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Home My WebLink About04-6450IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP, L.L.C., Plaintiff No. ?,(4s6 LIt vs. DEBRA C LANE Defendant COMPLAINT IN CIVIL ACTION 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03945896 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP, L.L.C., Plaintiff vs. Civil Action No. DEBRA C LANE Defendant COMPLAINT IN CIVIL ACTION 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 LAWYER REFERRAL SERVICES CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD ST. CARLISLE, PA 17013 COMPLAINT Plaintiff is a corporation with offices in P.O. Box 370470 Denver, CO 80237. 2. Defendant is residing at 250 West Baltimore St., Carlisle, PA 17013. 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 117447, 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of November 22, 2004, in the amount of 514,947.77 . 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 6.00% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Debra C. Lane individually, in the amount of $14,947.77 with continuing finance charges thereon at the rate of 6.00% per annum from November 22, 2004 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Mol n, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#:03945896 VERIFICATION The undersigned does hereby verify subject to the penalties of 118 PA. CS .S. 4904 relating to unsworn falsifications to authorities, that he/she is `3('?- m (NAME) , plaintiff herein, that C--V;ICZA? M MA Q L of o JS U tStti N 6t? (TITLE) (COMPANYhe/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and bel (SIGNATUR ) W W R# 03945896 W W (°S? ("nn( v1 -? ?? C? r...a - ? ?, ,k ? - r, ? . ;. ? ? ?? :. i ??,) ` C...,' ASSET ACQUISITION GROUP, LLC Plaintiff Vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-6450 CIVIL TERM DEBRA C. LANE, CIVIL ACTION -LAW Defendant NOTICE TO PLEAD TO: Asset Acquisition Group, LLC You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. jj Jones, Esquire orney for Defendant 7 Irvine Row Carlisle, PA 17013-3019 (717) 240-0296 ASSET ACQUISITION GROUP, LLC Plaintiff VS. DEBRA C. LANE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-6450 CIVIL TERM CIVIL ACTION - LAW ANSWER TO COMPLAINT WITH NEW MATTER 1. Admitted. 2. Admitted. 3. Admitted in part and denied part. It is admitted that Defendant applied for and received a credit card from Plaintiff's predecessor. It is denied that the account had the account number set forth in this allegation. 4. After reasonable investigation, Defendant is without knowledge or information sufficient of form or belief as to the truth of this averment and therefore strict proof is demanded. 5. Admitted. 6. Admitted. 7. Admitted. WHEREFORE, Defendant requests that this Court to deny the relief requested by Plaintiff without proof of the damages requested. NEW MATTER- STATUTE OF LIMITATION Defendant has not made a payment on the account in more that four years. WHEREFORE, Defendant requests that this Court dismiss the matter. Respectfully submitted, J fes'k Jones, Es A omey for Defen ant 7 Irvine Row Carlisle, PA 17013-3019 (717) 240-0290 I verify that the statements made in this Answer and New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. ? ??.y1Cl C ` " w? Debra C. Lane IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP, LLC, Plaintiff vs. No. 04-6450 CIVIL TERM REPLY TO NEW MATTER DEBRA C. LANE, Defendant. FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT PA I.D. #42524 Wellman, Weinberg & Reis Co., L.P.A. 2718 Koppers Building 436 7th Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03945896 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP, LLC, Plaintiff No. 04-6450 CIVIL TERM W DEBRA C. LANE, Defendant. REPLY TO NEW MATTER AND NOW, comes Plaintiff, Asset Acquisition Group, LLC, by and through its counsel, WELTMAN, WEINBERG & REIS, CO., L.P.A., and files the within Reply to New Matter, averring in support thereof the following: 8. It is denied that Defendant has not made a payment on the account in more than 4 years. In fact, Defendant fast made a payment on May 16, 2001. WHEREFORE, Plaintiff demands judgment in its favor and against the Defendant in the amounts demanded in its Complaint. WELTMAN, WEINBERG & REIS, W., L.P.A. S G. WARMBRODT D. #42524 1 man, Weinberg & Reis Co., L.P.A. Koppers Building 7th Avenue sburgh, PA 15219 2)434-7955 CERTIFICATE OF SERVICE The undersigned hereby certifies that true and correct copies of the within Plaintiff's Reply to New Matter mailed to the following on this day of + 0 2005 by first class, U.S. Mail, postage pre-paid: James K. Jones, Esquire Seven Irvine Row Carlisle, PA 17013 Respectfully Submitted: WELTMAN, WEINBERG & REIS CO., L.P.A. nq #42524 or oys for Plaintiff 718 oppers Building 436 eventh Avenue Pi burgh, PA 15219 12)434-7955 Esquire VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, he is an attorney for the Plaintiff herein; makes this Verification based upon the facts as supplied to him by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court and the Plaintiff's Verification cannot be obtained within the time allowed for filing of this Reply to New Matter and that the facts set forth in the foregoing Reply to New Matter are true and correct to the best of his knowledge, information and belief. n <-% `;; -., .,, ,?;_ w ; ' ra - < ? ?` _ - << ?:- _ -, i`n c., r.? - c, ; . SHERIFF'S RETURN - REGULAR CASE NO: 2004-06450 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ASSET ACQUISITION GROUP LLC VS LANE DEBRA C VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LANE DEBRA C DEFENDANT the , at 1513:00 HOURS, on the 6th day of January , 2005 at 250 WEST BALTIMORE ST CARLISLE, PA 17013 by handing to MATT LANE, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.70 Affidavit .00 Surcharge 10.00 .00 31.70 Sworn and Subscribed to before me this bif day of A.D. P othonotary So Answers: ?j R. Thomas Kline 01/07/2005 WELTMAN WEINBERG REIS J BY )JA4. Deputy S eriff PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument court. CAPTION OF CASE (entire caption must be stated in full) VS. $rar (-(-c ( Plaintiff ) ( Defendant ) No. 04-66 Civil i-- 19 0 1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): MA4?w, va:? &MMJJ?LL? 2. Identify counsel who will argue case: Wellman, YMnberg & Refs Co. (a) for plaintiff: W, j1I0,0 TM01400 Koppers Bldg. Address: 436 7th Ave. 11 Pittsburgh, PA 15219 (b) for defendant:-JQMa ? J&UO (412) 434-7955 Address: '-7 -17rv1,N Cr4, V- 1 i b LC r-4 17N3 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: W A 1-?-?rr.a.. fr?r len.? ? G I,' r~ xj n ?- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP LLC, Plaintiff, VS. DEBRA C LANE, Defendant. Case No.: 04-6450 CIVIL TERM MOTION FOR SUMMARY JUDGMENT 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. 3945896 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP LLC, Plaintiff, Case No.: 04-6450 CIVIL TERM VS. MOTION FOR SUMMARY JUDGMENT DEBRA C LANE, Defendant. MOTION FOR SUMMARY JUDGMENT AND NOW COMES, Plaintiff, by and through its counsel, Weltman, Weinberg & Reis, Co., L.P.A., and hereby files this Motion for Summary Judgment against the Defendant. In support thereof, Plaintiff avers as follows: 1. Plaintiff filed a Complaint against Defendant seeking judgment in the amount of $14947.77 with interest at the interest rate of 6.0% per annum from November 22, 2004, and costs. A true and correct copy of the Complaint is attached hereto as Exhibit "A" and made a part hereof. 2. Attached to the Complaint was Verification from an authorized representative of Plaintiff verifying the accuracy of the amount sought. See Exhibit "A". 3. Defendant filed an Answer to Plaintiff's Complaint. A true and correct copy of the Answer is attached hereto as Exhibit "B" and made a part hereof. 4. On or around October 3, 2007, Plaintiff served upon Defendant a set of requests for admissions and requests for production of documents. A true and correct copy of the same is attached hereto as Exhibit "C" and made a part hereof. 5. No response to the discovery demands has been received from the Defendant. 6. The requests for admissions are now deemed admitted under Pennsylvania Rule of Civil Procedure 4014(b). Thus Defendant has admitted that she has failed to make all required payments on the credit card; that she applied for the credit card; that the statements attached to Plaintiffs Discovery WWR No. 3945896 Request correctly identify the payments, charges, and balances on the account; that she has not submitted any written disputes as to billing inaccuracies; and that $11454.82 is a correct and accurate balance on the credit card account. 7. By way of her Answer, the documents attached to this Motion, and the Requests for Admissions, deemed admitted under Pa.R.C.P. 4014(b), the Defendant has admitted all facts material to this matter and verified the amount owed. 8. There are no meritorious defenses against this action and Plaintiff is entitled to summary judgment as a matter of Law against defendant. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant summary judgment in favor of Plaintiff and against Defendant for $14947.77 with interest at the legal interest rate of 6.0% per annum from November 22, 2004, and costs. Respectfully Submitted: By: 1' ` I William T. Molczan, quire 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. 3945896 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP LLC, Plaintiff, Case No.: 04-6450 CIVIL TERM VS. DEBRA C LANE, Defendant. ORDER OF COURT AND NOW, to-wit, this day of , 2008, upon Plaintiff's Motion for Summary Judgment, IT IS HEREBY ORDERED, ADJUDGED AND DECREED that said Motion is GRANTED and Judgment is entered in favor of Plaintiff for $14947.77 with interest at the rate of 6.0% per annum from November 22, 2004, plus costs. BY THE COURT J. WWR No. 3945896 CERTIFICATE OF SERVICE A true and correct copy of the within Plaintiffs Motion for Summary Judgment and Brief in Support has been served by U.S. Mail, Postage Pre-Paid, oncP"ay of &-f I ` 2008 upon the following: James K Jones, Esq. 7 Irvine Row Carlisle Pa 17013 By: William T. Molc , 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. 3945896 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, he is an attorney for the Plaintiff herein; makes this Verification based upon the facts as supplied to him by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court and the Plaintiff's Verification cannot be obtained within the time allowed for filing of this Motion, and that the facts set forth in the foregoing Motion are true and correct to the best of his knowledge, information and belief. li? Attorney for Plamtiff WWR No. 3945896 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP, L.L.C., No. Ou vis6 LI; v Plaintiff vs. DEBRA C LANE Defendant COMPLAINT IN CIVIL ACTION 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03945896 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP, L.L.C., Plaintiff VS. Civil Action No. DEBRA C LANE Defendant COMPLAINT IN CIVIL ACTION 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 LAWYER REFERRAL SERVICES CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD ST. CARLISLE, PA 17013 COMPLAINT 1. Plaintiff is a corporation with offices in P.O. Box 370470 Denver, CO 80237. 2. Defendant is residing at 250 West Baltimore St., Carlisle, PA 17013. 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 117447. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of November 22, 2004, in the amount of $14,947.77 . 5. Defendant is in default of the terns of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 6.00% per annum on the unpaid balance. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Debra C. Lane individually, in the amount of $1.4,947.77 with continuing finance charges thereon at the rate of 6.00% per annum from November 22, 2004 plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Mol Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#:03945896 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. .S. 4904 relating to unswom falsifications to authorities, that he/she is ncx& - m G?Lj WJ M n ii (NAME) C'?1eJa1 m atlA p ?. of o U cS?ti vt plaintiff herein, that (TITLE) (COMPA Y) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and beli krM? fil (SIGNATURE) W W R# 03945896 ?e4rc. L4nt ASSET ACQUISITION GROUP, LLC Plaintiff VS. DEBRA C. LANE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-6450 CIVIL TERM CIVIL ACTION -LAW NOTICE TO PLEAD TO: Asset Acquisition Group, LLC You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. rJ . Jones, Esquire 4Ad6mey for Defendant 7 Irvine Row Carlisle, PA 17013-3019 (717) 240-0296 tVUjBjj ASSET ACQUISITION GROUP, LLC Plaintiff VS. DEBRA C. LANE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-6450 CIVIL TERM CIVIL ACTION - LAW ANSWER TO COMPLAINT WITH NEW MATTER 1. Admitted. 2. Admitted. 3. Admitted in part and denied part. It is admitted that Defendant applied for and received a credit card from Plaintiffs predecessor. It is denied that the account had the account number set forth in this allegation. 4. After reasonable investigation, Defendant is without knowledge or information sufficient of form or belief as to the truth of this averment and therefore strict proof is demanded. 5. Admitted. 6. Admitted. 7. Admitted. WHEREFORE, Defendant requests that this Court to deny the relief requested by Plaintiff without proof of the damages requested. NEW MATTER - STATUTE OF LIMITATION 8. Defendant has not made a payment on the account in more that four years. WHEREFORE, Defendant requests that this Court dismiss the matter. Respectfully submitted, J . Jones, Es A orney for Defen ant 7 Irvine Row Carlisle, PA 17013-3019 (717) 240-0290 I verify that the statements made in this Answer and New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Debra. C. Lane WELTMAN, WEMERG & REIS CO. L P A BURLINGTON, NJ , . . . 609.914.0437 ATroBI m AT LAw 2718 Koppers Building CHICAGO, IL 847.940.9812 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 CINCINNATI, OH 412.434.7955 513.723.2200 www.wtltman.com CLEVELAND, OH 216.685.1000 COLUMBUS, OH JAMES C. WARMBRODT 614.228.7272 Attorney at Law 412.338.7113 DETROIT, MI 248.362.6100 Fax 412.338.7130 jwarmbrodt@weltman.com or INNOVATION GROWTH R PHILADELPHIA, PA + ESULTS 215.599.1500 September 28, 2007 James K. Jones, Esquire 7 Irvine Row Carlisle, PA 17013 RE: ASSET ACQUISITION GROUP, LLC vs. DEBRA C. LANE WWR# 3945896 Docket No.: 04-6450 Dear Mr. Jones: Enclosed please find Plaintiffs Requests for Admissions in the above referenced matter. Please provide responses to these requests within thirty (30) days of receipt of the same. Thank you for your attention in this matter. )rodt JCW/emo Enclosure EXHIBIT Very truly yours, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ASSET ACQUISITION GROUP, LLC, ) Plaintiff, ) V. ) DEBRA C. LANE, Defendant. ) CASE NO: 04-6450 CIVIL TERM PLAINTIFF'S REQUEST FOR ADMISSIONS Plaintiff demands that defendant answers and respond to the following Request for Admissions pursuant to Pa. Rules of Civil Procedure 4014. You are requested to admit the truth of each of the statements of fact hereinafter stated. You are instructed that: 1. These requests are made under Pennsylvania Rules of Civil Procedure 4001, et seq., and each of these matters of which an admission is requested shall be deemed admitted unless your sworn statement in compliance with such Rules is timely made. 2. If you do not admit each of such statements, you must specifically deny each one not admitted or set forth in detail the reasons why you cannot truthfully either admit or deny each such matter. 3. Your answer, signed and properly verified, must be delivered to the undersigned attorney of record for the Plaintiff within thirty (30) days after delivery hereof. 4. If you fail or refuse to admit the truth of any such statement of fact and the Plaintiff thereafter proves the truth thereof, you may be required to pay the reasonable expenses incurred in making such proof, including attorneys' fees, witness expenses, etc. 5. If, in response to any of the following statements of fact, it is your position that the statement is true in part or as to some items, but not true in full or as to all items, then answer separately as to each part or item. 6. If you have been sued in more than one capacity or if your answers would be different if answered in any different capacity, such as partner, agent, corporate officer or director or the like, then you are requested to answer separately in each such capacity. Failure to do so constitutes an admission in any such capacity. 7. In these Requests for Admissions: A. The word "person s " means all entities, and, without limiting the generality of the foregoing, includes natural persons, joint owners, associations, companies, partnerships, joint ventures, trusts, and estates; B. The word "document(s)" means all written, printed, recorded, graphic, or photographic matter, or, sound reproductions, however produced or reproduced, pertaining to any manner to the subject matter indicated; C. The words "identity". "identify'. "identification", when used with respect to a erson s means to state the full name and present or last known address and business address of such erson s and, if an actual person, his present or last known job title, and the name and address of his present or last known employers; D. The words "identity". "identify" "identification" when used with respect to a date, subject matter, name(s) or person(s) that wrote, signed initialed, dictated or otherwise participated in the creation of the same, the name(s) of the addressee or addressees if any and the name(s) and address(es) of each ep rson who have possession, custody, and control of said document(s). If any such document was, but is no longer in your possession, custody, or control, or in existence, state the date and manner of its disposition; and E. The word "identi when used with respect to an act (including an alleged offense), occurrence, statement, or conduct (hereinafter collectively called "act"), means to (1) describe the substance of the event or events constituting such an act, and to state the date when such act occurred; (2) identify each and every rson s participating in such an act; (3) identiall other erson s (if any) present when such act occurred; (4) state whether any minutes, notes, memoranda, or other record of such act was made; (5) state whether such record now exists; and (6) identify the person(s) presently having possession, custody or control of such record. 8. Unless otherwise indicated, all Requests herein relate to those certain events, persons, and period of time more fully described in the pleading in this case. 9. These requests are of a continuous nature. REQUEST FOR ADMISSION NO. 1: Defendant applied for and received a credit card issued by MBNA bearing account number 5490993999402391. Admitted Denied If the answer to Request for Admissions No. 1 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 2: Defendant used the credit card issued by MBNA bearing account number 5490993999402391 to purchase goods, materials and services. Admitted Denied If the answer to Request for Admissions No. 2 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 3: Attached hereto as Exhibit "A" are true and correct copies of the statements dated 12/20/01, 5/21/01 and 6/21/04 for the subject credit card account no. 5490993999402391. Admitted Denied If the answer to Request for Admissions No. 3 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 4: The subject credit card account no. 5490993999402391 is subject to finance charges of 14.99% per annum on the unpaid balance. Admitted Denied If the answer to Request for Admissions No. 4 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO. 5: The subject credit cart account no. 5490993999402391 was purchased by Plaintiff on March 25, 2003. (See the Assignment and Bill of Sale attached hereto as Exhibit "B") Admitted Denied If the answer to Request for Admissions No. 5 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO 6• Defendant is required to make monthly payments to Plaintiff on any outstanding balances owed on the subject credit card account no. 5490993999402391. Admitted Denied If the answer to Request for Admissions No. 6 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO 7• Defendant has failed to make any payments to Plaintiff on the subject credit card account no.5490993999402391. Admitted Denied If the answer to Request for Admissions No. 7 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO 8• Defendant has not submitted any written dispute as to any accounting inaccuracy concerning the amounts demanded by the Plaintiff on the subject credit card account no. 5490993999402391. Admitted Denied If the answer to Request for Admissions No. 8 is "denied", then supply specific written documentation supporting the denial. REQUEST FOR ADMISSION NO 9• The balance owed by the Defendant to the Plaintiff on the subject credit card account no. 5490993999402391 as of 3/25/03 was $11,454.82. (See the Statement of Account attached hereto as Exhibit "C") Admitted Denied If the answer to Request for Admissions No. 9 is "denied", then supply specific written documentation supporting the denial. submitted, PA L.P Warmbrodt, Esquire , WEINBERG & REIS 2 71 8 ppers Building 6 venth Avenue ' burgh, PA 15219 412) 434-79555 WWR#5491437 JUL. [n• LIMI IL:)Irivi MV. 14U r. ) - rwon state ct " 913322 MaL 13" AlvW Amclet1D/ L !1 UL 669.411 D 11i•1?& CUMKXDER VIM Ins 7, .W P.3. OK 11113f 'AL?QL IM. V. 79001-9177 Mau C U1O r0UK w I D1LIOC wax !A I)MY-dt9911 - i aO10itL27Diq711161NOO7rETA000NSWI1teNes011SfDtOD.Ia!l7l?t?Cl b.s 1 00t20it/io1100tS171om000041OOOO0001O111i1?001LS70eDO0L+fa1P7itt017tic DLwIL r sure cptmwr,-Ak4w c1& - 559 -15 T-C 1220 1121 01 72KD01)2K 1K C OVER OOAIT I= FIE 29.00 1120 12VD 01000100010Oq NC C 2940 ? 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O[ tf064-coax 11 V. ! 7V i . ) A551GNZWENT AND BELL OF SALE CACV of olora& LLC has entered into a Purc.'zase Age--..enc ("A-,m==t") dared'. ,?larc:h ? 2003 for the sale of Ac Counts. descrrnoed in ExhFok E thereof, to Asse: Acouisition Group, L C ("Buye-.1 upon the re-= and conditions se: forth in that Aor=-n=L NOW, T REFORE, for good and valuable consideration. Seller hereby se!1s, assigns and ttansfe.-s Buyc all of the Seq. =l s rights, title and interest in =h and evey one of the Accounts desc?oed the Amreeme= i THIS B OF SALE IS EXECUTED WITHOL RECOURSE OR WARRANTIES FXCErT AS STA AND PROVIDED FOR WITHIN THE PURCHASE AND SALE AGRF-r 1,e NT. Buye_ an f 4er a-cz,-- d= the Purchase Price shall be as sated in E xhFnir B (Teen Am-=nc=), aaached. -, the ap-mmem , IN WT Mart WREREOF, Se,'1= has signed and delive:-ecii this kzm=em on the 25th day of EXHIBIT - Pico n O N ktJ H Z O or U d 0 M J Q U Q F- W _m 2 Q x W U w J J O U i- J F- [11 U) U) Q JUL. (0. (UI}J I(;) IrIT 0 N epil e O td tQ N L 3 ? o ? m o` rn m? o v V o ID L- d 3 O L 0 m O U cq '? r a IA L W ' L O !t7 CV CO Ct 1? O N I.- N 3 U 0 0 ° m m w a? v m w z aL "* nV. ITv 1. -r rn N O L V " N d O N ? CL N EXHIBIT C, (I Qf Q CERTIFICATE OF SERVICE I, James C. Warmbrodt, hereby certify that a true and correct copy of the Request for Admissions was served on Defendant's attorney by regular U. S. Mail, postage ?,2? 003r, addressed as follows: prepaid, this day of&4 James K. Jones, Esquire 7 Irvine Row Carlisle, PA 17013 6 a r 1 - CX) 1 ?! Office of the Prothonotary 10 Cumberland County Curtis R. Long Prothonotary James K. Jones, Esquire 7 Irvine Row Carlisle, PA 17013 DATE: May 8, 2008 TO Attorney Jones: THIS IS TO NOTIFY YOU THAT CASE NUMBER 04-6450, Asset Acquisition Group LLC VS. Debra C. Lane HAS BEEN LISTED FOR ARGUMENT ON May 28, 2008 Cumberland County Argument Court Rules 1028(c), 1034(a) and 1035.2(a) shall be strictly enforced- If tbo CURTIS R. LONG Prothonotary Cumberland County t r 1 Courthouse Square 9LED? 'fj ? I QpiG Carlisle, PA 170130 ' PON 3 ` . .ra ® P"E9 02 1A $ 0 0004631598 MAY MAILED FROM ZIP COI 40 Z/- 6 Z/,5 0 James K. Jones, Esquire 7 Irvine Row Carlisle, PP 1N?]CIE 171 Ct 1 25 OSl RETURN TO SENDER LE AS NOT DEUNAGLREaTO FORWARDESSEC SC: 17013 =0119-00529- •~.-, :+rs.•.= 11111111111111111 )JII 1111111111 PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. CAPTION OF CASE (entire caption must be stated in foil) RE-,Sf.-t Rqwu'}?,6/) &av tLc V5. (Plaintiff) (Defendant) No . 6 / -cl? ??U Civil 19 1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.) : L ??NV?V? U N 2. Identify counsel who will argue case: Weltrnon, Weinberg & Refs Co. (a) for plaintiff :W A? MV, ? 1? 1 c z? h 1400 Koppers Bldg. Address ` 436 7th Ave. ? .? Pittsburgh, PA 15219 (b) for defendant : CJ(.?..VvIQ/J L a ? -w (412) 434-7955 Address: 00 LV c.K l l-?le f/i 17d13 3. I will notify all parties in writing within two days that this case has been Listed for argument. 4. Argument Court Date: IAIArV-4?- Att ev for IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP LLC, Plaintiff, Case No.: 04-6450 CIVIL TERM vs. DEBRA C LANE, Defendant. ORDER OF COURT AND NOW, to-wit, this ZS' day of &712, _, 2008, upon Plaintiff's Motion for Summary Judgment, IT IS HEREBY ORDERED, ADJUDGED AND DECREED that said Motion is GRANTED and Judgment is entered in favor of Plaintiff for $14947.77 with interest at the rate of 6.0% per annum from November 22, 2004, plus costs. J. W WR No. 3945896 PV TT-TP MT TR T Ia ssd d• A4i f • JlU.VES Office of the Prothonotary Cumberland County Curtis R. Long Prothonotary James K. Jones, Esq. 7 Irvine Row Carlisle, PA 17013 DATE: June 19, 2008 TO Attorney Jones: THIS IS TO NOTIFY YOU THAT CASE NUMBER 04-6450, Asset Acquisition Group LLC VS. Debra C. Lane CURTIS R. LONG Prothonotary Cumberland County 1 Courthouse Square Carlisle, PA 17013 FILEC-O -r`^E OF THE PP^-' ; A 'y 2CuJ ?l ii .JV !i 1 A L ?.?i1 [.. it 4 T 5KPses PON w° ar1 02 1A $ I 0004631598 JL MAILED FROM ZIPC James K. Jones, Esq. 7 Irvine Row Carlisle, PA 4 7ni a NIXIE 176 CE 1 06 06/ RETURN TO SENDER NOT DELIVERABLE AS ADDRESSEC UNABLE TO FORWARD BC: 17010 *05IS-011s1- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP,LLC., Plaintiff Case No.: 04-6450-CIVIL TERM TYPE OF PLEADING VS. PRAECIPE FOR JUDGMENT PER ORDER OF COURT DEBRA C LANE FILED ON BEHALF OF: Defendant. Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND USED FOR THAT PURPOSE. COUNSEL OF RECORD OF THIS PARTY: Patrick Thomas Woodman, Esquire PA I.D.#34507 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR # 03945896 $14,947.77 ANY INFORMATION OBTAINED SHALL BE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP,LLC., Plaintiff Case No.: 04-6450-CIVIL TERM VS. DEBRA C LANE Defendant. PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Pursuant to Pa.R.C.P. 237, I certify that a copy of this Praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. In light of the Court Order granting Summary Judgment in favor of Plaintiff on May 28, 2008, kindly enter Judgment against the Defendant, DEBRA C LANE, in the amount of $14,947.77 computed as follows: Amount Awarded per Order: $14,947.77 Interest from November 22, 2004 at the legal rate of 6% per annum: $0.00 TOTAL: $14,947.77 Attached is a copy of the Court Order in favor of Plaintiff for Judgment. WELTMAN, WEINBERG & REIS, CO., L.P.A. By: l -c woo Patrick Thomas Woodman, Esquire PA I.D.#34507 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Plaintiff's address is: c/o Weltman, Weinberg & Reis, Co., L.P.A., 1400 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 And Defendant's address is: 250 WEST BALTIMORE ST., CARLISLE,PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP LLC, Plaintiff, VS. DEBRA C LANE, Defendant. Case No.: 04-6450 CIVIL TERM ORDER OF COURT AND NOW, to-wit, this 24' day of f-,71g, 2008, upon Plaintiffs Motion for Summary Judgment, IT IS HEREBY ORDERED, ADJUDGED AND DECREED that said Motion is GRANTED and Judgment is entered in favor of Plaintiff for $14947.77 with interest at the rate of 6.0% per annum from November 22, 2004, plus costs. J. TRUE. COPY f-Rom N?401RU `a U ""ay Mahon`, i MM Ufflo ray bpi ! 1 O -.:31t! CW49t St Clf . IAA at. I awe pia W WR No. 3945896 0 -71Z As riv 'rt= rnT TR T VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. By: t f? 1i?9D0'J9M?` Patrick Thomas Woodman, Esquire PA I.D.#34507 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03945896 C"a ? c:a Yl ( ?w rT- ; { W ? iT7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP,LLC., Plaintiff Case No.: 04-6450-CIVIL TERM VS. DEBRA C LANE Defendant. NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendants ( ) Garnishee You are hereby notified that th fo owing Order or Judgment was entered against you on 10 g (xx) Assumpsit Judgment in the amount of $14,947.77, plus interest at 6% per annum, 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 (xx) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration Award ( ) By Consent James Jones, Esquire 8125 ADAMS DR SUITE A HUMMELSTOWN, PA. 17036 THIS IS AN ATTEMPT TO COLLECT A DEBT AND USED FOR THAT PURPOSE. Prothonotary By: &?5U PRO AINFORMATION R ) AN OBT INED SHALL BE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISITION GROUP,LLC., Plaintiff Case No.: 04-6450-CIVIL TERM VS. DEBRA C LANE Defendant. NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendants ( ) Garnishee You are hereby notified that the f Mowing Order or Judgment was entered against you on 7u, ne (xx) Assumpsit Judgment in the amount of $14,947.77, plus interest at 6% per annum, 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 (xx) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration Award ( ) By Consent DEBRA C LANE 250 WEST BALTIMORE ST CARLISLE,PA 17013 THIS IS AN ATTEMPT TO COLLECT A DEBT USED FOR THAT PURPOSE. Prothonotary By: PRO ONOTAR ) AND ANY INFO TION OBT INED SHALL BE M i.* ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISTION GROUP, LLC Plaintiff VS. DEBRA C LANE Defendant MEMBERS I' FCU, Garnishee, No. 04-6450-CIVIL PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03945896 I 1. y w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISTION GROUP, LLC Plaintiff VS. DEBRA C LANE Defendant MEMBERS 1 ST FCU, Garnishee Civil Action No. 04-6450-CIVIL PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMNERLAND County: 2. against DEBRA C LANE, Defendant,.250 U). Sa Awto a S¢ , ((isle, PA 17013 3. against MEMBERS 1sTFFCCU,&? Garnishee 4. Judgment Amount ea'"ke PA 1-1013 $ 14947.77 Less payments of $ 155.50 Interest $ 653.61 Costs $ SUBTOTAL: $ 15445.88 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Esqui PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03945896 . .1 41h '`J ., [l1?}? ?{? C1 L t r?+ 1 *&4.5o Po ATry 31.'10 55.50 Woo *ta,5.070- Po ATTY *C2.0o pveCD .50 LL 9*.u4313 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-6450 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSET ACQUISTION GROUP, LLC, Plaintiff (s) From DEBRA C. LANE, 250 W. Baltimore St., Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FCU,1000 Bryn Mawr Rd, Carlisle, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $14,792.27 Interest -- $653.61 Atty's Comm % Atty Paid $125.70 Plaintiff Paid Date: 4/28/09 L.L. $.50 Due Prothy $2.00 Other Costs C s R. Long, on ary (Seal) 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 By: Deputy Supreme Court ID No. 47437 Sheriffs Office of Cumberland County R Thomas Kline ? t?19 at 4"MIJ,10 h? L:uwwu L, 0%,11VIFF Sheri Solicitor C, Ronny R Anderson Jody S Smith Chief Deputy OFF14E aF THE a?,ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/08/2009 03:28 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on May 8, 2009 at 1528 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Debra C. Lane, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1000 Bryn Mawr Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Kristal Luckey, Member 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 May 11, 2009 to Debra C. Lane, 250 West Baltimore Street, Carlisle, PA 17013. 2004-6450 Asset Acquisition Group, LLC vs Debra C. Lane So Answers, R. ?iomas Kline, Sheriff By -??-? DeputAy SherYf ?r 2 N 0 ° nim - 4 m C') b IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISTION GROUP, LLC Plaintiff vs. DEBRA C LANE Defendant and MEMBERS I ST FCU Garnishee No. 04-6450 nrs -k .. . INTERROGATORIES IN ATTACHMENT MEMBERS 1ST FCU 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#03945896 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISTION GROUP, LLC Plaintiff vs. Civil Action No.: 04-6450-CIVIL DEBRA C LANE Defendant and MEMBERS 1 ST FCU Garnishee TO: MEMBERS 1sT FCU Suggested Reference No.: XXX-XX-4106 1000 Bryn Mawr Rd Carlisle, PA 17013 RE: DEBRA C LANE 250 WEST BALTIMORE STREET CARLISLE, PA 17013 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. 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? N I a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. !v'fi 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. N 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? n0 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? /1b 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? N 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? J? l?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 entity electronically depositing those funds on a recurring basis. fio 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. fi0 XKX217-00 land ?riman? ?ebr? C' l?rt.c-- joint WELTMAN, WEINBERG & REIS CO., L.P.A. By: "4- William T. Molez , Esqui PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03945896 T4 $30o stA.tuiv? U&nPtidii has bUA -{ak-cn out 0P *?- accuunf . A X25 ?@M51'(9 fcf- has be.ar? -1-alcen Qut of qiu accent. 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 Becky Marshall (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. b4u???? (SI NAT RE) ALED- OF THE 2009 MAY 12 PM 12: 0 3 ASSET ACQUISITION Plaintiff V. DEBRA C. LANE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-6450 CIVIL TERM IN RE: DEFENDANT'S CLAIM FOR EXEMPTION ORDER OF COURT AND NOW, this 29 h day of May, 2009, upon consideration of Defendant's Claim for Exemption, and it appearing that Defendant is attempting to file a third party property claim on behalf of her husband, the Claim for Exemption is stricken without prejudice to the right of Defendant's husband to file a timely third party property claim. BY THE COURT, J. esley Ol ., J. ? William T. Molczan, Esq. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 Attorney for Plaintiff /Debra C. Lane 250 W. Baltimore Street Carlisle, PA 17013 Defendant :rc `?'? Lis ?. 1 ° '1". 41 t ?. F J t U , tv of unt?Prt? R. THOMAS KLINE ' Sheriff EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 May 28, 2009 Cumberland County Court Administration 1 Courthouse Square Carlisle, PA 17013 MAY 2 8 2009 (n r RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Sergeant Enclosed please find Claim for Exemption pertaining to Civil Case Number 2004- 6450 Civil, Asset Acquisition Group, LLC - vs- Debra C. Lane, filed by Debra C. Lane. Also, please forward a copy of the Notice of Hearing to my attention in the Sheriff's office, however it is the Court's responsibility to notify all parties involved. Thank You for your consideration to this matter. Sharon R. Lantz MAY 7 8 2009 ot COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ASSET ACQUISITION GROUP, LLC Plaintiff No. 04-6450-CIVIL VS. DEBRA C LANE Defendant MEMBERS 1sT FCU Garnishee WRIT OF EXECUTION NOTICE This paper is a "Writ of Execution". It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that certain property cannot be taken and sold by the Sheriff to satisfy your debts. SUCH PROPERTY IS SAID TO BE EXEMPT. No matter what you may owe, there is a DEBTOR'S EXEMPTION established by law. This means that no matter what happens, the Sheriff must give you from the sale at least $300.00 in cash or property. There are also other exemptions which may be applicable to you. Listed below is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following promptly: (1) Complete the claim form on the opposite side and demand a prompt hearing. (2) Deliver the form or mail it to the Sheriffs Office at the address noted. You should come to court when and where you are told to appear ready to explain your exemption. IF YOU DO NOT COME TO COURT AND PROVE YOUR EXEMPTION, YOU MAY LOSE SOME OF YOUR PROPERTY. 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 TELEPHONE NO.: (717) 249-3166 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 exemptions set by law. 2. All wearing apparel used by yourself and all family members. 3. Bibles, school books, sewing machines, uniforms & equipment. 4. Tools of your trade such as carpenter's tools. 5. Most wages & unemployment benefits. 6. Social Security benefits, certain retirement funds and accounts. 7. Certain veteran & armed forces benefits. 8. Certain insurance proceeds. 9. Such other exemptions as may be provided by law. CLAIM FOR EXEMPTION TO THE SHERIFF: I, the above-named defendant, claim exemption of property from levy or attachment: (1) FROM MY PERSONAL PROPERTY IN MY POSSESSION WHICH HAS BEEN LEVIED UPON, (a) I desire that my statutory $300.00 exemption be: L? (1) set aside in kind (specify property, to be set aside in kind: (2) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption: (specify property and basis of exemption): (2) FROM MY PROPERTY WHICH IS IN THE POSSESSION OF A THIRD PARTY, I CLAIM THE FOLLOWING EXEMPTIONS: (a) my $300.00 statutory exemption: in cash (_, in kind (specify property): (b) Social Security benefits on deposit in the amount of $ (c) Other (speci amount & basis for exemption): J?L j` ,y EA'n . I request a prompt court hearing to determine the exemption.1 r= no ld hOco.Q?) P)Q a , Notice of hearing should ?be? lgiven me at the following: 711` l-? %ELEPHONE NUMBER: ADDRESS: - W , NAP 9-00131 1A4AI S (fe I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. § 4904 relating to unworn falsification to authorities: Q Defendant: !? A tlA / i X Date: THIS CLAIM TO BE FILED WITH: Office of the Sheriff of Cumberland County One Courthouse Square, Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone Number: (717) 240-6390 Note: Under paragraphs (1) and (2) of the Writ, a description of specific property to be levied upon or attached may be set forth in the Writ or included in a separate direction to the Sheriff. Under paragraph (2) of the writ, if attachment of a named garnishee is desired, his name should be set forth in the space provided. Under paragraph (3) of the writ, the Sheriff may, as under prior practice, add as a garnishee any person not named in this writ who may be found in possession of property of the defendant. See Rule 3111(a). For limitations on the power to attach tangible personal property, see Rule 3108(a) (b). Each court shall, by local rule, designate the officer, organization or person to be named in the notice. O I `i i'f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSETT ACQUISITION GROUP, LLC Plaintiff VS. -DEBRA C LANE Defendant No. 04-6450 CIVIL PRAECIPE FOR JUDGMENT AGAINST GARNISHEE MEMBERS 11T FEDERAL CREDIT UNION Garnishee FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03945896 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSETT ACQUISITION GROUP, LLC Plaintiff VS. DEBRA C LANE Defendant Civil Action No. 04-6450 CIVIL MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee PRAECII'E FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, MEMBERS 1 ST FEDERAL CREDIT UNION, in the amount of $15,574.08, which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG & REIS CO., L.P.A. By: WILLIAM T. MOLC N, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 152.19 (412) 434-7955 WWR#03945896 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: 1000 BRYN MAWR RD, CARLISLE, PA 17013 'OCT-22-2009 THU 10:43 AM MEMBERS 1ST MEMBER SVCS FAX NO. 7177956005 P. 01 st IV M EMBERS 1s t isf%DER" CREDIT UPTION To: J;vNaww? Fax Number: Company: Date: /?r? O q No. Pages: , includins cover From: Members 1st Federal Credit Union Ph: Fax: Re: "o C12GaQ e-- Comments: 5000 Louisa Drive ¦ P.O. Box 40 ¦ Mechnniesburg, PA 17055 M www.mernberslst.org Our mission: To serve the wwatunlty and partner with our members to offer value-oddedfFnanelaiPw4cts, "rvlces and solutions, OCT-22-2009 THU 10:43 AM MEMBERS 1ST MEMBER SVCS FAX NO. 7177956005 P. 02 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISTION GROUP, LLC Plaintiff VS. DEBRA C LANE Defendant No. 04-6450-CIM INTERROGATORMS IN ATTACHI UNT 11 MMMERS 1"r FCU and MEMBERS 1 ST FCU Garnishee FILED ON BEkIALF OF: r.I,,? -tee n Plaintiff COUNSEL OF RECORD OF ? c? ? ? ?'? THIS PARTY: ? a CA William T. Molczan, &quire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03945896 OCT-22-2009 THU 10:43 AM MEMBERS 1ST MEMBER SVCS FAX NO. 7177956005 P. 03 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSET ACQUISTION GROUP, LLC Plaintiff VS. DEBRA C LANE Defendant and MEMBERS 1 ST FCU Garnishee Civil Action No.: 04-6450-CML TO: MEMBERS 1'-"FCU Suggested Reference No.: XXX-XX-4106 1000 Bryn Mawr Rd Carlisle, PA 17013 RE: DEBRA C LANE 250 WEST BALTIMORE STREET CARLISLE, PA 17013 IMPORTANT NOTICES TO GARNISMEI 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. OCT-22-2009 THU 10:43 AM MEMBERS 1ST MEMBER SVCS FAX NO, 7177956005 P. 04 INTERROGATORIES IN ATTACRIVIENT 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? no la. If the answer to Interrogatory 1 is in the affumative, 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. )J/P 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. 120 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? nD 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? !Q 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? 60 ?. 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 depositing those funds on a recurring basis. no 'OCT-22-2009 THU 10:43 AM MEMBERS 1ST MEMBER SVCS FAX NO. 7177956005 P. 05 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. § 812371f so, identify each account. XYV n 7 7 - OD 4 1,515 7q. 0 WELTMAN, WFJ BERG & REIS CO., L.P.A. GW . -6nf an Cans,- Prrr4 ?Cb? C LAnt - ?Uinf By. - r William T. Mole , Esqui PA I.D. #47437 WELTMAN, WEII MM & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434.7955 WWR#03945896 Th' f&O ? ttfary r?.m?p i'an has bun -Ow Of OF A adea wt, A IZ5 PTDW61j Ae, has bw `hfl(,o old 09 44u k. =Af . OCT-22-2009 THU 10:44 AM MEMBERS 1ST MEMBER SVCS FAX NO. 7177956005 P. 06 VERI)F'YCATION 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 Becky Marshall (Name) Deposit Operations Analyst of Members 1st Federal Credit union --k IrAm/ "WN garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGN TUU FLED-Cl:r'G`F CF THE" PR07HCMTARY 2309 OCT 28 PM 1: 04 14. o o Po ATM Cxr`? S19110 Nah?Sd I.? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ASSETT ACQUISITION GROUP, LLC Plaintiff VS. DEBRA C LANE Defendant MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee Members I" Federal Credit Union 1000 Bryn Mawr Rd Carlisle, Pa 17013 Civil Action No. 04-6450 CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff ( ) Defendant (xx) Garnishee You are hereby notified that the following Order or Judgment was entered against you on lo 1JAID, (xx) Assumpsit Judgment in the amount of $15,574.08 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: 6v6b4 OTHONOT DEPUTY) 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: 412.434.7959 File # 03945896 MBNA vs. DEBRA C LANE and MEMBERS 1 ST FEDERAL CREDIT UNION CUMBERLAND County Court of Common Pleas NO. 04-6450 CIVIL Garnishee(s) PRAECIPE TO SATISFY ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter satisfied as to Garnishee(s), MEMBERS 1sT FEDERAL CREDIT UNION, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to and su Before rytMeL ibed Day of December, 2009 James f-Awarmbrodt, Esquire Attorn v f 6r Plaintiff Wendy L. GMult, Notary Public ARY PU LIC City of Pittsburgh, Allegheny County My Commission Expires July 15, 2010 Member, Pennsylvania Association of Notaries iia THIF Pr y? ,%M ARY 2009 DEC 14 Pi 3.3 7 e?c? H a8?3-2y !- as soao Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r .? nTARY 2010 KAR 29 p11 4: 07 v :' '.i 4`,S L1tANIt`''. Asset Acquisition Group, LLC Case Number vs. 2004-6450 Debra C Lane SHERIFF'S RETURN OF SERVICE 05/08/2009 03:28 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, tates that on May 8, 2009 at 1528 hours, attached as herein commanded all goods, chattels, rights, debts, its, and monies of the within named defendant, to wit: Debra C. Lane, in the hands, possession, or co trot of the within named garnishee, Members 1 st Federal Credit Union, 1000 Bryn Mawr Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Kristal Luckey, Member 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 May 11, 2009 to D bra C. Lane, 250 West Baltimore Street, Carlisle, PA 17013. 05/28/2009 On Thursday, May 28, 2009 at 1010 hours, a claim for exemption was filed by ebra C. Lane, the defendant in this case. The original claim form was hand carried to the Court A ministrators office to schedule a hearing. 03/29/2010 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: $76.38 SO ANSWE S, TZW??? March 29, 2010 RON R NDERSON, SHERIFF B i n R. Lantz 7so?? a 396 (c Goun ySulte Sheriff, Teleosoft, Inc. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-6450 Clvil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSET ACQUISTION GROUP, LLC Plaintiff (s) From DEBRA C. LANE, 250 W. Baltimore St., Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon i the possession of GARNISHEE(S) as follows: MEMBERS 1sT FCU, 1000 Bryn Mawr Rd, Carlisle, PA 17013 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishe paying any debt to or for the account of the defendant (s) and from delivering any prc (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found of anyone other than a named garnishee, you are directed to notify him/her that he/shy garnishee and is enjoined as above stated. Amount Due $14,792.27 L.L. $.50 Interest -- $653.61 Atty's Comm % Due Prothy $2.00 Atty Paid $125.70 Other Costs Plaintiff Paid Date: 4/28/09 eG;s R. Long„83 (Seal) By: s) is enjoined from ;rtv of the defendant. n the possession has been added as a 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