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HomeMy WebLinkAbout13-1242 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i; " Q` (} Tsi ;'f Jody S Smith Chief Deputy , 2013 MAR 20 AM 9: 4 Richard W Stewart CUMBERLAND COUNT Solicitor OFFCEOF°K`StERJF= PENNSYLVANIA Discover Bank Through Its Servicing Agent, DB Servicing Corporation Case Number vs. Kevin Reese 2013-1242 SHERIFF'S RETURN OF SERVICE 03/14/2013 08:07 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: Kevin Reese at 310 Cranes Gap Road, North Middleton Township, Carlisle, PA 17013. RYAN BURGETT, DEP73" SHERIFF COST: $34.00 SO ANSWERS, March 15, 2013 RbNW R ANDERSON, SHERIFF E ..�aur?ySuie 5herif':,"fgleas,i;;nc, C IN THE COURT OF COMMON PLEAS CV �Y CUMBERLAND COUNTY, PENNSYLVANIA �rn ` CIVIL DIVISION ter; Discover Bank, Through Its Servicing Agent, DB Servicing Corporation Z_o C-D Plaintiff N VS . Civil Action No. 13-124,a CIVIL' KEVIN REESE PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant KEVIN REESE above named, in the default of an Answer, in the amount of $3125 . 05 computed as follows : Amount claimed in Complaint $3125 . 05 Less payments / adjustments made $0 . 00 Attorney' s fees $0 . 00 TOTAL $3125 . 05 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R. C.P. 237 . 1 on the dates indicated on the Notices . WELTMAN, WEINBERG & REIS CO. , L. P.A. By: �✓�'f/'-��� Willi-am T. Mo czan, 437 30062477 C A Pit SJS Plaintiff ' s address is : c/o WELTMAN, WEINBERG & REIS CO. , L.P.A. , 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 And that the last known address of the Defendant is KEVIN REESE 310 CRANES GAP RD CARLISLE, PA 17013 ©�� 61CU red IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Bank, Through Its Servicing Agent DB Servicing Corporation Plaintiff Case No, 13-1241 CIVIL Vs. KEVIN REESE Defendant IMPORTANT NOTICE TO: KEVIN REESE 310 CRANES GAP RD CARLISLE, PA 17013 Date of Notice: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 32 SOUTH BEDFORD STREET CARLISLE, PA.17013 (717)249-3166 WELTMAN,WEINBERG& REIS CO., L.P.A. By: Matthew Urban P.A.I.DX 90963 WELTMAN,WEINBERG& REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412)434-7955 (412) 338-7130 30062477 A PIT M4Z 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. 13-1241 CIVIL NON-MILITARY AFFIDAVIT KEVIN REESE The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers , Civil Relief Act (SCRA) , 50 U. S.C. App. 521. Affiant further states that based upon investigation it is the affiant ' s belief that the Defendant, KEVIN REESE is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC) , which states that the DMDC does not possess any information indicating that the below individual is in the military service: KEVIN REESE 310 CRANES GAP RD CARLISLE, PA 17013 Affiant further states that the averments contained herein are true and correct to the best of Affiant ' s knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsification to authorities. AFFIANT Department of Defense Manpower Data Center Results as of:Apr-26.2013 06:2$:45 SCRA 3.0 `a Putrsumt to Savicememben Civil Relief Act Last Name: REESE First Name: KEVIN Middle Name: Active Duty Status As Of: Apr-26-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component r s•. NA NA r+',+'',ti.,�`y .. �,.N+-r'�; w�.: " Nu`.., NA This response reffs4tha lndMduais actve dutp status based on the Ac6va�Du y Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Data Active Duty End Date Status Service Component NA ..NA - `-, No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Cafl-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA .NA,' �� -r7 M1 No ✓ NA This response reflects whether the individual or hWher unit has r-eceived early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty, HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. i - Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 041225 Arlington,VA 22350 ' . t The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U,S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 02PBK4FBQOBF3CO 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. 13-1242 CIVIL KEVIN REESE NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order of Judgment was entered against you on o��-C- (xx) Assumpsit Judgment in the amount of $3125 . 05 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 (xx) Default ( ) Verdict ( ) Arbitration Awar Prothonotary t Of By: PROTHONOTARY OR DEPUTY KEVIN REESE 310 CRANES GAP RD CARLISLE, PA 17013 Plaintiff ' s address is : c/o WELTMAN, WEINBERG & REIS CO. , L. P.A. , 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff No. 13-1242 CIVIL VS. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) KEVIN REESE Defendant(s) ORRSTOWN BANK Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG &REIS CO.,L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 WWR No. 30062477 L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff vs. /n__ Civil Action No. 13-1242 CIVIL KEVIN REESE — 310 C rain-5 "`�t'Rd,Carible PA 1 jo 13 Defendant(s) � � ORRSTOWN BANK-77 E kin3 S+, bippansbur9 ,PA 17x6`/ �� , Garnishee(s) J �' r— -t)rn PRAECIPE FOR WRIT OF EXECUTION -0 TO THE PROTHONOTARY: r-C-) = X a =� = 99 Kindly issue a Writ of Execution in the above matter... p � 1. directed to the Sheriff of CUMBERLAND County: ' 2. against KEVIN REESE ,Defendant 3. against ORRSTOWN BANK, , , Garnishee 4. Judgment Amount $ $3,125.05 Less Payments/credits received $ $0.00 Interest $ $13.36 Costs $ SUBTOTAL: $ $3,138.41 Costs(to be added by Prothonotary): $ 5 WELTMAN, WEINBERG&REIS CO., L.P.A. *3�'oo CF�f- AY ^l r a 103.75 '► By: 11P. 50 William T. Molczan,Es ' e PA I.D. #47437 $183.x— Po ATry WELTMAN, WEINB RG&REIS CO.,L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 5o LL 0,#11134 4 40 WWR No. 30062477 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-1242 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 KEVIN REESE,31.0 Cranes Gap Rd,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 GARNISHEES)as follows: ORRSTOWN BANK,77 E.King St.,Shippensburg,PA 17257 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$3,125.05 Plaintiff Paid$ Interest -- $13.36 Attorney's Comm. % Law Library$.50 Attorney Paid$183.25 Due Prothonotary$2.25 Other Costs$ Date: 7/1/13 David D.Buell,Prothonotary (Sea!) Deputy REQUESTING PARTY: Name : WILLIAM T.MOLCZAN,ESQUIRE Address: WELTMAN,WEINBERG&REIS CO,LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH,PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No.47437 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r!l E 01=F ICE' Sheriff slop of�n�r�fr���xt�? 0 THE PROTHONOT,A,R' Jody S Smith t. Chief Deputy '0 13 JUL _g A-M 10 12 Richard W Stewart Solicitor _ t CUMBERLAND COUNTY PENNSYLVANIA Discover Bank Through Its Servicing Agent, DB Servicing Corporation Case Number vs. Kevin Reese 2013-1242 SHERIFF'S RETURN OF SERVICE 07/05/2013 10:35 AM -Jamie DiMartle, Deputy Sheriff, who being duly sworn according to law, states that on July 5, 2013 at 1035 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kevin Reese, in the hands, possession, or control of the within named garnishee, Orrstown Bank, 427 Village Drive, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Vanessa Albright, Customer Service Representative, 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 July 8, 2013 to Kevin Reese at 310 Cranes Gap Road, Carlisle, PA 17013 (envelope provided by atty's office). J MIE DI A LE, DEPUTY SO ANSWERS, July 08, 2013 RbNW R ANDERSON, SHERIFF (c)County5uile Sheriff,Teleosoft,Inc. WELTMAN,WEINBERG&REIS CO.,L.P.A. BY: James C Warmbrodt,Esquire Attorney for Plaintiff(s) I.D.No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959j ' File#30062477 M r_— DISCOVER BANK �;o c , THROUGH ITS SERVICING AGENT r" DB SERVICING CORPORATION v C--) __. Cumberland County ba ter: Court of Common Pleas ; cxa vs. KEVIN REESE NO. 13-1242 CIVIL and ORRSTOWN BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s),ORRSTOWN BANK, only. WELTMAN, WEINBERG&REIS CO.,L.P.A. By Ja s C Warmbrodt,Esquire mey for Plaintiff C k- 11 auo �#�y3oa SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ; s Sheriff : '`i.. " "'r) 101 . , a�ts�y 9 ,iaixt,� r 3 Jody S Chef Deputyh ' 26i ia Richard W Stewart rUMBrRLANU Cl U' 1 °�' Solicitor PENNSYLVANIA Discover Bank Through Its Servicing Agent, DB Servicing Corporation Case Number vs. 2013-1242 Kevin Reese SHERIFF'S RETURN OF SERVICE 07/05/2013 10:35 AM - Jamie DiMartle, Deputy Sheriff, who being duly sworn according to law, states that on July 5, 2013 at 1035 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kevin Reese, in the hands, possession, or control of the within named garnishee, Orrstown Bank, 427 Village Drive, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Vanessa Albright, Customer Service Representative, 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 July 8, 2013 to Kevin Reese at 310 Cranes Gap Road, Carlisle, PA 17013 (envelope provided by atty's office). 02/26/2014 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: $88.76 SO ANSWERS, February 26, 2014 R‘ONNK ANDERSON, SHERIFF n 9r/h. Ain 302/k3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff vs. KEVIN REESE Defendant(s) ORRSTOWN BANK MEMBERS 1ST FCU Garnishee(s) TO THE PROTHONOTARY: Civil Action No. 13-1242 CIVIL PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against KEVIN REESE , Defendant 3. against ORRSTOWN BANK, MEMBERS 1ST FCU, , Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): Ri4_9(?.61)*Affly Vet, MP w-70 it 1o3.7 ' " 1(4-sC(1 °2 Sl d 4� $3,125.05 $1,340.00 $185.79 $ $1,970.84 WELTMAN, WEINBERG & REIS CO., L.P.A. By: James ' Val cko, Esquire PA I.D. #79 96 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 g5lka 0# /621/64 2/,/_ ng WWR No. 30062477 d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff vs. KEVIN REESE Defendant(s) ORRSTOWN BANK MEMBERS 1ST FCU Garnishee(s) No. 13-1242 CIVIL PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7`h Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 W WR No. 30062477 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Vs. NO 13-1242 Civil Term CIVIL ACTION — LAW KEVIN REESE WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against KEVIN REESE, 310 CRANES GAP ROAD, CARLISLE, PA 17013 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of ORRSTOWN BANK GARNISHEE(S), as garnishee, 77 E. KING STREET, SHIPPENSBURG, PA 17257 AND MEMBERS 1ST FCU, 1711 SPRING ROAD, CARLISLE, PA 17013 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $1,785.05 Plaintiff Paid Interest $185.79 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Other Costs Attorney Paid $310.51 Date: 6/04/14 (Seal) David D. Buell, Prothonotary REQUESTING PARTY: Name : JAMES P. VALECKO, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO. L.P.A. 436 7TH AVENUE, SUITE 1400 PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 79596 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson _ Sheriff i~ T SHE PRO i HONG it, Jody S Smith Chief Deputy Richard W Stewart Solicitor QF 10E iV THE $!?ERfFF 20111 JUN -9 FM ,• U CUMBERLAND COUNTY PENNSYLVANIA Discover Bank Through Its Servicing Agent, DB Servicing Corporation vs. Kevin Reese Case Number 2013-1242 SHERIFF'S RETURN OF SERVICE 06/06/2014 10:35 AM - Christopher Sharpe, 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, Orrstown Bank, 427 Village Drive, Carlisle Borough, Carlisle, PA 17015, Cumberland County, by handing to Kristin Ramsay, Branch Executive Officer 1, 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. June 09, 2014 (C) CountySuite Sheriff, Te&eosoft, inc. 7— ‘ST P11ER SHARPE, DEPUTY SO ANSWERS, RONR ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson rLl ; !i` Sheriff THE(PRO�iiisem'N Jody S Smith Chief Deputy Richard W Stewart Solicitor 2014 J J'F —9 PH 3: 05 CUMBERLAND COUNTY OFFICE OF THE wiKER,rF PENNSYLVANIA Discover Bank Through Its Servicing Agent, DB Servicing Corporation Case Number vs. Kevin Reese 2013-1242 SHERIFF'S RETURN OF SERVICE 06/06/2014 10:49 AM - Christopher Sharpe, 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, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Kathleen Nissley, Registered 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 June 9, 2014 to Kevin Reese at 310 Cranes Gap Road, Carlisle, PA 17013. June 09, 2014 (c) CountySuite Sheriff, Teleosoft, I o, CHRIST HER SHARPE, DEPUTY SO ANSWERS, RONNFY R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLViI' CIVIL DIVISION vZ= -- r1-1 0:3 DISCOVER BANK, THROUGH ITS SERVICING AGENT,> N DB SERVICING CORPORATION A Plaintiff Civil Action No. 13-1242 CIVIL vs. KEVIN REESE Defendant(s) ORRSTOWN BANK MEMBERS 1ST FCU Garnishee(s) 40 INTERROGATORIES IN ATTACHMENT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 30062477 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, THROUGH ITS SERVICING AGENT, DB SERVICING CORPORATION Plaintiff vs. KEVIN REESE Defendant(s) ORRSTOWN BANK MEMBERS 1ST FCU Garnishee(s) Civil Action No. 13-1242 CIVIL TO: ORRSTOWN BANK, 77 E KING ST, SHIPPENSBURG, PA 17257 MEMBERS 1ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 RE: KEVIN REESE , 310 CRANES GAP RD, CARLISLE, PA 17013 Suggested Reference No.: XXX -XX -8386 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. 30062477 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)? 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. k�' 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? w ` 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, 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?^A'' 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? 1 o 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. WWR No. 30062477 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. u2.1g/ig 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. b1911(4 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? N/A 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. cx.c Q. w r4 WELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. Valkcko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 30062477 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 (Name) of 1s , 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. 30062477 WELTMAN, WEINBERG & REIS CO., L.P BY: James P Valecko, Esquire I.D. No. 79596 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 30062477 THE Attorney forPlaintiff(s)2 E�:RNL.su! 1+��t 8.87 .A. U AHQP� YLVP� Q,AgNTY DISCOVER BANK Cumberland County Court of Common Pleas vs. KEVIN REESE and ORRSTOWN BANK AND MEMBERS 1ST FCU Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION NO. 13-1242 CIVIL TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), ORRSTOWN BANK AND MEMBERS 1ST FCU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By James P :lecko, Esquire Attorney •r Plaintiff cutAt q.sopa a� cu16 saoo) �, {# 3Gi gp