment wiN be processed only for M» mnount of your New Bnlonce. Your automatic payment amount maybe Isss than the amount indicated on Mrs periodic statement based on credits or payments after Mre Closing Date. If you enroll by phone in our automatic payment service, pk~ase fill-in the following blanks bebw and retain the authorization for your records. Amount: ^ Full Pay ^ Min Pay ^ Min Pay + S ^ Fized Pays v Bank Routing #: ,Bank Account #: , Frsgverxy: z CndR Reporting. We may report in(armafion about your Account to credit bureaus. tote payments, missed paymsnh, or c other dsfauks on your Account may be reflected in your credit re We normally rspoA the status and payment history of your Account to crsdd reporing agencies each month. If iew that our r~porf is nwccurafs or incomplete, pkwse write g us at the folowing address: Discover. PO Box 15316, itmington, DE 198545316. Please indicate your name, address, N home tebphone number and Account number ~ PaFrits Interest: We begin to impale interest charges on a hansoclion fee or interest charge ham the day we odd it to the N daily balance. We continue to impose interest charges until you pay tEie total amount you owe us. You con avoid paying ~ interest on Purchases as described below. However you cannot avad paying interest on Balance Transfers or Cash Advances. How to Avoid Povina Interest on Pvrcha»s ("Grace Period"1 iFyou~pai s w rice on your prswous 6iflrng statement by the Payment Due Date shown on that billing statement, we w~iRN rqF impose interest charges on new Purchases or any prtion of a new Purchase, paid by the Payment Due Doh on your current billing statement. New Purchases ors Purc)sasss Ihaf first appear on the currenf billing statement. How We A Paymsr~ts Moy Impact Yaw Grace Period If ~o pay your T~Tsw BcTnca in eac ,depending on the balance to which we apply your payment, you may not get a grace period on new Purchases. How We Cekulede kNerest Clserges Deiy 6olsexe ibMlhod (includirg cumnt transoctionsj: Ws cakulate interest charges each billing period by first figuring the "daily bakmce" For e«h Transaction Category. Transaction C~ego~ies include standard Purchases, starxlard Cash Advances and difFsrent promofiorwl balances, such as Balance Transfers. How Ws Figure tlse Daly flalonce 4or Each Transaction Cehgay We start with the inning balance for each day. The beginning balance for the first day of the billing period is your balance on the day of your previous bit ing period We add any interest charges accrued on Mw previous day's daily balance and any new transactions and fees. We odd any new honsocfions or fees as of the ksler of the Transaction Date or the first day of the billing period in which the hnnsaction or fee posted M yaw Account. We subtract any new credits and payments. We make other adjustments (including those odjustmsnh rogvirsd in the "Paying Interest" section). Hew We Figure Yow Tetal krhrest Charges We muhiply Mre daily balance for each Transaction Category by its daily periodic rah. We do this far each day in the biNir~g period. This giros us the interest charges far each Transaction Category. To get a daily periodic rats, we divide tM APR Mwt applies to the Transaction Category by 365. We add up aN Mre daily interest charges. The sum is fhs total interest charge for the billing period. Hew We IrKhsde Fees We add Balance TransFer Fess to the applicabb Babnce Transfer Transaction Category We add Cash Advance Fees to the opplicabb Cash Advance Transaction Category. Ws add all other fees to the standard Purchase Transaction CCategory. Balance Subject to kMerest Rah. Your statement shows a Bakxrce Subject fo Interest Rate. It shows this for each hansaction category. The Balance Subject ro Interost Rate is the awsrags of the daily balances during the billing period. Credit Baia+aes. IF your Account has a credit balance, the amount is shown on Ma hoot of your bitling statement. A credit baance is money shot is owed to you. You may moles charges against this amount iF your Account is open. Ws wiN send ycw a refund of any remarmng balance of S 1.00 or man aker 6 mordhs, or as otherwise requrrsd by applicable krv+. For TDD (Tilecamrrwrsfcetiar: Device (ar dse Deal] ossistemce, plwse cat 1-800-347-7449. DiscaQQ~66rt~ror and/a r««d telephone calve between you and Discover representatives for qualify assurance purposes. The Discover®card is issued by Dixowr Bank, Member FDIC RZNFE001 QU@ShOnS~ Visit www.Discover.com or call 1 800-DISCOVER (1 800-3472683(. ~SC~ER VERIFICATION ~~~~ u s~"~1~- Leeal Placement Account Manager (N~e) (Title) of DB Servicin¢ Corooration 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 ~ 0 - ~ °~ - ( a MARK A COLLINS XXXXXXXXXXXX9266 (Si afore) DB Servicing Corporation serving affiliate for Discover Bank PO Box 3025 New Albany, OH 43054 WWR# 30054667 C A Pit SJS SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~i~ti~s, of huanb~xl~tt A '°" ~~".U"CIF- FF-• i. ~ 1` i Cr 2~1i ~ NQ~ ~7 AM 11.54 t;t1MBEr~LAs~~ C4t1~TY PEN~tSYl.VANIA Discover Bank Through Its Servicing Agent, DB Servicing Corporation vs. Case Number Mark A. Collins 2012-6858 SHERIFF'S RETURN OF SERVICE 11/19/2012 05:53 PM -Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Mark A. Collins at 757 Carol Street, New Cumberland Borough, New Cumberland, PA 17070. AMANDA COBAUGH, DEPUTY SHERIFF COST: $62.00 November 21, 2012 SO ANSWERS, '~ RON R ANDERSON, SHERIFF icl i:cu^iySude Sh~r'..Y, '(~eso~t. Inr. MARlI�o � 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. 12-6858 CIVIL MARK A COLLINS Defendant(s) S 1 MEMBERS 1 ST FCU INTE ATORIES IN ATTACMdENT 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 ry C:a, r WWR No. 30034667 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK,THROUGH ITS SERVICING AGENT, WOW DB SERVICING CORPORATION (OAR 112013 Plaintiff VS. Civil Action No. 12-6858 CIVIL MARK A COLLINS Defendant(s) MEMBERS I ST FCU Garnishee(s) TO: MEMBERS I ST FCU, 1711 SPRING RD,CARLISLE,PA 17013 RE: MARK A COLLINS,757 CAROL ST,NEW CUMBERLND,PA 17070 Suggested Reference No.: XXX-XX-1895 XXX-Xx- EMMRTANT NOTICES TO GARNISHEEI 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 Garnishees possession 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.30054667 RECEIVED MAR 11 2013 INTERROGATORIES IN ATTACMSNT { 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)? 1P 1 a. If the answer to Interrogatory 1 is in the affirmative,state the following: the amount of money you owe or owed to defendant,and, if such money is in the form of a fund,the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him;and the nature and amount of each of such liabilities. bq�(X�kcO'J-NArs' ^ Ork g -on 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. 0 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 o 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in i which the defendant had an interest Q S. 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? O U 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? 7. If you are a bank or other financial institution,at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law?If so,Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account,and the entity electronically depositing those funds on a recurring basis. UVL� OD WWR No.30054667 MAR 112013 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. u Q�`l roily u,,r. �ptoS .zt,� C tiny any -mot 9. If the answer to Interrogatory I is in the affirmative,state the date the sheriff served these interrogatories on this institution. a 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. If the response to Interrogatory 7 is in the affirmative,are gbff 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? , !,PI— 12. If the response to Interrogatory I I is in the affirmative,state the amount of non-exempt funds on deposit in the account. p� WELTMAN,WEINBERG&REIS CO.,L.P.A. By. William T.MoIczan,EsqP6 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.30054567 REt EMW MAR 11 2013 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 4`u' W-C � a4 (Name) of , C J , garnishee herein, (Title) (Company) that he/she is duly authorized to make this verification,and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) WWR No.30054667 WELTMAN,WEINBERG&REIS CO.,L.P.A. ' BY: William T. Molczan, Esquire Attorney for Plaintiff(s) :-: I.D. No.47437 '_,- 436 Seventh Avenue, Suite 1400 aw Pittsburgh, PA 15219 ° ` w2- Phone: 412.434.7955 r ` Fax: 412.434.7959 ) File# 30054667 v DISCOVER BANK CUMBERLAND County Court of Common Pleas vs. MARK A COLLINS NO. 12-6858 CIVIL and MEMBERS 1ST FCU Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter settled, discontinued, and ended as to Garnishee(s), MEMBERS 1 ST FCU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By � William T. Mo1jdan, Esquire Attorney for Flaintiff Owe C # /lv/ 3&0g SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson __ -!f_;4 r t w Sheriff i-HE:. PF?0THr0N011,JV( Jody S Smith , Chief Deputy '013 P �} : € IN Richard W Stewart 0UMBERLA€ D COUNTY Solicitor Co Far E OF NE>14ERIrr PENNSYLVANIA Discover Bank Through Its Servicing Agent, DB Servicing Corporation Case Number vs. 2012-6858 Mark A. Collins SHERIFF'S RETURN OF SERVICE 03/08/2013 11:47 AM-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, Mark A. Collins, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Connie Barrick,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 March 11, 2013 to Mark A. Collins at 757 Carol Street, New Cumberland, PA 17070. 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, - .� September 26, 2013 RoNtrY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Tel=_osofi,!tic.