The URL can be used to link to this page

Home My WebLink About13-6031 Supreme Court of;Pe�nnsylvania NVWR# 20197274 C A Pit ABR Cou of C m n Pleas ��' For Pmthonotaq? Use Orel•: . ; Civil'Gover Shee , C UMBERLAND C oun t y �:,; • ,�. t { ' t Docket No: .The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the f iling artd service of pleadings or other papers as required bi.- lam, or rules of court. Commencement of Action: S IX Complaint ❑ Writ of Summons ❑ Petition E Transfer from Another Jurisdiction Declaration of Takin C Lead Plaintiff's Name: Lead Defendant's Name: T MIDLAND FUNDING LLC DEBORAH CAMPBELL I C Are money damages requested? ® Yes ❑ No Dollar Amount Requested: El within arbitration limits N I (check one) c3 outside arbitration limits Is this a Class Action Suit? ❑ Yes 13 No Is this an MDJ Appeal? ❑ Yes W No A William T. Molczan,47437 Name of Plaintiff /Appellant's Attorney: ❑ 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 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 (3 Product Liability (does not include [3 Employment Dispute Mass tort) Discrimination C ❑ Slander /Libel /Defamation ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other: ❑ Other: 1 13 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 1/1/2011 F ii._ - is � i ts " t t�n t R E�3 T i'i O NO) IA "" t i1OrT Z' ;;U; BERLAH VAt A ay Pi~p1i�3SY�. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff No: L rv� vs. COMPLAINT IN CIVIL ACTION DEBORAH CAMPBELL 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 20197274 C A Pit ABR CCU- 01 9 ` e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff vs. Civil Action No DEBORAH CAMPBELL 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 CIVIL ACTION 1. Plaintiff, MIDLAND FUNDING LLC, is a business entity with offices located at 8875 Aero Drive, Suite 200, San Diego, CA 92123. 2. MCM� records show that the Defendant(s) DEBORAH CAMPBELL is/ are individual(s) residing at 1322 1/2 SPRING RD APT B, CARLISLE, PA 17013 3. As set forth in records maintained on behalf of Plaintiff, this action is based upon a credit agreement entered into between Defendant(s) and the original credit grantor. 4. Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was assigned all the rights, title and interest to Defendants GE MONEY BANK account XXXXXXXXXXXX3004 (hereinafter "the account "). Midland Credit Management, Inc. (hereinafter "MCM ") services the account on behalf of Plaintiff. 5. MCMI records state that this action is based upon a credit agreement entered into between defendant(s) and the original credit grantor. MCM� records further state that defendant(s) used or authorized the use of the credit account but failed to make the payments due pursuant to the agreement. 6. MCM§ records show that the defendant(s) owed a balance of $3581.53 as of 2013- 08 -28. 7. Attached hereto are records regarding the account and/or payment(s) received. WHEREFORE, Plaintiff respectfully requests that judgment be entered in favor of Plaintiff and against Defendant(s) in the amount of $3581.53, togeth r with interest and costs. By Weltman, Weinbe & Reis, Co., LPA Attorney for Plaintiff Page - 1 8550716499 AFFINDEBTMEDIA 20197274 PayPal Extras P ayPal "Extras Account N CAM PBE� 3004 Customer Visit us at Service: 1.88.44 Summary of Account ActMty Payment (rdormation Previous Balance $3,581.53 New Balance $0,00 - Other Credits $3,581.53 Minimum Payment This Period SSW= New Balance $0.00 Amount Past Due $0.00 Total Minimum Payment Due $880.00 Credit Limit $3,000.00 Payment Due Date 08/102011 Available Credit $O.OD Late Payment Warning: If we do not receive your minimum Cash Limit 5380.00 payment by the date listed above, you may have to pay a late AvaOable Cash $0,00 fee up to $35.0D. Statement Closing Date 081072011 Days in Billing Cycle 28 1 PayPal Extras Rewards Program Rewards Information Previous Reward Point Balance 0 Continue to earn 3X Points on gas & restaurant purchases, + Points Earned This Period 0 2X Points on PayPal & eBay purchases, and 1X Point Points Redeemed 0 everywhere MasterCard is accepted! You can begin = Current Reward Point Balance 0 redeeming for rewards when you have earned 2,500 Points. 0 3,000 6,000 9,000 12,000+ Transaction Summary Tram Date Post Date Reference Number Description of Transaction or Credit Amount D11107 08107 F1192DD6V009999W CHARGE OFF ACCOUNT- PRINCIPALS ($2,994.27) 08/07 08/07 F1192D06V0099N W CHARGE OFF ACCOUNT *FINANCE CHARGES' ($587.28) FEES TOTAL FEES FOR THIS PERIOD $0.00 INTEREST CHARGED 08107 08/07 INTEREST CHARGE ON PURCHASES $0.00 08/07 08/07 INTEREST CHARGE ON CASH ADVANCES $0.00 TOTAL INTEREST FOR THIS PERIOD $0.00 2011 Totals Year to -Date Total Fees Charged in 2011 $130.00 Total interest Charged in 2011 $457.28 Interest Charge Calculation Your Annual Percentage Rate (APR)is the annual interest rate on your account Expiration Annual Percentage Balance Subject to Type of Selene Deht Rate Interest Rate Interest Charge Purchases WA 23.99% (v) $0.00 $0.00 Cash Advances WA 26.99% (v) $0.00 $0.00 (v) = Variable Rate PAYMENT DUE BY 5 P.M- (ET) ON THE DUE DATE NOTICE: We may convert your payment into an electronic debit. Sea reverse for details, Billing Rights information and other Important Information. 8640 YaG 1 5 7 110e01 Z PAGE 1 of 3 1192 1000 9302 01Bn8640 I CC��,,��.. Detach and mail this portion with your cheek. Do not Include any correspondence with your check. —� PayPal ras Account Number.11111�1113004 Total Nlnlmtlm Amount Payment Due Ovedimtt New Ba(anca P end Due Past Due Date Amount $860.00 $0.00 08!102011 $0.00 $0.00 Payment Enclosed: Please use $ ❑ ❑ ❑ ❑ ■ ❑ blue or black Ink. Save a stamp, pay on-fine at www.paypal.00m New address or small? Print changes an back. DEBORAH CAMPBELL a �y r" 1322 12 SPRING RD APT 8 CARLISLE PA 17013-1555 Make Payment to: PAYPAL CREDIT SVCSIGEMB lit 20197274 PO BOX 960060 ORLANDO, FL 32896-0060 -= ram PayPal"Extras Cardholder News and Information Your Total Minimum Payment Due on this statement Includes the Amount Past Due (if any) shaven. 20197274 8640 YBG 1 5 7 120001 E X PAM 2 of 3 1192 1000 P302 OIBRO640 Verification Mycah Struck, being duly sworn (or affirmed) according to law deposes and says that I am employed as a Legal Specialist for Midland Credit Management, Inc. ( "MCM "), servicer of this account on behalf of plaintiff. I am a competent person over eighteen years of age, and make these statements herein based upon personal knowledge of those account records maintained on plaintiffs behalf. I am authorized to make this verification on plaintiffs behalf. The facts set forth in the foregoing pleading are true and correct. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to au orities. SEP 2 G 2013 Date Mycah Struck OH 14 Weltman, Weinberg & Reis. Co., L.P.A Page - 2 1111 ®1011111ll�l��ll��lllplll�� AIU�IWIIIUI��I�IAIWllllu�lll� 8550716499 AFFINDEBTMEDIA 20197274 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson = L t J f3 F Sheriff jHr PRO`tHflNCAi�"' ,attr of arartGr• rx Jody S Smith ' Chief Deputy ��{ �� ' t4TY Solicitor yt ANA X01 Richard W Stewart NOV Hd �j °:,yF': .... i ?1'u .t-CIF.= � 1 ANIA Midland Funding, LLC vs. Case Number Deborah Campbell 2013-6031 SHERIFF'S RETURN OF SERVICE 10/25/2013 06:44 PM- Deputy Jason Kinsler, 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: Deborah Campbell at 1322 1/2 Spring Road- B, Carlisle Borough, Carlisle, PA 17013. JAS R, DEPUTY SHERIFF COST: $34.78 SO ANSWERS, October 28, 2013 RONIKR ANDERSON, SHERIFF t;:j Ccu^::yt:ui�e Shenff:To OSeft.L:.. y 1..J t- t ws .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff No: 13-6031 CIVIL VS . PRAECIPE FOR DEFAULT JUDGMENT DEBORAH CAMPBELL 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 20197274 C A Pit DKB Judgment Amount $3581 . 53 IN. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff VS . Civil Action No. 13-6031 CIVIL DEBORAH CAMPBELL PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant DEBORAH CAMPBELL above named, in the default of an Answer, in the amount of $3581 . 53 computed as follows : Amount claimed in Complaint $3581 . 53 Less payments / adjustments made $0 . 00 Attorney' s fees $0 . 00 TOTAL $3581 . 53 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. B Y: William T. Molcza , 47437 20197274 C A P ' DKB Plaintiff ' s address is : c/o WELTMAN, WEINBERG & REIS CO. , L. P.A. , 436 7th Ave Ste 1400 Pittsburgh PA 15219-1827 And thatthe last known address- of the Defendant is DEBORAH CAMPBELL 1322 1/2 ``SPRING RD APT B CARLISLE,,.: PA 17013 416,50 PQATr"f �-+1143a833 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA i CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff Case No. 13-6031 CIVIL VS. DEBORAH CAMPBELL Defendant IMPORTANT NOTICE TO: DEBORAH CAMPBELL 1322 112 SPRING RD APT B CARLISLE, PA 17013 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, ------��... Matthew Urban P.A.I.D.#90963 WELTMAN,WEINBERG& REIS CO., L.P.A. 436 7th Ave Ste 1400 Pittsburgh, PA 15219 Phone: (412)434-7955 (412) 338-7130 20197274 A PIT A4S IN THE COURT OF COMMON PLEAS :. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff VS . Civil Action No. 13-6031 CIVIL NON-MILITARY AFFIDAVIT DEBORAH CAMPBELL 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, DEBORAH CAMPBELL 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: DEBORAH CAMPBELL 1322 1/2 SPRING RD APT B 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 _ Results as of:Jan-03-2014 05:23:25 •- Department of Defense.Manpower Data � • Center SCRA 3.0 Status Report Pursuant,to Servicemembers,Cif Relief Act Last Name: CAMPBELL First Name: DEBORAH Middle Name: Active Duty Status As Of: Jan-03-2014 On Active Duty On Active Duty Status Date Active Du Start Data Active Duty End Date Status Service Component NA NA' - -No NA This response reflects the Individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Slat us Date Active Duty Start Dale 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 Du ty 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 F 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,Nary,Marine Corps,Air Force,NOAH,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�7 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:hftp://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: R6XDK9B7103A530 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff VS . Civil Action No. 13-6031 CIVIL DEBORAH CAMPBELL 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 (xx) Assumpsit Judgment in the amount of $3581 . 53 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 A rd Prothonotary By: '°� . PROTHONOTARY (OR DEPUTY) DEBORAH CAMPBELL 1322 1/2SPRING RD APT B CARLISLE; PA 17013 -- Plaintiff' s address is :. : c/o WELTMAN, WEINBERG & -REIS CO. , L.P.A. , 436 7th Ave Ste 1400. - Pittsburgh PA 15219-.1827 (412) 434-7955 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff vs. Civil Action No. 13-6031 CIVIL DEBORAH CAMPBELL , %3aa11, CAnb Defendant(s) ORRSTOWN BANK 71 1..w' 45 g4 k�.% f �rl�Sk �-7C)1 CITIZENS BANK 111Nor4 WELLS FARGO BANK Leer Sc, 1A1il1n 54 • ` Carktsl e ("PA nO13 Garnishee(s) PRAECIPE 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 DEBORAH CAMPBELL , Defendant 3. against ORRSTOWN BANK, CITIZENS BANK, WELLS FARGO BANK, Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): S1-178 103.7s((/1 .so r os5 pd a $ $3,581.53 $0.00 $148.36 $ $3,729.89 WELTMAN, WEINBERG & REIS CO., L.P.A. By: James P. alecko, Esquire PA I.D. # 9596 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7"' Avenue, Suite 2500 Pittsburgh, PA 15219 (412) 434-7955 WWR No. 20197274 (,LkJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MIDLAND FUNDING LLC Plaintiff vs. DEBORAH CAMPBELL Defendant(s) ORRSTOWN BANK CITIZENS BANK WELLS FARGO BANK, Garnishee(s) No. 13-6031 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. 20197274 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA • 17013 (717) 240-6195 www.cepa.net MIDLAND FUNDING LLC Vs. NO 13-6031 Civil Term CIVIL ACTION — LAW DEBORAH CAMPBELL WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against DEBORAH CAMPBELL, 1322 112 SPRING ROAD, APT B, 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 ORRSTOWN BANKGARNISHEE(S), as garnishee, 77 E. KING STREET, SHIPPENSBURG, PA 17257, CITIZENS BANK, 665 NORTH EAST STREET, CARLISLE, PA 17013 AND WELLS FARGO BANK, 604 E. HIGH 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. 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 1 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 $3,581.53 Plaintiff Paid Interest $148.36 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $184.03 Other Costs Date: 10/14/2014 III Cal,ZeGi "e14-1/ David D. Buell, Prothonotary (Seall By: fite24,- Y)dr 02.j Deputy REQUESTING PARTY: Name : JAMES P. VALECKO, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 4Mi7" 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 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF ICE QF THE''FIFF FiL. 3-0Fi` IC uF THE P ROTH0NOTAR- 2Dl4 OCT 24 AM 9:52_ CUMBERLAND COUNTY PENNSYLVANIA Midland Funding, LLC vs. Deborah Campbell Case Number 2013-6031 SHERIFF'S RETURN OF SERVICE 10/22/2014 10:55 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Orrstown Bank, 427 Village Drive, Carlisle Borough, Carlisle, PA 17015, Cumberland County, by handing to Bree Vance, Customer Service, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and mase the contents there of known to her. October 23, 2014 (c) CountySuito Sheriff, Teleosoft, inc. WI ` IA CLI '" , DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY HLED-OFFICE THE PRDTHO'NOTAR ?� l4 OCT 214 AM 9; 52 C PENNS EVAN: A COUNTY DI eilarotri E OF THE SHERIFF Midland Funding, LLC vs. Deborah Campbell Case Number 2013-6031 SHERIFF'S RETURN OF SERVICE 10/22/2014 02:55 PM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Citizen's Bank, 665 North East Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Tabithba Zarichansky, Banker, personally three copies of interrogatories together with three true and attested copies of the Writ of Execu 'on a -- made the contents there of known to her. October 23, 2014 (c) CountySuite Sheriff, Toleosoft, Inc. WI LIAM CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY !LED -'U F rL__ Cir" THE PPO 1 HC 9u l Aryl' 2014 OCT 24 AM ; : 52 • c CUMBERLAND COUNTY PENNSYLVANIA OFFICE QF THE $H. RIFF Midland Funding, LLC vs. Deborah Campbell Case Number 2013-6031 SHERIFF'S RETURN OF SERVICE 10/23/2014 10:35 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Jennifer Hommerbocker, Service Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on October 24, 2014 to Debor Campbell at 1322 1/2 Spring Road, Carlisle, PA 17013. W" IAM CLINE, DEPUTY SO ANSWERS, October 23, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Te!eosoft, Inc. SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee MIDLAND FUINDING, LLC vs. DEBORAH CAMPBELL : NO. 13-6031 and WELLS FARGO BANK, GARNISHEE ENTRY OF APPEARANCE : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND TO THE PROTHONOTARY: Kindly enter my appearance on behalf Wells Fargo Bank, Garnishee in the above - captioned matter. Date: 1O- -AA SIRLIN LESSER & BENSON, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee MIDLAND FUINDING, LLC vs. Pi 2: 44 : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND DEBORAH CAMPBELL : NO. 13-6031 and WELLS FARGO BANK, GARNISHEE ANSWERS TO INTERROGATORIES IN ATTACHMENT TO: MIDLAND FUINDING, LLC, Plaintiff 1.- 6. Wells Fargo Bank holds no assets of and owes no debt to the Judgment Debtor herein. Dated: \\-3j\ JON .5 IN Atto ev for arnishee WELLS FARGO Wells Fargo Bank, N.A. Liens, Levies & Garnishments 101 N. Independence Mall East MAC Code# Y1372-039 Philadelphia, PA 19106 VERIFICATION Diana Nazario, being duly sworn according to law, deposes and says that she is the Legal Order Processing Associate of Wells Fargo Bank, NA Garnishee herein, and verifies that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to sworn falsification to authorities. Diana Nazario Legal Order Processing Associate Case: 104489714 Date: 10/30/2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA MIDLAND FUNDING LLC Plaintiff(s), vs. DEBORAH CAMPBELL Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. CIVIL DIVISION NO136031 CD ANSWERS TO INTERROGATORIES OF GARNISHEE, CITI/.hNS BANK C) N 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 no record of any deposit account in the name of the defendant, DEBORAH CAMPBELL, 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 Dara Wilkerson who being duly sworn according to the law deposes and says that she is the Legal 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. Dl�u Lut11)-" Dara Wilkerson Sworn and subscribed before me this DECEMBER, 2014. day of COMMONWEALTH OF PENNSYLVANIA Notarial Seal Penny ). Donaldson, Notary Public City of Pittsburgh, Allegheny County My Commission Expires Jan. 18, 2017 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES Certificate of Service I, Dara Wilkerson, 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 DECEMBER, 2014. JAMES P VALECKO, ESQ WELTMAN, WEINBERG & REIS CO, LPA 436 7TH AVE PITTSBURGH, PA 15219 DEBORAH CAMPBELL Dara Wilkerson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA MIDLAND FUNDING LLC, Plaintiff(s), vs. DEBORAH CAMPBELL, Defendant(s), vs. Citizens Bank of Pennsylvania, Garnishee. CIVIL DIVISION NO136031 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 Attorney for Plaintiff(s) I.D.No. 79596 436 Seventh Avenue, Suite 2500 Pittsburgh,PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File# 20197274 MIDLAND FUNDING LLC Cumberland County Court of Common Pleas vs. DEBORAH CAMPBELL NO. 13-6031 CIVIL and ORRSTOWN BANK CITIZENS BANK WELLS FARGO BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), ORRSTOWN BANK CITIZENS BANK WELLS FARGO BANK, only. WELTMAN, WEINBERG&REIS CO., L.P.A. By — n James P alecko, Esquire Attorney for Plaintiff 04 P7 q Is-3 �� 3l sa s3