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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 II�I�II�I�IN���I��I�I�0�1�11�1�I I��I�II�I�I�III�I�I�I�O�II�ID�OI�II�a10��1�1 Im01�ll���lll�q� ®a�l�l�l 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 ilDll�ll�ll�llll�lldll0ll�l�llll8l 111111 Ifni I IMI��Ullllll�l �11111�1 INIIIIIlallIIIIlllI1la ®1111 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.