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Home My WebLink About13-2747 t' ILIED - O i' ICE 011= H, E PRO T H.0N0T'ARY N 13 MAY (S PM 1: 4'0 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. ) 3 - 2n `(,) '-) 0 (U il VS. PRA.EC.IPE TO TRANSFER JUDGMENT RYAN L TRAUGH Defendant a w . FILED ON BEHALF OF Plaintiff + COUNSEL OF RECORD_ OF THIS PARTY: William T Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG Sc .REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434 -7955 WWR #04521797 �2t�aaus�� 4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. RYAN L TRAUGH Defendant PRAECIPE TO TRANSFER JUDGMENT TO THE PROTHONOTARY: Please transfer the within Judgment entered in The Court of Common Pleas of DAUPHIN County, Pennsylvania, known as No. 2005 -CV- 5085 -CV, and index it against the Defendant above named, in the amount of $249A qa- DAUPHIN County costs to follow Judgment. 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434 -7955 WWR #04521797 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 Defendantis: I l 1 S MARKET ST, .MECHANICSBURG, PA 17055 In The Court of Common plea.5 of �Daupbin Countp, Venuoylbania Discover Bank VS. No. 2005 -CV- 05085 -CV Ryan L. Traugh CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that judgment was entered in favor of PLAINTIFF, DISCOVER BANK and against DEFENDANT, RYAN L. TRAUGH on FEBRUARY 7, 2006 in said case in the amount of $2,091.92 Sri Testimonp Wbereat, I have hereunto set my hand and affixed the a f the Court, on Thursday, April 25, 2013. Prothonotary By. � eputy w ,. Date: '4/25/2013 Dauphin County User: TSULTZABER Time: 08:38 AM Complete Case History Page 1 of 3 Case: 2005 -CV- 05085 -CV Discover Bank vs. Ryan L Traugh Filed: 12/5/2005 Subtype: Civil Physical File: Y Appealed: N Comment: Status History Pending 12/5/2005 Pending / Judgment 2/7/2006 Judge History Date Judge Reason for Removal 12/5/2005 No Judge, Current Payments Receipt Date Type Amount Warmbrodt, James C (attorney f 268541 2/6/2012 Civil Filing 37.75 Weltman Weinberg & Reis 94324 12/5/2005 Civil Filing 105.00 271131 3/20/2012 Civil Filing 13.00 Weltman Weinberg & Reis Co 98173 2/7/2006 Civil Filing 18.00 WELTMAN WIENBERG & REIS 294278 4/25/2013 Miscellaneous 26.25 Exemplified Record 26.25 Total 200.00 Miscellaneous Receipts Receipt Date 294278 4/25/2013 Exemplified Record 26.25 Sum: 26.25 Plaintiff Name: Discover Bank SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys Warmbrodt, James C (Primary attorney) Send Notices Defendant Name: Traugh, Ryan L SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Date: 4/25/2013 Dauphin County User: TSULTZABER Time: 08:38 AM Complete Case History Page 2 of 3 Case: 2005 -CV- 05085 -CV Discover Bank vs. Ryan L Traugh Other Party Name: PNC Bank - Garnishee SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Party type: Comment: Register of Actions 12/5/2005 New Civil Case Filed This Date. No Judge, Plaintiff: Discover Bank Attorney of No Judge, Record: James C Warmbrodt Filing: Complaint Paid by: Weltman No Judge, Weinberg & Reis Receipt number: 0094324 Dated: 12/5/2005 Amount: $105.00 (Check) 12/17/2005 Complaint: Sheriffs Return filed stating No Judge, service was completed. So answers J.R. Lotwick, Sheriff. Ryan L Traugh Assigned to Dauphin Co Sheriffs Office Service fee $51.00 Served 12/17/2005 2/7/2006 Filing: Judgment Paid by: Weltman No Judge, Weinberg & Reis Co Receipt number: 0098173 Dated: 2/7/2006 Amount: $18.00 (Check) Default Judgment is entered in favor of No Judge, Plaintiff and against Defendant, Ryan L Traugh, as follows: Amount claimed in Complaint $1,791.92 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees 300.0( TOTAL $2,091.92 for failure to answer Plaintiffs Complaint. See Praecipe & Notice filed. Copies of all documents mailed. AOPC MONTHLY CIVIL COURT No Judge, STATISTICAL REPORT DATA; CIVIL ACTION 2/6/2012 Filing: Writ of Execution Paid by: No Judge, Warmbrodt, James C (attorney for Discover Bank) Receipt number: 0268541 Dated: 2/6/2012 Amount: $37.75 (Check) For: Discover Bank (plaintiff) Writ of Execution No Judge, Garnishee - PNC Bank Sheriff - Dauphin County Amount Due $2091.92 + Costs. See Praecipe, filed. Interrogatories, filed. No Judge, Date: 4/25/2013 Dauphin County User: TSULTZABER Time: 08:38 AM Complete Case History Page 3 of 3 Case: 2005 -CV- 05085 -CV Discover Bank vs. Ryan L Traugh Register of Actions 3/20/2012 Filing: Dissolve Attachment Paid by: No Judge, Weltman Weinberg & Reis Receipt number: 0271131 Dated: 3/20/2012 Amount: $13.00 (Check) For: PNC Bank - Garnishee (other party) The above Writ of Attachment against No Judge, PNC Bank, ONLY, Garnishee is hereby marked Dissolved and /or Discontinued. See Praecipe, filed. 4/26/2012 Writ Expired. Sheriffs Cost $96.50. So No Judge, Answers, J.R. Lotwick, Sheriff. 4/25/2013 Miscellaneous Payment: Exemplified No Judge, Record Paid by: WELTMAN WIENBERG & REIS Receipt number: 0294278 Dated: 4/25/2013 Amount: $26.25 (Check) Judgment Order date In Favor Of Disposition Judgment 02/07/2006 Plaintiff 02/07/2006 Open Default Comment: 2091.92 Plaintiff: Discover Bank Defendant: Traugh, Ryan L Judgment Order date In Favor Of Disposition Judgment 02/06/2012 Plaintiff 02/06/2012 Open Writ of Execution Comment: 2091.92 Plaintiff: Discover Bank Defendant: Traugh, Ryan L Judgment Order date In Favor Of Disposition Judgment 02/06/2012 Plaintiff 03/20/2012 Dissolved Writ of Execution Comment: 2091.92 Plaintiff: Discover n Other Party: PNC G a rnishee C I here r true an o al f' d. Prothonota erk of s APR 2 5 2013 1. i COPIES OF ALL DOCUMENTS TILED IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 2005 -CV- 5085 - RYAN L TRAUGH Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant r-I ( )Garnishee „ You are hereby notified that the following r� } - ..i f Order or Judgment was entered against you .�; - f 9 on 200 o (T C (xx) Assumpsit Judgment in the amount ; ¢, of $2,091.92 plus costs. N CL N Trespass Judgment in the amount 2X 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. -s cy , (xx) Entry of Judgment of ( ) Court Order 1 { } Non -Pros Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prot _ By: PROTH NQTARY (OR DEPUJ Y} RYAN L TRAUGH r 6402 BEDFORD ST . HARRISBURG,PA 17111 1 r Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7 Avenue, Pittsburgh, PA 15219 1- 888 - 434 -0085 i i i IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 2005 -CV- 5085 -CV VS. PRAECIPE FOR DEFAULT JUDGMENT RYAN L TRAUGH Q h Defendant,` :•t,. 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. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434 -7955 i WWR#0452I797 Judgment Amount $ 2,091.92 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. i ar IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CIVIL DIVISION , DISCOVER BANK Plaintiff VS. Civil Action No. 2005 -CV- 5085 -CV RYAN L TRAUGH Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, RYAN L TRAUGH above named, in the default of an I Answer, in the amount of $2,091.92 computed as follows: f Amount claimed in Complaint $1,791.92 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $300.00 TOTAL $2,091.92 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA KC.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By V v WILLIAM T. MOLCZAN SQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434 -7955 WWR #04521797 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 6402 BEDFORD ST., HARRISBURG,PA 17111 . I IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case # 200- CI,/- 5 C4 RYAN L TRAUGH Defendants) (s) C= C= IMPORTANT NOTICE Cn C7 TO: RYAN L TRAUGH 6402 BEDFORD ST - HARRISBURG, PA 17111 00 Date of Notice: 3 / WWR#: 04521797 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 FOLLOWING 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE MID PENN LEGAL SERVICES 213 N. FRONT STREET HARRISBURG, PA 17111 (717) 232-7536 BY: JAMES BRODT, ESQUIM PA I. ' #42524 WELT WEINBERG & REIS CO., L.P.A. 2718 OPPERS BLDG,.436 7TH AVE. �p H PIT: TBURGH, PA 15219 f IN THE COMMON PLEAS COURT OF DAUPHIN COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Case no: 2005 -CV- 5085 -CV r R C ,? ✓�J ra Plaintiff NON - MILITARY AFFIDAVIT _ VS. RYAN L TRAUGH Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he /she is the duly authorized agent of the Plaintiff in the within matter. Affiant further 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, RYAN L TRAUGH is not in the military service. i Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which. states that the Defendant, RYAN L TRAUGH is not in the military service. Further Affiant sayeth naught. i AF PIAAT SWORN TOAVD SUBSCRIBED in my presence this 2t7 day Notarial Seal N ARYPUB CityptPYuraLdt,NotRypublic 9h. Allegheny coaaty, my Cammission XPiresJal 15 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. I ' Request for Military Status Page 1 of 1 Department of Defense Manpower Data Center JAN -26 -2006 05:34:36 Military Status Report Pursuant to the Service Members' Civil Relief Act ! < Last Name First/Middle Begin Date Active Duty Status Service/Agency TRAUGH Based on the information you have furnished, the DMDC does not I possess any information indicating that the individual is currently on active duty. j Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the individual, per the Information provided, as to all branches of the Military. i U"7 r'i Robert J. Brandewie, Director Department of Defense - Manpower Data Center = co ' 1600 Wilson Blvd., Suite 400 f Arlington, VA 22209 -2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense 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 Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly 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 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 is on active duty, or is otherwise entitled to the protections of the SCRA, you are most strongly encouraged to contact us by phone at (703 -696- 6762). We will then conduct further research. Your failure to re- contact DMDC may cause provisions of the SCRA to be invoked against you. This response reflects current active duty status only. For historical information, please contact the military services SCRA point of contact. See: hU:// www. defense1ink .miUfaq(gis/PC09SLDR.htm1 i Report ID: BMDSXLFZFBA https://www.dmde.osd.mil/scra/owa/scm.prc�_Select •1/26/2006 Pate: 4125/2013 Dauphin County NO. 0294278 Time: 08:25 AM Receipt Page 1 of 1 Received of: WELTMAN WIENBERG & REIS $ 26.25 Twenty-Six and 25/100 Dollars Case: 2005-CV-05085-CV Plaintiff: Discover Bank vs. Ryan L Traugh Amount Exemplified Record 26.25 Total: 26.25 Check: 11067891 Payment Method: Check Stephen E Farina , Prothonotary Amount Tendered: 26.25 By: Clerk: TSULTZABER Deputy Clerk IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff ^� VS. Civil Action No. RYAN L TRAUGH Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on_ asi �6 13 (xx) Assumpsit Judgment in the amount of $ 22999 --42 plus costs. 4 .L 091.gA ( ) 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 RYAN L TRAUGH B y. �� . � II 111 S MARKET ST PROTHONOTARY (OR DEPUTY) MECHANICSBURG, PA 17055 wj IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 13-2747 CIVIL RYAN L TRAUGH !!! S. Market Sf,, Me PA Defendant(s) r-) N MID PENN BANK—�}�aa &LAZste f'�,C:��e ,PA 1-7Da3 T,� w � PNC BANK- 106 0061e Nvd , CoAislE PA, )'10 13 M c rn i Garnishee(s) � r :�D _ PRAECIPE FOR WRIT OF EXECUTION r-c> — ° TO THE PROTHONOTARY: ' D Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: ' Intl 2. against RYAN L TRAUGH ,Defendant 3. against MID PENN BANK,PNC BANK, ,Garnishee 4. Judgment Amount $ $ 99.42 Less Payments/credits received $ $0.00 Interest $ $14.79 Costs $ �a lo6.7J SUBTOTAL: $ 2 Costs(to be added by Prothonotary): $ Q) WELTMAN, WEINBERG&REIS CO.,L.P.A. *aq.00 PIS pT J� salsas Ct3F By: W — 33,5o " William T. Molczan, Esquir PA I.D.#47437 X383.qr- PO A-rtY WELTMAN, WEINBERG&REIS CO.,L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 4-9-as bue-00 •5o LL aff 1114,8d 10 P-#aqa 5'75 I WWR No.4521797 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-2747 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 RYAN L.TRAUGH, I 11 S.Market Street,Mechanicsburg,PA 17055 (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: MID PENN BANK,4622 Carlisle Pike,CArlisle,PA 17023 PNC BANK, 105 Noble Blvd,Carlisle,PA 17013 and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the gamishee(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$2,091.92 Plaintiff Paid$ Interest -- $14.79 Attorney's Comm. % Law Library$30 Attorney Paid$383.75 Due Prothonotary$2.25 Other Costs$ Date: VIM.- 14 David D.Buell,Prothonotary C- 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 Ronny R Anderson SHERIFF'S OFFICE OF CUMBERLAND COUNTY Sheriff Jody S Smith WOT ho.hlo TAR'! Chief Deputy ;w Richard W Stewart 24 Ph Solicitor ll OFFC—E OF THE SHZRIFF cUMBERLA',40 COU""rl'� PEHNISYL\'At"" Discover Bank vs. Case Number Ryan L. Traugh 2013-2747 SHERIFFS RETURN OF SERVICE 07/22/2013 11:31 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, 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 Eppley,Assistant Branch Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Executio nd made the contents there of known to her. 'J' r ILLIAM CLINE, i�D,., DEPUTY SO ANSWERS, July 24, 2013 4RON ANDERSON, SHERIFF (C)COUMYSUite Sheriff,Teleosoft,Inc. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 13-2747 CIVIL RYAN L TRAUGH Defendant(s) r 71 cn ry MID PENN BANK 0' PNC BANK Garnishee(s) c) _ I> ioa TO: MID PENN BANK, 4622 CARLISLE PIKE, CARLISLE, PA 17013 PNC BANK, 105 NOBLE BLVD, CARLISLE, PA 17013 RE: RYAN L TRAUGH, 111 S MARKET ST,MECHANICSBURG, PA 17055 Suggested Reference No.: XXX-XX-2494 XXX-XX- ^n swi5 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. 4521797 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)? no la. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. n/a 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. no 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? no 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? no 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? no 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? no 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. no • WWR No. 4521797 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. no 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. n/a 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. n/a 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? n/a 12. If the response to Interrogatory 11 is in the affirmative,state the amount of non-exempt funds on deposit in the account. n/a WELTMAN, WEINBERG& REIS CO., L.P.A. By: l� y� William T. Molczan, E uire PA I.D. 1447437 WELTMAN, WEINBERG &REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR No. 4521797 4 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 (j c1cok. ' -c t f� (Name) Qe.pos t Seri Spec to((sr of M..cl 664e-g-- , 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 .1440 - • .►, _ -z- 2...cf--(3 (SIGNATURE) WWR No. 4521797 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r) Sheriff H,E P R 0 T 1.10NO lid 1,. [ Jody S Smith Chief Deputy 2013 JUL 26 A14 I0* 29 Richard W Stewart Solicitor � � O� TW:t •R(Fr CUMBERLAND COUNTY PENNSYLVANIA Discover Bank vs. Case Number Ryan L. Traugh 2013-2747 SHERIFF'S RETURN OF SERVICE 07/24/2013 10:51 AM-Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2013 at 1051 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Ryan L. Traugh, in the hands, possession, or control of the within named garnishee, Mid Penn Bank, 4622 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania, by handing to Nathan Kelso, Assistant 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. The writ of execution and notice to defendant was mailed on July 25, 2013 to Ryan L. Traugh at 111 S Market Street, Mechanicsburg, PA 17055. AMANDA COBAUGH, DEPUTY SO ANSWERS, July 25, 2013 RbNW R ANDERSON, SHERIFF (c)County5uito Sheriff,Teleosoft,Inc. SIRLIN LESSER& BENSON,P.C. ` Ti i By: Jon C. Sirlin,Esquire pfl Identification No.: 17498lFl; ' C *� 123 South Broad Street,Suite 2100 PEAQ T , Philadelphia,PA 19109 VA (215) 864-9700 Attorney for Garnishee DISCOVER BANK COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. RYAN L. TRAUGH : NO. 13-2747 and PNC BANK,GARNISHEE ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of PNC Bank, Garnishee, in the above-captioned matter. JON C. IN Atto ey fo Garnishee Date: SIRLIN LESSER&BENSON,P.C. By: Jon C. Sirlin,;Esquire Identification No.: 17498 ''° + 2 P1 ; 206 123 South Broad Street,Suite 2100 riy3i,W p " Philadelphia,PA 19109 1EN SYEMt'4fA (215)864-9700 Attorney for Garnishee DISCOVER BANK COURT OF COMMON PLEAS COUNTY OF CUMBERLAND VS. RYAN L. TRAUGH : NO. 13-2747 and PNC BANK, GARNISHEE ANSWERS TO INTERROGATORIES IN ATTACHMENT TO: DISCOVER BANK,Plaintiff 1-6. The Bank has an account balance of$2,593.21 in account(s)titled jointly to Ryan L.Traugh,Barbara Ann Traugh as joint tenants. Pursuant to the terms and conditions of the deposit agreement between the bank and the depositor, the bank claims a priority lien in, and a right of set-off against the account consisting of $100.00 Legal Processing Charge and must allow for the general monetary exemption under 42 Pa.C.S. § 8123. In addition,pursuant to 42 Pa.C.S.A. Section 2503,a garnishee's attorney fee in the minimum amount of$350.00 is authorized and will be deducted from the attached funds. 7. (Q) 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 entity electronically idepositing those funds on a recurring basis. (A) No. 8. (Q) 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. (A) No. XN i C. IRLIN Dated: �� Atto r Garnishee .......... { ....... i i . I I�. VERIFICATION The undersigned hereby verifies that I am an authorized representative of PNC Bank,N.A.; that the statements made in the foregoing Answers to i .. Interrogatories are true and correct to the best of my knowledge,information and belief and that'these statements are made subject to the penalties of 18Pa. C.S. s4904,relating to unworn falsification to authorities. RE: Discover Bank Vs Ryan L Traugh DOCKET NO 13-2747 CIVIL Theresa A Dusch Team Lead, Garnishment Processing i Position i S is DATE: August 7,2013 I I Lit-233946.1 t I i I I i i WELTMAN,WEMERG &REIS CO.,L.P.A. F THE PRA OFFICE BY: William T Molczan,Esquire Attorney for Plaintiff s) NDNO TAR I.D.No.47437 � SEp ii2 436 Seventh Avenue, Suite 1400 .4: 10 Pittsburgh,PA 15219 C1111BE'kAND Phone: 412.434.7955 PENNSYLV,COUNT Y Fax: 412.434.7959 File#4521797 DISCOVER BANK Cumberland County Court of Common Pleas VS. RYAN L TRAUGH NO. 13-2747 CIVIL and PNC BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s),PNC BANK, only. WELTMAN, WEINBERG&REIS CO.,L.P.A. B W Y William T Molczan, quire Attorney for Plaint "n C� SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff .: k''R O T '3 i 1 Jody S Smithy � � 26 2; ' Chief Deputy Richard W Stewart �.UMBE ENNSYLV AC LANL COU t ,i Solicitor � r< ,_�.�3 ,..F.. = HIy Discover Bank vs. Case Number Ryan L. Traugh 2013-2747 SHERIFF'S RETURN OF SERVICE 07/22/2013 11:31 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, 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 Eppley,Assistant 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. 07/24/2013 10:51 AM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2013 at 1051 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Ryan L. Traugh, in the hands, possession, or control of the within named garnishee, Mid Penn Bank, 4622 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania, by handing to Nathan Kelso, Assistant 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. The writ of execution and notice to defendant was mailed on July 25, 2013 to Ryan L. Traugh at 111 S Market Street, Mechanicsburg, PA 17055. 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: $150.26 SO ANSWERS, February 26, 2014 RONO R ANDERSON, SHERIFF a-.2s00". a. U--' 41/ft 939k V 3D /9, '