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HomeMy WebLinkAbout13-5826 a Supreme C ,,,, o �� t o Te,nnsvlvania WWR0 30179385 C A Pit SJS Cour of Common:heas �bN For Pmthowta Use On l y : f Civil'Go�er,Sheet n' �' C UMBERLANI7:.�_ ,:.� County Docket No The information collected on This form is used solely for court ad ministration purposes. This form does not supplement or replace the filing and service of'pleadings or other papers as required b lain or rules of court. Commencement of Action: S E3 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 SHELLEY A GEORGE 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? ❑ Yes IR No Is this an MDJ Appeal? 13 Yes Q No Name of Plaintiff /Appellant's Attorney: William T. Molczan 47437 ❑ Check here if you have no attorney (are a Self - Represented {Pro Se] 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 `r 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 13 Employment Dispute Mass tort) Discrimination C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other: ❑ Other: I 13 Other: O 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 1/1/2.011 I~ ILEFU-0 i ICE J 01 THE PROTHONOTAR A �1 7013 OCT -1 PM 2: 04 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK ¢¢ Plaintiff No: 13- 50a vs. COMPLAINT IN CIVIL ACTION SHELLEY A GEORGE Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan,47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh PA 15219 -1827 (412) 434 -7955 FAX: 412- 338 -7130 30179385 C A Pit SJS a 0, U 1 9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No SHELLEY A GEORGE 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 1160 REDWOOD DR CARLISLE, PA 17013 S. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX0364. 6. Defendant made use of said credit card and has a current balance due of $12743.14. A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1 ". 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, SHELLEY A GEORGE, INDIVIUDALLY, in the amount of $12743.14 with interest at the statutory rate of 6.00 o per annum from date of judgment and costs. William T. Mo cza ,47437 WELTMAN, WEINBER REIS CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh PA 15219 -1827 (412) 434 -7955 FAX: 412- 338 -7130 WWR# 30179385 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. OEM DISCO Discover More Card Account number ending in 0364 Open Date: Apr 23, 2013- Close Date: May 22, 2013 Cardmember Since 2002 Page 1 of 4 ACCOUNT SUMMARY PAYMENT INFORMATION Previous Balance $12,743.14 New Balance $12 Payments and Credits – $0.00 Minimum Payment Due * $12,743.14 Purchases + $0.00 Payment Due Date June 17, 2013 .Balance Transfers + $0.00 Includes past due amount of: $2823.00 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 $12,743.14 purchase and balance transfer APRs for new transactions may be increased up to the Penalty APR of 26.24/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 ;IFmt�ti�? ���ingntcl�fir�es' YouvIl pyoFFthe AnylcwyrdlenZJ'up` r vstri t#tls cord: and each at onih fsalate sftown art F pay�g a!t estuvtafecf iota1 4 Cash Advance Credit Line $0 I j t ' rynr f yta►etnenFun o o-' 4 crf t Cash Advance Credit Line Available $0 — Only the minimum a ment 1 15 years 1 $12,743 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 April Opening Balance S 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. Pcymen#O�pan� �S�j►�MIIl1 @f� if �!� P}lone Account number ending in 0364 Tease cfo nbt fbld i or.sta e ✓ , r , ..., ...,T,.Dtsover;corrt 1' 800 34 26$3 Minimum Payment Due $12,743.14 Iillinillliiliuiilllluliilllliillt111111 'lllllll!I'I "1'11111 New Balance $12,743.14 Payment Due Date June 17, 2013 SHELLEY A GEORGE Amount enclosed $ 1 160 REDWOOD DR CARLISLE PA 1 701 3 -1 378 PO BOX 6103 CAROL STREAM IL 60197 -6103 301783afi Intemet payments must be received by 5PM ET to be credited as of the some day. "IIIIIIIII'II' 1111 ' "III "'I Address, e-mail or telephone changed? Note changes on reverse side. WiBff 000001986458917292613127431400424391274314 SFIELLEY A GEORGE Account number ending in 0364 Open Date: Apr 23, 2013 - Close Date: May 22 2013 Page 2 of 4 Important Information You must ensure that sufficient funds ore available in your bank account, and See your Cardmember Agreement. Your Cordmember Agreement all transactions must comply with U.S. low. 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! Coll 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, Solt Lake City, UT 84130 -0421. 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 ore not required to investigate any potential errors, and you may hove applied in accordance with your Cordmember 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 : / /discover.com /billing rights 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 oil or part of your Account balancg of on time. 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 Du Date. Send only, our ayment and the bottom portion of this statement g blanks below and retain the authorization for your records. in f�e envelope provi o d. 8o not send cash. If you p by heck, y Amount: ❑Full Pa oulhoriz@ us o use in ormation on your check to make an a edrornc fund y _ 0 Min Pay OMin Pay+ $ transfer trom t your account at the financial institution indicated on your check Other At$ ;Bank Routing #: or to process he payment pp s a check tr9nsadion. If o payment is processed moun 8 as on electronic fund ironster, 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 some Monthly on the ❑ Payment Due Date ❑ Close Dote day we receive your payment, and you will not receive your check bock from your financial institution. 0 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 mode 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 con 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 -2683. 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 statement, or the next automatic payment date referred to on your statement, How We Calculate Interest Charges. We Use the Daily Balance Method 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 o Balance Sub processed the business day prior to the weekend or bank holiday. In order to Subject schedule monthly payments by telephone, you will need this statement and to Interest Rate. It shows this for each transaction category. The Balance your bank account information. You will be asked to provide the last four (4) Subject to Interest Rate is the overage of the daily balances during the billing digits of the social security number of the primary borrower. By providing period. those numbers as your electronic si8nature, you will be agreeing to this authorization to allow us and your ank to deduct each payment you Credit Balances. If your Account has a credit balance, the amount is shown b authorize, in the amount selected by you, from your bank account. You also on the front of your billing statement. A credit balance is money that is owed authorize us to initiate debit or credit entries to your bank account, as to you. You may make charges against this amount if your Account is open. applicable, to correct an error in the processing of such payment. You can We will send you a refund of any remaining balance of $1.00 or more after cancel a scheduled payment by phone at 1- 800 - 347 -2683 or by mail at 6 months, or as otherwise required by applicable low, or upon request made Discover, PO Box 30421, Salt Lake City, UT 84130 -0421; however, we must to the address in the Contact Us section on page 3 of your billing statement. receive notice at least three business days in advance of the scheduled Discover may monitor and /or record telephone calls between you and payment. If your payments may vary in amount, we will tell you on each Discover representatives for quality assurance purposes. will month billing statement when your payment will be made and how much it 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 38TSi85 To make changes to your address, email or telephone number, visit Discover.com Continued on next page lima IR11 DISCOVER Discover More Card Account number ending in 0364 Open Date: Apr 23, 2013 - Close Date: May 22, 2013 Page 3 of 4 CONTACT US 0 Web Mobile © Phone Inquiry 0 Mail Payments Access your WI N 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 TOO 1- 800 -347 -7449 Salt Lake City Carol Stream m.Discover.com LIT 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 $ 35.00 TOTAL INTEREST CHARGED IN 2013 $ 227.12 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Current Billing Period: 30 days ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE Purchases 21.24% V $0.00 $0.00 Cash Advances 25.24% V $0.00 $0.00 V= Voriable Rote Information For You For more information about how interest charges ore calculated see your Cardmember Agreement or go to www .discover.com /interesicharges 30179385 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION S HELLEY A GEORGE Accouni number ending in 0364 Open Date: Apr 23 2013 - Close Date: May 22 2013 Pag 4 of 4 30179385 VERIFICATION (Name) (Ti le) 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 - I /o�3` /� M 9_W4 (Si ture) DB Servicing Corporation servicing affiliate For Discover Bank SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy 20 Pll Az Richard W Stewart ` Solicitor PC Discover Bank Case Number vs. Shelley A. George 2013-5826 SHERIFF'S RETURN OF SERVICE 10/23/2013 09:30 PM- Deputy Ronald Hoover, 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: Shelley A. George at 1160 Redwood Drive, Carlisle Borough, Carlisle, PA 17013. RONALD HOOVER, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, October 24, 2013 RbNtrY R ANDERSON, SHERIFF (Gi%QU:^:iy;>u:c Sh3fiff.!ElcQSC?t NOTAhlt IN THE COURT OF COMMON PLEAS 2013 DEC 23 Ppf 3: 13 CUMBERLAND COUNTY, PENNSYLVANIA CUMBERLAND COUNTY CIVIL DIVISION ANfA DISCOVER BANK Plaintiff VS. Civil Action No. 13-5826 CIVIL SHELLEY A GEORGE PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant SHELLEY A GEORGE above named, in the default of an Answer, in the amount of $12743 . 14 computed as follows: Amount claimed. in Complaint $12743 .14 Less payments / adjustments made $0 . 00 Attorney' s fees $0 . 00 TOTAL $12743 . 14 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. Y William T. Molczan,47A37 30179385 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 SHELLEY A GEORGE 1160 REDWOOD DR CARLISLE, PA 17013 av-4 . 4 C11L14 11 O)y ' 00717 A/6- C� d IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case No. 13-5826 CIVIL vs. SHELLEY A GEORGE Defendant IMPORTANT NOTICE TO: SHELLEY A GEORGE 1160 REDWOOD DR CARLISLE, PA 17013-137 Date of Notice: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA. 17013 (717)249-3166 WELTMAN,WEINBERG& REIS CO., L.P.A. By: rZ�-- William T. Molczan P.A.I.D.#47437 WELTMAN,WEINBERG& REIS CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh, PA 15219 Phone: (412)434-7955 (412)338-7130 30179385 A PIT H4N IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 13-5826 CIVIL NON-MILITARY AFFIDAVIT SHELLEY A GEORGE 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, SHELLEY A GEORGE 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: SHELLEY A GEORGE 1160 REDWOOD DR CARLISLE, PA 17013 Affiant further states that the averments contained herein are true and correct to the best of Affiant ' s knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsification to authorities . AFFIANT Department of Defense Manpower Data Center Results as of:Dec-09-2013 05:35:58 SCRA 3.0 SfLat Pepwt Pu umt to Sery cerrtemben Civil Relief Act Last Name: GEORGE First Name: SHELLEY Middle Name: Active Duty Status As Of: Dec-09-2013 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 387 Days 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 Data Order Nadficallon End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notittcation to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. ohl`ll� P ' 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 maybe 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(NOAH 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: 96C70E10T0F6E00 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS . Civil Action No. 13-5826 CIVIL SHELLEY A GEORGE NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the follow'ng Order of Judgment was entered against you on 0 , 91 1 ap►3 . (xx) Assumpsit Judgment in the amount of $12743 . 14 plus costs . ( ) Trespass Judgment in the amount of $ plus costs . ( ) If not satisfied within sixty (60) days, your motor vehicle operator' s license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Awar Prothonotary By: PROTHONOTARY (OR DEPUTY) SHELLEY A GEORGE 1160 REDWOOD DR 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 - A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 13-5826 CIVIL SHELLEY A GEORGE Defendant(s) CITIZENS BANK Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION r ps TO THE PROTHONOTARY: G v Kindly issue a Writ of Execution in the above matter... < 1. directed to the Sheriff of CUMBERLAND County: 2. against SHELLEY A GEORGE , Defendant 3. against CITIZENS BANK. . .Garnishee 4. Judgment Amount $ $12,743.14 Less Payments/credits received $ $0.00 Interest $ $104.74 Costs $ SUBTOTAL: $ $12,847.88 Costs(to be added by Prothonotary): $ WELTMAN, WEINBERG& REIS CO., L.P.A. By: James P. V ecko,Esquire oj3t PA I.D. #7 596 WELTMAN, WEINBERG&REIS CO., L.P.A. �r L 4367 1h Avenue, Suite 1400 Pittsburgh,PA 15219 tr �� (412)434-7955 tBy . rJ3 a 11y99�1v-� WWR No. 30179385 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 13-5826 CIVIL VS. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) SHELLEY A GEORGE Defendant(s) CITIZENS BANK Garnishee(s) 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. 4367 1h Avenue, Suite 1400 Pittsburgh, PA 15219 (412)434-7955 WWR No. 30179385 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-5826 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due DISCOVER BANK, Plaintiff(s) From SHELLEY A.GEORGE, 1160 REDWOOD DRIVE,CARLISLE,PA 17013 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: CITIZENS BANK, 665 NORTH EAST STREET,CARLISLE,PA 17013 and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s)or otherwise disposing thereof, (2) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$12,743.14 Plaintiff Paid$ Interest$104.74 Attorney's Comm. % Law Library$.50 Attorney Paid$184.03 Due Prothonotary$2.25 Other Costs$ Date:,2/24!14 David D.Buell,Prothonotary Deputy REQUESTING PARTY: Name :JAMES P.VALECKO,ESQUIRE Address:WELTMAN,WEINBERG &REIS CO.,L.P.A 4367 1h AVENUE,SUITE 1.400 PITTSBURGH,PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 79596 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , ,:f I i Sheriff of atria o ' ,r�r i-F� {,� i L,;, ., ''' r 4 Jody S Smith C' <E! Chief Deputy _ • u { Richard W Stewart CUMBERLAND coot '' Solicitor OP F CE,:,c " ,,E'IE~ PENNSYLVANIA Discover Bank vs. Case Number Shelley A. George 2013-5826 SHERIFF'S RETURN OF SERVICE 03/03/2014 01:13 PM - Ryan Burgett, 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, Citizens Bank, 665 North East Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Tabitha Zarichansky, Personal Universal Banker, 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 March 4, 2014 to Shelley A. George at 1160 Redwood Drive, Carlisle, PA 17013. RYAN BURGETT, TY- SO ANSWERS, March 04, 2014 RONO R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION DISCOVER BANK Plaintiff(s), vs. 135826 SHELLEY A GEORGE -0 a yr, Defendant(s), c*-5 and Citizens Bank of Pennsylvania, —1 Garnishee. ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK rs.a C=1, The Garnishee, Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1 to 12) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $1984.88 after deduction of Garnishee's Processing Fee of $125.00 and Statutory Exemption of $300.00, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $31.00, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $33.00, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $32.67, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $56.48, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE AND BRIANNE T GOERGE, held jointly other than by the entireties, with an available balance of $2.69, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE AND MICHAEL M GEORGE, held jointly other than by the entireties, with an available balance of $0.61, being held subject to - this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $123.93, being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Bethan Harris who being duly sworn according to the law deposes and says that she is the Ops Associate II, Operations Services, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Bethan Harris Sworn and subscribed before me this / / day of MARCH , 2014. 0,1) Notary Public OF PENNS��v A� CG��IEGN�tw w2 acr �'�� u�cY Para WlI fir, PAec Pp�� CO Not COY °f p tsskon s P40 26. 1014 My C omm var0 �em�Y , Qennsvl Certificate of Service I, Bethan Harris, hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this 1/ day of MARCH, 2014. JAMES P VALECKO, ESQ WELTMAN, WEINBERG & REIS CO, LPA 436 7TH AVE PITTSBURGH, PA 15219 SHELLEY A GEORGE Bethan Harris IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA DISCOVER BANK, Plaintiff(s), VS. SHELLEY A GEORGE, Defendant(s), VS. Citizens Bank of Pennsylvania, Garnishee. CIVIL DIVISION 135826 Answers to Interrogatories Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA I.D. No. 62378 Stradley, Ronon, Stevens & Young Great Valley Corporate Center 30 Valley Stream Parkway Malvern, PA 19355-1481 (484) 323-1351 (610) 640-1965 fax ndeenis@stradley.com www.stradley.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHELLEY A GEORGE Defendant CITIZENS BANK Garnishee Civil Action No. 13 -5826 CIVIL PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, CITIZENS BANK , in the amount of $1984.88, which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T Molczan Esq, 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 #30179385 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg & Reis Co., .L.P.A., 1400 Koppers Building, 436 71" Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: 525 WILLIAM PENN PL, PITTSBURGH, PA 15219 sIlo.� goy �nfi� ivlaitPJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA DISCO VEJ BANK Plaintiff(s), vs. SHELLEY A GEORGE Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. CIVIL DIVISION 135826 ANSWERS TO IN LERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1 to 12) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $1984.88 after deduction of Garnishee's Processing Fee of $125.00 and Statutory Exemption of $300.00, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $31.00, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $33.00, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $32.67, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $56.48, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE AND BRIANNE T GOERGE, held jointly other than by the entireties, with an available balance of $2.69, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE AND MICHAEL M GEORGE, held jointly other than by the entireties, with an available balance of $0.61, being held subject to this Writ of Execution. The Garnishee, Citizens Bank of Pennsylvania, states that it maintains a checking account in the name of the defendant, SHELLEY A GEORGE, with an available balance of $123.93, being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Bethan Harris who being duly sworn according to the law deposes and says that she is the Ops Associate II, Operations Services, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Sworn and subscribed before me this ( day of MARCH , 2014. uhiuk- Notary Public p,4a.. nj; Bethan Harris Certificate of Service I, Bethan Harris, hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this // day of MARCH, 2014. JAMES P VALECKO, ESQ WELTMAN, WEINBERG & REIS CO, LPA 436 7TH AVE PITTSBURGH, PA 15219 SHELLEY A GEORGE Bethan Harris IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA DISCOVER BANK, Plaintiff(s), vs. SHELLEY A GEORGE, Defendant(s), vs. Citizens Bank of Pennsylvania, Garnishee. CIVIL DIVISION 135826 Answers to Interrogatories Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA I.D. No. 62378 Stradley, Ronon, Stevens & Young Great Valley Corporate Center 30 Valley Stream Parkway Malvern, PA 19355 -1481 (484) 323 -1351 (610) 640 -1965 fax ndeenis @stradley.com www.stradley.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHELLEY A GEORGE Defendant CITIZENS BANK Garnishee Citizens Bank 525 William Penn P1 Pittsburgh, Pa 15219 Civil Action No. 13 -5826 CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff ( ) Defendant (xx) Garnishee You are hereby notified that the following Order or Judgment as entered against you on (xx) Assumpsit Judgment in the amount of $1984.88 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 Prothon otary By: PROTHONOTARY (OR DEPUTY) WELTMAN, WEINBERG & REIS BY: James P Valecko Esquire I.D. No.79596 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 30179385 Ur PRO THONO-Tiki\ CO., L.P.A. Attorney for Plaintiff(s) 21114, -- �i ti CUM'�3 :r?LAND COUNTY PENNS YLVA NIA; DISCOVER BANK Cumberland County Court of Common Pleas vs. SHELLEY A GEORGE and CITIZENS BANK Garnishee(s) PRAECIPE TO SATISFY ATTACHMENT EXECUTION NO. 13-5826 CIVIL TO THE PROTHONOTARY: Kindly marked the above matter satisfied as to Garnishee(s), CITIZENS BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By al James P ecko, Esquire or Attorney Plaintiff *sq 5D' 11 SFSPCc3 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 13-5826 CIVIL SHELLEY A GEORGE 1 (u,00 K w�"bi, Defendant(s) Cw k,,5‘e1 -0*1 1-)°1. CITIZENS BANK 1 (D(pS Nov -Ki eR6-1" Garnishee(s) car ` vie (—)0I -� 013 l CIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against SHELLEY A GEORGE , Defendant 3. against CITIZENS BANK, , , Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): 11 $ $12,743.14 $ $1,984.88 IU1 s$.r $ $496.82 $ $11,255.08 ELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. V ecko, Esquire PA I.D. #7 596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 gags -Atg LillOyi,m6 neC WWR No. 30179385 1 / /c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHELLEY A GEORGE Defendant(s) CITIZENS BANK Garnishee(s) No. 13-5826 CIVIL PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA I.D. #79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 30179385 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. NO 13-5826 Civil Term CIVIL ACTION --'LAW SHELLEY A. GEORGE WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against SHELLEY A. GEORGE, 1160 REDWOOD DRIVE, 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 CITIZENS BANKGARNISHEE(S), as garnishee, 665 NORTH EAST STREET, CARLISLE, PA 17013 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (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 $10,758.26 Plaintiff Paid Interest $496.82 Law Library Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $239.03 . Other Costs Date: 09/10/14 /0.th.[LI . David D. D. Buell, Prothonotary (Sea I) BjJ?(77,70.L' Deputy REQUESTING PARTY: Name : JAMES P. VALECKO, ESQUIRE Address: WELTMAN, WEINBERG & REIS, CO., L.P.A. 436 7 AVENUE, SUITE 2500 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 2Bibles, 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA DISCOVER BANK Plaintiff(s), vs. CIVIL DIVISION 13-5826 �, AI SHELLEY A GEORGEo. ` Y� -nn ter_ Defendant(s),'Fri cry ryc" -<> N.) o , andQ y 1>c7 ca -7 Citizens Bank of Pennsylvania, �'' - { ` Garnishee. ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1 to 12) At the time of service of above -captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of Pennsylvania, states that it maintains 2 CHECKING accounts in the name of the defendant, SHELLEY A GEORGE, with an available balance less than the Garnishee's Processing Fee of $125.00 and Statutory Exemption of $300.00, accordingly, no funds are being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Heather Zito who being duly sworn according to the law deposes and says that she is the Operations Clerk, Operations Services, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Sworn and subscribed before me this n day of , 2014. cOMM0NNNEACTI-EisINSYLVANI.- NOTA/l_ SEAL Dare VVilicerson, Notary Public. City of Pittsburgh, Allegheny Cotir,ty My Commission Expires April Z6, MEMBER, PERUSYVI AN FA---FaTOT, l'ATI (5-rii-cl. AIIIE':!i Notary Public Certificate of Service I, Heather Zito, hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this 17 day of SEPTEMBER, 2014. JAMES P VALECKO, ESQ WELTMAN, WEINBERG & REIS CO, LPA 436 7TH AVE PITTSBURGH, PA 15219 Qik'-)%1 Heather Zito IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA DISCOVER BANK, Plaintiff(s), vs. SHELLEY A GEORGE, Defendant(s), vs. Citizens Bank of Pennsylvania, Garnishee. CIVIL DIVISION 13-5826 Answers to Interrogatories Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA I.D. No. 62378 Stradley, Ronon, Stevens & Young 2005 Market Street, Suite 2600 Philadelphia PA 19103 (215) 564-8672 (215) 564-8120 fax ndeenis@stradley.com www.stradley.com WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James P Valecko, Esquire I.D. No. 79596 436 Seventh Avenue, Suite 2500 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 30179385 i'ROTH:) O. Attorney for Plaintiff(s) 2CR OCT —3 P ; X�. CU'o E[ L/ D C; t' : "t DISCOVER BANK Cumberland County Court of Common Pleas vs. SHELLEY A GEORGE NO. 13-5826 CIVIL and CITIZENS BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), CITIZENS BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By James P V lecko, Esquire Attorney f r Plaintiff 0,,,v,A,4\qbpd oJpil--T7/0b, aw 3009/3