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Home My WebLink About13-5435 i Supreme Courtio Pennsylvania ". # 30159918 C A Pit SJS Cou if Commo,n'"Beas vi1 Cover,Sheet FarProDronotan'Use Orrt�: CUMBERLAND'. C011rity Docket No. Q O The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or otherpapers as required by low or rules of court. Commencement of Action: S a Complaint ❑ Writ of Summons ❑ Petition E Transfer from Another Jurisdiction Declaration of Taking DISCOVER BANK C Lead Plaintiff s Name: Lead Defendant's Name: T MARGARET L BROLL I O Are money damages requested? El Yes ❑ No Dollar Amount Requested: ® within arbitration limits N (check one) ❑outside arbitration limits A Is this a Class Action Suit? 13 Yes 19 No Is this an MDJ Appeal? 13 Yes Ed 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 fl-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: ❑ Other: N MASS TORT ❑ Asbestos B ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-DES ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Toxic Tort—Implant ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Toxic Waste ❑ Ground Rent ❑ Mandamus ❑ Other: ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure: Residential Retraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Waranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: Updated 1/1/2411 t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 13- 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 (412) 434 -7955 FAX: 412- 338 -7130 c? 30159918 C A Pit SJS C= C= M� cn C 4 C.., c) x3. -5 y e t /// j . 7 �� g s 7�s rr 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 XXXXXXXXXXXX2553. 6. Defendant made use of said credit card and has a current balance due of $15113.25. 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 $15113.25 with interest at the statutory rate of 6.00 o per annum from date of judgment and costs. William T. olc n,47437 WELTMAN, WEINB n G & REIS CO., L.P.A. 436 Seventh Av ue, Suite 1400 Pittsburgh, PA 15219 (412) 434 -7955 FAX: 412- 338 -7130 WWR# 30159918 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. DISC VER` Discover. More Card Account number ending in 2553 Open Date: May 1, 2013- Close Date: May 22, 2013 Cardmember Since 2000 Page 1 of 4 ACCOUNT SUMMARY PAYMENT INFORMATION Previous Balance $15,113.25 New Balance $15,1 13.25 Payments and Credits — $0.00 Minimum Payment Due * $15,113.25 Purchases + $0.00 Payment Due Date June 17, 2013 Balance Transfers + $0.00 * Includes past due amount of: $2640.00 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 $15,113.25 purchase and balance transfer APRs for new transactions may be increased up to the Penalty APR of 21.99% 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 l�youtnakenti;addtf!dnalcharg` - 'You will pay offtlie Ani�youw +ilendup using this card and each month balance shown -an fats paying an estimated total Cash Advance Credit Line $0 yP°y 'StatePneraY;tn abauf.:r, af. - Cash Advance Credit Line Available $0 Only the minimum payment 16 years $15,113 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. Payment Coupon C►nline Pay b Phone Account number ending in 2553 Please do not fold, clip or staple �I f�iscover.aom 1 $00 3d7'i683 Minimum Payment Due $15,113.25 New Balance $15,113.25 Payment Due Date June 17, 2013 MARGARET L BROLL Amount enclosed 866 CARLWYNNE MNR APT 301 $ CARLISLE PA 17013 -4523 PO BOX 6103 p CAROL-STREAM IL 60197 -6103 301 SWA Iniemei payrnents'must be received by 5PM ET to be credited as of the same day. Address, e-mail or telephone changed? Note changes on reverse side. 000001986458385720079151132500095241511325 GAHIBR MARGARET L BROLL Account number ending in 2553 Open Date: May 1 2013 - Close Date: May 22 2013 Page 2 of 4 Important Information You must ensure that sufficient funds are available in your bank account, and all transactions must comply with U.S. law. See your Cardmember Agreement. Your CardmemberAgreement contains all the terms of your Account. You can set automatic payments for: (i) statement New Balance, (ii) statement Minimum Payment Due, (iii) statement Minimum Payment Due plus a fixed Lost or stolen cards. Report immediately! Call 1- 800 - 347 -2683. dollar amount, or (iv) Other dollar amount. If your scheduled "Other dollar What To Do If You Think You Find A Mistake On Your Statement amount" payment is not enough to cover the Minimum Payment Due as listed If you think there is an error on your statement, write to us at: Discover, PO on your monthly billing statement, your scheduled payment for that month Box 30421, Salt Lake City, UT 84130-042 1. You must write to us within 60 will be increased to cover the Minimum Payment Due. If the scheduled days after the error appeared on your statement. You may call us, but if you payment is greater than the Minimum Payment Due, any excess will be do we are not required to investigate any potential errors, and you may have applied in accordance with your Cardmember Agreement. If your scheduled to pay the amount in question. The Billing Rights Notice further explains your payment is greater than the New Balance on your billing statement, that rights. Please see your Card member Agreement or visit payment will be processed only for the amount of your New Balance. Your https:Hdiscover.com /billingrights for a copy of this notice. automatic payment amount may be less than the amount indicated on the billing statement based on credits or payments after the Close Date. Payments. You may pay all or part of your Account balance at anytime. If you enroll by phone in our automatic payment service, please fill -in the However, you must pay at least the Minimum Payment Due by the Payment followin blanks below and retain the authorization for Due Date. Send only, yyour ppayment and the bottom portion of this statement 9 your records. in the envelope provided. Do not send cash. If you pay by check, you []Full Pa $ authorize us o use information on your check to make an electronic fund Amount: y L1 Min Pay Min Pa y + transfer from yy Other our account at the financial institution indicated on your check 0 Oth Amount$ Bask Routing #: or to process the payment as a check transaction. If a payment is processed g as an electronic fund transfer, the transfer will be for the amount of the Bank Account # check. When we use information from your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same Monthly on the 0 Payment Due Date 0 Close Date day we receive your payment, and you will not receive your check back from your financial institution. 11 Day of month (insert date) The processing of your payment may be delayed if you send cash, Credit Reporting. We may report information about your Account to credit correspondence or other items with your payment, if you send the payment to bureaus. Late payments, missed payments, or other defaults on your Account any other address or if you use an envelope other than the one provided. may be reflected in your credit report. We normally report the status and Payments received in proper form at our processing facility by 5PM local time payment history of your Account to credit reporting agencies each month. If on any day will be credited to your Account as of that day. Payments received you believe that our report is inaccurate or incomplete, please write us at the at our processing facility after 5PM local time will be credited to your Account following address: Discover, PO Box 15316, Wilmington, DE 19850 -5316. as of the next day. If you have misplaced your envelope, send your payment Please include your name, address, home telephone number and Account to Discover, PO Box 6103, Carol Stream, IL 60197.6103. Please allow 7.10 number. days for delivery. If your payment is returned unpaid, we reserve the right to resubmit it as an electronic debit. Payments made online or by phone will be Paying Interest. Your due date is at least 25 days after the close of each credited as of the day of receipt if made by 5 PM Eastern time. billing period (at least 23 days for billing periods that begin in February). We You can pay your monthly Minimum Payment Due, or a greater amount that will not charge you any interest on Purchases if you pay your entire balance does not exceed your current Account balance, over the telephone or you can by the due date each month. We will begin charging interest on Cash setup automatic payments through a customer service representative by Advances and Balance Transfers as of the later of the Transaction Date or the calling 1- 800 - 347 -26B3. Automatic payments for the billing period shown first day of the billing period in which the transaction posted to your Account. on your statement will be deducted on the Payment Due Date shown on that How We Calculate Interest Charges. We Use the Daily Balance Method statement, or the next automatic payment date referred to on your statement, unless you request a recurring payment date (e.g., the 15" day of the month) (including current transactions) to calculate the Balance Subject to Interest that occurs before your Payment Due Date or Close Date. If your scheduled Rate. For more information, please call us at 1- 800 - 347 -2683. payment date falls on a weekend or bank holiday, your payment will be Balance Subject to Interest Rate. Your statement shows a Balance Subject processed the business day prior to the weekend or bank holiday. In order to to Interest Rate. It shows this for each transaction category. The Balance schedule monthly payments by telephone, you will need this statement and Subject st Interest Rate is the average of the daily balances during the billing your bank account information. You will be asked to provide the last four (4) digits of the social security number of the primary borrower. By providing period. those numbers as your electronic signature, you will be agreeing to this authorization h allow us and your bank Credit Balances. If your Account has a credit balance, the amount is shown , f on the front of your billing statement. A credit balance is money that is owed deduct each payment you authorize, s the amount selected di you, from your bank account. You also to you. You may make charges against this amount if your Account is open. authorize us to initiate debit or credit entries to your bank account, as W will send you a refund of any remaining balance of $1.00 or more after applicable, to correct an error in the processing of such payment. You can b months, or as otherwise required by applicable low, or upon request made cancel a scheduled payment by phone at LIT or mail at to the address in the Contact Us section on page 3 of your billing statement. Discover, PO Box 30 Salt Lake City, 844130 -130 - 04421; 21; however, must Discover may monitor and /or record telephone calls between you and payment. If your payments may vary in amount, we willl l cell you on each receive notice at least t three business days in n advance the scheduled ed d Discover representatives for quality assurance purposes. monthly billing statement when your payment will be made and how much if will be. The Discovery card is issued b y 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 Ai t tvi §18 To make changes to your address, email or telephone number, visit Discover.com Continued on next page D�SC�VER � .:. Discover More Card Account number ending in 2553 Open Date: May 1, 2013 - Close Date: May 22, 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 $ 140.00 TOTAL INTEREST CHARGED IN 2013 $ 1,144.68 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Current Billing Period: 22 days ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE Purchases 16.99% 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 /interesicharges 30159918 - - NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION MARGARET L BROLL Accourit number ending in 2553 Open Date: May 1, 2013 - Close Date: May 22, 2013 Page 4 of 4 30159918 - e � Y � N VERIFICATION Lt 'O 41' (Name) (Titl 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 . Z 2 013 XQ qlaa!ure) DB Servicing Corporation servicing affiliate For Discover Bank SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff tt '; r n_ i f i. I G L i]P� Jody S Smith ``��'�t trdraM�rr� Chief Deputy 2013 0CT —4 AK 10: 1 Richard W Stewart r$��Sf � A 11` T`' Solicitor OFFICE OF THE S"ER'�'" P Eh1 iq S Y LV/',M A Discover Bank vs. Case Number Margaret L Broll 2013-5435 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 b the Defendant, to wit: Margaret L Broll at 866 Carlwynne Mnr.Apt. 301, Carlisle, PA 17013. LIAM INE, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, October 01, 2013 RbNN'tY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft.Inc. _ bs' M IN THE CUMBERLAND O OUNTTY, CPENNSYLVANIA ,�� 2: j CIVIL DIVISION �Up�HwS�Y�d�`J �OUf1Ty 9 DISCOVER BANK LV�N1A Plaintiff vs . Civil Action No. 13-5435 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 $15113 . 25 computed as follows : Amount claimed in Complaint $15113 . 25 Less payments / adjustments made $0 . 00 Attorney' s fees $0 . 00 TOTAL $15113 . 25 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R. C.P. 237 . 1 on the dates indicated on the Notices . WELTMAN, WEINBERG & REIS CO. , L.P.A. By: �/ William . Molcz , 47437 30159918 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 (9 . °PCI 6115 (' ILA 11434 M "!ecI IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff CASE#: 13-5435 MARGARET L BROLL Defendant IMPORTANT NOTICE TO: Margaret L Broil 866 Carlwynne Mnr Apt 301 Carlisle, Pa 17013 Date of Notice: I/,) P i WWR#:30 1 59918 I 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717)249-3166 WELTMAN, WEINBERG& REIS CO., L.P.A. By: MATTHEW D. URBAN, ESQUIRE PA I.D.#90963 WELTMAN WEINBERG& REIS CO., L.P.A 1400 KOPPERS BLDG,436 7TH AVE. PITTSBURGH,PA 15219 (412)434-7955 WWR#30159918 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs . Civil Action No. 13-5435 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-03-2014 08:3943 • Center SCRA 3.0 ! F Status Report Pursuant to Serviceneffibers Civil.Relief Act Last Name: BROLL First Name: MARGARET Middle Name: Active Duty Status As Of: Jan-03-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duy 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. 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(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: S64619E7C0D7C20 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs . Civil Action No. 13-5435 CIVIL TERM MARGARET L BROLL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order of Judgment was entered against you on ( 13I14{ (xx) Assumpsit Judgment in the amount of $15113 . 25 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 ward ::oth0fota ry . 0 PROTHO NOTAR 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 '," Olt Pi ?C1 7 HQa ' �'C9��iC1 TA r `r 201411A R 3 I PH rr : 12 CUMBERLAND RLAt D COL TY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 13 -5435 CIVIL TERM vs. PRAECIPE FOR WRIT OF EXECUTION , (BANK ONLY) MARGARET L BROLL ?Lois Co o IL 111e. (limp�Ar ( tt "see ' of 3 Defendant(s) W . I'1%i/1 CAAisle, Po Oor ? M &TBANK — 11 O ruler Pi4l-W3 MEMBERS 1ST FCU I'7 ! j �rt h5 a Garnishee(s) C) 01AL CXD -?ek atLie. �IIt (1 7lt 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 So LL Lt4119y8a19 (4+- 363 16D- No. ba WWR No. 30159918 � k�ss� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MARGARET L BROLL Defendant(s) M & T BANK MEMBERS 1ST FCU Gam shee(s) TO THE PROTHONOTARY: Civil Action No. 13-5435 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 M & T BANK, MEMBERS 1ST FCU, Garnishee 4. Judgment Amount $15,113.25 Less Payments/credits received $0.00 Interest $173.91 Costs SUBTOTAL: $15,287.16 Costs (to be added by Prothonotary): WELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. V ecko, 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. 30159918 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 • (717) 240 -6195 www.ccpa.net DISCOVER BANK Vs. MARGARET L. BROLL WRIT OF EXECUTION (Pa R.C.P. 3252) NO 13 -5435 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 GARNISHEE(S), as garnishee, 1711 SPRING ROAD, CARLISLE, PA 17013 (Specifically describe property) and to notify the garnishee that M &T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 (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 $15,113.25 Plaintiff Paid Interest $173.91 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Other Costs Attorney Paid $184.03 Date: 3/31/14 104-1_6cLI Paz-a David D. Buell, Prothonotary REQUESTING PARTY: Name : JAMES P. VALECKO, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7TH AVENUE, SUITE 1400 PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412 - 434 -7955 Supreme Court ID No. 79596 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 r xs FOTHONOrI\' 20111 APR 11 PM 2= 05 OU 1 E RL l O COUNT Y F±pSYL`�AtdlA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RECEIVED APR 0 7 2014 DISCOVER BANK Plaintiff vs. MARGARET L BROLL Defendant(s) M &TBANK MEMBERS 1ST FCU Garnishee(s) Civil Action No. 13 -5435 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. 30159918 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA /VC env) CIVIL DIVISION APR DISCOVER BANK Plaintiff vs. MARGARET L BROLL Defendant(s) M &TBANK MEMBERS 1ST FCU Garnishee(s) Civil Action No. 13 -5435 CIVIL TERM TO: M & T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013 MEMBERS 1ST FCU, 1711 SPRING RD, 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! 07 2014 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. 30159918 RECEIVED APR 07 2014 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)? "S 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 wed to him; and the nature and amount of each of such liabilities. S dtprogf I I cer fi caa� 6. �1 �� ,�S \nauid� ihz, 4360 plc . `D,o ��c1ca ()J- 2. At the time you were served or at any subsequen 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? ou 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. WWR No. 30159918 RECEIVED APR 07 2014 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. no 9. If the answer to Interrogatory l is in the affirmative, state the date the sheriff served these interrogatories on this institution. ��I a ,201U 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. two 4,7,0q 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 ' V 1, ecko, Esquire PA I.D. #7''596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434 -7955 W WR No. 30159918 RECEIVED APR 0 7 2014 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 sess ctLxo ayp D las na1Ls- JCfy3ZV( ( � � of l � , garnishee herein, itle) (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. 30159918 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY t OFF iCE n FF rTiE PROTHC}.i , ZGRI APR -9 AM 9:-55 CUMBERLAND COUNTY PENNSYLVANIA Discover Bank vs. Margaret L Broil Case Number 2013-5435 SHERIFF'S RETURN OF SERVICE 04/04/2014 09:37 AM - Dawn Kell, 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 Lottie Loe, Head 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. CILA,11. DAWN KELL, DEPUTY SO ANSWERS, April 07, 2014 RON6 R ANDERSON, SHERIFF (c) CounzySuito SherT, Te]cosoft, Ronny RAnderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY "L1& APR ~q �M n�5� - -. ~ �° CHMPER/AQD[OUI-IT\ PENNSYLVANIA Discover Bank vs. Margaret L Broil Case Number SHERIFF'S RETURN OF SERVICE 04804/2014 10:34 AM - Dawn Kell, 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, 100 South Spring Garden Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Tana Emery, Vice President, 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 Apri 7, 2014 to Margaret L. Broil at 866 Carlwynne Manor, Apt. 30, Carlisle, PA 17013. April 07, 2014 (c) CountySuitc, Sheriff, Tolecsoft, Inc. SO ANSWERS, RON R ANDERSON, SHERIFF Mkr(aL411t 14 APR 67 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MARGARET L BROLL Defendant(s) M &TBANK MEMBERS 1ST FCU Garnishee(s) Civil Action No. 13 -5435 CIVIL TERM A inn dect ArStAkt( S INTERROGATORIES IN ATTACHMENT FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & 436 7"' Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 7r-vr (7) REIS C0.41,.P. 4 WWR No. 30159918 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MARGARET L BROLL Defendant(s) M&TBANK MEMBERS 1ST FCU Garnishee(s) Civil Action No. 13-5435 CIVIL TERM TO: M & T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013 MEMBERS 1ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 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. 30159918 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)? S 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`` 00D .0 (4 S(k.V IRA cer , ccurc 15-P 0 -c c L is \ictxc is -� I i t C? , oa — 0-0 t d 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. nn 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. WWR No. 30159918 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. Po 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. apnA U ,ZuiU 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. ft,QV] , rW� 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? YUL 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 IV ecko, Esquire PA I.D. #7 596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434 -7955 WWR No. 30159918 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 isOf SS) (k a t) (Na e) ttp J os ,eel cr of JVCfl]9°fr'K 1 Si- , garnishee herein, (Company) R V 1 20f4 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. 30159918 • • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MARGARET L BROLL Defendant(s) M &TBANK MEMBERS 1ST FCU Garnishees) Civil Action No. 13 -5435 CIVIL TERM C) TO: M & T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013 MEMBERS 1ST FCU, 1711 SPRING RD, CARLISLE, PA 17013 RE: MARGARET L BROLL , 866 CARLWYNNE MNR APT 30, CARLISLE, PA 17013 Suggested Reference No.: XXX -XX -2495 XXX -XX- GJ)S,j°rs 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. 30159918 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)? M & T BANK HAS NO OPEN ACCOUNTS FOR ABOVE NAMED 1a. 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? 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? 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. WWR No. 30159918 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 (Title) (Name) of ` _ e, t‘'K , garnishee herein, (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. APR 242014 (SIG CATHY S FISHER M &T BANK WWR No. 30159918 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. 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. PPc WELTMAN, WEINBERG & REIS CO., L.P.A. By: James V ecko, Esquire PA I.D. #7'596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 30159918 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MARGARET L BROLL Defendant MEMBERS 1ST FCU Garnishee Civil Action No. 13-5435 CIVIL TERM PRAECIPE FOR JUDGMENT AGAINST GARNISHEE C) rn rn cn -- r— > C) TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, MEMBERS 1ST FCU, in the amount of $1,437.41, which is less than the amount 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. Molczan Es re PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#30159918 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: 5000 Louise Drive, P.O. Box 40, Mechanicsburg, PA 17055 et ISAP] JVba'd1� -#1 s st-t a/c. GMtrtaL41 App. h. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MARGARET L BROLL Defendant(s) M&TBANK MEMBERS 1ST FCU Garnishee(s) Civil Action No. 13-5435 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 ) v --a (412) 434-7955 WWR No. 30159918 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MARGARET L BROLL Defendant(s) M&TBANK MEMBERS 1ST FCU Garnishee(s) Civil Action No. 13-5435 CIVIL TERM TO: M & T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013 MEMBERS 1ST FCU, 1711 SPRING RD, 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. 301 9918 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 him any money or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of deposit)? S 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.`` OOD . A4 Sa.0�n IRA certi-fi coc,°6 , �1 '1 11 C1LWA - tS \ir1C C��s -� 3 0-06 ctctyiu-i 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. nn 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? n� 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? A1C 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. WWR No. 30159918 1 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. 110 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. (LonA :te iu 10. If the answer to Interrogatory I 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. RP() , 7/13 I 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. 'QL WELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. Va4.ecko, Esquire PA I.D. #791596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 \VWR No. 30159918 ,‘L 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 Niops AIVOUS4 tle) S) UJ q171 (Name) fn-Q'c I S'r , garnishee herein, (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. Vs/WR No. 30159918 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MARGARET L BROLL Defendant MEMBERS 1ST FCU Garnishee Members 1st FCU 5000 Louise Drive P.O. Box 40 Mechanicsburg, PA 17055 Civil Action No. 13-5435 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff ( ) Defendant (xx) Garnishee You are hereby notified that the following Order or Jud m nt was entered against you on S Assumpsit Judgment in the amount of $1,437.41 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 ova - By: ,�... . PROTHONOTARY (OR DEPUTY) WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James P Valecko, Esquire Attorney for Plaintiff(s) I.D. No. 79596 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 30159918 LEE OF OF THE PROTHONOTAfVf 20114MAY tZ PM 3:214 CUMBERLAND COUNTY PENNSYLVANIA DISCOVER BANK Cumberland County Court of Common Pleas vs. MARGARET L BROLL and M & T BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION NO. 13-5435 CIVIL TERM TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), M & T BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By James PjValecko, Esquire Attornev for Plaintiff 5sqls-7/ /27% 3 os76Y WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James P Valecko Esquire Attorney for Plaintiff(s) I.D. No.79596 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 30159918 il-('% PRO THONO 2 r1tY CBERL A NO COU ,46 2 7 41111: 03 PENNS YL VA NIAtd T' DISCOVER BANK Cumberland County Court of Common Pleas vs. MARGARET L BROLL and MEMBERS 1ST FCU Garnishee(s) PRAECIPE TO SATISFY ATTACHMENT EXECUTION NO. 13-5435 CIVIL TERM TO THE PROTHONOTARY: Kindly marked the above matter satisfied as to Garnishee(s), MEMBERS 1ST FCU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By JamesPalcko, Esquire Attorney fo Plaintiff wIl;.-q.soyd aa Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OP -P ,n,F rfa F; $r;RR: NN'.. 47,1 ,,;�� 1 Iii .7 I ERLAND CIJUN PENNS`t L P N!A Discover Bank vs. Margaret L Broil Case Number 2013-5435 SHERIFF'S RETURN OF SERVICE 04/04/2014 09:37 AM - Dawn Kell, 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 Lottie Loe, Head 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. 04/04/2014 10:34 AM - Dawn Kell, 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, 100 South Spring Garden Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Tana Emery, Vice President, 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 April 7, 2014 to Margaret L. Broil at 866 Carlwynne Manor, Apt. 30, Carlisle, PA 17013. 01/08/2015 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. However, plaintiffs attorney did file a praecipe for judgment against garnishee Members 1st Federal Credit Union for $ 1,437.41. SHERIFF COST: $171.54 SO ANSWERS, January 08, 2015 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoff, (nc. s.� THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net DISCOVER BANK Vs. MARGARET L. BROLL WRIT OF EXECUTION (Pa R.C.P. 3252) NO 13-5435 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 G'ARNISHEE(S), as garnishee, 1711 SPRING ROAD, CARLISLE, PA 17013 (Specifically describe property) and to notify the garnishee that M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 (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 $15,113.25 Plaintiff Paid Interest $173.91 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Other Costs Attorney Paid $184.03 Date: 3/31/14 (Sea f) David D. Buell, Prothonotary REQUESTING PARTY: Name : JAMES P. VALECKO, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7TH AVENUE, SUITE 1400 PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 79596 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the eal of said Court at Carlisle, Pa. This 6) day of_ Qr , 0 Iy prothonotary ,. a, `?V' 2