HomeMy WebLinkAbout13-5434 Supreme Court of Rennsvivania ` WR 30141225 C A Pit SJS
Court of Common fleas
Civil Cover Sheet For Prothoirolarr L %se Only:
C UMBERLAND', County Docket No:
The information collected on this fibrin is used solely for court administration purposes. This fbrnn does not
supplement or replace the filing fling and ser i4ce ofpleadings or other papers as required by lain or rules of court.
Commencement of Action:
S pl Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction Declaration of Takin
C DISCOVER BANK
Lead Plaintiff's Name: Lead Defendant's Name:
T MARGARET L BROLL
I
0 Are money damages requested? ® Yes ❑ No Dollar Amount Requested: ® within arbitration limits
N (check one) ❑ outside arbitration limits
A Is this a Class Action Suit? 13 Yes Q No Is this an NMJ Appeal? 13 Yes W No
Name of Plaintiff /Appellant's Attorney: William T. Molczan,47437
❑ Check here if you have no attorney (are a Self - Represented [Pro Sel Litigant)
Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Protection Administrative Agencies
• Malicious Prosecution I Debt Collection: Credit Card ❑ Board of Assessment
• Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
S ❑ Premises Liability ❑ Statutory Appeal: Other
E
E3 Product Liability (does not include [3 Employment Dispute
Mass tort) Discrimination
C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other: ❑ Other:
I ❑ Other:
O
N MASS TORT
❑ Asbestos
B ❑ Tobacco REAL PROPERTY MISCELLANEOUS
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Updated 1/1/2011
NOTICE
Pennsylvania Rule of Civil Procedure 205.5. (Cover Sheet) provides, in part:
Rule 205.5. Cover Sheet
(a)(1) This rule shall apply to all actions governed by the rules of civil procedure except the
following:
(i) actions pursuant to the Protection from Abuse Act, Rules 1901 et seq.
(ii) actions for support, Rules 1910.1 et seq.
(iii) actions for custody, partial custody and visitation of minor children, Rules
1915.1 et seq.
(iv) actions for divorce or annulment of marriage, Rules 1920.1 et seq.
(v) actions in domestic relations generally, including paternity actions, Rules
1930.1 et seq.
(vi) voluntary mediation in custody actions, Rules 1940.1 et seq.
(2) At the commencement of any action, the party initiating the action shall complete
the cover sheet set forth in subdivision (e) and file it with the prothonotary.
(b) The prothonotary shall not accept a filing commencing an action without a
completed cover sheet.
(c)i The prothonotary shall assist a party appearing pro se in the completion of the form.
(d) A judicial district which has implemented an electronic filing system pursuant to
Rule 205.4 and has promulgated those procedures pursuant to Rule 239.9 shall be exempt from the
provisions of this rule.
(e) The Court Administrator of Pennsylvania, in conjunction with the Civil Procedural
Rules Committee, shall design and publish the cover sheet. The latest version of the form shall be
published on the website of the Administrative Office of Pennsylvania Courts at www.pacourts.us.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK /
Plaintiff No: 3 —� � 4 /r1
vs.
COMPLAINT IN CIVIL ACTION
MARGARET L BROLL
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan,47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219 C -- ) ,
(412) 434 -7955 _
FAX: 412- 338 -7130 zz
30141225 C A Pit SJS ¢-�
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
MARGARET L BROLL
Defendant
COMPLAINT AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within
twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing
with the court your defenses or objections to the claims set forth
against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or
for any other claim or relief requested by the plaintiff. You may lose
money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249 -3166
COMPLAINT
1. Plaintiff, Discover Bank, is a banking institution organized under
the laws of the State of Delaware and maintains a business address of
12 Reads Way, New Castle, DE 19720.
2. DB Servicing Corporation is the servicing affiliate for Discover
Bank, f /k /a Greenwood Trust Company, an FDIC - insured Delaware State
bank. As the servicing affiliate, DB Servicing Corporation performs a
variety of services for Discover Bank including, business management
services in support of Discover Bank business lines, including, among
other things, credit cards, deposits, personal loans and student
loans, customer service, collections, credit risk, collection of
delinquent accounts and other support services. The collection of
delinquent accounts includes the right to forward the account to the
attorneys and /or collection agencies for collection and to file suit
on Discover Bank's behalf.
3. At all times pertinent hereto, DB Servicing Corporation is the
servicing affiliate for Discover Bank, in reference to Defendant
account, which is the subject of this litigation.
4. Defendant is adult individual(s) residing at 866 CARLWYNNE MNR APT
30 CARLISLE, PA 17013
S. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX2193.
6. Defendant made use of said credit card and has a current balance
due of $15309.23. A copy of Plaintiff's STATEMENT is attached hereto,
marked as Exhibit 11
7. Defendant is in default by failing to make monthly payments when
due. As such, the entire balance is immediately due and payable to
Plaintiff.
8. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and /or refused to pay the balance due the Plaintiff.
WHEREFORE, Plaintiff prays for Judgment in its favor and against
Defendant, MARGARET L BROLL, INDIVIDUALLY, in the amount of $15309.23
with interest at the statutory rate of 6.00 o per annum from date of
judgment and costs.
William T. Mo an,47437
WELTMAN, WEINB9ERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434 -7955
FAX: 412- 338 -7130
WWR# 30141225 C A Pit SJS
This law firm is a debt collector attempting to collect this debt for
our client and any information obtained will be used for that purpose.
DISCOVER Discover More Card
Account number ending in 2193
Open Date: Apr 1, 2013- Close Date: Apr 15, 2013
Cardmember Since 1986
Page 1 of 4
ACCOUNT SUMMARY PAYMENT INFORMATION
Previous Balance $15,309.23 New Balance $ 1 5,309.23
Payments and Credits — $0.00 Minimum Payment Due * $15,309.23
Purchases + $0.00 Payment Due Date May 10, 2013
Balance Transfers + $0.00 * Includes past due amount of: $2670.00
Cash Advances + $0.00
Fees Charged + $0.00 Late Payment Warning: If we do not receive your minimum payment by the
Interest Charged + $0.00 date listed above, you may have to pay a late fee of up to $35.00 and your
New Balance $15,309.23 purchase and balance transfer APRs for new transactions may be increased up to
the Penalty APR of 26.99/o variable.
See Interest Charge Calculation section following the Minimum Payment Warning: If you make only the minimum payment each
Transactions section for detailed APR information period, you will pay more in interest and it will take you longer to pay off your
Credit Line $0 balance. For example:
Credit Line Available $0 ffyoumal:eriaoddthonalckores! Youwill.payofffhe; Ani�.youwillendvp
using 7h�s card and each rnonih balance'shown can ifvs paying nn esfimated tphtl;
Cash Advance Credit Line $0 siate?tieot th about;; of.
you: pay
Cash Advance Credit Line Available $0 Only the minimum payment 16 years $15,309
You may be able to avoid interest on Purchases. If you would like information about credit counseling services, call 1- 800 - 347 -1121.
See reverse for details.
REWARDS
Contact Us Discover.com Cashback Bonus® Anniversary Month
1- 800 - 347 -2683 August
Opening Balance $ 0.00
New Cashback Bonus This Period + $ 0.00
Redeemed This Period — $ 0.00
Cashback Bonus Balance $ 0.00
To learn more, log in at Discover.com
Make Check payable to Discover. NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
Please fold on the perforation below, detach and return with your payment.
Ptryment Coupon Pay Online Pay by Ph o ne Account number ending in 2193
Pleas? do notfold cVp or staple Dtstovercom 1 800347:2683 Minimum Payment Due $15,309.23
�I' I' I�I'' II' liil�lllillllliliilllllili�illilllllll� 'll New Balance 515,309.23
Payment Due Date May 10, 2013
MARGARET L BROLL Amount enclosed $
866 CARLWYNNE MN APT 301
CARLISLE PA 17013 -4523
PO BOX 6103
CAROL STREAM IL 60197 6
.301 44225d Internet payments must be received by 5 P ET to be credited as of the some day. Q
Address, e-mail or telephone changed? Note changes on reverse side. EXHIU ! i tj
000001986451737123936153092300039021530923
MARGARET L BROLL Account number ending in 2193 Open Date: Apr 1, 2013 - Close Date: Apr 15, 2013 Page 2 of 4
Important Information You must ensure that sufficient funds are available in your bank account, and
See your Cardmember Agreement. Your. Card member Agreement all transactions must comply with U.S. low.
contains all the terms of your Account. -
Lost or stolen cards. Report immediate) !Call 1- 800 - 347 -2683. You can set automatic payments for: (i) statement New Balance, (ii) statement
P Y Minimum Payment Due, (iii) statement Minimum Payment Due plus a fixed
What To Do If You Think You Find A Mistake On Your Statement dollar amount, or (iv) Other dollar amount. If your scheduled "Other dollar
If you think there is an error on your statement, write to us at: Discover, PO amount" payment is not enough to cover the Minimum Payment Due as listed
Box 30421, Salt Lake City, UT 84130 -0421. You must write to us within 60 on your monthly billing statement, your scheduled payment for that month
days after the error appeared on your statement. You may call us, but if you will be increased to cover the Minimum Payment Due. If the scheduled
do we are not required to investigate any potential errors, and you may have payment is greater than the Minimum Payment Due, any excess will be
to pay the amount in question. The Billing Rights Notice further explains your applied in accordance with your Cardmember Agreement. If your scheduled
rights. Please see your Card member Agreement or visit payment is greater than the New Balance on your billing statement, that
hops : / /discover.com/biIlingrights for a copy of this notice. payment will be processed only for the amount of your New Balance. Your
automatic payment amount may be less than the amount indicated on the
Payments. You may pay all or part of your Account balance at any time. billing statement based on credits or payments after the Close Date.
However, you must pay at least the Minimum Payment Due by the Payment
Due Date. Send only your ppayment and the bottom portion of this statement If you enroll by phone in our automatic payment service, please fill -in the
in the envelope provided. IJa not send cash. If you pay by check, you following blanks below and retain the authorization for your records.
authorize us to use information on your check to make an electronic fund
transfer from yyour account at the financial institution indicated on your check Amount: ❑ Full Pay ❑Min Pay ❑Min Pay+ $
or to process the payment as a check transaction. If a payment is processed
as on electronic fund transfer, the transfer will be for the amount of the ❑ Other Amount$ Bank Routing #:
check. When we use y information from your check to make an electronic fund gunk Account #
transfer, funds may be withdrawn from our account as soon as the same
day we receive your payment, and you will not receive your check back from Monthly on the ❑ Pa yment Due Date financial institution. Y y El Close Dote
The processing of your payment may be delayed if you send cash, ❑ Day of month (insert date)
correspondence or other items with your payment, if you send the payment to
any other address or if you use an envelope other than the one provided. Credit Reporting. We may report information about your Account to credit
Payments received in proper form at our processing facility by 5PM local time bureaus. Late payments, missed payments, or other defaults on your Account
on any day will be credited to your Account as of that day. Payments received may be reflected in your credit report. We normally report the status and
of our processing facility offer 5PM local time will be credited to your Account payment history of your Account to credit reporting agencies each month. If
as of the next day. If you have misplaced your envelope, send your payment you believe that our report is inaccurate or incomplete, please write us at the
to Discover, PO Box 6103, Carol Stream, IL 60197.6103. Please allow 7.10 following address: Discover, PO Box 15316, Wilmington, DE 19850 -5316.
days for delivery. If your payment is returned unpaid, we reserve the right to Please include your name, address, home telephone number and Account
resubmit it as an electronic debit. Payments made online or by phone will be number.
credited as of the day of receipt if mode by 5 PM Eastern time.
Paying Interest. Your due date is of least 25 days offer the close of each
You can pay your monthly Minimum Payment Due, or a greater amount that billing period (at least 23 days for billing periods that begin in February). We
does not exceed your current Account balance, over the telephone or you can will not charge you any interest on Purchases if you pay your entire balance
setup automatic payments through a customer service representative by by the due date each month. We will begin charging interest on Cash
calling 1- 800 - 347 -2683. Automatic payments for the billing period shown Advances and Balance Transfers as of the later of the Transaction Date or the
on your statement will be deducted on the Payment Due Dote shown on that first day of the billing period in which the transaction posted to your Account.
statement, or the next automatic payment date referred to on your statement,
unless you request a recurring payment date (e. ., the 15" day of the month) How We Calculate Interest Charges. We Use the Daily Balance Method
that occurs before your Payment Due Date or Close Date. If your scheduled (including current transactions) to calculate the Balance Subject to Interest
payment dale falls on a weekend or bank holiday, your payment will be Rate. For more information, please call us of 1- 800 - 347 -2683.
processed the business day prior to the weekend or bank holiday. In order to
schedule monthly payments by telephone, you will need this statement and Balance Subject to Interest Rate. Your statement shows a Balance Subject
your bank account information. You will be asked to provide the last four (4) to Interest Rote. It shows this for each transaction category. The Balance
digits of the social security number of the primary borrower. By providing Subject to Interest Rote is the average of the doily balances during the billing
those numbers as your electronic signature, you will be agreeing to this period.
authorization to allow us and your bank to deduct each payment you
authorize, in the amount selected by you, from your bank account. You also Credit Balances. If your Account has a credit balance, the amount is shown
authorize us to initiate debit or credit entries to your bank account, as on the front of your billing statement. A credit balance is money that is owed
applicable, to correct an error in the processing of such payment. You can to you. You may make charges against this amount if your Account is open.
cancel a scheduled payment by phone at 1- 800 - 347 -2683 or by mail at We will send you o refund of any remaining balance of $1.00 or more after
Discover, PO Box 30421, Solt Lake City, UT 84130 -0421; however, we must 6 months, or as otherwise required by applicable law, or upon request made
receive notice at least three business days in advance of the scheduled to the address in the Contact Us section on page 3 of your billing statement.
payment. If your payments may vary in amount, we will tell you on each Discover may monitor and /or record telephone calls between you and
monthly billing statement when your payment will be made and how much it Discover representatives for quality assurance purposes.
will be.
The Discover® card is issued by Discover Bank, Member FDIC. TL23N
CHANGE OF ADDRESS
If correct on front, do not use. Please print clearly in blue or black ink, in the space provided.
Street Address Home Phone
Work Phone
City Email
38 t V i 225
To make changes to your address, email or telephone number, visit Discover.com
Continued on next page
DISCOVER - Discover More Card
Account number ending in 2193
Open Date: Apr 1, 2013 - Close Date: Apr 15, 2013
Page 3 of 4
CONTACT US
0 Web Mobile O Phone ® Inquiry 0 Mail Payments
Access your � Manage your 1- 800 - DISCOVER Discover Discover
account securely account anytime, (1- 800 - 347 -2683) PO Box 30943 PO Box 6103
at Discover.com anywhere at TDD 1- 800 - 347 -7449 Salt Lake City Carol Stream
m.Discover.com UT 84130 IL 60197 -6103
Transactions
Trans. Date Post Date
Fees TOTAL FEES FOR THIS PERIOD $ 0.00
Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 0.00
2013 Totals Year -to -Date
TOTAL FEES CHARGED IN 2013 $ 105.00
TOTAL INTEREST CHARGED IN 2013 $ 855.00
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Current Billing Period: 15 days
ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO
TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE
Purchases 21.99% V $0.00 $0.00
Cash Advances 23.99% V $0.00 $0.00
V= Variable Rate
Information For You
For more information about how interest charges are calculated see your Cardmember Agreement or go to www.discover.com /interestcharges
30141225
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
_.1. MARGARET L BROLL Account number ending in 21`93 Open Date: Apr 1 .2013 - Close Date: Apr 15, 2013 Page 4 of 4
4
30141225:
VERIFICATION
(Name) (Tit
of DB Servicing Corporation, servicing affiliate of Discover Bank does hereby verify, under penalty of
perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities
states, that he /she is a duly authorized representative of plaintiff herein. Additionally, he /she verifies that
Discover Bank, f/k/a Greenwood Trust Company, which is an FDIC - insured Delaware state bank, lacks
sufficient knowledge or information to verify this complaint. He /she verifies that he /she is authorized to
make this verification. As an employee of DB Servicing Corporation, he /she has sufficient knowledge
and information to make this verification, and consequently verifies that the facts set forth in the
foregoing complaint are true and correct to the best of his/her knowledge and information and that he /she
is personally familiar with the account and the relationship between Discover Bank and DB Servicing
Corporation.
It is further stated that Discover Bank and DB Servicing Corporation extend credit through issuance of the
Discover Card. As the servicing affiliate, DB Servicing Corporation performs a variety of services for
Discover Bank, including business management services in support of Discover Bank business lines,
including, among other things, credit cards, deposits, personal loans and student loans, customer service,
collections, credit risk, collection of delinquent accounts and other support services. The collection of
delinquent accounts includes the right to forward the same to the attorneys and/or collection agencies for
collection and to file suit on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank
are wholly owned subsidiaries of Discover Financial Services.
Date �a�a �) 3
(Signature)
DB Servicing Corporation servicing affiliate
For Discover Bank
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ot cfih�be Fit ED-OHICL
r),i-'0_�H 0 K,0 T
Jody S Smith T H
Chief Deputy
-4 AV11612
VR ,130CT
Richard W Stewart 4;�AW 20
Solicitor OFfIC60FTHESPERIFF 41TY
U,UUMBERLAQ CQW�
PEfiNVLVANIA,
Discover Bank
vs. Case Number
Margaret L Broil 2013-5434
SHERIFF'S RETURN OF SERVICE
09/30/2013 11:24 AM- Deputy William Cline, being duly sworn according to law, served the requested Complaint&
Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to
wit: Margaret L Broil at 866 Carlwynne Mnr.Apt. 301, Carlisle, PA 17013.
Wilft I AM C INE, DEPUTY
SHERIFF COST: $34.78 SO ANSWERS,
October 01, 2013 RbN1V R ANDERSON, SHERIFF
(c)CountySuile Sheriff,Teleosoft,Inc,
r ,
IN THE COURT OF COMMON PLEAS 29/4JAN 2 j PM 12: 8
CUMBERLAND COUNTY, PENNSYLVANIA �3
CIVIL DIVISION CuMVERLAN D � N
NNSYLVA NIA TY
DISCOVER BANK
Plaintiff
vs . Civil Action No. 13-5434 CIVIL TERM
MARGARET L BROLL
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendant MARGARET L BROLL above
named, in the default of an Answer, in the amount of $14047 . 23 computed as
follows :
Amount claimed in Complaint $15309 . 23
Less payments / adjustments made $1262 . 00
Attorney' s fees $0 . 00
TOTAL $14047 . 23
I hereby certify that appropriate Notices of Default, as attached have
been mailed in accordance with PA R. C. P. 237 . 1 on the dates indicated on the
Notices .
WELTMAN, WEINBERGG & REIS CO. , L.P.A.
By:
William . Molcza 47437
30141225 C A Pit SJS
Plaintiff ' s address is :
c/o WELTMAN, WEINBERG & REIS CO. , L.P.A. ,
436 7th Ave Ste 1400 Pittsburgh PA 15219-1827
And that the last known address of the Defendant is :
MARGARET L BROLL
866 CARLWYNNE MNR APT 30
CARLISLE,, PA 17013
NO-
g=I)'i 39oa
j2*
�CF.�
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
Case No. 13-5434 CIVIL TERM
VS.
MARGARET L BROLL
Defendant
IMPORTANT NOTICE
TO:
MARGARET L BROLL
866 CARLWYNNE MNR APT 301
CARLISLE, PA 17013-453 I
Date of Notice: j --/7 11 �
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY
ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA. 17013
(717)249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
Matthew Urban
P.A.I.D.#90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Ave Ste 1400
Pittsburgh, PA 15219
Phone: (412)434-7955
(412) 338-7130
30141225 A PIT H4N
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs . Civil Action No. 13-5434 CIVIL TERM
NON-MILITARY AFFIDAVIT
MARGARET L BROLL
The undersigned is the duly authorized agent and/or attorney for the
Plaintiff in the within matter and states as follows :
Affiant states that the within Affidavit is made pursuant to and in
accordance with the Servicemembers ' Civil Relief Act (SCRA) , 50 U. S . C. App.
521 .
Affiant further states that based upon investigation it is the affiant ' s
belief that the Defendant, MARGARET L BROLL is not in military service.
Affiant further states that this belief is supported by the attached
certificate from the Defense Manpower Data Center (DMDC) , which states that
the DMDC does not possess any information indicating that the below
individual is in the military service:
MARGARET L BROLL
866 CARLWYNNE MNR APT 30
CARLISLE, PA 17013
Affiant further states that the averments contained herein are true and
correct to the best of Affiant ' s knowledge, information and belief and that
these averments are made subject to the penalties of 18 Pa C. S .A. Section
4904 relating to unsworn falsification to authorities .
AFFIANT
Department of Defense Manpower Data Results as of:Jan-10-20140740:47
Center
SCRA 3.0
*? ' ,,, •,?e
Status Report
Y8
Pursuant to Servicerembe s Civil Relief Act
Last Name: BROLL
First Name: MARGARET
Middle Name:
Active Duty Status As Of: Jan-10-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects the Individuals'active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Da s of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA -.NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date_
Order Notification Start Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the Individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
)410/11, YA. : 7
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
` Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c).
This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve
Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration(NOM Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1).
Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: 96TBGF9AUODAC30
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs . Civil Action No. 13-5434 CIVIL TERM
MARGARET L BROLL
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the follo ing Order of Judgment
was entered against you on ` a��‘.°‘
(xx) Assumpsit Judgment in the amount of $14047 . 23 plus costs .
( ) Trespass Judgment in the amount of $ plus costs .
( ) If not satisfied within sixty (60) days, your motor vehicle
operator' s license and/or registration will be suspended
by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration Lard
°R(Awito)09
Prothonotary
By: T.. ' �^„�,.. ..
PROTHONOTARY (OR DEPUTY)
MARGARET L BROLL
866 CARLWYNNE MNR APT 30
CARLISLE, PA 17013
Plaintiff ' s address is :
c/o WELTMAN, WEINBERG & REIS CO. , L.P.A. ,
436 7th Ave Ste 1400
Pittsburgh PA 15219-1827
(412) 434-7955
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
MARGARET L BROLL
Defendant(s)
MEMBERS 1ST FCU
M&TBANK
Garnishee(s)
TO THE PROTHONOTARY:
Civil Action No. 13-5434 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against MARGARET L BROLL , Defendant
3. against MEMBERS 1ST FCU, M & T BANK, , Garnishee
4. Judgment Amount
Less Payments/credits received
Interest
Costs
SUBTOTAL:
Costs (to be added by Prothonotary):
coAt
1b3.-7Sr, "
1(o s� " "
$ $14,047.23
$ $531.00 .4 135 t°' a3
$ $346.87
$ $13,863.10
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
pot oubil,
James P. V ecko, Esquire
PA I.D. #79 96
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
(5. Co
e)t)4 WDS .)-) itt' Lex
2.-k=k- 26V-79
WWR No. 30141225
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
MARGARET L BROLL
Defendant(s)
MEMBERS 1ST FCU
M&TBANK
Garnishee(s)
No. 13-5434 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James P. Valecko, Esquire
PA I.D. #79596
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 30141225
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite]00 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
DISCOVER BANK
Vs.
MARGARET L. BROLL
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 13-5434 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against MARGARET L. BROLL, 866 CARLWYNNE MANOR,
APT. 30, CARLISLE, PA 17013 Defendant (s)
(1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein;
(2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of
MEMBERS 1sT FCU, 1711 SPRING ROAD, CARLISLE, PA 17013 AND M&T BANK, l WEST HIGH
STREET, CARLISLE, PA 17013GARNISHEE(S), as garnishee, (Specifically describe property) and to
notify the garnishee that
(a) an attachment has been issued;
(b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the
defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof;
(c) the attachment shall not include
(i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any
funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law.
(ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed
$10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being
funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law.
(iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If
multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as
determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general
exemption provided in 42 Pa.C.S. § 8123.
1
(3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added
as a garnishee and is enjoined as above stated.
Amount Due $13,516.23
Interest $346.87
Attorney's Comm. %
Attorney Paid $184.03
Date: 6/30/14
(Sea[)
Plaintiff Paid
Law Library $.50
Due Prothonotary $2.25
Other Costs
David D. Buell, Prothonotary
Deputy
REQUESTING PARTY:
Name : JAMES P. VALECKO, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7TH AVENUE, SUITE 1400
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 79596
MAJOR EXEMPTIONS UNDER PENNSYLVANIA
AND FEDERAL LAW
1. $300 statutory exemption
2. Bibles, school books, sewing machines, uniforms and equipment
3. Most wages and unemployment compensation
4. Social Security benefits
5. Certain retirement funds and accounts
6. Certain veteran and armed forces benefits
7. Certain insurance proceeds
8. Such other exemptions as may be provided by law
2
Ronny R Anderson.
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFFICE OF 14 $HERD':=
IL 14
CUMBERLAND C w:1
PENNSYLVANIA
Discover Bank
vs.
Margaret L Broil
Case Number
2013-5434
SHERIFF'S RETURN OF SERVICE
07/09/2014 10:39 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton
Township, Carlisle, PA 17015, Cumberland County, by handing to Jan Finkle, Member Service Rep.,
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.
July 14, 2014
(c) CourtySuite Sherif', Teleosoft, Inc.
LLIAM CLINE, DEPUTY
SO ANSWERS,
RONNY R ANDERSON, SHERIFF
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
i + iruntarrfv,
OFFICE rFTN'"r E
��t,.1.-1
ass. JL . 1 -f
CUMBERLAND COU -
PENNSYLVANIA
Discover Bank
vs.
Margaret L Broil
Case Number
2013-5434
SHERIFF'S RETURN OF SERVICE
07/09/2014 02:55 PM - 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, M & T Bank, 960 Walnut Bottom Road, South Middleton Township,
Carlisle, PA 17013, Cumberland County, by handing to Nancy Leach, Teller, personally three copies of
interrogatories together with three true and attested copies of the Writ of Execution and made the contents
there of known to her.
July 11, 2014
The writ of execution and notice to defendant was mailed on July 11, 2014 to Margaret L. Broil at 866
Garlwynne Manor, Apartment 301, Carlisle, PA 17013.
() CountySuite Sheriff, Teleosoft, Inc.
LIA CLINE, DEPUTY
SO ANSWERS,
RONNY R ANDERSON, SHERIFF
t � t
'
THE Pfr O HONo TA ,
2014 JUL 28 Pt; 2: 25
CU p13ERL N0 fr�
IN THE COURT OF COMMON PLEA �� �>�) Mb COUNTY, PENNSYLVANIA
CIVIL DIVISIO�
DISCOVER BANK
Plaintiff
vs.
MARGARET L BROLL
Defendant(s)
MEMBERS 1ST FCU
M&TBANK
Garnishee(s)
Civil Action No. 13-5434 CIVIL TERM
INTERROGATORIES IN ATTACHMENT
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James P. Valecko, Esquire
PA I.D. #79596
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 30141225
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
MARGARET L BROLL
Defendant(s)
MEMBERS 1ST FCU
M&TBANK
Garnishee(s)
Civil Action No. 13-5434 CIVIL TERM
TO: MEMBERS 1ST FCU, 1711 SPRING RD, CARLISLE, PA 17013
M & T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013
RE: MARGARET L BROLL , 866 CARLWYNNE MNR APT 30, CARLISLE, PA 17013
Suggested Reference No.: XXX -XX -2495
XXX -XX -
IMPORTANT NOTICES TO GARNISHEE!
A. You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure to do so may result in Judgment against you.
B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of
Execution is issued.
C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes
into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the
resultant liability of a Garnishee -Bank would not be measured by the balance in the. debtor's account, either at the
time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited
and withdrawn during the intervening period.
WWR No. 30141225
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)?
(\
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.
2. At the time you were served or at any subsequent time was there in your possession, custody or
control of yourself and one or more other persons any property of any nature owned solely or in part by the
defendant.
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or part by the defendant or in which defendant held or claimed any interest?
N\c4
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?
�\P
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?
6. At any time after you were served did you pay, transfer, or deliver any money or property to the
defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant
against you?
7. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which funds are deposited electronically on a
recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or
attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption,
the amount being withheld under each exemption and the amount of funds in each account, and the entity
electronically depositing those funds on a recurring basis.
No
WWR No. 30141225
8. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which the funds on deposit, not including any
otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each account.
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
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.
C\�
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?
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James P. Nalecko, Esquire
PA I.D. #79596
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 30141225
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
L.
(Title)
Lor,RiE MASKA
M8,1041110e)
(Company)
, garnishee herein,
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.
Jul 2 3 2014
ovicAA \JCI(r---
(SIGNATURE)
WWR No. 30141225
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAPEWED
CIVIL DIVISION
JUL 1 1 2014
DISCOVER BANK
Plaintiff
vs.
Civil Action No. 13-5434 CIVIL TERM
MARGARET L BROLL
Defendant(s) -0=
MEMBERS 1ST FCU �,
z�
M&TBANK ��
Garnishee(s) <c)
D c)
Y c5
TO: MEMBERS 1ST FCU, 1711 SPRING RD, CARLISLE, PA 17013
M & T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013
RE: MARGARET L BROLL , 866 CARLWYNNE MNR APT 30, CARLISLE, PA 17013
Suggested Reference No.: XXX -XX -2495
XXX -XX -
IMPORTANT NOTICES TO GARNISHEE!
A. You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure to do so may result in Judgment against you.
B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of
Execution is issued.
C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes
into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the
resultant liability of a Garnishee -Bank would not be measured by the balance in the debtor's account, either at the
time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited
and withdrawn during the intervening period.
WWR No. 30141225
-k8ldsec.9. Va
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 hiiR
or were liable to him for any reason (including funds on deposit for checking or savings accounts and certifica of
deposit)? f10 JUL 112014
1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof;
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe or owed to him; and the nature and amount of each of such liabilities.
nlcx-
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. 30141225
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.
$ 3. 9-7 clx,c1(
fl
RECEIVED
JUL 1 1 2014
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
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. No_
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.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James P. Malecko, Esquire
PA I.D. #79596
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 30141225
VERIFICATION RECEIVED
JUL 1 I 20N
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is
(Name)
MC.‘mcnef— of Mfirbes-s 15*-• , 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.
WWR No. 30141225
INTERROGATORIES LN 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 hill
or were liable to him for any reason (including funds on deposit for checking or savings accounts and certifica e §[
JULdeposit)? [.�� v� � 1 2014
. ��
1 a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof;
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claim,ed that you owe or owed to him; and the nature and amount of each of such liabilities.
[l\6-
' ,|
2. At the time you were served or at any subsequent time was there in your possession, custody or
control of yourself and one or more other persons any property of any nature owned solely or in part by the
defendant. ()/~)
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or part by the defendant or in which defendant held or claimed any interest?
[\�
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?
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.
W\VRNo, 3Ul4\225
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.
.531deckr
RECEIVED
JUL 1 1 2014
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
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. No.
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?
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: ✓
James P. alecko, Esquire
PA I.D. #79596
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 30141225
VERIFICATION
RECEIVED
JUL 2014
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is
(Name)
70_ inC.ine.0 of JJ , 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 ofhis/her knowledge, information and belief.
WWR No. 30141225
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 hit,/u.�11'
or were liable to him for any reason (including funds on deposit for checking or savings accounts and certifies e'f
deposit)?
2014
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 writ -ten
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.
{116-
2. At the time you were served or at any subsequent time was there in your possession, custody or
control of yourself and one or more other persons any property of any nature owned solely or in part by the
defendant.
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or part by the defendant or in which defendant held or claimed any interest?
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. 30141225
VERIFICATION
RECEIVED
JUL 1 1 2014
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is
(Name)
JQ C .---)CAThoy.r.-- of MciThnber , 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.
WWR No. 30141225
INTERROGATORIES IN ATTACHMENT
| 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 hitin,7.4, or
deposit)?or were liable to him for any reason (including funds on deposit for
- savings
JUL/-\~� °� � � �0&y
. �� -~"r
|u. lfthe answer toInterrogatory 1 is in the afflrmative, state the foliowing: 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.
2. At the time you were served or at any subsequent time was there in your possession, or
control of yourself and one or more other persons any property of any nature owned solely or in part by the
defendant. r\r-�
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?
/�/�~
�
� `
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. lf 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 )an? 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. [-10
WWR No. 30141225
8.. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which the funds on deposit, not including any
otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each account.
'� ��`U-7
- --� ' '
RIECEIvEt
JUL 1 1 2014
9. \[ the answer 0V Interrogatory 1 is in the affirmative, state the date the sher[7ncrvcd these
interrogatories on this institution.
\
10. lfthe answer toInterrogatory l is in the affirmative, state the date the written instrument, checking
or savings account, certiflcate ofdeposit, or other funds were frozen, restricted, or otherwise put on hold by this
institution. F\\
\|. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account
which are not deposited electronically onurecurring basis and which are idenhficdumbeing funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law?
n_
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James P. alecko, Esquire
PA /.//. 1//959n
\9ELTMAN`WEINBERG8iBElSCO.,l..P./\.
436 7th Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 30141225
VERIFICATION
RECEIVED
JUL 1 1 2014
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 fr)t,)1•:,-_,c_t
(Name)
0[7'7 inCAThc-nef- of Mcsib&& 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.
WWR No. 30141225
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: James P Valecko, Esquire Attorney for Plaintiff(s)
I.D. No. 79596
436 Seventh Avenue, Suite 2500
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 30141225
DISCOVER BANK
Cumberland County
Court of Common Pleas
vs.
MARGARET L BROLL
NO. 13-5434 CIVIL !ERM
and
M&T BANK AND MEMBERS 1ST FCU
Garnishee(s)
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
CD
TO THE PROTHONOTARY:
Kindly mark the above matter discontinued and ended as to Garnishee(s), M&T BANK AND
MEMBERS 1ST FCU, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
James P alecko, Esquire
Attorney for Plaintiff
""*T1
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