HomeMy WebLinkAbout13-6034 Supreme Court,of,Pennsyhania w«TR# 20173294 C A Pit ABR
Court=of Common Pleas
t ` V�
Civil Gover. -Sheet For Protholwtarr Use Onh':
C UMBERLAND; , , _ -�; Couniy Docket No:
The information collected on this form is used solely for court adminish purposes. This form does not
supplemenr or replace the filing and service of'pleadings or other papers as required bi- law or rules of court.
Commencement of Action:
S [3 Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction L3 eclaration of Takin
C Lead Plaintiff's Name: Lead Defendant's Name:
T MIDLAND FUNDING LLC BRIAN DEPEW
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 13 No Is this an AMJ 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 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:
T ❑ 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 1/1/2011
t
PROTNOr o�TA� y
20113 OCT 15 Pp1 2: 4 8
CUP- DERLAND COUNTY
P ENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff No : , �� l.� �/� / !U/
vs.
COMPLAINT IN CIVIL ACTION
BRIAN DEPEW
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
20173294 C A Pit ABR
S
�1o3,7S �
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs. Civil Action No
BRIAN DEPEW
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
f
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) BRIAN DEPEW is/ are individual(s)
residing at 110 S 1 ST ST, LEMOYNE, PA 170431973.
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 Defendant§ WEBBANK account
XXXXXXXXXXXXXXX5098 (hereinafter "the account "). Midland Credit Management,
Inc. (hereinafter "MCM ") services the account on behalf of Plaintiff.
5. MCM§ 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 $2349.55 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 $2349.55, tooget er with interest and costs.
By l�✓ �/
Weltman, Weinb g & -Reis, Co., LPA
Attorney for Plaintiff
Page - 1
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8557411155 AFFINDEBTMEDIA 20173294
DELL FINANCIAL SERVICES, L.L.C.
CUSTOMER ACCOUNT INFORMATION
Customer Account
ACCOUNT NUMBER 5098 CUSTOMER NAME BRIAN H DEPEW SSN " " * "* 2065
BILLING ADDRESS 60 MILLER ST APT B3
LEMOYNE, PA 17043 -1523 LAST BALANCE: $2,349.55 BALANCE AS OF DATE: 6/11/2012
PHONE (717) 557 -1888
Prior Billing Addresses
( li(( III�I< dlEllflllil�fflll�' IIIIfIIA6sIIIIIIII��IIfiIIfIIIIIn�IIIIII�I�IIINlllllll ` GIIIIIIIIIIaIIIN91911VIIIIIII�G9111111169111 11111101911111n1111916611111 IIIII Illlllllallllll 9
60 MILLER ST APT B3 LEMOYNE PA 170431523 9/1/2012
1128 COLUMBUS AVE APT.5 LEMOYNE PA 17043 5/5/2012
257 WALTON STREET LEMOYNE PA 17043 10/6/2011
Orders
IN 10 M1 0 71 I lI pol-RIVEMIIlIillIllIlIllIRRIIIIgIilill1illill1illill11ill1l1imiiiiililigillilliililllll ililllillilliIill1lil1oll1I 11111111111 I1111 111111111
11/29/2010 534563569 256GB Solid State Drive 1 $502.46
11/29/2010 534563569 Intel Core2 Duo SU73001.3GHz 1 $468.95
11/29/2010 534563569 HW WRTY +SVC,ANW M11x,BSC,INIT,DHS 1 $239.00
11/29/2010 534563569 4GB Dual Channel DDR3 at 1066MHz 1 $41.88
11/29/2010 534563569 Optional Bluetooth Module, 2.1 1 $16.75
11/29/2010 534563569 Alienhead 30 1 $0.00
11/29/2010 534563569 No Internal WWAN Antenna Installed 1 $0.00
11/29/201.0 534563569 AUTO- UPDATES,ON, AW 1 $0.00
11/29/2010 534563569 WIN 7 HOME PREM, 64, ENG,AW NB 1 $0.00
11/29/2010 534563569 PC- RESTORE, DIM /INSP 1 $0.00
11/29/2010 534563569 1YR LIMITED WARRANTY 1 $0.00
11/29/2010 534563569 11.6 -inch WideHD, No WWAN, BLK 1 $0.00
11/29/2010 534563569 Alienhead 3D 1 $0.00
11/29/2010 534563569 DATASAFE LOCAL BACKUP 1 $0.00
11/29/2010 534563569 SW,SFTCON,BSC,ANW 1 $0.00
11/29/2010 534563569 Adobe Acrobat Reader 9.0 MLANG CNB 1 $0.00
11/29/2010 534563569 NBD OS,ANW M11x,BSC,INITYR,DHS 1 $0.00
11/29/2010 534563569 AlienFX Color, Quasar Blue 1 $0.00
11/29/2010 534563569 Web Cam 1 $0.00
11/29/2010 534563569 MCAFEE PEARL MUI,30DAY,W /0,CNB 1 $0.00
11/29/2010 534563569 Alienware M11x a /b /g/n 2x2 MIMO Wireless 1 $0.00
11/29/2010 534563569 WARRANTY SPRT,ANWNB,INITYR 1 $0.00
11/29/2010 534563569 Standard Nameplate 1 $0.00
11/29/2010 534563569 Steam Factory Installed 1 $0.00
11/29/2010 534563569 NO WARRANTY,YRS 2 /3(DIM,INSP,NBD) 1 $0.00
11/29/2010 534563569 DELL- DOWNLOAD -FLAG EXHIBIT. 1 $0.00
11/29/2010 534563569 Internal High - Definition Surro 1 $0.00
1 1/29/2010 534563569 Integrated 10 /100NIC 1 $0.00
1 L 0 534563569 Command Center SW, M11x 1 $0.00
Data printed by Midland Credit Management, Inc. from electronic records created, maintained, and provided by Dell Financial Services, L.L.C.
Page 1 of 6
11/29/2010 534563569 1GB NVIDIA GeForce GT 335M 1 $0.00
11/29/2010 534563569 S AND P DIB MARCOM,DHS NOTEBOOKS 1 $0.00
11/29/2010 534563569 Alienware M11x, Cosmic Black 1 ($0.04)
5/27/2011 702485678 4 GB DELL CERTIFIED REPLACEMENT MEMORY M 2 $339.98
Transactions
IBM ' .u�, , , Imat 7,111 W WI S' Nfl ffiffi, " l�I��I���I II�I�I���III�II�Gdlgl 1ENWARM. 1111011111
12/6/2010 12/7/2010 1 PURCHASE $1,345.15 534563569
12/20/2010 12/20/2010 365 DEFERRED FINANCE CHARGES DEBIT $15.47
12/20/2010 12/20 /2010 306 INSURANCE PREMIUM ASSESSED $5.59
1/7/2011 1/12/2011 30 PAYMENT ($46.59)
1/10/2011 1/10/2011 399 PRINCIPAL CREDIT PAID ($41.00)
1/10/2011 1/10/2011 165 PAYMENT- THANKYOU! ($5.59)
1/10/2011 1/10/2011 404 INSURANCE PREMIUM PAID ($5.59)
1/10/2011 1/10/2011 165 PAYMENT- THANKYOU! ($41.00)
1/10/2011 1/12/2011 31 PAYMENT REVERSAL $41.00
1/10/2011 1/12/2011 31 PAYMENT REVERSAL $5.59
1/12/2011 1/12/2011 414 INSURANCE PREMIUM REVERSED $5.59
1/12/2011 1/12/2011 399 PRINCIPAL CREDIT PAID ($46.59)
1/12/2011 1/12/2011 409 PRINCIPAL CREDIT REVERSED $41.00
1/20/2011 1/20/2011 365 DEFERRED FINANCE CHARGES DEBIT $33.73
1/20/2011 1/20/2011 306 INSURANCE PREMIUM ASSESSED $11.80
2/6/2011 2/8/2011 30 PAYMENT ($39.82)
2/6/2011 2/8/2011 30 PAYMENT ($11.98)
2/8/2011 2/8/2011 399 PRINCIPAL CREDIT PAID ($39.82)
2/8/2011 2/8/2011 404 INSURANCE PREMIUM PAID ($11.98)
3/1/2011 3/1/2011 365 DEFERRED FINANCE CHARGES DEBIT $41.89
3/1/2011 3/1/2011 306 INSURANCE PREMIUM ASSESSED $11.44
3/1/2011 3/1/2011 300 BILLED FINANCE CHARGES $2.00
3/20/2011 3/22/2011 30 PAYMENT ($37.77)
3/20/2011 3/22/2011 30 PAYMENT ($12.23)
3/22/2011 3/22/2011 400 FINANCE CHARGE CREDIT PAID ($2.00)
3/22/2011 3/22/2011 404 INSURANCE PREMIUM PAID ($10.23)
3/22/2011 3/22/2011 399 PRINCIPAL CREDIT PAID ($37.77)
4/1/2011 4/1/2011 365 DEFERRED FINANCE CHARGES DEBIT $31.66
4/1/2011 4/1/2011 300 BILLED FINANCE CHARGES $2.00
4/1/2011 4/1/2011 306 INSURANCE PREMIUM ASSESSED $11.18
I
4/26/2011 4/26/2011 304 LATE CHARGE ASSESSMENT $25.00
5/1/2011 5/1/2011 300 BILLED FINANCE CHARGES $2.00
5/1/2011 5/1/2011 306 INSURANCE PREMIUM ASSESSED $11.09
5/1/2011 5/1/2011 365 DEFERRED FINANCE CHARGES DEBIT $30.22
5/1/2011 5/3/2011 30 PAYMENT ($14.32)
5/1/2011 5/3/2011 30 PAYMENT ($85.68)
201 5HN 5/3/2011 929 NP INSURANCE PREMIUM PAID ($0.01)
Data printed by Midland Credit Management, Inc. from electronic records created, maintained, and provided by Dell Financial Services, L.L.C.
Page 2 of 6
i
s
5/3/2011 5/3/2011 822 PRINCIPAL CREDIT ADJUSTMENT ($0.01)
5/3/2011 5/3/2011 941 FINANCE CHARGE CREDIT ADJUSTMENT $0.01
5/3/2011 5/3/2011 312 INTEREST CREDIT ADJUSTMENT ($0.01)
5/3/2011 5/3/2011 367 PRINCIPAL DEBIT ADJUSTMENT $0.01
5/3/2011 5/3/2011 399 PRINCIPAL CREDIT PAID ($60.68)
5/3/2011 5/3/2011 403 LATE CHARGE CREDIT PAID ($25.00)
5/3/2011 5/3/2011 404 INSURANCE PREMIUM PAID ($10.32)
5/3/2011 5/3/2011 400 FINANCE CHARGE CREDIT PAID ($4.00)
5/3/2011 5/3/2011 368 DEFERRED FINANCE CHARGES CREDIT ($0.07)
5/31/2011 6/1/2011 1 PURCHASE $321.15 702485678
6/1/2011 6/1/2011 365 DEFERRED FINANCE CHARGES DEBIT $29.55
6/1/2011 6/1/2011 300 BILLED FINANCE CHARGES $2.00
6/1/2011 6/1/2011 306 INSURANCE PREMIUM ASSESSED $10.58
6/26/2011 6/26/2011 304 LATE CHARGE ASSESSMENT $35.00
7/1/2011 7/1/2011 365 DEFERRED FINANCE CHARGES DEBIT $28.77
7/1/2011 7/1/2011 300 BILLED FINANCE CHARGES $8.68
7/1/2011 7/1/2011 306 INSURANCE PREMIUM ASSESSED $13.52
7/10/2011 7/10/2011 403 LATE CHARGE CREDIT PAID ($35.00)
7/10/2011 7/10/2011 399 PRINCIPAL CREDIT PAID ($25.52)
7/10/2011 7/10/2011 165 PAYMENT -THANK YOU! ($60.52)
7/26/2011 8/1/2011 304 LATE CHARGE ASSESSMENT $35.00
8/1/2011 8/1/2011 365 DEFERRED FINANCE CHARGES DEBIT $29.50
8/1/2011 8/1/2011 300 BILLED FINANCE CHARGES $9.54
8/1/2011 8/1/2011 306 INSURANCE PREMIUM ASSESSED $13.64
8/24/2011 8/24/2011 403 LATE CHARGE CREDIT PAID ($35.00)
8/24/2011 8/24/2011 399 PRINCIPAL CREDIT PAID ($25.64)
8/24/2011 8/24/2011 165 PAYMENT -THANK YOU! ($60.64)
8/24/2011 8/26/2011 195 PAYMENTREVERSAL $60.64
8/24/2011 8/26/2011 195 PAYMENTREVERSAL $0.00
8/26/2011 8/26/2011 409 PRINCIPAL CREDIT REVERSED $25.64
8/26/2011 8/26/2011 413 LATE CHARGE CREDIT REVERSED $35.00
8/26/2011 9/1/2011 304 LATE CHARGE ASSESSMENT $35.00
9/1/2011 9/1/2011 300 BILLED FINANCE CHARGES $10.13
9/1/2011 9/1/2011 365 DEFERRED FINANCE CHARGES DEBIT $30.00
9/26/2011 10/1/2011 304 LATE CHARGE ASSESSMENT $35.00
9/30/2011 9/30/2011 403 LATE CHARGE CREDIT PAID ($70.00)
9/30/2011 9/30/2011 399 PRINCIPAL CREDIT PAID ($47.22)
9/30/2011 9/30/2011 165 PAYMENT -THANK YOU! ($117.22)
9/30/2011 10/4/2011 166 PAYMENT REVERSAL $0.00
9/30/2011 10/4/2011 166 PAYMENT REVERSAL $117.22
10/2/2011 10/2/2011 300 BILLED FINANCE CHARGES $10.05
10/2/2011 10/2/2011 365 DEFERRED FINANCE CHARGES DEBIT $29.67
201 4122 10/4/2011 409 PRINCIPAL CREDIT REVERSED $47.22
Data printed by Midland Credit Management, Inc. from electronic records created, maintained, and provided by Dell Financial Services, L.L.C.
Page 3 of 6
10/4/2011 10/4/2011 413 LATE CHARGE CREDIT REVERSED $70.00
10/4/2011 10/4/2011 365 DEFERRED FINANCE CHARGES DEBIT $0.19
10/26/2011 11/1/2011 304 LATE CHARGE ASSESSMENT $35.00
10/28/2011 10/28/2011 122 CREDIT CARD PAYMENT ($187.17)
10/28/2011 10/28/2011 400 FINANCE CHARGE CREDIT PAID ($26.05)
10/28/2011 10/28/2011 399 PRINCIPAL CREDIT PAID ($82.17)
10/28/2011 10/28/2011 403 LATE CHARGE CREDIT PAID ($105.00)
10/28/2011 10/28/2011 122 CREDIT CARD PAYMENT ($26.05)
10/31/2011 10/31/2011 10 LATE FEE CREDIT ($70.00)
10/31/2011 10/31/2011 360 LATE CHARGE CREDIT ADJUSTMENT $70.00
10/31/2011 10/31/2011 822 PRINCIPAL CREDIT ADJUSTMENT ($70.00)
11/1/2011 11/1/2011 365 DEFERRED FINANCE CHARGES DEBIT $30.69
11/1/2011 11/1/2011 300 BILLED FINANCE CHARGES $10.54
11/1/2011 11/1/2011 306 INSURANCE PREMIUM ASSESSED $14.41
11/27/2011 12/4/2011 304 LATE CHARGE ASSESSMENT $35.00
12/4/2011 12/4/2011 306 INSURANCE PREMIUM ASSESSED $12.77
12/4/2011 12/4/2011 365 DEFERRED FINANCE CHARGES DEBIT $27.59
12/4/2011 12/4/2011 300 BILLED FINANCE CHARGES $11.30
1/2/2012 1/4/2012 304 LATE CHARGE ASSESSMENT $35.00
114/2012 1/4/2012 300 BILLED FINANCE CHARGES $11.22
1/4/2012 1/4/2012 365 DEFERRED FINANCE CHARGES DEBIT $26.80
2/2/2012 2/4/2012 304 LATE CHARGE ASSESSMENT $35.00
2/3/2012 2/3/2012 820 FIN CHGS DEFERRED DEBIT IN $412.39
2/3/2012 2/3/2012 300 BILLED FINANCE CHARGES $11.11
2/3/2012 2/3/2012 300 BILLED FINANCE CHARGES $0.89
2/3/2012 2/3/2012 317 BILLED DEFERRED FINANCE CHARGES $412.39
2/3/2012 2/3/2012 433 PRINCIPAL CREDIT OUT ($982.60)
2/3/2012 2/3/2012 434 PRINCIPAL DEBIT IN $982.60
2/3/2012 2/3/2012 441 LATE CHARGE CREDIT OUT ($105.00)
2/3/2012 2/3/2012 442 LATE CHARGE DEBIT IN $105.00
2/3/2012 2/3/2012 365 DEFERRED FINANCE CHARGES DEBIT $26.73
2/3/2012 2/3/2012 819 FIN CHGS DEFERRED CREDIT OUT ($412.39)
2/4/2012 4/11/2012 6 FINANCE CHARGE CREDIT ($0.20)
2/4/2012 4/11/2012 6 FINANCE CHARGE CREDIT ($0.20)
2/4/2012 4/11/2012 6 FINANCE CHARGE CREDIT ($0.17)
3/2/2012 3/4/2012 304 LATE CHARGE ASSESSMENT $35.00
3/4/2012 3/4/2012 300 BILLED FINANCE CHARGES $11.00
3/4/2012 3/4/2012 300 BILLED FINANCE CHARGES $36.49
4/2/2012 4/4/2012 304 LATE CHARGE ASSESSMENT $35.00
4/4/2012 4/4/2012 300 BILLED FINANCE CHARGES $52.87
5/2/2012. 5/2/2012 304 LATE CHARGE ASSESSMENT $35.00
5/4/2012 5/4/2012 300 BILLED FINANCE CHARGES $53.37
201 6/3/220112 6/3/2012 304 LATE CHARGE ASSESSMENT $35.00
Data printed by Midland Credit Management, Inc. from electronic records created, maintained, and provided by Dell Financial Services, L.L.C.
Page 4 of 6
6/4/2012 6/4/2012 300 BILLED FINANCE CHARGES $57.36
6/11/2012 6/11/2012 410 CO FIN CR OUT ($682.32)
6/11/2012 6/11/2012 476 CO LATE CHARGE CREDIT OUT ($280.00)
6/11/2012 6/11/2012 478 CO INSURANCE CREDIT OUT ($83.48)
6/11/2012 6/11/2012 468 CO PRIN CR OUT ($1,303.75)
6/11/2012 6/11/2012 469 CO PRIN DBIN $1,303.75
6/11/2012 6/11/2012 471 CO FIN DBIN $682.32
6/11/2012 6/11/2012 477 CO LATE CHARGE DEBIT IN $280.00
6/11/2012 6/11/2012 479 CO INSURANCE DEBIT IN $83.48
6/11/2012 6/11/2012 313 AUTOMATIC INITIAL CHARGEOFF ($2,349.55)
8/31/2012 8/31/2012 468 CO PRIN CR OUT ($1,303.75)
8/31/2012 8/31/2012 314 AUTOMATIC FINAL CHARGEOFF ($2,349.55)
8/31/2012 8/31/2012 470 CO FIN CR OUT ($682.32)
8/31/2012 8/31/2012 476 CO LATE CHARGE CREDIT OUT ($280.00)
8/31/2012 8/31/2012 478 CO INSURANCE CREDIT OUT ($83.48)
Account Bal Sygupm��� ymar rrg
�a ' N
12/7/2010 $1,345.15
12/20/2010 $1,350.74
1/10/2011 $1,304.15
1/12/2011 $1,304.15
1/20/2011 $1,315.95
2/8/2011 $1,264.15
3/1/2011 $1,277.59
3/22/2011 $1,227.59
4/1/2011 $1,240.77
4/26/2011 $1,265.77
5/1/2011 $1,278.86
5/3/2011 $1,178.85
6/1/2011 $1,512.58
6/26/2011 $1,547.58
7/1/2011 $1,569.78
7/10/2011 $1,509.26
8/1/2011 $1,567.44
8/24/2011 $1,506.80
8/26/2011 $1,567.44
9/1/2011 $1,612.57
9/30/2011 $1,495.35
10/2/2011 $1,540.40
10/4/2011 $1,657.62
10/28/2011 $1,444.40
10/31/ $1,374.40
20171//3 $1,434.35
Data printed by Midland Credit Management, Inc. from electronic records created, maintained, and provided by Deli Financial Services, L.L.C.
Page 5 of 6
12/4/2011 $1,493.42
1/4/2012 $1,539.64
2/3/2012 $1,999.03
3/4/2012 $2,081.52
4/4/2012 $2,169.39
4/11/2012 $2,168.82
5/2/2012 $2,203.82
5/4/2012 $2,257.19
6/3/2012 $2,292.19
6/4/2012 $ 2,349.55
6/11/2012 $2,349.55
20173294
Data printed by Midland Credit Management, Inc. from electronic records created, maintained, and provided by Dell Financial Services, L.L.C.
Page 6 of 6
f
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 plaintiff's 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 authorities.
SEP Z013
Date
Mycah Struck
OH 14
Weltman, Weinberg & Reis. Co., L.P.A
Page - 2
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8557411155 AFFINDEBTMEDIA 20173294
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson =r!Li'D-au� `
Sheriff ti-' hE T H19 NIJ
Jody S Smith
Chief Deputy 2013 Noy 12 AID! ID- C 7
Richard W Stewart " (;�f�' 8EFLAND C��.N.�.�,.
Solicitor O PiCE`F ��"���'�'� PENNSYLVANIA
Midland Funding, LLC Case Number
vs. 2013-6034
Brian H Depew
SHERIFF'S RETURN OF SERVICE
10/31/2013 04:19 PM- Deputy Ryan Burgett, 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: Brian H Depew at 110 S. 1 st Street, Lemoye Borough, Lemoyne, PA 17043.
RYAN BURGETT, DEPUTY
SHERIFF COST: $82.24 SO ANSWERS,
November 04, 2013 RbNW R ANDERSON, SHERIFF
. . ,c-w-.;Sue Sheriff:T ere osoft '...,.
i=;.C,
H� ��' r OPdo
1Ati
nits JAM 13 PM 2: 25
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff No: 13-06034
vs .
PRAECIPE FOR DEFAULT JUDGMENT
BRIAN DEPEW
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
20173294 C A Pit DKB
Judgment Amount $2349 . 55
(NIA sltb.Q)pa
1�-' '? 00(-i t)t
kI Lk 'Maki
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs . Civil Action No. 13-06034
BRIAN DEPEW
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendant BRIAN DEPEW above named, in
the default of an Answer, in the amount of $2349 . 55 computed as follows :
Amount claimed in Complaint $2349 . 55
Less payments / adjustments made $0 . 00
Attorney' s fees $0 . 00
TOTAL $2349 . 55
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 T. Mol zan, 4 437
20173294 C A Pit DKB
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 :
BRIAN DEPEW
110 S 1ST ST
LEMOYNE, PA 17043
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
Case No. 13-06034
vs.
BRIAN DEPEW
Defendant
IMPORTANT NOTICE
TO:
BRIAN DEPEW
110 S 1ST ST
LEMOYNE, PA 17043-1973 S Date of Notice: ( ( a 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 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
20173294 A PIT A4S
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs . Civil Action No. 13-06034
NON-MILITARY AFFIDAVIT
BRIAN DEPEW
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, BRIAN DEPEW 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:
BRIAN DEPEW
110 S 1ST ST
LEMOYNE, PA 17043
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 .
1-2141-111//yA --
AFFIANT
1
Department of Defense Manpower Data Results as of:Jan-03-2014 05:23:41
Center
SCRA 3.0
0 � J
�Report
°t '' Pursuant to Servicemembers Civil Relief.Act
•
Last Name: DEPEW
First Name: BRIAN
Middle Name:
Active Duty Status As Of: Jan-03-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date:. '.Active Duty End Date Status Service Component
NA NA No NA
This response reflects the individuals'active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status - Service Component
NA NA f 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.
)011(.14,Ade yit 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: 363F3947803A540
A
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs . Civil Action No. 13-06034
BRIAN DEPEW
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 11i3I14
(xx) Assumpsit Judgment in the amount of $2349 . 55 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 Award
Prothonotary
By •
PROTHONOTARY (OR DEPUTY)
BRIAN DEPEW
110 S 1ST ST
LEMOYNE, PA 17043
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
lJ�
�o3.�7S It ti
1(n Soo <t
- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs.
BRIAN DEPEW
Defendant(s)
BELCO COMMUNITY CREDIT UNION
Garnishee(s)
TO THE PROTHONOTARY:
Civil Action No. 13-06034
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 BRIAN DEPEW , Defendant
3. against BELCO COMMUNITY CREDIT UNION, , , Garnishee
4. Judgment Amount
Less Payments/credits received
Interest
Costs
SUBTOTAL:
Costs (to be added by Prothonotary):
k.41
rn
'f7
$2,349.55
$0.00
$51.76
$2,401.31
c...:
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James P. V ecko, Esquire
PA I.D. #79 96
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
baastA/2- CO.
U._=Y A- 6,
WWR No. 20173294
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs.
BRIAN DEPEW
Defendant(s)
BELCO COMMUNITY CREDIT UNION
Garnishee(s)
No. 13-06034
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James P. Valecko, Esquire
PA I.D. #79596
WELTMAN, WEINBERG & REIS CO., L:P.A.
436 7th Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 20173294
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
MIDLAND FUNDING LLC
Vs.
BRIAN DEPEW
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 13-6034 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against BRIAN DEPEW, 110 S 1sT STREET, LEMOYNE, PA
17043 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
BELCO COMMUNITY CREDIT UNIONGARNISHEE(S), as garnishee, 5304 CARLISLE PIKE,
MECHANICSBURG, PA 17050 (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
1
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 $2,349.55 Plaintiff Paid
Interest $51.76 Law Library $.50
Attorney's Comm. % Due Prothonotary $2.25
Other Costs
Attorney Paid $231.49
Date: 6/04/14
(Seal)
10,0z -ea '1J2iL
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
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
(' THE PitO (i rONr
2i'IIf JUf4 -9 PM 3: 05
CUMBERLAND COUNT'
PENNSYLVANIA
OFFICE :>F THE SK,RIFF
Midland Funding, LLC
vs.
Brian H Depew
Case Number
2013-6034
SHERIFF'S RETURN OF SERVICE
06/06/2014 02:50 PM - Christopher Sharpe, 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, Belco Community Credit Union, 5304 Carlisle Pike,
Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Colleen Dean,
Member Service Representative II, 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 June 9, 2014 to Brian Depew at 110 S 1st
Street, Lemoyne, PA 17043.
June 09, .2014
(c) CountySuite Sheriff, Teieosott, Inc.
CHRIST PHER SHARPE, DEPUTY
SO ANSWERS,
RONR ANDERSON, SHERIFF
ONZ(NDER
r?,. PRO�t'rJr�t1°,
2014 JUN 2 PH 2: 3 3
CUMBERLAND COUNTY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND C
PENNsAAVENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs.
BRIAN DEPEW
Defendant(s)
BELCO COMMUNITY CREDIT UNION
Garnishee(s)
Civil Action No. 13-06034
4-,, f 'ers /7
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. 20173294
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MIDLAND FUNDING LLC
Plaintiff
vs.
BRIAN DEPEW
Defendant(s)
BELCO COMMUNITY CREDIT UNION
Garnishee(s)
Civil Action No. 13-06034
TO: BELCO COMMUNITY CREDIT UNION, 5304 CARLISLE PIKE, MECHANICSBURG, PA 17050
RE: BRIAN DEPEW , 110 S 1ST ST, LEMOYNE, PA 17043
Suggested Reference No.: XXX -XX -2065
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. 20173294
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)?
I a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof;
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe or owed to him; and the nature and amount of each of such liabilities.
Niv
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?
�I o
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?
Np
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.
�I D
WWR No. 20173294
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. Ac
c Dutra 1 00-56d
OS6d / (\Jo Fund i4 (`e ; tot b ( C
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
o
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.
o
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?
No
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
c� o
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
JamesP. V4lecko, 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. 20173294
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
TAY raL\icagi
IrGl o d- AAa l 1/ S i' of &ICO GCCA-
(Title) / (Company)
, garnishee herein,
that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief.
0-0A- 12€
(SIGNAT)
WWR No. 20173294
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Matthew D. Urban, Esquire
I.D. No.90963
436 Seventh Avenue, Suite 2500
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 20173294
OF THE: PRO
Attorney for Plaintiffs) O/ O 'O TA fi I
AUG -4 PN I. 48
CUPENNSAND COUNTY
Y
MIDLAND FUNDING LLC
CUMBERLAND County
Court of Common Pleas
vs.
BRIAN DEPEW
and
BELCO COMMUNITY CREDIT UNION
Garnishee(s)
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
NO. 13-06034
TO THE PROTHONOTARY:
Kindly marked the above matter settled, discontinued, and ended as to Garnishee(s),
BELCO COMMUNITY CREDIT UNION, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Matthew D. Urban, Esquire.
Attorney for Plaintiff
otjA *et .sola�
cjk:1* llln9G /g�
2-t�
aoct.n.