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Home My WebLink About12-7039Our File No.: 342448 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK Plaintiff, vs. BARBARA L SABOL 335 WESLEY DR APT 507 MECHANICSBURG, PA 17055-3534 Defendant. ~3-~~ ~=~IC~: __ ~'r~UTr,~,'i ~?~1~ ~d~'' E ~ i'f~ ~: ~9 ,,r~F.;i~`.~'.~~~dU COUNT`=' ;'~_td,~~YL'r'A~~1A COURT OF COMMON PLEAS CUMBERLANDr~CO Y NO.. ~~..~n.~ I J ~' NOTICE 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 \ ~~~2 ~ ~~ ('~A~'C ~~ a~~~ WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $],986.17 and requests this Court award costs to the extent pe ~ ed by applicable law. APOTHAKER & A OC TES, P.C. Attorney f¢r Plai iff A Law Firm Engaged in D bt Collection BY: David J. Apot ker, uire Our File No.: 342448 l i VERIFICATION L th~e,l ~ro ~~~ ~ ccoti..7 ~A~a e~ (Name) ~ - (Title)- ~~ of DB Servicing Corporation, the servicing affiliate for Discover Bank, does hereby verify, under penalty of perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities and states, that he/she is a duly authorized representative of plaintiff herein and authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and accurate to the best of his/her knowledge and information and that he/she is familiar with the manner and method by which plaintiff maintains its normal business books and records, including computer records of defaulted accounts. S/he is also familiar with the relationship between Discover Bank and DB Servicing Corporation. That Discover Bank, f/k/a Greenwood Trust Company, is an FDIC insured Delaware State bank, and its servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank including, among other things, business management services, customer service, and collection of delinquent accounts. The collection of delinquent accounts includes the right to forward the same to the attorneys to file suit on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank are wholly owned subsidiaries of Discover Financial Services. Date t o -16 ' Z o ~ Z (Signature) Defendant's Name: BARBARA L SABOL DB Servicing Corporation servicing Account Number: ending in 7428 affiliate for Discover Bank Our File No.: 342448 PO Box 3025 New Albany, OH 43054 DISCOVER BANK BARBARA L SABOL 335 WESLEY DR APT 507 MECHANICSBURG, PA 17055-3534 STATEMENT OF ACCOUNT Debtor's Name: BARBARA L SABOL Account Number: ending in 7428 Balance Due: $1,986.17 Our File No.: 342448 EXHIBIT "A" ; SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~ ~ ~_, ~ Ronny R Anderson ,mow ~ ~ ... Sheriff ~ ~ ~ti~~ ci ~urrtlir~,I ~~ ~ `~'~ -- ~~ ~ Jody S Smith ,~jt .pet " '~ ..~ y~ a . ~ t Chief Deputy ~" ^~ ~~ "_i~-. ~ M Richard W Stewart ~ ~; ~e-~"'~ Solicitor ~ ~ ~ ~ ~ ':~a: .. ~ ~ '" , _, ..~, ~.,~ Discover Bank Case Number vs. Barbara Sabol 2012-7039 SHERIFF'S RETURN OF SERVICE 11/26/2012 04:00 PM -Deputy Ryan Burgett, 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: Barbara Sabol at 335 Wesley Drive, Apt. 507, Lower Allen, Mechanicsburg, PA 17055-3534. SHERIFF COST: $38.00 November 27. 2012 RYAN BUR EP SO ANSWERS, RON R ANDERSON, SHERIFF r '~iu ,i ', u d ~re^ f l e ~~soft c... Our File No.: 342448 DISCOVER BANK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. BARBARA L SABOL NO.: 12-7039 CIVIL Defendant(s) , PRAECIPE FOR WRIT OF s EXECIO + rn ', _k—= To the Prothonotary: ' rn —I Issue a Writ of Execution in the above matter, P)C:t cc CB ti (1) directed to the Sheriff of CUMBERLAND County; —+ f (2) against BARBARA L SABOL, defendant(s); and (3) against MEMBERS FIRST FCU 1 CARLISLE BARRACKS #842 CARLISLE, PA 17013, and PNC BANK 105 NOBLE BOULEVARD CARLISLE, PA 17013 Garnishee(s); (4) and index this writ in the judgment index (a) against BARBARA L SABOL, defendant(s), and (b) against MEMBERS FIRST FCU 1 CARLISLE BARRACKS #842 CARLISLE, PA 17013, and PNC BANK 105 NOBLE BOULEVARD CARLISLE, PA 17013, as Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of Garnishee(s) as follows: Bank Attachment Only - All assets and accounts, including, but not limited to, bank accounts, brokerage firm accounts. stocks, cd's, insurance, safety deposit boxes, etc. (5) Amount Due $1,986.17 Interest from January 18, 2013 $76.72 Minus Payments made $(0.00) Plus Costs $195.50 Total $2,258.39 Ctit4 ‘63 6°P/Afrl ?P.7 s i4 David J. Apo aker, Esquire .SCI< <� -a5 Attorney for Plaintiff(s) lCt � rSo� co. s � 77. a s / CLIg 88 so y gek c,2 q,'lQ QIk( U34,, Of �,'�1C ZSSmed WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-7039 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff(s) From BARBARA L. SABOL,335 WESLEY DR.,APT. 507,MECHANICSBURG,PA 17055-3534 (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 FIRST FCU, 1 CARLISLE BARRACKS#842,CARLISLE,PA 17013 PNC BANK, 105 NOBLE BLVD,CARLISLE,PA 17013-ALL ASSETS AND ACCOUNTS, INCLUDING,BUT NOT LIMITED TO BANK ACCOUNTS,BROKERAGE FIRM ACCOUNTS, STOCKS,CD'S,INSURANCE,SAFETY DEPOSIT BOXES,ETC. 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$1,986.17 Plaintiff Paid$ Interest FROM JANUARY 18, 2013-$76.72 Attorney's Comm. % Law Library$.50 Attorney Paid$187.25 Due Prothonotary$2.25 Other Costs$195.50 Date: 10/413 124. tilee _ David D. Buell,Prothonotary Deputy REQUESTING PARTY: Name : DAVID J.APOTHAKER,ESQUIRE Address: APOTHAKER& ASSOCIATES,P.C. 520 FELLOWSHIP RD C306 MT. LAUREL,NJ 08054 Attorney for: PLAINTIFF Telephone: 856-780-1000 Supreme Court ID No. r t Our File No.: 342448 ) DISCOVER BANK ) ) COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY vs. ) ) BARBARA L SABOL ) NO.: 12-7039 CIVIL 335 WESLEY DR APT 507 ) MECHANICSBURG, PA 17055-3534 ) Civil Action XXX-XX-9180 ) -o c cn ...-a .�t= Defendant ) ' MEMBERS FIRST FCU and PNC BANK ) 2• Garnishee INTERROGAT ES TO GARNISHEE TO: MEMBERS FIRST FCU, Garnishee: 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. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed defendant(s) any money or were liable to defendant(s) for any reason? o,� S 2. At the time you were served or at any subsequent time was there in your possession, custody, control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the defendant(s)? 11. o 3. At the time you were served or any subsequent time did you hold legal title to any property of any nature owed solely or in part by the defendant(s) or in which the defendant held or claimed any interest? n 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had any interest? AO 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and what was the consideration thereof? 0 6. At any time after you were served did you pay. transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? �(\ 7. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant(s) 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 and the entity electronically depositing those funds on a recurring basis. SOLLCO SeCi tY11 8. If you are a bank or o er financial institution, at the time you were served or at any subsequent time did the defendant(s) 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 exemption under 42PA.C.S.§8123? If so, identify each account. RI IL- 9. How mull i the value of any property in your possession belonging to_the defendant(s)? tX1 .51 - uv�& c .0'� 10. In the space below, the plaintiff may set forth additional appropriate interro tories. Dated: Zl' David J. Apothaker,Esquire APOTHAKER&ASSOCIATES,P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel,New Jersey 08054 (856) 780-1000 Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i Jody S Smith $. H '` Chief Deputy Richard WStewart � lafl t-4'r s Solicitor =:)p FX1 Discover Bank Case Number vs. Barbara Sabol 2012-7039 SHERIFF'S RETURN OF SERVICE 10/23/2013 09:15 AM -Stephen Bender, 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Beth Ann Eppley, Vice President, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on October 24, 2013 to Barbara L. Sabol at 335 Wesley Drive,Apt. 507, Mechanicsburg, PA 17055-3534. 2E� STEPHEI-BENDER, DEPUTY SO ANSWERS, October 24, 2013 RONNY R ANDERSON, SHERIFF tc.CountySu,ko Snor(-,Toros.,,... V SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy -:i 0 F pj 1 f; Richard W Stewart Solicitor %E J"11 S`f LV A H J!" s , Discover Bank vs. Case Number Barbara Sabol 2012-7039 SHERIFF'S RETURN OF SERVICE 10/21/2013 11:18 AM- Brian Grzyboski, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 321 York Road, Carlisle, PA 17013, Cumberland County, by handing to Nick Smith- Branch Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution andr made the contents there of known to him. BRIAN GRZYBO I,bfPPY SO ANSWERS, October 24, 2013 RbNW R ANDERSON, SHERIFF (w)Cou.^.tySuite Sh :'ff, Our File No.: 342448 , ' 8 ; APOTHAKER&ASSOCIATES,P.C. :t.", ) a ' By: David J. Apothaker,Esquire ,_, fH3L_Id.ANND COU UTY 520 Fellowship Road C306 PENNSYLVANIA PO Box 5496 Mount Laurel,NJ 08054 (800)672-0215 Attorneys for Plaintiff ) DISCOVER BANK ) COURT OF COMMON PLEAS OF ) CUMBERLAND COUNTY Plaintiff ) vs. ) ) NO.: 12-7039 CIVIL BARBARA L SABOL ) ) Civil Action Defendant ) ) MEMBERS FIRST FCU ) ) Garnishee ) ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee 9 C ERS FIRST FCU, dissolved. David J. •pothaker, Esquire Attorney for Plaintiff awl 9.saPda II? !04 91?Sy ,i2._ kt 09 a c't I Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OF FICZ OF Tek S RI? UF 1 HE PROTHONQ T ,`t °t' nitsMAY16 AM 8:42 CUMBERLAND COUNTY PENNSYLVANIA Discover Bank vs. Barbara Sabol Case Number 2012-7039 SHERIFF'S RETURN OF SERVICE 10/21/2013 11:18 AM - Brian Grzyboski, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 321 York Road, Carlisle, PA 17013, Cumberland County, by handing to Nick Smith - Branch Manager , personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to him. 10/23/2013 09:15 AM - Stephen Bender, 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, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Beth Ann Eppley, Vice President, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on October 24, 2013 to Barbara L. Sabol at 335 Wesley Drive, Apt. 507, Mechanicsburg, PA 17055-3534. 05/14/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $146.15 SO ANSWERS, May 14, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. aa` RONO R ANDERSON, SHERIFF